Sofema Aviation Services (SAS) www.sassofia.com considers the Operational Suitability Data (OSD) changes which will be introduced following the issue of Certification Specifications for Maintenance Certifying Staff Data ‘CS-MCSD — Issue 1
Introduction
The objective of Decision 2020/019/R is to improve the level of safety by requiring the applicant for a type certificate (TC) or a restricted type certificate (RTC) of an aircraft to identify the minimum syllabus of the maintenance certifying staff type-rating training, including the determination of the type rating.
The minimum syllabus, together with the requirements contained in Appendix III ‘Aircraft type training and examination standard’ to Annex III (Part-66) to Commission Regulation (EU) No 1321/2014, shall form the basis for the development and approval of Part-66 type-rating training courses.
Certification Specifications and Guidance Material for Maintenance Certifying Staff Data
Introducing the concept of MASE maintenance areas of special emphasis
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.
GM1 MCSD.430 Maintenance areas of special emphasis (MASE)
In order to identify the MASE, the applicant should consider the following:
- Novelty — related to special features derived from a new or unusual design of a system or a subsystem (e.g. not covered by Appendices I and III of Part-66):
o new materials or combination of materials;
o new manufacturing processes;
o new or unusual aircraft configuration and/or system architecture;
o novel reconfiguration of systems;
o new interface or interaction with other parts or systems;
o unusual location of a part of a system or unusual construction;
o new functions;
o new types of operations;
o the potential for new failure modes;
o introduction of a new threat (for example, new threats regarding fire, fuel, hydrogen, energy storage devices) or a new prevention/detection/mitigation method;
o new maintenance techniques;
o novel operating conditions or limitations;
o new human–machine interface (HMI);
o Specificity or uniqueness relevant to the aircraft maintenance.
- Criticality — related to the safety impact of the maintenance procedure on the aircraft and persons.
- Difficulty — depending on how difficult or complex it is to perform the maintenance task or procedure. It could include issues associated to human factors, performance and limitations, e.g.:
o accessibility;
o the effect of weight and volume on human physical limitations;
o environmental conditions (temperature, task lighting, noise levels, vibrations, etc.);
o HMI;
o The use of complex tools/equipment;
o specific interpretation skills and complexity of the work instructions;
o coordination among persons (teamwork).
- In-service experience.
The above-mentioned criteria are not exhaustive and do not exclude each other. The applicant may decide to include other applicable elements they consider valid for a particular aircraft type.
The applicant shall identify and put in place adequate methods and processes to capture the MASE.
Appendix II of Part-66 provides an example of a checklist that can help to identify the MASE correlated to the CS-25 and CS-29 requirements.
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 link.
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Operational Suitability Data, OSD, easa part 21, SAS blogs, CS 25, Type Certificate, Restricted type-certificate, CS 29, Maintenance Certifying Staff, Decision 2020/019/R i, type-rating training, MASE, Maintenance areas of special emphasis, not covered by Appendices I and III of Part-66)
