Sofema Aviation Services (SAS) www.sassofia.com considers the challenges and a way forward of enabling Certification by an EASA Part 145 Organisation Holding appropriate Approval
Introduction – What Does EASA Say?
1.3.2.1. Component training.
- Depending on the complexity and the technology of the component, the CC/S shall be able to demonstrate he/she received appropriate theoretical and practical component training from:
- the OEM or;
- the OEM recognized training organization or;
- An appropriately rated maintenance organisation provided:
· the person nominated to carry out the training can demonstrate he/she has received training to an appropriate level for the subject component;
· the person nominated to carry out the training is appropriately authorized by the maintenance organisation and is able to demonstrate a significant experience in the relevant component maintenance;
· The training syllabus has been reviewed by the Engineering Manager and/or the Quality Manager;
· the component is available for practical training purpose.
Note: For simple component, the maintenance organisation may take credit for the CC/S experience and/or previous training on a component from the same family and same technology.
Question: Could an Electric Fuel Pump ATA 28 be Considered Similar to an Electric Hydraulic Pump ATA 29?
Essentially yes – Same Family & Same Technology does not depend on ATA, it depends on:
- Purpose
- Function
- Inspection Techniques Used
- Tooling & Equipment Required to Service the Component
- Generic Process for Testing and Returning to Service
- Special Skills to accomplish any of the above or “Normal” Job-Specific Skills
So the C Ratings are often generic and associate directly within some cases multiple ATA chapters.
What about Crew Handsets – if they appear in ATA 25 can they be maintained in accordance with C6 approval?
The first question is what is the OEM CMM reference for the OH of the Handset?
The CMM could be ATA 25 or ATA 23 – does it matter ? Essentially no, providing the organisation has obtained the necessary ratings and has the task included in the scope of approval.
EASA provides the following guidance:
AMC 145.A.20 Terms of approval
If the maintenance manual (or an equivalent document) does not follow the ATA Chapters, the corresponding subjects still apply to the applicable C rating.
What is required to support the assessment of component certifying competence?
The first comment to make is that OEM’s are often reluctant to provide support, training & documentation to competitors.
So it is often necessary for the Component Maintenance Organisation to take full control of the process and required training.
Consider the following questions:
1/ Do you have access to the approved data – CMM ?– this is a mandatory requirement – without approved data, it becomes an issue for the competent authority to accept and agree with the authorisation.
2/ Do you have all the required facilities / Tooling / Necessary Equipment?
3/ Do you have sufficient competent manpower who are acceptable to the QAM and able to demonstrate a full understanding of the process from Receipt into the shop to issuing a CRS on completion of any maintenance action?
- Note this point can be supported with mentored OJT.
- A technical assessment can be made if appropriate.
Next Steps
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Tags:
ATA, aviation, EASA Part 145, OEM, EASA regulatory compliant, EASA Part 145 Organisation, SAS blogs, Component Certifying Staff, Component training, CC/S, AMC 145.A.20
