Sofema Aviation Services www.sassofia.com takes a look at what obligations sit with an EASA 145 following the implementation of an SMS.
Considering the difference between āCONTRACTING MAINTENANCEā & āSUBCONTRACTING MAINTENANCEā
(a) āSubcontracting maintenanceā means subcontracting to a third party under the maintenance organisation management system.
This is the case when a third party carries out certain maintenance tasks on behalf of the Part-145 organisation, and the responsibility remains within the Part-145 organisation (this Part-145 organisation must have the tasks within its scope of approval). Whether the third party is approved or not is not relevant for the designation of subcontracting, since the third party will be working under the management system of the Part-145 organisation and the maintenance will be released under the approval of this organisation. See also GM1 145.A.75(b).
(b) āContracting maintenanceā means contracting to another maintenance organisation which will release the maintenance under its own approval.
This is the case when a Part-145 organisation, contracted to carry out maintenance by an owner/operator/CAMO, further contracts certain maintenance tasks to another approved Part-145 organisation and transfers the responsibility for the release of such tasks to the second Part-145 organisation.
Note – Contracting should only be foreseen when it is allowed by the person or organisation that requests the maintenance. Authors Comment – (Disclosure to ensure the owner/operator is aware.)
(c) In case (a), the subcontracted organisation works under the approval of the contracting organisation, whereas in case (b), the contracted organisation works under its own approval.
Contracting and Subcontracting (GM1 145.A.205)
Concerning Responsibility related to Contracting & Subcontracting
A Part-145 organisation is responsible for ensuring that all subcontracted activities are subject to hazard identification and risk management, ref 145.A.200(a)(3), and to compliance monitoring, ref 145.A.200(a)(6).
Note – A Part-145 organisation is responsible for identifying hazards that may stem from the existence of complex maintenance arrangements – With due regard to the organisationsā interfaces ref GM1 145.A.200(a)(3).
Example ā When āMultiple Organisationsā are contracted, or when multiple levels of contracting/subcontracting are included.
Compliance Monitoring Considerations
A Part-145 organisation is responsible for ensuring that interfaces and communication channels are established with the contracted maintenance organisation for occurrence reporting.
For subcontracted activities, interfaces and communication channels are also needed for the purpose of the internal safety reporting scheme (145.A.202).
Note – This does not replace the obligation of the contracted organisation to report to the competent authority in accordance with Regulation (EU) No 1321/2014.
In addition, the compliance monitoring function should at least check that the approval of the contracted maintenance organisation(s) effectively covers the contracted activities and that it is still valid.
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Tags:
Compliance Monitoring, Contracting Maintenance, EASA Part 145, Subcontracting Maintenance
