Sofema Aviation Services (SAS) www.sassofia.com looks at the compliance obligations related to the requirements of Certification Specification – Maintenance Certifying Staff Data CS-MCSD
CS-MCSD is applicable to Group 1 aircraft as defined in point 66.A.5 of Part-66, in respect of which EASA establishes and notifies to the applicant the operational suitability data (OSD) certification basis in accordance with Part 21.
CS MCSD.430 Maintenance areas of special emphasis (MASE)
Maintenance areas of special emphasis (MASE) are elements considered by the applicant as having a degree of novelty, specificity or uniqueness relevant to the maintenance of the applicant’s product. These could be technical or operational features that maintenance staff need to be aware of and to take into consideration.
MASE are also type- and safety-related knowledge, training and assessment areas that the applicant considers necessary to highlight to maintenance staff.
Obligations for a TCH to provide the OSD-MCS:
[Art. 1 37a1] Only new TCs, applications filed after 17 February 2014.
- Limited to Group 1 a/c. GM No. 1 to 21.A.15d
- OSD approval to obtained before EIS of the first a/c by an EU operator
- or need to use OSD for preparation of such EIS. GM to 21.A.21f
[Art. 1 37a2] Catch-up for existing TC or on-going certifications, for which the application was filed before 17 February 2014, is voluntary.
[Art. 1 37a3] No OEB-MCS approved report exists: therefore no Grandfathering activity is expected.
[Art. 1 37a4] DOA scope extension before 18 December 2015. If no OSD-MCS exists, no extension is required.
[Art. 2] Changes and STCs are exempted until 19 Dec.2016. If no OSD-MCS exists, no application for OSD-MCS change is required.
Training Organisation Requirements
Type training courses approved before the approval of the OSD-MCS shall include the relevant elements.
defined in the mandatory part of that OSD latest between: 18 December 2017 or within two years after the OSD approval.
The introduction of the OSD in the Basic Regulation created the obligation for the Type Certificate Holder to provide the “minimum syllabus” for maintenance certifying staff for certain aircraft.
As a consequence of this, the Appendix III to Part-66 (in its point 1(a)(ii)) was amended with Regulation (EU) 1321/2014 to state that the theoretical training and examination shall comply with:
- “the relevant elements defined in the mandatory part of the operational suitability data established in accordance with Regulation (EU) No 748/2012 or, if such elements are not available, the standard described in point 3.1 of this Appendix”
Next Steps
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CS-MCSD, DOA, Maintenance areas of special emphasis, Maintenance Certifying Staff, MASE, OEB-MCS, Operational Suitability Data, OSD, OSD-MCS, SAS blogs, Type training courses
