Sofema Aviation Services (SAS) www.sassofia.com considers the role purpose and relationship between Operational Suitability Data (OSD) and the Master Minimum Equipment List (MMEL).
Transition from JAA/EASA MMEL/OEB
With the entry into force of Commission Regulation (EU) No 69/2014 on 18 February 2014 the concept of Operational Suitability Data (OSD) was implemented, integrating operational evaluation elements into the certification design process as foreseen in the Basic Regulation.
Commission Regulation (EU) No 69/2014 introduces Article 7a of Commission Regulation (EU) No 748/2012.
- Paragraph 3 of Article 7a states: “Operational Evaluation Board reports and master minimum equipment lists issued in accordance with JAA procedures or by the Agency before the entry into force of this Regulation [18 February 2014] shall be deemed to constitute the operational suitability data approved in accordance with point 21.A.21(e) of Annex I (Part 21) and shall be included in the relevant type-certificate. Before 18 June 2014 the relevant type-certificate holders shall propose the Agency a division of the operational suitability data in mandatory data and non-mandatory data.”
Note that the type Certificate Data Sheet (TCDS) will not be revised to indicate the first OSD revision followed by “or later approved revisions” or similar statement.
Introduction – MMEL Cert Basis
MMEL within OSD provides for an approval process comparable to Type Design Certification:
- Ensures clear sharing of duties and responsibilities between Agency and (S)TC Holders.
- MMEL is required to consider EASA level of involvement.
- EASA has provisioned additional privileges for DOA holders for MMEL minor changes approval.
CS-MMEL Objectives
- Maintain consistency with JOEB process
- The JAR-MMEL content is integrated
- CS-MMEL provides the necessary requirements/criteria for compliance finding in a TC framework
MMEL Development Methodology
Method of Compliance MoC to CS-MMEL.140:
- An acceptable level of safety as intended by the applicable requirements is maintained
o What is acceptable shall be defined in MoC “performance-based requirements” not prescriptive (like CS-25 etc.)
Note: The Methodology is an essential aspect of the OSD MMEL.
MMEL Safety Methodology
Method of Compliance MoC to CS-MMEL.140/145:
- CS MMEL.145 (c)(1) Consequences of the item failure: Fail/pass criteria to be defined by TCH.
ORO.MLR.105 (a) requires EU operators to:
- Base their new MELs on OSD MMEL available directly from the Type Certificate Holder.
MMEL General
Under AIR-OPS regulations, operators:
- Shall have an MEL (ORO.MLR.105) if conducting:
o Commercial air transport operations (CAT);
o Commercial specialised operations;
o Non-commercial operations with complex motor-powered aircraft;
o Non-commercial specialised operations with complex motor-powered aircraft.
Next Steps
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Sofema Aviation Services (SAS) www.sassofia.com provides regulatory training for EASA Part 21, CS 25 & OSD – please see the following course. For additional details, please visit our website or email team@sassofia.com
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aviation, Commission Regulation (EU) No 748/2012, EASA, JAA, Master Minimum Equipment List (MMEL), MMEL, Operational Suitability Data (OSD), OSD, Regulation (EU) No 748/2012, SAS blogs
