Introduction
Steve Bentley CEO of Sofema Aviation Services (www.sassofia.com) reviews roles, responsibilities and obligations.
This document considers the process whereby we can provide Commercial Air Transport CAT Flight Crew with approval to perform Pre-Departure Inspection (PDI) including Associated Tasks (I.A.W. M.A.301(1)) as well as Tasks In Accordance with EASA Part 145 AMC 145.A.30(j)(4).
Concerning Pre-Departure Inspection
AMC M.A.301(1) Continuing airworthiness tasks (ED Decision 2016/011/R)
1. With regard to the pre-flight inspection, it is intended to mean all of the actions necessary to ensure that the aircraft is fit to make the intended flight.
These should typically include but are not necessarily limited to:
(a) a walk-around type inspection of the aircraft and its emergency equipment for condition including, in particular, any obvious signs of wear, damage or leakage. In addition, the presence of all required equipment including emergency equipment should be established.
(b) an inspection of the aircraft continuing airworthiness record system or the operators’ technical log as applicable to ensure that the intended flight is not adversely affected by any outstanding deferred defects and that no required maintenance action shown in the maintenance statement is overdue or will become due during the flight.
(c) a control that consumable fluids, gases etc. uplifted prior to flight are of the correct specification, free from contamination, and correctly recorded.
(d) a control that all doors are securely fastened.
(e) a control that control surface and landing gear locks, pitot/static covers, restraint devices and engine/aperture blanks have been removed.
(f) a control that all the aircraft’s external surfaces and engines are free from ice, snow, sand, dust etc. and an assessment to confirm that, as the result of meteorological conditions and de-icing/anti-icing fluids having been previously applied on it, there are no fluid residues that could endanger flight safety.
Alternatively to this pre-flight assessment, when the type of aircraft and nature of operations allow for it, the build-up of residues may be controlled through scheduled maintenance inspections/cleanings identified in the approved maintenance programme.
2. Tasks such as oil and hydraulic fluid uplift and tyre inflation may be considered as part of the pre-flight inspection.
Note the following which should be clearly documented and evidenced during audit that the procedure is effective – Where document? – Consider for example the following – Tech Log / AMP / CAME Part 1 – refer also item 3.
3. In the case of air carriers licensed in accordance with Regulation (EC) No 1008/2008, the CAMO should publish guidance to maintenance and flight personnel and any other personnel performing pre-flight inspection tasks, as appropriate, defining responsibilities for these actions and, where tasks are contracted to other organisations, how their accomplishment is subject to the quality system of M.A.712.
It should be demonstrated to the competent authority that pre-flight inspection personnel have received appropriate training for the relevant pre-flight inspection tasks.
Note 1 Regarding PDI Training – To Ensure Auditable Standards, It is usual for this standard to be managed by an EASA Part 145 Organisation.
The training standard for personnel performing the pre-flight inspection should be described in the continuing airworthiness management exposition.
Note 2 Regarding the Management of 145 Trainer Competence – The 145 Organisation will be expected to demonstrate the “management” of any person who delivers such training to ensure it is carried out to an organisational standard. (Again this is Auditable)
Note 3 – There is no requirement for recurrent PDI Training – Good Practice would be to assess on a 24 months (2-year) basis as a minimum.
Concerning other Tasks – Outside of the Scope of the PDI
AMC 145.A.30(j)(4) Personnel requirements
ED Decision 2015/029/R
1. For the issue of a limited certification authorisation:
(a) the commander should hold either an air transport pilots license (ATPL), or a commercial pilots license (CPL).
(b) The flight engineer should hold either an ATPL, CPL or a national flight engineer licence acceptable to the competent authority on the aircraft type.
2. In addition, the limited certification authorisation is subject to the maintenance organisation exposition containing procedures to address the personnel requirements of 145.A.30(e) and associated AMC and guidance material. The procedures should be accepted by the competent authority and should include as a minimum:
(a) Completion of adequate maintenance airworthiness regulation training.
(b) Completion of adequate task training for the specific task on the aircraft. The task training should be of sufficient duration to ensure that the individual has a thorough understanding of the task to be completed and will involve training in the use of associated maintenance data.
Note – Task Training typically consists of Theoretical & Practical Elements additionally concerning the Management of 145 Trainer Competence – The 145 Organisation will be expected to demonstrate the “management” of any person who delivers such training to ensure it is carried out to an organisational standard. (Again, this is Auditable)
(c) Completion of the procedural training as specified in Part-145.
2.(i) Typical tasks that may be certified and/or carried out by the commander holding an ATPL or CPL are minor maintenance or simple checks included in the following list:
(a) Replacement of internal lights, filaments and flash tubes.
(b) Closing of cowlings and refitment of quick access inspection panels.
(c) Role changes e.g. stretcher fit, dual controls, FLIR, doors, photographic equipment etc.
(d) Inspection for and removal of de-icing/anti-icing fluid residues, including removal/closure of panels, cowls or covers that are easily accessible but not requiring the use of special tools.
(e) Any check/replacement involving simple techniques consistent with this AMC and as agreed by the competent authority.
2.(ii) Holders of flight engineer licence acceptable to the competent authority on the aircraft type, may only exercise this limited certification authorisation privilege when performing the duties of a flight engineer.
In addition to paragraph 2(i)(a) to (e) other typical minor maintenance or simple defect rectification tasks that may be carried out are included in the following list:
(a) Replacement of wheel assemblies.
(b) Replacement of simple emergency equipment that is easily accessible.
(c) Replacement of ovens, boilers and beverage makers.
(d) Replacement of external lights.
(e) Replacement of passenger and cabin crew seats, seat belts and harnesses.
(f) Simple replacement of overhead storage compartment doors and cabin furnishing items.
(g) Replacement of static wicks.
(h) Replacement of aircraft main and APU aircraft batteries.
(i) Replacement of in-flight entertainment system components other than public address.
(j) The de-activation only of sub-systems and aircraft components as permitted by the operator’s minimum equipment list where such de-activation is agreed by the competent authority as a simple task.
(k) Re-setting of tripped circuit breakers under the guidance of maintenance control.
(l) Any other task agreed by the competent authority as a simple task for a particular aircraft type.
3. The authorisation should have a finite life of twelve months subject to satisfactory re-current training on the applicable aircraft type.
Note – Such Annual Recurrent Training should generate auditable training records and be delivered to a standard.
Sofema Aviation Services (www.sassofia.com) and SofemaOnline (www.sofemaonline.com) offer classroom & online training in Maintenance Regulatory & Vocational training.
For details please email office@sassofia.com or online@sassofia.com
Tags:
Aircraft Maintenance, Certification Approval, continuing airworthiness, Flight Crew
