Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 continuing airworthiness management system is considered to be extended to the subcontracted organisation. 9. Contracts should not authorise the sub-contracted organisation to sub-contract to other organisations elements of the continuing airworthiness management tasks. 13. The operator should only sub contract to organisations which are specified by the competent authority on the AOC or EASA Form 14 as applicable. If de-icing / anti-icing were adopted as a maintenance task, then this AMC imposes some controls on sub-contracting. The operator’s de-icing / anti-icing policy and procedures could be placed in the control of the airworthiness management exposition. Service providers would no longer be able to sub-contract to other organisations. Service providers would need to be “specified” on the AOC, or Form 14, and this would require NAA/EASA action. AMC M.A.301 -1- Continuing airworthiness tasks 1. With regard to the pre-flight inspection it is intended to mean all of the actions necessary to ensure that the aircraft is fit to make the intended flight. These should typically include but are not necessarily limited to: (f) a control that all the aircraft’s external surfaces and engines are free from ice, snow, sand, dust etc.. and an assessment to confirm that, as the result of meteorological conditions and de-icing/anti-icing fluids having been previously applied on it, there are no fluid residues that could endanger flight safety. Alternatively to this pre-flight assessment, when the type of aircraft and nature of operations allows for it, the build up of residues may be controlled through scheduled maintenance inspections/cleanings identified in the approved maintenance programme. 3. In the case of commercial air transport, an operator should publish guidance to maintenance and flight personnel and any other personnel performing pre-flight inspection tasks, as appropriate, defining responsibilities for these actions and, where tasks are contracted to other organisations, how their accomplishment is subject to the quality system of M.A.712. It should be demonstrated to the competent authority that pre-flight inspection personnel have received appropriate training for the relevant pre-flight inspection tasks. The training standard for personnel performing the pre-flight inspection should be described in the operator’s continuing airworthiness management exposition. airsight GmbH - 84 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 M.A.712 (e) In case of commercial air transport the M.A. Subpart G quality system shall be an integrated part of the operator's quality system. If a contamination check is undertaken as part of the pre-flight inspection, and contamination is detected, then the “control” that the aircraft surfaces are clean is postponed until the posttreatment check. This means that the pre-flight inspection is not completed as per the AMC. At this stage a sub-contracted body is usually involved, who will technically be following the operator’s checking/inspecting procedures as required by OPS 1.345 and defined in the operator’s de-icing / anti-icing programme and procedures. Their accomplishment by a sub-contractor is subject to the operator’s Quality Systems required under OPS 1.035 as well as M.A.712, which may be integrated. This point can be clarified further when the “control” for clean surfaces must be delayed due to de-icing requirements; the responsibility is passed from maintenance to operations. In practice this may have very limited impact. However, a clear dividing line could be drawn between what are the maintenance tasks and responsibilities and which are operations’. M.A.401 Maintenance data (a) The person or organisation maintaining an aircraft shall have access to and use only applicable current maintenance data in the performance of maintenance including modifications and repairs. (b) For the purposes of this Part, applicable maintenance data is: 1. any applicable requirement, procedure, standard or information issued by the competent authority or the Agency, 2. any applicable airworthiness directive, 3. applicable instructions for continuing airworthiness, issued by type certificate holders, supplementary type certificate holders and any other organization that publishes such data in accordance with Part 21. If de-icing / anti-icing were a maintenance task, then this Rule would apply, giving the NAA/Agency indirect influence over service providers’ procedures. As this indirect and specific intervention does not exist currently through operations airsight GmbH - 85 -
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Interim Report - Introduction - EASA

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