Continuing Airworthiness Management

Bermuda DCA SeminarApril 2009Module 1Approval of Organisationsfor the Management ofContinued AirworthinessCopyright 2008 AVISA Aviation Safety Systems LTD11

Bermuda DCA SeminarApril 2009Module 1These modules regarding theimplementation of OTAR 39 are presentedby AVISA Aviation Safety SystemsCopyright 2008 AVISA Aviation Safety Systems LTD22

• My backgroundIntroductions– Over 40 years in industry! I started as a 3 yearold!– Airline and MRO background– UK CAA Surveyor, JAA and EASA experience– Head of Section – Requirements and Policy– International MRB working Group– B777 Type Certification– International Fuel Tank System Safety team– AVISA aviation consultant3

Schedule• Airworthiness Management Principles• Maintenance Programs• Fuel Tank System Safety• Ageing Aircraft Wiring issues• Wide Spread Fatigue Damage & Aircraft repairsand assessment programs• Software Management• Flight Data Recorders4

Continuing AirworthinessManagementOTAR Part 39 is Titled ContinuedAirworthiness RequirementsWhat is continued airworthiness?55

Continuing AirworthinessManagement• How do we CONTINUE the airworthinessprocess?• What keeps an aircraft or aircraftcomponent airworthy?Lets consider this question ……………….6

Continuing AirworthinessManagementBritish Airways TridentWas this airplane airworthy?In compliance with therequirementsin force?7

Continuing AirworthinessManagementAir France ConcordeWas this aircraftairworthy?In compliance with therequirements inforce?8

Continuing AirworthinessManagementAir New Zealand DC 10crash in Antarctica –Mount ErebusWas this airplaneairworthy?In compliance with therequirements inforce?9

Continuing AirworthinessManagementPittsburgh – B737Rudder malfunctionWas this airplaneairworthy?In compliance with therequirements inforce?10

Continuing AirworthinessManagementUK Register B737accident -KegworthWas this airplaneairworthy?In compliance with therequirements inforce?11

Continuing AirworthinessManagementUK Register B737In-flight GalleyCeilingFireWas this airplaneAirworthy?In compliance withthe requirements inforce?12

Continuing AirworthinessManagementEach of the in-service incidents andaccidents resulted from failures of theaviation safety systemIt is important to learn from the systemicfailures in order to develop a morerigorous safety system – this is one of thefunctions of Airworthiness Management.13

Continuing AirworthinessManagementWhat are the processes that contribute toairworthiness then?14

ContinuingAirworthiness“covers all of the processes ensuring that atany time in their operating life, all aircraftcomply with the airworthinessrequirements in force and are in acondition for safe operation.”EC Regulation 2042/200315

Continuing AirworthinessManagement• AD• Flight Manual• Modifications• Repairs• MMEL• Life Limits• Airworthiness Limitations• C of A• Occurrence Reporting• Records• MaintenanceProgramme• Maintenance Standards• Reliability Programme• CertificationMaintenanceRequirements• Weight & Balance1616

Continuing AirworthinessManagementIf all of these processes are continuedairworthiness processes then we need anorganisation to manage them in acoordinated way – especially where alarge transport airplane is being operated!1717

Is OTAR 39 unique?Continuing AirworthinessManagementWhat do other States do?1818

Continuing AirworthinessManagementFAA – FAR 121.363(a) Each certificate holder is primarilyresponsible for(1) The airworthiness of its aircraft includingits airframes, aircraft engines, propellers,appliances and parts thereof.1919

Continuing AirworthinessManagementEC Regulation 2042/2003 – Part MSUBPART BACCOUNTABILITYM.A.201 Responsibilities(a) The owner is responsible for the continuing airworthiness of an aircraft andshall ensure that no flight takes placeunless:1. the aircraft is maintained in an airworthy condition, and;2. any operational and emergency equipment fitted is correctly installed andserviceable or clearly identified asunserviceable, and;3. the airworthiness certificate remains valid, and;4. the maintenance of the aircraft is performed in accordance with the approvedmaintenance programme as specifiedin M.A.302.2020

Continuing AirworthinessManagementEC Regulation 2042/2003 – Part MM.A.201 Responsibilities(b) When the aircraft is leased, the responsibilities of theowner are transferred to the lessee if:1. the lessee is stipulated on the registration document, or;2. detailed in the leasing contract.When reference is made in this Part to the ‘owner’, the termowner covers the owner or the lessee, as applicable.2121

So, OTAR 39 is not unique!Continuing AirworthinessManagementWhat will OTAR 39 require of the operator ofa leased airplane?2222

Continuing AirworthinessManagementAir Safety Support International (ASSI) Issue5.4 Overseas Territories AviationRequirementsSubpart B — Maintenance Management39.51 Management personnel2323

Continuing AirworthinessManagement(c) Each holder of a foreign air operator’scertificate operating Territory registeredaircraft under the provisions of an ICAOArticle 83 bis agreement shall appoint apost-holder to establish and maintainarrangements for the continuedairworthiness management of theoperator’s aircraft as required by thisOTAR Part.2424

Continuing AirworthinessManagement(d) The senior person identified in 39.51(c)shall ensure that suitable arrangements forcontinued airworthiness management arein place by way of holding an appropriateapproval, or by contract with anorganisation holding an approval, grantedby the Governor under Subpart F of thisPart.2525

Continuing AirworthinessManagement39.55 Management responsibilitiesThe person identified in paragraph 39.51 isresponsible for ensuring the certificate ofairworthiness continues to remain valid bysuitable arrangements identified inparagraph 39.53 that also ensures:(a) the aircraft, including its airframe,engine(s), propellers, appliances,emergency equipment and operationalequipment, is maintained in an airworthycondition;2626

Continuing AirworthinessManagement39.59 Maintenance control manual(a) The maintenance control manual shallform the basis for an approval prescribedin Subpart E of this Part, the content ofwhich shall be representative of theorganisation and be acceptable to theGovernor.2727

Continuing AirworthinessManagement39.59 Maintenance control manual(d) The maintenance control manual shallcontain the necessary procedures forapplicable continued airworthinessmanagement functions prescribed inparagraph 39.55 and 39.57 to ensure thecontinued airworthiness of the operatingaircraft and ensure the continued validityof the Certificates of Airworthiness.2828

Continuing AirworthinessManagement39.59 Maintenance control manual(f) The maintenance control manual shallcontain details of the available facilities,personnel including their responsibilitiesand data to be utilised for the purpose ofcontinued airworthiness management.2929

Continuing AirworthinessManagement• Nominated Post Holder• Suitable arrangements• Approval• Maintenance Control Manual• Procedures30• Responsibilities• Facilities & personnelAll of this then combines to make anorganisation approved for themanagement of continued airworthiness!30

Continuing AirworthinessManagementSubpart F — Continued airworthinessmanagement approval in associationwith an ICAO Article 83 bis agreement3131

Continuing AirworthinessManagement39.103 Applicability(a) Organisations that undertake continuedairworthiness management of aircraftregistered in the Territory and operatedunder an ICAO Article 83bis agreementshall hold an appropriate approval grantedby the Governor under the requirements ofthis Subpart.3232

Continuing AirworthinessManagement39.103 Applicability(b) Such organisations may be:(1) holders of a foreign air operator’scertificate which operate Territoryregistered aircraft under an ICAO Article83bis agreement; or(2) organisations that are contracted toperform the functions of continuedairworthiness management by an airoperator certificate holder under an Article3333

Continuing AirworthinessManagement39.103 Applicability(b) Such organisations may be:(1) holders of a foreign air operator’s certificate whichoperate Territory registered aircraft under an ICAOArticle 83bis agreement; or(2) organisations that are contracted to perform thefunctions of continued airworthiness management by anair operator certificate holder under an Article 83bisagreement with the Territory.The operator can obtain the approval orcontract out the continuing airworthinessmanagement tasks!3434

Continuing AirworthinessManagement39.105 Standards(a) Foreign air operator certificate holdersreferred to in paragraph 39.103(b)(1)seeking approval under this Subpart shallcomply with the requirements of EASAPart M Subpart G as varied by paragraph39.105(d).3535

39.105 StandardsContinuing AirworthinessManagement(a) Foreign air operator certificate holders referred to in paragraph39.103(b)(1) seeking approval under this Subpart shall comply withthe requirements of EASA Part M Subpart G as varied by paragraph39.105(d).Even if contracting out, the operator muststill comply with EASA Part M sub-Part G!3636

39.105 StandardsContinuing AirworthinessManagement(b) Organisations referred to in paragraph 39.103(b)(2) thathold an approval under EASA Part M Subpart G shallcomply with the requirements of that approval and theapplicable requirements of Subparts B and C of thisOTAR Part.An organisation currently approved inaccordance with EASA Part M needs toadapt its procedures before obtainingBermuda DCA Approval3737

Continuing AirworthinessManagement39.105 Standards(c) Organisations referred to in paragraph39.103(b)(2) seeking approval under thisSubpart but which do not hold an approvalunder EASA Part M Subpart G shallcomply with the requirements of EASAPart M Subpart G as varied by paragraph39.105(d).3838

39.105 StandardsContinuing AirworthinessManagement(c) Organisations referred to in paragraph 39.103(b)(2)seeking approval under this Subpart but which do nothold an approval under EASA Part M Subpart G shallcomply with the requirements of EASA Part M Subpart Gas varied by paragraph 39.105(d).An operator which carries out all of theairworthiness management tasks will berequired to comply with EASA Part M sub-Part G!3939

Continuing AirworthinessManagement39.105 Standards(d) The following variations to the requirements of EASAPart M Subpart G shall apply to those organisationsreferred to in paragraph 39.105(a) and (c):(1) any reference to a competent authority shall be read asa reference to the Governor of the Territory in which theaircraft is registered; and(2) any reference to the owner shall be read as a referenceto the operator; and(3) Subpart I is not applicable; and(4) Paragraph M.A.715 is not applicable and therequirements of OTAR Part 39.11 shall apply instead;and4040

39.105 StandardsContinuing AirworthinessManagement(5) Paragraph M.A.711(a)(3) and (b) are not applicable;and(6) Paragraph M.A.803 Pilot Owner Authorisation is notapplicable.4141

• Sub-Part I is not applicable?• M.A. 715 is not applicable?Continuing AirworthinessManagement• M.A.711(a)(3) & (b) are not applicable?4242

Continuing AirworthinessManagementSUBPART IAIRWORTHINESS REVIEW CERTIFICATEM.A.901 Aircraft airworthiness reviewTo ensure the validity of the aircraftairworthiness certificate an airworthinessreview of the aircraft and its continuingairworthiness records must be carried outperiodically.4343

Continuing AirworthinessManagementSUBPART IAIRWORTHINESS REVIEW CERTIFICATEM.A.901 Aircraft airworthiness reviewTo ensure the validity of the aircraft airworthiness certificatean airworthiness review of the aircraft and its continuingairworthiness records must be carried out periodically.EASA Part M and Part 21 require a C of A to be issuedwithout a defined expiry period and continuing validity tobe certified by the issue of an Airworthiness ReviewCertificate: this process will not be adopted by OTAR4444

Continuing AirworthinessManagementM.A.711 Privileges of the organisation(a) An approved continuing airworthiness managementorganisation, may:3. arrange to carry out any task of continuing airworthinesswithin the limitation of its approval with anotherorganisation that is working under its quality system.(b) An approved continuing airworthiness managementorganisation, may additionally be approved to:1. issue an airworthiness review certificate, or;2. make a recommendation for the airworthiness review toa Member State of Registry.4545

Continuing AirworthinessManagementM.A.715 Continued validity of approval(a) An approval shall be issued for an unlimited duration. Itshall remain valid subject to:1. the organisation remaining in compliance with this Part,in accordance with the provisions related to the handlingof findings as specified under M.B.705 and;2. the competent authority being granted access to theorganisation to determine continued compliance with thisPart, and;3. the approval not being surrendered or revoked.(b) Upon surrender or revocation, the approval certificateshall be returned to the competent authority.4646

Continuing AirworthinessManagementM.A.715 Continued validity of approval(a) An approval shall be issued for an unlimited duration. It shall remain validsubject to:1. the organisation remaining in compliance with this Part, in accordance withthe provisions related to the handlingof findings as specified under M.B.705 and;2. the competent authority being granted access to the organisation todetermine continued compliance with thisPart, and;3. the approval not being surrendered or revoked.(b) Upon surrender or revocation, the approval certificate shall be returned tothe competent authority.OTAR Approvals will be required to be renewed on acontinuing basis!4747

Continuing AirworthinessManagementIs this the only change brought about byOTAR 39?No: we also have to consider:‣ Continuing Airworthiness Improvements – 39.61 (f) &39.70‣ Supplemental Structural Inspection Document‣ Fuel Tank Safety‣ Ageing Aircraft‣ Widespread Fatigue DamagePlus‣ Software Management – 39.55 – ManagementResponsibilities 39.55.(n)4848

Continuing AirworthinessManagementThe Continuing Airworthiness Improvementsand Software Management topics aredealt with by separate modules.4949