An Operator is required to have a process to manage Continuing Airworthiness as a direct responsibility, moreover it is required also to either have its own approved “in house” Part 145 or to Contract a Part 145 Organization to cover at least the requirements of both Line Maintenance and Minor Maintenance.
Whilst the Maintainer is responsible to sign a Certificate of Release to Service “CRS” for all maintenance performed it is ultimately the responsibility of the Operators – Part M organization to ensure that all required maintenance requirements have been met.
There are a number of areas where there is an overlap of responsibilities sitting between the Part M organization and the Part 145 Organization.
For example in the area of Mandatory Reporting to the Civil Aviation Authority “CAA” compliance with AMC 20-8 should be arranged so that there is in place a controlled procedure to provide guidance on how Mandatory reporting will be achieved.
It is a requirement for both the Part M & Part 145 organisations to deliver Electrical Wiring Interconnect system Training “EWIS” and Fuel Tank Safety Training “FTS”.
Whilst each has specific responsibilities to deliver the training to all applicable staff, the Part M organization also has oversight of the effective compliance of the Part 145 organization to meet its obligations where these directly affect the Continuing Airworthiness of the operator’s aircraft.
For example this would as a minimum concern the acceptability of the 145 organisations procedures.
In respect of the obligation to show compliance with the requirements of EASA Part M Subpart “D” the Operator is ultimately responsible for the provision of all Instructions for Continued Airworthiness “ICAW” This typically requires an annex to the contract to be in place which obliges the Operator to ensure the Maintainer has all necessary approved data to perform the required maintenance. For its part the Part 145 organization has to take all necessary steps to ensure that the maintenance is performed and certified in accordance with current and applicable data.
In respect of the obligation to show compliance with the requirements of EASA Part M subpart “E” it is necessary to ensure the Part 145 organization has all necessary information concerning the aircraft Component status and configuration including AD compliance of any components which are to be replaced. This obligation ultimately rests with the Operator.
Sofema Aviation Services delivers regulatory training for Part M, and Part 145 organization approvals. For additional details please visit www.sassofia.com or email office@sassofia.com
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Electrical Wiring Interconnect system Training, EWIS, FTS, fuel tank safety training, Part 145 Organization, part M, SAS, Sofema Aviation Services
