Sеveral areas are being addressed and more is to come
So lets look at what is happening and the direction EASA is moving in please see highlighted comments, intended to support observation, comment and further understanding.
5) GM 145.A.48 is added as follows:
‘GM 145.A.48 Performance of maintenance AUTHORISED PERSON An ‘authorised person’ is a person formally authorised by the maintenance organisation to perform or supervise a maintenance task.
An ‘authorised person’ is not necessarily ‘certifying staff’.
SIGN-OFF A ‘sign-off’ is a statement issued by the ‘authorised person’ which indicates that the task or group of tasks has been correctly performed.
A ‘sign-off’ relates to one step in the maintenance process and is, therefore, different to a certificate of release to service.’
So we are understanding that certain persons within the maintenance process may receive an approval to perform “ non certifying” inspection tasks.
6) AMC1 145.A.48(b) is added as follows: ‘AMC1 145.A.48(b) Performance of maintenance
The procedure should identify the error-capturing methods, the critical maintenance tasks, the training and qualification of staff applying error-capturing methods, and how the organisation ensures that its staff is familiar with critical maintenance tasks and error-capturing methods.’
We already have error reporting processes – (reactive process) Now we are seeing Proactive Behaviours to identify potential errors.
This will be thought provoking as to how this may be promoted in a real and effective way within the organisation – currently reporting rates of such exposures are quite low and it will require a step change in culture and behaviour to impact this in a positive way.
7) AMC2 145.A.48(b) is added as follows: ‘AMC2 145.A.48(b) Performance of maintenance CRITICAL MAINTENANCE TASKS
Identifies the need for a “developed” procedure to clearly identify how the subject of Critical Maintenance Tasks will be dealt with and which documentation will be used to determine the applicability
Consider also that there is an obligation placed on the Operator to ensure the EASA Part 145 organisation remains fully compliant.
(a) The procedure should ensure that the following maintenance tasks are reviewed to assess their impact on flight safety:
(1) tasks that may affect the control of the aircraft flight path and attitude, such as installation, rigging and adjustments of flight controls;
(2) aircraft stability control systems (autopilot, fuel transfer);
(3) tasks that may affect the propulsive force of the aircraft, including installation of aircraft engines, propellers and rotors; and
(4) overhaul, calibration or rigging of engines, propellers, transmissions and gearboxes.
(b) The procedure should describe which data sources are used to identify critical maintenance tasks.
Several data sources may be used, such as:
(1) information from the design approval holder;
(2) accident reports;
(3) investigation and follow-up of incidents;
(4) occurrence reporting;
(5) flight data analysis;
(6) results of audits;
(7) normal operations monitoring schemes; and
(8) feedback from training.’
The above items 1 to 8 are all reactive in essence – still to be considered and added to the mix are “proactive” sources of information which will be challenging
Also note that the EASA 145 organisation has limitations in respect of its ability to access some of the above data sets which are owned by the operator.
8) AMC3 145.A.48(b) is added as follows: ‘AMC3 145.A.48(b) Performance of maintenance ERROR-CAPTURING METHODS
(a) Error-capturing methods are those actions defined by the organisation to detect maintenance errors made when performing maintenance.
(b) The organisation should ensure that the error-capturing methods are adequate for the work and the disturbance of the system.
A combination of several actions (visual inspection, operational check, functional test, rigging check) may be necessary in some cases.’
9) AMC4 145.A.48(b) is added as follows: ‘
AMC4 145.A.48(b) Performance of maintenance INDEPENDENT INSPECTION
Independent inspection is one possible error-capturing method.
(a) What is an independent inspection An independent inspection is an inspection performed by an ‘independent qualified person’ of a task carried out by an ‘authorised person’, taking into account that:
(1) the ‘authorised person’ is the person who performs the task or supervises the task and they assume the full responsibility for the completion of the task in accordance with the applicable maintenance data;
(2) the ‘independent qualified person’ is the person who performs the independent inspection and attests the satisfactory completion of the task and that no deficiencies have been found.
The ‘independent qualified person’ does not issue a certificate of release to service, therefore they are not required to hold certification privileges;
(3) the ‘authorised person’ issues the certificate of release to service or signs off the completion of the task after the independent inspection has been carried out satisfactorily;
(4) the work card system used by the organisation should record the identification of both persons and the details of the independent inspection as necessary before the certificate of release to service or sign-off for the completion of the task is issued.
(b) Qualifications of persons performing independent inspections
The organisation should have procedures to demonstrate that the ‘independent qualified person’ has been trained and has gained experience in the specific inspection to be performed.
The organisation could consider making use of, for example:
(1) staff holding a certifying staff or support staff or sign-off authorisation or equivalent necessary to release or sign off the critical maintenance task;
(2) staff holding a certifying staff or support staff or sign-off authorisation or equivalent necessary to release or sign off similar task in a product of similar category and having received specific practical training in the task to be inspected; or
(3) a commander holding a limited certification authorisation in accordance with 145.A.30(j)(4) and having received adequate practical training and having enough experience in the specific task to be inspected and on how to perform independent inspection.
Note that here within the examples EASA does not identify that the independent person may in fact be an unlicensed “but fully competent & trained Mechanic – (QUOTE FROM EASA An ‘authorised person’ is not necessarily ‘certifying staff’. )
(c) How to perform an independent inspection
An independent inspection should ensure correct assembly, locking and sense of operation. When inspecting control systems that have undergone maintenance, the independent qualified person should consider the following points independently:
(1) all those parts of the system that have actually been disconnected or disturbed should be inspected for correct assembly and locking;
(2) the system as a whole should be inspected for full and free movement over the complete range;
(3) cables should be tensioned correctly with adequate clearance at secondary stops;
(4) the operation of the control system as a whole should be observed to ensure that the controls are operating in the correct sense;
(5) if different control systems are interconnected so that they affect each other, all the interactions should be checked through the full range of the applicable controls; and
(6) software that is part of the critical maintenance task should be checked, for example: version, compatibility with aircraft configuration.
Including Software Verification is something that could be considered as relatively “new” into the process – note the need to understand the operators Software status and configuration management processes
(d) What to do in unforeseen cases when only one person is available REINSPECTION:
(1) Reinspection is an error-capturing method subject to the same conditions as an independent inspection is, except that the ‘authorised person’ performing the maintenance task is also acting as ‘independent qualified person’ and performs the inspection.
(2) Reinspection, as an error-capturing method, should only be performed in unforeseen circumstances when only one person is available to carry out the task and perform the independent inspection.
The circumstances cannot be considered unforeseen if the person or organisation has not assigned a suitable ‘independent qualified person’ to that particular line station or shift.
Note that shortage of Manpower is not therefore a reason to NOT perform a 2 person Independent Inspection.
(3) The certificate of release to service is issued after the task has been performed by the ‘authorised person’ and the reinspection has been carried out satisfactorily. The work card system used by the organisation should record the identification and the details of the reinspection before the certificate of release to service for the task is issued.’
10) AMC 145.A.48(c) is added as follows:
‘AMC 145.A.48(c) Performance of maintenance
The procedures should be aimed at:
(a) minimising multiple errors and preventing omissions. Therefore, the procedures should specify:
(1) that every maintenance task is signed off only after completion;
(2) how the grouping of tasks for the purpose of sign-off allows critical steps to be clearly identified; and
(3) that work performed by personnel under supervision (i.e. temporary staff, trainees) is checked and signed off by an authorised person;
(b) minimising the possibility of an error being repeated in identical tasks and, therefore, compromising more than one system or function.
Thus, the procedures should ensure that no person is required to perform a maintenance task involving removal/installation or assembly/disassembly of several components of the same type fitted to more than one system, a failure of which could have an impact on safety, on the same aircraft or component during a particular maintenance check. However, in unforeseen circumstances when only one person is available, the organisation may make use of reinspection as described in point (d) of AMC4 145.A.48(b).’
Note the above HUMAN Factor related requirement, together with the need to ensure that Production Planning and in turn Maintenance Planning groups perform the following –
Ensure the correct delivery of paperwork to enable the above to take place in without the risk of introducing errors.
11) GM 145.A.48(c) is added as follows:
‘GM 145.A.48(c) Performance of maintenance
To minimise the risk of multiple errors or errors being repeated, the organisation may implement: — procedures to plan the performance by different persons of the same task in different systems; — duplicate inspection or re-inspection procedures.’
12) GM 145.A.48(d) is added as follows:
‘GM 145.A.48(d) Performance of maintenance — critical design configuration control limitations (CDCCL) The organisation should ensure that when performing maintenance the CDCCL are not compromised.
The organisation should pay particular attention to possible adverse effects of any change to the wiring of the aircraft, even of a change not specifically associated with the fuel tank system.
For example, it should be common practice to identify segregation of fuel gauging system wiring as a CDCCL.
The organisation can prevent adverse effects associated with changes to the wiring by standardising maintenance practices through training, and not through periodic inspections. Training should be provided to avoid indiscriminate routing and splicing of wire and to provide comprehensive knowledge of critical design features of fuel tank Annex II to ED Decision 2016/011/R systems that would be controlled by a CDCCL.
Guidance on the training of maintenance organisation personnel is provided in Appendix IV to AMC 145.A.35.’
13) GM 145.A.65(b)(1) is added as follows:
‘GM 145.A.65(b)(1) Safety and quality policy, maintenance procedures and quality system
Appendix XI to AMC M.A.708(c) provides guidance on the elements that need to be considered for the maintenance contract between the CAMO and the maintenance organisation.
The Part-145 organisation should take into account these elements to ensure that a clear contract or work order has been concluded before providing maintenance services.’
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