Part M - important news for owners/ operators

[EGBKFLYER]

Mods - feel free to merge this with other appropriate threads.

If your aircraft comes under the new EASA Part M regulations for Airworthiness, you know that the new rules apply from 28 Sept 2008. There was a strong possibility that the rules were going to be delayed until Sept 2009 but this has not happened.

Thee CAA has ruled that if your aircraft needs an ARC renewal before Jan 2009, you can continue to get the relevant paperwork from your M3 or Part 145 maintenance organisation. Thereafter and you will need to find a Subpart G-approved company to issue the ARC and manage your maintenance. At present, this could prove difficult as very few companies working on GA aircraft have the necessary approvals. 2009 could be a mess for a lot of GA as a result - well done CAA...

Check out Information for Owners/Operators | Airworthiness | Safety Regulation for more information.

[jxk]

I wish all M3 organisations would refuse to have anything to do Part G for at least 5 years by then hopefully it might be sorted.

[NutLoose]

CAA will be able to issue an Arc for you.

[jxk]

I don't want the CAA to issue my ARC - I'd rather have my current M3 do it as I think they've got more experience with light aircraft.

[EGBKFLYER]

Nutloose - you're quite right, although the CAA are trying to avoid this (will enjoy watching them try!) and will make it expensive.

jxk - unfortunately we're long past the point where holding out against the change is going to work. I recommend all maintenance organisations that want to be approved get a move on and sort out their applications asap - CAA surveyors are going to be very busy and it will be first com, first served...

[jxk]

It would be nice to get a move on but the goal posts keep moving. So, should the M3 organisations chase around like a scolded cats or wait until there's a clear spec? I would like to see what the French do - I simply can't believe they're going to implement all these rules and regs. Perhaps, we could wait until one of the other countries are on board and copy them.

[A and C]

CAA delays

As you might expect the CAA is responsable for a great deal of the delays with this part M introduction, they have been very slow in commenting on the part M applications so the whole process seems to drag on for ages.

The first part of the the companys application was done before xmas and the approval has yet to get the approval with the deadline now only weeks away!

I would think that there must be panic in aviation house as this fiasco unfolds.

[EGBKFLYER]

A nd C - I hope there is a panic at the Belgrano! They've caused it after all. Even the surveyors were clueless - one told me the deadline would definitely move to Sept 09 and another that it would not! That was about a month ago.

jxk - this is where being British is a disadvantage, since we always seem to play by the letter of the rules! I can imagine several other countries opting in to the deadline move and delaying til next year while we all thrash about here, trying to get things sorted.

[robin]

Oh Great...

Looking at the list of approved organisations there is no-one within 100 nm of home base and those that are do not have the approvals for my type.

Who do I sue for distraint of trade........?

[dragqueen120]

Laymans

Hi, just bought a CofA aircraft lastweek (Cessna 120), read ya thread but am not ofay with the jargon being new to ownership etc. What do I need to do? is it set up a maintenance contract with some one or am I barking up the wrong expensive tree!

Many thanks in advance

[robin]

Yep - that is pretty much the case.

Start off with the company that is currently doing the work, if it isn't too far away, but if not start looking.....

[vee-tail-1]

Go to the EASA website and you will get all you need from the horses mouth.

See "Guidance for Owners of Private Aircraft of 2730 kgs MTOM & Below"


Rulemaking | Rulemaking archives

Scroll down to: COMMENT RESPONSE DOCUMENT (CRT) ARCHIVES
then click on CRD 2007-08 Go to page 357 of 457

There you will see in print along with references to part M that:
(a) THE OWNER is responsible for the continued airworthiness of his aircraft. (c) NO NEED TO CONTRACT WITH A CAMO. The OWNER may manage the continuing airworthiness of his aircraft under his own responsibility. And much more of interest.

Not sure how the French will react to part M as it is very similar to their present system. The GSAC recently published a guide for small maintenance workshops wishing to implement part M sub parts F,G,&I . It showed how a CAMO would function in practice and seems to indicate that one person could be the CAMO and another the maintenance organisation.
Important to realise that EASA requires the administration of continuing airworthiness (the paperwork) to be quite separate from the maintenance (nuts & bolts & servicing) of the aircraft.

[jxk]

Important to realise that EASA requires the administration of continuing airworthiness (the paperwork) to be quite separate from the maintenance (nuts & bolts & servicing) of the aircraft.

BUT I WONDER WHY?
This sounds like airline practice where there's a 'rolling' type of maintenance.
I've always been happy with my maintenance organisation which has done a thorough job with all the AD and SID research and at the same time done a good job with the nuts and bolts. Why do we need two (or 3) separate departments? How about joined-up maintenance. eg M3.

[vee-tail-1]

I guess it's a flight safety matter, rather like dual inspection of flying controls. The person who did the work might genuinely believe he did a good job. But an inspector unconnected with the aircraft or mechanics can find faults that the others missed.
Certainly my experience is that an aircraft fresh out from servicing is highly likely to have some technical requirement missed.
Having someone dedicated to manage ADs, maintenance programme updates, time limited items, service bulletins, mods, next required servicing, recording of data, archives, etc, makes sense. The mechanics/engineers can then get on with the technical stuff which they do best.

[dragqueen120]

Thanks people for your words of wisdom. I shall sort it out.
then perhaps I can do what was intended and hop in and fly away some where sunny. Headcorn this weekend if I get my finger out!

Ta

[EGBKFLYER]

Couple of points here:

1. The new rules apply only to Annex I aircraft - those being administered by EASA. Annex II aircraft come under state (UK CAA for us in the UK) control and will continue to be maintained and administered under the old state rules (BCAR etc). To find out if your aircraft is Annex I or II, see this document:

http://www.caa.co.uk/docs/33/CAP747.PDF

Section 1 carries the list. Dragqueen - your C120 is Annex II so your maintenance will be carried out under BCARs by an M3 organisation or similar. You don't need to worry about EASA (lucky you!)

2. A maintenance company can be Subpart G and F approved, which means that the same person may manage your aircraft's airworthiness and also do the work on it when required. You can have the aircraft managed by one company and worked on by another, but I think this will be unlkely in practice. Most companies I know want to keep the whole operation in house as thety do now.

[vee-tail-1]

."" A maintenance company can be Subpart G and F approved, which means that the same person may manage your aircraft's airworthiness and also do the work on it when required. Most companies I know want to keep the whole operation in house as they do now."

Not so! the organisation can manage continuing airworthiness, and the same organisation can do the servicing & maintenance. But the person doing the servicing is not allowed to carry out management & review of continuing airworthiness. No time to dive into my copy of part M and the relevant MA... but airworthiness review staff in an organisation have to be separate from the servicing and maintenance people.
You could have a maintenance organisation that has the minimum of just two people, one does the dirty work and the other does the paperwork.
Edited to say the relevant MA is AMC MA 707 in NPA No 2007-08 and as it has been translated from the original French it is bl***y hard going!

[EGBKFLYER]

I'll try to find the Part M section too but I beg to differ Vee-tail. I work with an organisation that has been G approved and F approved, with the Chief Engineer as the only Airworthiness Review Staff and licenced engineer for Sub F work.

I'm thinking about small organisations - maybe the rules differ here?

[vee-tail-1]

Reading the MA 707 there seems to be a distinction made between staff carrying out continuing airworthiness management and those carrying out airworthiness reviews for issue of an ARC.
The GSAC guide I mentioned in an earlier post is more specific. Giving examples of a combined CAMO / Maintenance Organisation set-up, where the Cessna supervisor is required to do airworthiness examinations on Robin aircraft, and vice versa for the Robin supervisor. The general principle of the inspector of the paperwork being different to the person who did the servicing still holds.
If only it was all written in plane! English. God knows how people whose native language is not French or English get on with part M

[giloc]

Originally Posted by vee-tail-1

But the person doing the servicing is not allowed to carry out management & review of continuing airworthiness.

That's not what M.A.707 says. In fact, it specifically says that in Subparts F,G, and I-approved organisations the maintenance staff may be nominated to conduct airworthiness reviews even where they have been involved in the maintenance of the aircraft, as long as they haven't been involved in the maintenance management.