EASA issues Additional Airworthiness Specifications Update – Review by Sofema Aviation Services (SAS) www.sassofia.com
The following questions have been identified and answered by EASA – please visit this link.
Relevant Areas For consideration by EASA Part 21, Part CAMO & Part 145 Organisations:
- Are the repairs/alterations/changes, that are validated under the FAA PART 26 rule, automatically acceptable under the new EASA AASR rule?
- Are the Repair Evaluation Guidelines (REG’s) for example on a Boeing model (that meets the FAA ASSR / PART 26 requirements) accepted by EASA? If so, automatically? Do the TCH’s individually have to apply for the review and approval of the REG?
- Point 26.331: Shall a compliance plan be submitted to EASA by STC holders that do not hold structures in their DOA Scope of Work; and only owns STCs that are cabin related and do not introduce fatigue-critical modified structure (FCMS)?
- As STC Holders how can we obtain the list of Fatigue Critical Baseline Structure FCBS?
- When not sure if FCBS is affected by an STC, is there any Compliance Plan required?
- An EASA approved STC is applied to aircraft which are nowadays operated in the US under FAA regulations. Does the (Fatigue & Damage Tolerance) F&DT still need to be performed? Or could we wait until an actual operator contacts us?
- There are many structural repairs manual (SRM) repairs to fatigue critical structure (FCS) however the SRM does not define the classification of the repair per 21A91/21.435. How does an operator know the repair classification if it has not been specified?
- 26.370(a) (ii): where an operator’s fleet consists of a/c certificated after 2009 and therefore has no REG – there will be no “REG” survey compliance threshold for repairs. When does one, therefore, plan to review the DTI?
- Will rework repairs (blend out, trim-outs, etc.) be on a list of repairs that require DTE?
- Is it our correct interpretation of 26.370 g(5) that a physical survey for repairs for aircraft certified as per CS 25.571 (Damage Tolerance) is not a must as long as repair records for the aircraft are considered complete by the CAMO and the requirements?
- Who needs to evaluate a change/repair in case the original design organization for the change/repair no longer exists?
- Typically a DTI has a threshold and interval, how should the operator establish that start time (to calculate the 1st due to inspection) if an unrecorded Mod/repair was found during the survey, and not knowing the cycles/landing at Incorp of the Mod/repair?
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easa part 21, DTE, F&DT, FCBS, EASA AASR rule, FAA PART 26, EASA Specifications, REG, SAS blogs, Part CAMO, DOA, aviation, FAA, SRM, Airworthiness, STC, Part 145, EASA, DTI, CAMO, Aviation Maintenance
