EASA Part M "Complex Tasks"

[powerlimited]

Hi,
I have viewed the list of EASA "Complex Tasks" and whilst it is useful for a general broad brush approach I would like your thoughts on a real life scenario.

As an independant engineer (not 145 or subpart F) you come across an aircraft with a Mag problem, further investigation reveals a stripped distributor gear. Can you replace said gear and return to service assuming alls well on the ground run etc?

Any further guidance on what can and can't legally be done?

Regards.
Pwrltd

[Beeline]

Independent engineer must have an approval or authorisation granted from a 145/subpart f company and must sign the CRS under there approval number and exposition.

You cannot be your own 145/21/147 and Part 66 independent engineer.

[Bus429]

Beeline,

Are you absolutely certain? In that case Part M is wrong...

[Beeline]

Companies are currently abusing the regulations as per Part M due to ambiguity within the text.

We have discussed this many times within the forum. Single vs Multiple release
NPA 145.012.

[Wirelock]

i think it is possible that you can use an approved person to start 145 with you. i knew a guy who worked for various different companies doing exactly what you require to get going

[Bus429]

I think you'll find that Part M Appendices VII and VIII apply to non-commercial <2730 kg. The latter provides guidance for pilot/owner maintenance and there are meant to be controls such as naming those that can certify maintenance in the AMP. In my experience, those pilots entrusted with 50hr checks and some invariably fail to certify either correctly (Part M release, not 145). Subpart H describes certification of such tasks. Other stuff to remember that, while Subpart F does have some provision for maintenance on some commercial aircraft; Part 145 is the regulation that covers commercial and MPCA (>5700). Pilots can be issued a 145 authorisation by an AMO and they are no different from licensed engineers with regard to certification of the task-trained stuff they can do. They have to use data and certify corectly too. Different beast from Part M.
Appendix VII of Part M lists those tasks an LAE cannot perform on his/her own - outside the auspices of a Subpart F AMO (or 145 for that matter). Remember that some parts of Part M apply to maintenance performed by independents, Subpart Fs, pilot/owners and 145 AMOs .

[powerlimited]

Bus429, many thanks for your reply.

Thankfully, someone can see the difference between Part 145 and Part M.

So, what do you recon about replacing parts in Magnetos? In your opinion would this be allowed?

Many Thanks
Pwrltd

[jxk]

I would say that unless you have approval to do this task the answer is no for EASA aircraft. In the Part F you would have demonstrate that you have the appropriate tools, manuals and test equipment to accomplish this task.
Of course the tougher the regulations become the more likely it is for these jobs to be done without the required paperwork and authorisation.

[Bus429]

Powerlimited
My last post was written in rather a hurry, hence typos.
To answer your question, I reckon probably not - look at Appendix VII para 3 (d)
There are some alleviations in the pipeline for ELA 1 & 2 but I've not got them to hand...

[powerlimited]

Bus429
Many thanks for your reply, I thought as much.

Cheers
Pwrltd