Presentation by Sofema Aviation Services (SAS) www.sassofia.com
- CAMO Requirements to ensure compliance with CS 26
- Initial Assessment & Request for Reference Documentation
- Report Required by 26th Feb 2022
- Forthcoming Changes to Aircraft Maintenance Program required by 26th Feb 2024
CS 26.370 Continuing airworthiness tasks and aircraft maintenance programme — Operators and organisations responsible for maintenance programmes for large aeroplanes under Part-M.
Terminology Used
FCS Fatigue Critical Structure is a structure that is susceptible to fatigue cracking that could lead to a catastrophic failure of an aircraft. For the purposes of this AMC, FCS refers to the same class of structure that would need to be assessed for compliance with § 25.571(a) at Amendment 25-45, or later.
The term FCS may refer to fatigue critical baseline structure, fatigue critical modified structure, or both.
DTE Damage Tolerance Evaluation is a process that leads to a determination of maintenance actions necessary to detect or preclude fatigue cracking that could contribute to a catastrophic failure. As applied to repairs and modifications, a DTE includes the evaluation of the repair or modification and the fatigue critical structure affected by the repair or modification.
DTI,s Damage Tolerance Inspections are the inspections developed as a result of a DTE.
Required CAMO Actions
Step 1 – Review of aeroplane records and initial request for data.
Operator or owner review of design approval holder compliance data – Means to address the adverse effect of repairs and modifications that have not had DTIs incorporated into the AMP.
A conducted by the continuing airworthiness management organisation of the applicable documents supplied by type certificate (TC) holders and STC holders in compliance with points 26.302, 26.306 to 26.309 and 26.332 to 26.334 of Part-26, which supports the identification of the available FCS and DTIs relevant to each aeroplane.
For modifications with an approved DTI that is available and compliant with points 26.307 or 26.333 of Part 26, all the applicable DTIs should be incorporated into the AMP by 26 February 2024 or before operating the aeroplane in accordance with Part-CAT, whichever occurs later.
Operators CAMO’s shall ensure that the adverse effects that repairs and modifications may have on FCS are addressed by:
- Incorporating into the AMP all available approved DTIs for modifications by 26 February 2024
- Modifications incorporated in an aeroplane imported to the EU after 26 February 2021
o For all major modifications affecting FCS incorporated in an aeroplane that is imported to the EU after 26 February 2021, the applicable approved DTI should be obtained and incorporated into the AMP by 26 February 2024 or before operating the aeroplane in accordance with Part-CAT, whichever occurs later.
CAMO Tasks Due in 2022
- A candidate list of the major modifications in the aeroplane that affect or include FCS has been identified by means of a review of records and listed in a report prepared by the continuing airworthiness maintenance organisation by 26 February 2022.
- Requests for FCMS lists and DTIs for modifications identified in point (c)(1) above as supplemental type certificates (STCs) and other changes, approved prior to 1 September 2003, are submitted to the design approval holder by 26 March 2022, or an alternative source of approved DTIs is identified.
- A final list of the major modifications in the aeroplane that affect or include FCS, taking into account the candidate list above, the available design approval holder lists of changes that affect the FCBS and the continuing airworthiness management organisation’s own evaluation, should be completed and report created by 26 August 2022 or before operating the aeroplane in accordance with Part-CAT, whichever occurs later.
- Incorporating in the AMP the approved DTIs for all other repairs and modifications in accordance with the schedule adopted in a plan to be included, or referred to, in the AMP by 26 February 2024
Required Demonstration by the CAMO
- Operator or owner review of design approval holder compliance data – Means to address the adverse effect of repairs and modifications that have not had DTIs incorporated into the AMP
- A conducted by the continuing airworthiness management organisation of the applicable documents supplied by type certificate (TC) holders and STC holders in compliance with points 26.302, 26.306 to 26.309 and 26.332 to 26.334 of Part-26, which supports the identification of the available FCS and DTIs relevant to each aeroplane.
- For modifications with an approved DTI that is available and compliant with points 26.307 or 26.333 of Part 26, all the applicable DTIs should be incorporated into the AMP by 26 February 2024 or before operating the aeroplane in accordance with Part-CAT, whichever occurs later.
CAMO Required Outcome
- A plan established by the continuing airworthiness management organisation to obtain and implement all the applicable DT data for existing major modifications and reinforcing repairs affecting the FCS.
- The plan to be incorporated, in full or by reference, into the AMP for approval in accordance with point M.A.302 of Annex I (Part-M) to Regulation (EU) No 1321/2014.
- For each modification identified in the list contained in the report of point (c)(3) above and that is subject to this point, the plan shows that: (i) requests for DT data have been made to the DAH that has to comply with point 26.334 of Part-26, and an agreement for obtaining approved DTIs is reached, or
o An agreement is established with a third party to provide approved DTIs,
- The plan ensures that reinforcing repairs to the FCS will be identified and assessed for DT by specifying processes for:
o Conducting surveys and records reviews of the affected aeroplanes as necessary to ensure the identification and documentation of all the existing reinforcing repairs that affect the FCS; and
o Obtaining DT data for reinforcing repairs identified above.
o This plan also includes schedules for:
– Conducting aeroplane surveys,
– Obtaining DT data for repairs and
– Incorporating all approved DTIs into the AMP
Next Steps
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Tags:
Aircraft Maintenance Program, AMP, aviation, CAMO, EASA regulations, SAS blogs, CS 26, Fatigue Critical Structure, Damage Tolerance Evaluation, Damage Tolerance Inspections
