Maintenance Annex Guidance Review by Sofema Aviation Services (SAS) www.sassofia.com.
Introduction
The Maintenance Annex Guidance (MAG) defines the procedures and activities of the Federal Aviation Administration (FAA), the European Union Aviation Safety Agency (EASA), and the Aviation Authorities (AA) to implement the Maintenance Annex.
What’s in Change 9?
Change 9 to the U.S.-EU MAG introduces primarily clarifications and administrative updates, ensuring alignment with current standards, better-defining roles, and streamlining processes for both U.S.- and EU-based repair stations. The emphasis is on enhancing clarity, particularly concerning contracting, certification, and the use of forms and documentation. This review provides an overview of the significant changes in Change 9 while helping stakeholders align their operations with these updated requirements. The update is intended to support a more efficient oversight and cooperation process between FAA and EASA, improving both parties’ ability to ensure compliance with international aviation safety standards. Several clarifications and revisions are made to improve clarity, administrative efficiency, and compliance with existing regulations.
Clarifications on Procedures and Responsibilities
- Section A focuses on authority interaction, providing detailed guidelines on communication, consultation, and training between the Federal Aviation Administration (FAA) and the European Union Aviation Safety Agency (EASA).
- This section emphasizes maintaining mutual confidence between the two bodies.
- A key addition includes provisions for the use of document management software, highlighting the shift towards more digitalized processes for record-keeping and communication.
Updates to EASA and FAA Member State Designations
- There are corrections to the list of EU Member States in various paragraphs, ensuring the guidance remains accurate regarding which countries fall under EASA oversight. For example, Paragraphs 10.12 and 10.13 have been updated to correct EU Member State references.
- Section C, related to the certification process for EU-based Approved Maintenance Organizations (AMOs), also has updated member state references in Paragraphs 7.4 and 7.5.
- Clarification on the Use of Forms and Reports
- A significant part of Change 9 revolves around improved clarity in documentation and reporting. Specifically:
- Form 8 and Form 9 have been restructured, including references to OpSpec A101, reflecting updated reporting standards between the FAA and EASA.
- Updates in Appendix 1 address administrative edits to improve procedural clarity. This includes revisions in Paragraphs 14.5.1.2(b), 14.5.1.5, and 14.5.2.5, streamlining the text to remove ambiguities.
- Adjustments in Contracting and Non-EASA Certificated Repair Stations
- Section B, Appendix 1, Paragraph 16.0 has been revised to better define contracting procedures, specifically removing previous notes and replacing them with subparagraphs that differentiate between EASA-certificated and non-EASA-certificated repair stations.
- These adjustments make it clearer how contracting with different types of repair stations should be handled, improving compliance with both FAA and EASA standards.
- Expanded Notes for Clarity
- Additional notes have been incorporated throughout Change 9 to expand or clarify existing guidelines, especially in Paragraph 17.0 of Appendix 1. These changes aim to provide further guidance on nuanced topics, such as release statements and certification procedures.
- Special Condition Updates
- Revisions to Special Conditions applicable to U.S.-based repair stations seeking approval under EASA Part-145 have been clarified, including procedural updates for work away from fixed locations and conditions that pertain to the use of EASA Form 1 for certification.
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