AMC & GM to Part-M — Issue 2, Amendment 10
Acceptable Means of Compliance and Guidance Material to Annex I (Part-M) to Regulation (EU) No 1321/2014, Issue 2, Amendment 10
Annex II to ED Decision 2026/005/R ‘AMC and GM to Part-M — Issue 2, Amendment 10’
The amendments are presented as follows: — deleted text is struck through; — new text is highlighted; — an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
Annex I to Decision 2015/029/R of the Executive Director of the Agency of 17 December 2015 is amended as follows:
GM1 M.A.202 Occurrence reporting
MANDATORY REPORTING — GENERAL
(a) If the persons identified in point M.A.202(a) are employed by, contracted by or whose services are used by an organisation established in a Member State, Article 4(6) of Regulation (EU) No 376/2014 requires that occurrences be reported to that organisation. This may be the case, for example, in cases in which independent certifying staff provide services to a CAMO established in the EU that has requested them to perform maintenance. In such cases, the provisions of Regulation (EU) No 376/2014 are to be complied with and the occurrence is to be reported through the organisation concerned. However, situations may arise in which the individuals referred to in point M.A.202(a) work for an organisation established outside the EU or act exclusively on their own behalf, outside the framework of an organisation. This may occur, for example, in cases in which the owner manages the continuing airworthiness of the aircraft and also performs maintenance under the pilot-owner privilege. In such cases, the reporting provisions set out in point M.A.202 are to be followed. (b) Implementing Regulation (EU) 2015/1018 lays down a list classifying occurrences in civil aviation to be mandatorily reported. This list should not be understood as being an exhaustive collection of all the issues that may pose a significant risk to civil aviation safety and, therefore, reporting should not be limited to the items listed in that Regulation. (c) Reporters are encouraged to include as much relevant information as possible in their reports. Annex I to Regulation (EU) No 376/2014 may be used as a reference for the types of information mandatory for each specific type of occurrence. Furthermore, reporters should include any factors that may be relevant to the occurrence, including contributing human factors. Providing these details supports a better understanding of the safety hazards and enables a more accurate identification of the safety risks. (d) AMC-20 ‘General Acceptable Means of Compliance for Airworthiness of Products, Parts and Appliances’, and in particular AMC 20-8A, provides further details on occurrence reporting.
AMC M.A.202(a) Occurrence reporting
Accountable persons or organisations should ensure that the type certificate (TC) holder or the declarant of a declaration of design compliance receives adequate reports of occurrences for that aircraft type, to enable it to issue appropriate service instructions and recommendations to all owners or operators. Liaison with the TC holder or the declarant of a declaration of design compliance is recommended to establish whether published or proposed service information will resolve a problem or to obtain a solution to a particular problem.
An approved continuing airworthiness management or maintenance organisation should assign responsibility for co-ordinating action on airworthiness occurrences and for initiating any necessary further investigation and follow-up activity to a suitably qualified person with clearly defined authority and status. In respect of maintenance, reporting a condition which endangers flight safety is normally limited to: − serious cracks, permanent deformation, burning or serious corrosion of structure found during scheduled maintenance of the aircraft or component. − failure of any emergency system during scheduled testing
AMC M.A.202(b) Occurrence reporting
The reports may be transmitted by any method, i.e. electronically, by post or by facsimile. Each report should contain at least the following information: − reporter or organisation’s name and approval reference if applicable, − information necessary to identify the subject aircraft and/or component, − date and time relative to any life or overhaul limitation in terms of flying hours/cycles/landings etc., as appropriate, − details of the occurrence. AMC 20-8 General Acceptable Means of Compliance for Airworthiness of Products, Parts and Appliances provides further guidance on occurrence reporting.
GM1 M.A.202(b)(1) Occurrence reporting
ORGANISATION RESPONSIBLE FOR THE DESIGN
Depending on the case, ‘the organisation responsible for the design of the aircraft or component’ may be: (a) the design approval holder: it may be the holder of a type certificate, a restricted type certificate, a supplemental type certificate, a European Technical Standard Order (ETSO) authorisation, a major repair design approval, a major change design approval or any other relevant approval or authorisation for products, parts and appliances deemed to have been issued under Regulation (EU) No 748/2012; (b) the declarant of a declaration of design compliance made under Subpart C of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012.
GM1 M.A.301 Continuing airworthiness tasks
MANAGEMENT OF AIRCRAFT CONFIGURATION
(a) For each individual aircraft, aircraft configuration is the consistent set of the aircraft’s functional and physical characteristics, as defined in the applicable documentation and as present on the aircraft, including any hardware or software component. The aircraft configuration is established based on the following elements, as defined and approved in accordance with the applicable regulations and bilateral agreements:
(1) the aircraft, engine and propeller type design; (2) the embodied changes; for example, minor and major changes, STCs and standard changes; (3) the embodied repairs; (4) unintentional deviations from the approved type design occurring in production, sometimes referred to as ‘concessions’, ‘divergences’ or ‘non-conformances’; (5) design-related requirements established in applicable ADs; (6) exemptions, waivers or derogations affecting the elements listed above, if appropriately approved. These configuration elements of an individual aircraft are the baseline for determining the aircraft’s conformity with its approved design. A clear understanding of the aircraft configuration is essential to ensure its continuing airworthiness. Additionally, some elements of the configuration of an individual aircraft may influence the environmental certification of the aircraft or engines, or the contents of the aircraft maintenance programme (AMP), the flight manual, etc. (b) The person or organisation that is responsible for the continuing airworthiness of the aircraft is responsible for managing the aircraft configuration. This includes ensuring that: — all data necessary to determine the approved configuration is available; — no conflicts exist between the configuration elements referred to above that could affect the airworthiness of the aircraft; — the aircraft conforms to its approved design.
GM1 M.A.301(g) Continuing airworthiness tasks
CONFLICT BETWEEN CONFIGURATION ELEMENTS
(a) Ensuring that there are no conflicts between the different configuration elements involves identifying any potential conflicts with previously embodied configuration elements prior to the embodiment of a new configuration element, such as a new modification or repair. This is necessary because the design approval holder, or declarant of a declaration of design for a particular modification or repair, cannot in all cases be expected to be aware of all the possible configuration elements embodied on all aircraft of a given type. In many cases, this verification may be limited to ensuring the absence of interfaces between configuration elements. For example, this may apply to repairs carried out in accordance with the SRM in areas where no other structural modifications or repairs are present. In addition, in some cases, the absence of conflicts may be ensured in cases in which a modification or repair has been specifically designed for an individual aircraft, taking into account its configuration during the design process. In concerns arise, and the person or organisation responsible for the continuing airworthiness of the aircraft is unable to determine the absence of conflicts affecting the airworthiness of the aircraft, assistance from an appropriately approved design organisation should be sought.
(b) The following list, although not exhaustive, provides examples of combinations of installations which have the potential to create compatibility issues; for example, the installation of: — autopilots on aircraft with other modifications that alter flight characteristics, including the lift, drag, weight and thrust of aircraft. The cumulative effect of multiple modifications that individually increase drag should not be disregarded; — multiple accessories mounted on the skid tubes of helicopters; — changes to or the introduction of new operating limitations or procedures. This would include multiple flight manual supplements affecting the same or interconnecting systems; — multiple modifications to the same structure (the superposition of stresses, changes in stiffness, or changes to safe life, fail safe, or damage tolerance characteristics should be considered); — any software changes in interdependent systems; — modifications to light-emitting or reflecting characteristics (internal and/or external) of aircraft with night vision imaging system (NVIS) lighting systems; — automatic dependent surveillance-broadcast (ADS-B) Out equipment with previously installed GPS antennas or upgrades of global positioning system (GPS) antennas/navigators that may affect ADS-B Out function (performance); — highly integrated avionics components (e.g.,one multi-function display (MFD) and one primary-function display (PFD) in cases in which interconnectivity was changed, added or removed); — modifications to items that affect ditching certification (e.g. replacement windows with different construction or push-out window STCs, changes to waterline location, or the installation or relocation of equipment, such as valves, below the waterline); — Equipment whose use under normal operation could damage other equipment in close proximity (e.g. heat from a searchlight mounted next to skid-mounted float bags on helicopters); — any modification near attitude and heading reference system (AHRS) magnetic field sensors (flux valves, etc.); — multiple modifications to the same primary structure that include the use of blind fasteners; — multiple changes affecting ice protection system operation; — de-icing boots with structural changes that could impinge on the ability of the boots to expand; — multiple changes to the interior aircraft configuration (seats, emergency lighting, etc.) which may affect emergency evacuation of occupants and occupant protection; — multiple modifications installing equipment that applies electrical loads on the same aircraft electrical generating system; or
— multiple modifications installing equipment that requires an assessment of electromagnetic compatibility.
GM1 M.A.305(c)(2) Aircraft continuing airworthiness record system
IMPACT OF MODIFICATIONS AND REPAIRS
[…] (c) For traceability purposes, the status of modifications and repairs may include the activities performed to ensure that a particular modification or repair is compatible with the other configuration elements of the aircraft, and that no conflict exists between them that could affect the airworthiness of the aircraft, as described in GM1 M.A.301(g). This may include, for example, information on any consultation with the design approval holder.
AMC1 M.A.801(c) Aircraft certificate of release to service
[…] 3. A release in accordance with this paragraph does not affect the controlled environment, in accordance with point (b) of M.A.901 conditions to extend the ARC prescribed in point (b) of M.A.902, of the aircraft as long as the point M.A.801(c)2 recheck and release has been carried out by an approved maintenance organisation.
AMC M.A.901 Aircraft airworthiness review
In order to ensure the validity of the aircraft airworthiness certificate, M.A.901 requires performing periodically an airworthiness review of the aircraft and its continuing airworthiness records, which results in the issuance of an airworthiness review certificate valid for one year.
GM M.A.901(a) Aircraft airworthiness review
EASA Form 15a is issued by competent authorities while EASA Form 15b is issued by a CAMO or CAO organisation.
GM1 M.A.901 Airworthiness review — General
Responsibilities of airworthiness review staff:
KEY CONSIDERATIONS FOR THE AIRWORTHINESS REVIEW
The following is a summary of the requirements contained in M.A.901, as well as the associated AMC and Appendices, in relation to the responsibilities of the airworthiness review staff: — Airworthiness review staff are responsible for performing the accomplishment of both the documental and the physical survey. — Procedures must be established by the CAMO or CAO in order to perform the airworthiness review, including the depth of samplings minimum sample size and the depth of the investigations.
— Procedures must make very clear that the final word about the depth of the inspections (both documental and physical) belongs to the airworthiness review staff, who can go may increase the sample size and/or extend the depth of the investigations beyond the depth that established in the CAME or CAE if they find it necessary. This also includes determining whether a partial or complete repetition of the airworthiness review is required. For example, this may be the case if findings are not corrected within a reasonable time frame, which could lead to a discrepancy between the status represented by the airworthiness review certificate (ARC) and the actual condition of the aircraft. AtIn the end, it is the responsibility of the airworthiness review staff to be satisfied that the aircraft complies with Part-M and is airworthy, and the organisation must ensure that no pressure is put or restrictions are imposed on the airworthiness review staff when performing their duty. — An compliance airworthiness review report must be produced by the airworthiness review staff, detailing all items checked and the outcome of the review. — Airworthiness review staff are responsible for the items checked during the airworthiness review. However, they do not take over the responsibilities of the CAMO, maintenance organisation, DOAdesign organisations, POAproduction organisations or any other organisations, not being responsible for problems not detected during the airworthiness review or for the possibility that the approved or declared maintenance programme AMP may not include certain recommendations from the design approval holder. Obviously, if the airworthiness review staff are not independent of the airworthiness management process and were nominated on the basis of the option of having overall authority on such a process, they will be responsible for the full continuing airworthiness of such aircraft. Nevertheless, this responsibility will be a consequence of their position in the organisation and not of their function as airworthiness review staff. — The issuance of the airworthiness review certificate (ARC) by the airworthiness review staff only certifies that the aircraft is considered airworthy in relation to the scope of the airworthiness review performed and the fact that the airworthiness review staff are not aware of instances of non-compliance which may endanger flight safety compromise the airworthiness of the aircraft. Furthermore, it only certifies that the aircraft is considered airworthy at the time of the review. It is the responsibility of the owner or contracted CAMO or CAO the person or organisation responsible for the aircraft continuing airworthiness in accordance with point M.A.201 to ensure that the aircraft is fully airworthy at any time.
GM2 M.A.901 Airworthiness review — General
AIRWORTHINESS CERTIFICATES
An airworthiness certificate refers to either a certificate of airworthiness or a restricted certificate of airworthiness issued in accordance with Regulation (EU) No 748/2012.
GM1 M.A.901(b) Airworthiness review — General
‘CONTINUOUSLY MANAGED’
For the purpose of point M.A.901(b)(1)(i), ‘continuously managed in accordance with point M.A.201 of this Annex or point ML.A.201 of Annex Vb’ means that the continuing airworthiness of an aircraft has been managed, without interruptions, by one or more persons or organisations as specified in point M.A.201 or point ML.A.201, as applicable. Interruptions in the continuing airworthiness management could have a significant impact on the overall condition of the aircraft; for example, due to a lack of control over the tasks required for preservation. Whenever responsibility for the continuing airworthiness management of an aircraft is transferred between persons or organisations, care should be taken to ensure that no interruption occurs in the continuing airworthiness management process. The period during which an aircraft should be continuously managed starts from the issuance of the last ARC, regardless of whether it remained valid during that period or not. For example, in the case of an aircraft with an expired ARC that has remained in preservation (i.e. storage or parking), the condition in point (b)(1) of point M.A.901 is considered met if the aircraft’s continuing airworthiness has been continuously managed in accordance with point M.A.201 or point ML.A.201, as applicable.
AMC1 M.A.901(db)(2) Airworthiness review — General
The recommendation sent by a CAMO or CAO to the competent authority of the Member State of registry should be, at least, in English when the Member State of registry is different from the CAMO/CAO’s Member State. Otherwise, it can be completed in the official language(s) of the CAMO/CAO’s Member State. The recommendation sent to the competent authority should contain at least the items described below: (a) General information − CAMO information − owner/lessee information − date and place where the document review and the aircraft survey were carried out − period and place the aircraft can be seen if required by the competent authority (b) Aircraft information − registration − type − manufacturer − serial number − flight manual reference − weight and centre of gravity data − maintenance programme reference (c) Documents accompanying the recommendation − copy of registration papers − copy of the owners request for a new airworthiness review certificate (d) Aircraft status
− aircraft total time and cycles − list of persons or organisations having carried out continuing airworthiness activities including maintenance tasks on the aircraft and its components since the last airworthiness review certificate (e) Aircraft survey − a precise list of the areas of the aircraft that were surveyed and their status (f) Findings − a list of all the findings made during the airworthiness review with the corrective action carried out
RECOMMENDATION FOR THE ISSUANCE OF AN AIRWORTHINESS REVIEW CERTIFICATE (ARC)
(a) The application for the issuance of an ARC should be made in a form and manner established by the competent authority of the Member State of registry. (b) The recommendation should be in English or in any of the official languages of the European Union acceptable to the competent authority of the Member State of registry. (c) The recommendation should include the airworthiness review report, as defined in AMC1 M.A.903(h), and the following: (1) Aircraft information — in case of import of an aircraft, the previous aircraft registration and reference to the airworthiness statement issued by the authority that was responsible for the oversight of the aircraft, or reference to the evaluation programme; — reason(s) for not fulfilling the conditions set out in point M.A.901(b)(1), such as: import of used aircraft from a third country; aircraft previously operated as State aircraft; the former airworthiness certificate has been revoked or surrendered; or transfer of oversight responsibilities in accordance with ICAO Article 83 bis. (2) Aircraft documentation — copy of the approvals of the flight manual and its supplements; — approved AMP developed in accordance with point M.A.302; — aircraft continuing airworthiness records specified in points (c) and (d) of M.A.305. (3) Maintenance — a copy of the work packages requested by the person or organisation that manages the aircraft’s continuing airworthiness, including details of any bridging check to comply with the new maintenance programme. (4) Aircraft maintenance check flight — if applicable, a copy of the maintenance check flight report. (5) Coordination details — contact details of the organisation that issues the recommendation, such as email address and phone number; — the period and place in which the aircraft can be surveyed by the competent authority, as part of the recommendation assessment specified in point (c) of point M.B.902. (g)(6) Statement
A statement signed by the airworthiness review staff recommending the issue of an airworthiness review certificateARC. The statement should confirm that the airworthiness review has been performed in accordance with point M.A.903, and that the aircraft is considered airworthy at the time the review was completed. The statement should confirm that the aircraft in its current configuration complies with the following: − airworthiness directives up to the latest published issue, and; − type certificate datasheet or airworthiness data sheet (for aircraft subject to a declaration of design compliance); − maintenance programme; − limitation for life-limited parts and time-controlled components; − the valid weight and centre of gravity schedule reflecting the current configuration of the aircraft; − Part 21 or Part 21 Light, as applicable, for all modifications and repairs; − the current flight manual including supplements, and; − operational requirements. The above items should clearly state the exact reference of the data used in establishing compliance; for instance, the number and issue of the type certificate data sheet or airworthiness data sheet (for aircraft subject to a declaration of design compliance) used should be stated. The statement should also confirm that all the above is properly entered in the aircraft continuing airworthiness record system and/or in the operator’s technical log.
AMC1 M.A.901(ie)(i) Aircraft airworthiness review — General
Suitable accommodation should include: (a) an office with normal typical office equipment, such as desks, telephones internet access, photocopying machines, etc., whereby the documented review of the aircraft continuing airworthiness records can be reviewed performed. (b) a hangar, when needed, for the physical survey. The support of personnel appropriately qualified in accordance with Part-66 assistance of appropriate certifying staff is necessary when the competent authority’s airworthiness review staff is not appropriately qualified as specified in point M.A.903(d).
GM1 M.A.901(h) and M.A.902(b) Airworthiness review — General and Validity of the airworthiness review certificate
The ARC certifies that an airworthiness review has been performed in accordance with point M.A.903 and that, at the time of the review, the aircraft was considered airworthy. Although an airworthiness
review is not required to be performed when extending the validity of the ARC, it should only be extended if there is no reason to believe that the aircraft is not airworthy. Therefore, the ARC should not be issued or extended when the aircraft is in a condition significantly different from that required for flight — for example, with major components such as engines or wings removed during heavy maintenance (e.g. C-check level activities), or as a result of modification work or long-term storage. Once the necessary maintenance has been completed or is near completion (for example, if only minor maintenance or the certificate of release to service remains outstanding), and there is no reason to question the aircraft’s airworthiness, the ARC may be issued or extended, provided that all other applicable requirements are met. The same principle applies if a recommendation for the issuance of the ARC is to be issued.
AMC M.A.901(k) Aircraft airworthiness review
FULL DOCUMENTED REVIEW
1. A full documented review is a check of at least the following categories of documents: — registration papers; — M.A.305 aircraft continuing airworthiness record system; — M.A.306 aircraft technical log system; — list of deferred defects, minimum equipment list and configuration deviation, list if applicable; — aircraft flight manual including aircraft configuration; — aircraft maintenance programme; — maintenance data; — relevant work packages; — AD status; — modification and SB status; — modification and repair approval sheets; — status of life-limited parts and time-controlled components; — relevant EASA Form 1 or equivalent; — mass and balance report and equipment list; — aircraft, engine and propeller TC data sheets or airworthiness data sheet (for aircraft subject to a declaration of design compliance). — As a minimum, sample checks within each document category should be carried out.
2. The CAMO or CAO should develop procedures for the airworthiness review staff to produce a compliance report that confirms the above have been reviewed and found in compliance with Part-M.
AMC1 M.A.901(nf) Aircraft airworthiness review— General
(a) ‘Without loss of continuity of the airworthiness review pattern’ means that the new expiryation date is set up 1 one year after the previous expiryation date. As a consequence, when the
airworthiness review is anticipated, the validity or the ARC airworthiness review certificate is longer than 1 one year (up to 90 days longer). This anticipation of up to 90 days also applies to the 12-month requirements shown in M.A.901(b), which means that the aircraft is still considered as being in a controlled environment if it has been continuously managed by a single organisation and maintained by appropriately approved organisations, as stated in M.A.901(b), from the date when the last airworthiness review certificate was issued until the date when the new airworthiness review is performed (this can be up to 90 days less than 12 months). (b) The anticipation may be applied whether the airworthiness review is carried out by an approved organisation or by the competent authority. The 90-day anticipation period allows for the airworthiness review to be properly planned and performed before the expiry of the ARC. This includes ensuring that all necessary resources can be planned and made available, such as the availability of the aircraft for the physical survey, the airworthiness review staff, and, if applicable, any staff assisting the airworthiness review staff. (c) If the airworthiness review is anticipated by more than 90 days, the expiry date of the ARC will be set to one year from the date of issuance, regardless of the previous airworthiness review pattern.
AMC M.A.901(o) Airworthiness review
A copy of both the physical survey and document review compliance reports stated above should be sent to the competent authority together with any recommendation issued.
AMC1 M.A.9012(a) (c)2, (e)2 and (f) Aircraft airworthiness review Validity of the airworthiness review certificate
(a) When the aircraft has remained within a controlled environment, the extension of the validity of the airworthiness review certificate does not require an airworthiness review but only a verification of the continuous compliance withM.A.901(b). It is acceptable to anticipate the extension of the airworthiness review certificate by a maximum of 30 days without a loss of continuity of the airworthiness review pattern, which means that the new expiryation date is set up one year after the previous expiryation date. This anticipation of up to 30 days also applies to the 12 month requirements shown in M.A.901(b), meaning that the aircraft is still considered as being in a controlled environment if it has been continuously managed by a single organisation and maintained by appropriately approved organisations, as stated in M.A.901(b), from the date when the last airworthiness review certificate was issued until the date when the extension is performed (this can be up to 30 days less than 12 months). It is also acceptable to perform the extension of the validity of thean airworthiness review certificate ARC after its expiryation date, as long as all the conditions for the extension referred to in point M.A.902(b) are met. However, as stated in point M.A.902(d), the aircraft must not be flown during the period during which the ARC is expired. However, this means the following:
— The aircraft could not fly since the airworthiness review certificate expired until it is extended, and — The new expiration date (after extension) is set one year after the previous expiration date (not one year after the extension is performed). (b) The ARC is valid for one year with the validity starting from the day it was issued and expiring at the end of the day immediately before the date of issue in the following year, except when the airworthiness review is anticipated as specified in AMC1 M.A.901(f). When the validity is extended, the previous expiry date is effectively postponed by one year. For example, an ARC issued on 28 May 2024 (without anticipation) will expire on 27 May 2025. The first extension would shift the expiry date to 27 May 2026, and the second extension to 27 May 2027. (c) The extension should be recorded in the appropriate section of the original ARC, whether it is a physical or digital version. It is not the intent to extend a copy of the ARC, as this could result in an uncontrolled or invalid certificate. If a copy of the ARC is carried on board the aircraft, it must be ensured that it is kept up to date and that it accurately reflects the information contained in the original certificate.
AMC1 M.A.9012(b) Aircraft airworthiness review Validity of the airworthiness review certificate
CONDITIONS FOR ARC EXTENSION:
1. (a) If the continuing airworthiness of the aircraft is not managed according to an Appendix I continuing airworthiness contract (refer to Appendix I to Part-M), the aircraft should be considered to be outside a controlled environment condition in point M.A.902(b)(1) is not met. Nevertheless, such contract is not necessary when the operator and the CAMO are the same organisation itself holds a Part-CAMO or Part-CAO approval under which it is responsible for the continuing airworthiness of the aircraft in accordance with point M.A.201. 2. The fact that limited pilot-owner maintenance as defined in M.A.803(b) is not carried out and released by an approved maintenance organisation does not change the status of an aircraft in a controlled environment providing the CAMO under contract has been informed of any such maintenance carried out. (b) The extension of the validity of the ARC does not require an airworthiness review but only a verification of compliance with point M.A.902(b). As such, it does not involve any elements of the documented review or the physical survey.
GM1 M.A.903 Airworthiness review process
OTHER REGULATORY REQUIREMENTS AFFECTING AIRCRAFT CONFIGURATION
For efficiency and to promote synergies, the organisation or competent authority that conducts the airworthiness review may choose to verify compliance with requirements that are outside the scope of the airworthiness review. This may include, in particular, requirements concerning equipment required to be carried on board, as well as components required to be installed on the aircraft, if these are related to operational requirements. However, it should be noted that such additional verifications or their results should not compromise the completeness, scope or result of the airworthiness review. Specifically, the time allocated to verifying items directly relevant to the airworthiness review should not be diverted to the assessment of requirements that are outside its scope.
Examples of such additional requirements include those established in: — Annex V (Part-SPA) and Subpart D of Annex IV (Part-CAT), Annex VI (Part-NCC), Annex VII (Part- NCO), and Annex VIII (Part-SPO) to Regulation (EU) No 965/2012; — Annex I (Part-26) to Regulation (EU) 2015/640; — Implementing Regulation (EU) 2023/1770 laying down provisions on aircraft equipment required for the use of the Single European Sky airspace and operating rules related to the use of the Single European Sky airspace; — Regulation (EU) 1332/2011 laying down common airspace usage requirements and operating procedures for airborne collision avoidance. Any non-compliances identified in relation to these additional requirements may be recorded as observations in the airworthiness review report. Although confirming the presence of components required for specific operational purposes is not within the scope of the airworthiness review, any such components, if installed, should still be checked such as any other during the airworthiness review. For example, if the component is part of a modification, it may be selected for sampling during the airworthiness review. In such a case, it should be verified that it complies with point M.A.304, that a corresponding maintenance release was issued following its installation, and that the component is physically installed on the aircraft.
AMC M.A.903(b) Transfer of aircraft registration within the EU
In case of transfer of aircraft registration within EU, the aircraft owner/ operator should verify that the competent authority of the new Member State of registry has entered the new aircraft registration on the existing airworthiness review certificate and validated the change.
AMC1 M.A.903(b);(c) Airworthiness review process
DOCUMENTED REVIEW AND PHYSICAL SURVEY
(a) The documented review of the aircraft’s records and the physical survey of the aircraft could be based on samples and should cover the following: (1) Aircraft continuing airworthiness record system — the total in-service life accumulated in the applicable parameter for aircraft, engine(s), propeller(s), life-limited parts and time-controlled components has been properly recorded (e.g. flight hours, flight cycles, APU hours, engine hours); — aircraft, engine, propeller, life-limited part and time-controlled component maintenance entries are up to date and correct; and — as applicable, technical log system entries. (2) Aircraft flight manual (AFM) — the aircraft flight manual and its supplements are applicable to the current aircraft configuration, including any revisions issued by the design organisation when mandated by ADs, and correspond to the version carried on board.
(3) AMP — the AMP includes the mandatory continuing airworthiness requirements; — reference to the approval and revision status; and — the applicable maintenance as required by the maintenance programme has been carried out or carried forward in a controlled manner. (4) Aircraft defects and rectification — defects have been recorded and rectified in accordance with applicable maintenance data, or deferred in accordance with point M.A.403; — if available, the dent and buckle chart, or similar, accurately reflects the current condition of the aircraft; — deferred defects are within any limits specified in the maintenance data or the MEL/CDL; and — no evident defect can be detected that has not been addressed in accordance with to point M.A.403. (5) Airworthiness directives (ADs) — applicable ADs are properly recorded in accordance with AMC M.A.305(c)1; — applicable ADs and measures mandated by the competent authority in immediate reaction to a safety problem are not overdue; and — ADs have been properly complied with, if applicable, as evidenced by the corresponding maintenance release and, if feasible and appropriate, by physical confirmation on the aircraft. (6) Modifications and repairs — modifications and repairs that have been embodied are properly recorded in accordance with AMC M.A.305(c)2; — modifications and repairs have been carried out in accordance with the applicable data, as defined in point M.A.304; — the physical configuration of the aircraft is consistent with the recorded status of modifications and repairs; and — any potential impact on airworthiness resulting from conflicting modifications and/or repairs has been identified and appropriately addressed. (7) Life-limited parts and time-controlled components — the approved life limit of life-limited parts and the operating time of timecontrolled components have not been exceeded; — the life-limited parts and time-controlled components installed on the aircraft accurately match the details recorded in the continuing airworthiness record system; and — the in-service history of life-limited parts is properly recorded.
(8) Mass and balance — the current mass and balance statement reflects the current aircraft configuration. (9) Approved design — the aircraft complies with the configuration elements specified in GM1 M.A.301; — the aircraft, engine and propeller comply with the relevant elements of the type certificate data sheet (TCDS) or airworthiness data sheet, as applicable, such as certification maintenance requirements and specific maintenance requirements; — markings and placards are in accordance with the approved design and are written in one or more of the official languages of the European Union, as accepted by the competent authority of the Member State of registry; — the identification plates of the aircraft, engine(s), propeller(s), as applicable, are installed and display accurate information; and — if applicable, the layout of passenger accommodation (LOPA) complies with the approved configuration. (10) Aircraft certificates — if issued, the certificate of registration, airworthiness certificate and noise certificate are checked for their validity. Their contents are accurate and consistent with the nationality and registration marks displayed on the aircraft and with the identification plate(s). (11) Maintenance — maintenance has been released in accordance with Regulation (EU) No 1321/2014; — if applicable, during the period when the aircraft was not within the scope of Regulation (EU) No 1321/2014, the maintenance has been released in accordance with appropriate airworthiness requirements of the State which was responsible for the oversight of the aircraft, as specified in AMC1 M.A.903(b)(12)(ii); and — components that have been replaced are eligible for installation according to a design approved under Regulation (EU) No 748/2012 or an applicable EU bilateral agreement. (b) The content of Appendix III to GM1 M.B.303(b) may serve as a reference when developing a checklist for conducting the airworthiness review. (c) If the previous airworthiness review was incomplete in accordance with point M.A.903(f), the reasons for its interruption should be reviewed; for example, whether unresolved findings have contributed to the interruption. (d) The airworthiness review should not be conducted under conditions that could adversely affect human performance and potentially have a negative impact on the outcome of the assessment. Such conditions may negatively impact both the accuracy of the airworthiness review and the effectiveness of the staff involved since they touch on crucial human factors such as perception, decision-making and physical performance.
The following are examples of such conditions: (1) Excessive noise, which can compromise communication and the focus. (2) Performing the physical survey of the aircraft outside a hangar during adverse weather or at night. (3) Inadequate or excessive lighting, which may affect the reading of documents and the identification of potential damage during the physical survey. (4) Excessive operational pressure put on airworthiness review staff to expedite the airworthiness review process, which can lead to rushed investigations and the potential to overlook critical issues. (5) Physical or mental fatigue among the staff involved in the airworthiness review, stemming from long working hours, travel to the location where the airworthiness review is to be conducted (e.g. jetlag, duration), or excessive workload. If such conditions exist, the airworthiness review may only be conducted if they are adequately mitigated.
AMC2 M.A.903(b);(c) Airworthiness review process
AIRWORTHINESS REVIEW SAMPLING
(a) In order to perform an airworthiness review based on sample checks, the approved organisation should establish a procedure, approved by the competent authority, considering the following: (1) A sampling method should be defined, preferably using statistical principles, to ensure both comprehensiveness and reliability. The method should follow an internationally recognised sampling standard or should be supported by historical data from previous airworthiness reviews. The use of simple linear sampling rules, such as the ‘10 % of the population’, is not recommended as they tend to be unreliable, producing overly large samples for large populations and underrepresenting small ones. (2) The minimum sample size should be specified taking into account the number of items per type of information, as illustrated by the example in GM1 M.A.903(b);(c). This allows a minimum sample size to be determined during the airworthiness review, based on the number of items under review (population), so that by checking that sample an overall representation of the items within that information set is obtained. The ‘population’ depends on the type of information under review, as specified in AMC1 M.A.903(b);(c). For the purposes of determining the population, only those items required to be retained in accordance with the applicable requirements (e.g. point M.A.305) should be considered, using, if necessary for large populations, a reasonable approximation. This may include, for example, the total number of applicable ADs, the total number of embodied modifications, or the total number of technical log entries covering the previous three years. (3) A risk-based approach should be applied to determine whether the minimum sample size for a particular airworthiness review should be increased. For example, the parameters of the statistical method, such as the confidence level for the expected percentage of
compliant items, may be adjusted to reflect the level of risk associated with a particular aircraft. This results in a larger sample size for cases in which there are higher uncertainties or concerns regarding the aircraft’s airworthiness. Therefore, the sample size should be increased based on factors such as but not limited to: — aircraft that have been recently imported (in the process of being imported or imported during the previous airworthiness review); — the ICAO airworthiness implementation score of the State from which the aircraft is being or was imported; — aircraft for which the airworthiness certificate has been recently revoked or surrendered; — aircraft that its continuing airworthiness has been managed by multiple persons or organisations since the last airworthiness review; — judgement of the airworthiness review staff, for example, considering the criticality of certain items or known issues affecting specific areas. (4) As a general principle, once the sample size has been determined, the items included in the sample should be randomly selected from the entire relevant population. However, in certain situations, deviation from random selection may be justified. For example: — in the case of conducting airworthiness reviews to a fleet of similar aircraft, the sample should vary between aircraft to avoid reviewing the same items repeatedly for the different aircraft; — judgemental sampling may take precedence based on the airworthiness review staff’s professional judgement, particularly when specific items are known to be problematic or carry higher criticality. (5) In relation to the aircraft continuing airworthiness statuses required by point M.A.305, such as status of ADs, modifications, repairs and life-limited parts, it is essential that this information be complete and up to date in order to determine the appropriate sample size. (6) The investigation of each item should confirm the status of the item, if applicable and practicable, by covering the complete process. For example, for a modification, this includes verifying that it is approved, reviewing the maintenance records of its installation, confirming the availability and compliance with any applicable ICAs, and checking its physical embodiment on the aircraft. (7) Although the focus of the airworthiness review is on the period since the last ARC was issued, the selected sample should also include items dated prior to the previous airworthiness review. (8) Criteria and provisions should be established to allow airworthiness review staff to consider interrupting the airworthiness review, in accordance with point M.A.903(f), for example, for cases in which a significant number of non-compliances is identified relative to the selected sample size. A considerable number of findings may indicate deficiencies in the continuing airworthiness management process, and the root cause(s) could
potentially affect other areas of continuing airworthiness management or even other aircraft. It should be emphasised that the airworthiness review is intended to confirm that the aircraft is in an airworthy condition, and not to compensate for deficiencies in the continuing airworthiness management of the aircraft.
GM1 M.A.903(b);(c) Airworthiness review process
SAMPLE SIZE
As an example, the following table describes the required sample size for each possible number of items per type of information (population) to have 95 % confidence that at least 80 % of the items of the population are correct if the technique described below is followed.
Number of items per type of information Sample size (population)
1 to 5 All items 6 to 10 6 11 to 16 8 17 to 25 9 26 to 35 10 36 to 55 11 56 to 100 12 101 to 1000 14
(i) This sampling technique assumes zero tolerance for non-compliances within the sample. If a non-compliant item is identified, all previously checked items (including the non-compliant one) must be excluded from the population, and the sampling process must be restarted to retain the intended level of confidence of the percentage of compliant items. For example: — initial population size: 38 — required sample size (check table above): 11 — first six items checked are compliant; the seventh item is non-compliant — remove all seven checked items from the population — new population size: (38–7) = 31 — recalculate a new sample size (check table above): 10 — restart the sampling process (ii) Based on the expected frequency of specific airworthiness review scenarios (e.g. a significant number of aircraft imports), and if justified, a dedicated sampling table tailored to that scenario may be developed. Otherwise, the minimum sample size applicable to ‘standard’ airworthiness reviews may be used as a baseline. In such cases, the sample size may be increased, as
necessary, during the performance of the airworthiness review, taking into account the risk indicators identified.
AMC1 M.A.903(b)(12)(ii) Airworthiness review process
MAINTENANCE PERFORMED WHILE THE AIRCRAFT WAS OUTSIDE THE SCOPE OF REGULATION (EU) No 1321/2014
When an airworthiness review is conducted on an aircraft that in the past was subject to different a regulatory framework, such as a used aircraft imported from a third country or one that has carried out activities or services as defined in Article 2(3)(a) of the Basic Regulation (e.g. police operations, search and rescue, firefighting), it should be expected that, during such period, maintenance was performed in accordance with the rules accepted by the aviation authority responsible for the oversight of the aircraft at the time. During the airworthiness review, the maintenance certificates required to demonstrate compliance with point M.A.305, which were issued while the aircraft was outside the scope of Regulation (EU) No 1321/2014 should be verified to ensure that they contain the following information: (a) details of the maintenance performed including detailed reference to the data used; (b) the date on which such maintenance was completed; (c) if applicable, the identity of the maintenance organisation; and (d) the identity of the person signing the maintenance release including the licence or authorisation number of that person. It should be confirmed that the maintenance organisation’s approval is recognised by the appropriate authority that was responsible for the oversight of the specific aircraft or component. Additionally, if maintenance has been performed by individuals acting on their behalf, it should be verified that this practice was permitted by the aviation authority in charge of the oversight of the aircraft at that time. During the physical survey, it should be confirmed that there are no uncertainties regarding the maintenance performed or indications of absence of the required maintenance. If there are doubts about the adequacy of the maintenance performed, including concerns regarding its quality or integrity, which may include: — indications that maintenance may not have been properly performed (e.g. poor maintenance standards or maintenance released but not performed); — evidence that maintenance was performed by non-approved entities, or without adequate oversight; — significant gaps or missing information in maintenance records, maintenance may need to be performed again or thoroughly inspected by an approved organisation or a person authorised under Regulation (EU) No 1321/2014 to ensure that the aircraft meets the necessary airworthiness standards.
AMC1 M.A.9013(lc) and (md) Aircraft Aairworthiness review process
PHYSICAL SURVEY
1. The physical survey could may require actions categorised as maintenance (e.g. operational tests, tests of emergency equipment, visual inspections requiring panel opening, etc.). In this case, after the airworthiness review, a maintenance release to service should be issued. 2. When the airworthiness review staff are not appropriately qualified as per Part-66 certifying staff in order to release such maintenance, point M.A.9013(dl) requires them to be assisted by such qualified personnel. However, the function of such Part-66 personnel certifying staff is limited to performing and releasing the maintenance actions related to the physical survey as requested by the airworthiness review staff,; it is not being their function to perform the physical survey of the aircraft.
3. This means that the airworthiness review staff thatwho is going to sign the airworthiness review certificate ARC or the recommendation should be the one responsible for the accomplishment of performing both the documented review and the physical survey of the aircraft. It is not the intent of the rule to delegate the survey to Part-66 personnel who are not airworthiness review staff. Furthermore, the provision of M.A.901(n) that allows a 90-day anticipation for the physical survey provides enough flexibility to ensure that the airworthiness review staff (ARS) are present.
4. The physical survey may include verifications to be carried out during flight.
5. The physical survey should not be performed remotely, meaning that the airworthiness review staff should be physically present.
6. The CAMO or CAO should develop procedures for the ARS to produce a compliance report that confirms that the physical survey has been carried out and found satisfactory.
7. To ensure compliance, the physical survey may include relevant sample checks of items.
AMC1 M.A.903(e) Airworthiness review process
AIRWORTHINESS REVIEW PLANNING
(a) One of the primary objectives of the airworthiness review is to ensure that the information within the aircraft continuing airworthiness records is consistent with the actual configuration and condition of the aircraft. Airworthiness review staff are responsible for determining the most effective method for this verification, ensuring that the time elapsed between the verification of an item in the documented review and its corresponding physical survey (or vice versa) should not exceed 30 consecutive days. Furthermore, the time span from the start until the completion of the airworthiness review should be within a reasonable time frame. This is to avoid a misalignment between the verifications conducted during the airworthiness review and the actual status of the aircraft at the time the ARC or recommendation is issued. Airworthiness review staff are responsible for determining what constitutes a reasonable time frame, considering factors such as aircraft utilisation, maintenance performed, time required to address the findings, and ADs issued during the airworthiness review period. It is up to the
airworthiness review staff to determine whether there is a need to repeat certain verifications, or as a last resort, to interrupt the airworthiness review and initiate a new one. (b) To ensure the effectiveness of the airworthiness review, it is recommended that the physical survey be scheduled, if practicable, to be carried out during maintenance, in order to allow access to areas that are otherwise difficult to access and to avoid time pressure due to operational constraints. It should be noted that this does not imply that the entire physical survey is to be carried out at a single point in time; for example, while the aircraft is disassembled during heavy maintenance. Certain items, such as placards, can only be verified once maintenance is nearing completion. Accordingly, the physical survey may be performed in phases, depending on the items to be verified. In addition, as specified in GM1 M.A.901(h) and M.A.902(b), it should be ensured that the ARC or recommendation is not issued if there is evidence or indication that the aircraft is not airworthy. Therefore, it is expected that the ARC or recommendation is issued only upon completion, or near completion, of the maintenance activities.
AMC1 M.A.903(f) Airworthiness review process
INCOMPLETE AIRWORTHINESS REVIEW
An airworthiness review is considered satisfactorily completed if it has been conducted in accordance with the applicable requirements and procedures, resulting in the issuance of an ARC or a recommendation, as applicable. This includes the closure all findings raised during the airworthiness review, and confirmation that there is no evidence or reason to believe that the aircraft is not airworthy. An incomplete airworthiness review refers to a situation in which the review process is interrupted and cannot be finalised, resulting in neither an ARC nor a recommendation being issued. The following are examples of situations that may lead to an incomplete airworthiness review: — Findings not addressed or not corrected within a reasonable time frame — Failure to provide the necessary support to airworthiness review staff as required by point M.A.901(e), such as denying access to the aircraft or its records — Lack of cooperation with the airworthiness review staff — Identification of a significant number of discrepancies within the selected sample size. Repeated detection of non-compliances may indicate systemic deficiencies in the continuing airworthiness management An airworthiness review report in accordance with AMC1 M.A.903(h) should be produced even in the case of an incomplete airworthiness review. However, since the airworthiness review is incomplete, it is not necessary to fill in all the information that is typically required. Only the information that is available and known should be included in the report. The reasons for the interruption of the airworthiness review should be indicated as an observation in the airworthiness review report. The competent authority of the Member State of registry should be informed of the reasons leading to the interruption of the airworthiness review, and should take appropriate actions, which may include:
— if different, notifying the competent authority responsible for the organisation that manages the continuing airworthiness of the aircraft; — conducting an airworthiness review under point M.B.901(b); — including the aircraft in the ACAM programme; — closely monitoring the situation of the aircraft and, if necessary, suspending or revoking its ARC in accordance with point M.B.304(a).
AMC1 M.A.903(g) Airworthiness review process
MANAGEMENT OF NON-COMPLIANCES
(a) Non-compliances detected during the airworthiness review should be reported as findings to the person or organisation that is responsible for the continuing airworthiness of the aircraft. It should be noted that airworthiness review staff are subject to occurrence reporting requirements while performing the airworthiness review. (b) Airworthiness review staff should verify that the reported non-compliance(s) have been properly addressed. This includes reviewing the actions taken to correct the non-compliance(s), such as rectification or deferral of defects, together with the supporting evidence provided, and, if necessary, performing a physical verification on the aircraft to confirm the implementation of those actions. Deferring a defect in accordance with point M.A.403 is considered an acceptable means of addressing a non-compliance. (c) Although the corrections may be sufficient to close the airworthiness review findings and to issue the ARC or the recommendation, the root cause(s), contributing factor(s) and corrective action(s) should be determined by the organisation that is responsible for the continuing airworthiness of the aircraft, in accordance with its procedures. This may reveal underlying weaknesses in the continuing airworthiness management process and helps prevent the recurrence of non-compliances. Similarly, if a person is responsible for the continuing airworthiness, it is recommended that the same principle be followed.
AMC1 M.A.903(h) Airworthiness review process
AIRWORTHINESS REVIEW REPORT
(a) The airworthiness review report should include at least the following: (1) General information — the CAMO, CAO or competent authority that conducts the airworthiness review, including name and, except in the case of the competent authority, the approval number; — the person or organisation that is responsible for the continuing airworthiness of the aircraft in accordance with point M.A.201, including the name and, in the case of an organisation, the approval number;
— aircraft owner or operator, including the name and address; — the date and place the documented review and the physical survey were conducted; and — a list of the organisations or persons that were responsible for the continuing airworthiness of the aircraft since the issuance of the former ARC. (2) Aircraft information — aircraft registration, or the assigned registration, as applicable; — aircraft/engines/propellers, manufacturer, type and serial number; — if applicable, aircraft flight manual reference and current revision; — if applicable, noise certificate reference; — reference to the current mass and balance statement reflecting the current configuration of the aircraft; — AMP reference and current revision. (3) Aircraft status — aircraft total time and cycles. (4) Documented review — evidence and details of the review of the continuing airworthiness records in accordance with point M.A.305, including sampled items; and — checklist/report covering the items defined in point M.A.903(b). (5) Physical survey — a precise list of the areas of the aircraft that were surveyed and their status (a description referring to wings, fuselage, interior, etc., is not considered detailed enough); — evidence and details of sampled items, if appropriate; and — checklist/report covering the items defined in point M.A.903(c). (6) Findings: — a list of all the findings linked to the airworthiness of the aircraft raised during the airworthiness review; and — feedback on the actions taken per raised finding from the person or organisation responsible for the aircraft continuing airworthiness in accordance with point M.A.201. (7) Observations — if any, a list of all the observations raised during the airworthiness review. Observations should record relevant information that does not constitute a finding, such as non-compliances with requirements outside the scope of the
airworthiness review (e.g. operational requirements) as explained in GM1
M.A.903.
(8) Personnel — details of airworthiness review staff including name and, if applicable, the authorisation number; and — if applicable, the name (or details) of the person(s) and certifying staff that assist during the airworthiness review. (9) Issuance of the ARC (EASA Form 15b) or recommendation: — a statement indicating whether the conditions in point M.A.901(b)(1) are met. (b) A copy of the airworthiness review report should be sent to the person or organisation that is responsible for the aircraft continuing airworthiness in accordance with point M.A.201. If, during the assessment of the recommendation by the competent authority, any mistakes or errors are detected, the airworthiness review report should be amended by the airworthiness review staff that performed the airworthiness review, and a new copy should be sent to the person or organisation that is responsible for managing the continuing airworthiness of the aircraft.
AMC M.A.904(a)1 Airworthiness reviews of aircraft imported int the EU
In order to allow for possible participation of authority personnel, the applicant should inform the competent authority at least 10 working days in advance of the time and location of the airworthiness review.
AMC M.A.904(b) Airworthiness review of aircraft imported into the EU
CONTENT OF RECOMMENDATION
The recommendation sent to the competent authority should contain at least the items described below. (a) All the information set forth by AMC M.A 901(d) (b) Aircraft information − aircraft assigned registration; − state of manufacturer; − previous registration; − export certificate number; − TC and TC data sheet numbers; − noise and emissions TC and TC data sheet numbers;
− comparison of prior maintenance programme with the proposed new maintenance programme. (c) Documents accompanying the recommendation − copy of the application; − original export certificate; − copy of the approvals of the flight manual and its supplements; − list of ADs incorporated up to the latest published issue; − proposed new maintenance programme; − status of all life-limited parts and time-controlled components; − the valid weight and centre of gravity schedule reflecting the current configuration of the aircraft, and; − Reference to the Part 21 approval or Part 21 Light approval/declaration for all modifications and repairs. (d) Maintenance − a copy of the work packages requested by the CAMO including details of any bridging check to ensure all the necessary maintenance has been carried out. (e) Aircraft maintenance check flight − a copy of the maintenance check flight report.
AMC1 M.A.9035(a)1 Transfer of aircraft registration within the EUUnion
(a) The applicant should notify to the competent authority ofwithin the former Member State of registry so as to allow the proper transfer exchange of information between the two competent authorities during the aircraft transfer process. (b) The requirements in point M.A.905 concerning the transfer of aircraft apply only when the aircraft has an airworthiness certificate issued in accordance with Regulation (EU) No 748/2012 at the time of application. If this is not the case, the requirements in point M.A.906 should be followed, regardless of whether the aircraft is already registered in a Member State and the applicant intends to register it and obtain an airworthiness certificate in another Member State. (c) An AMP should be approved prior to the issuance or amendment of the ARC per point M.A.905. Therefore, an AMP should be submitted to the new competent authority for approval, unless an agreement exists as specified in point M.1(3)(ii) or it was indirectly approved in accordance with point M.A.302(c). If there are significant differences between the previous and the new AMP, a bridging check should be performed and any required maintenance must be completed before the ARC is issued or amended.
GM1 M.A.905(b)(2) Transfer of aircraft registration within the Union
INVALID ARC DURING TRANSFER
If the ARC has expired or expires during the transfer process, or has been suspended, revoked or surrendered, the applicant may consider, as applicable and subject to the fulfillment of the related conditions, any of the following options: (a) ensure that the validity of the expired ARC is extended in accordance with point M.A.902; (b) ensure that the reasons for the suspension of the ARC have been addressed; (c) obtain a new ARC in accordance with point M.A.901(b)(1) and submit it to the new Member State of registry; (d) request the new Member State of registry to issue a new ARC in accordance with point M.A.901(j); (e) submit a recommendation for the issuance of the ARC in accordance with point M.A.901(b)(2) to the new Member State of registry.
AMC M.A.904(a)2 Airworthiness reviews of aircraft imported into the EU AMC1 M.A.906 Airworthiness review of aircraft without an airworthiness certificate issued in accordance with Regulation (EU) No 748/2012
1. When performing an airworthiness review of aircraft imported into the EU the aircraft and the relevant records should be reviewed to determine the work to be undertaken to establish the airworthiness of the aircraft.
ESTABLISHING THE AIRWORTHINESS STATUS OF A USED AIRCRAFT WITHOUT AN AIRWORTHINESS CERTIFICATE
2.(a) In determining the work to be undertaken dDuring the airworthiness review, on the as required in point M.A.906(a)(2), the following should be taken into consideration: (a)(1) tThe information included in the airworthiness statement referred to in point 21.A.174(b)(3)(ii)(A) of Annex I (Part 21) or, as applicable, in point 21L.A.143(f)(1) of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012; from third country authorities such as e.g. export certificates, primary authority information; (b)(2) tThe information related to the on aircraft maintenance of the aircraft, history issued to meet the aircraft continuing airworthiness record system’s requirements equivalent to those specified in point M.A.305. such as continuing airworthiness records, aircraft, engine, propeller, rotor and life limited part log books or cards as appropriate, tech log/flight log/cabin log, list of deferred defects, total flight times and cycles, times and cycles since last maintenance, accident history, former maintenance schedule, former AD compliance status; When assessing the aircraft’s continuing airworthiness records, the following should be considered:
— Maintenance records may be reconstructed in accordance with point (g) of AMC M.A.305(e) when the original records are incomplete or missing, subject to acceptance by the competent authority of the importing Member State of registry. — Previous maintenance performed on the aircraft and its components has been released in accordance with the rules of the State that was responsible for the aircraft’s oversight, as specified in AMC1 M.A.903(b)(12)(ii). In cases in which there are doubts about the quality or integrity of the maintenance performed, these should be appropriately addressed. — Records should be available in English or in any other language acceptable to the competent authority of the Member State of registry. If the records are in a different language, a translation into any language acceptable to the competent authority of the Member State of registry should be provided; (c) the information on aircraft such as aircraft, engine and propeller type certificate datasheets, noise and emission certificate data sheets, flight manual and supplements; (d) the aircraft continuing airworthiness status such as the aircraft and component AD status, the SB status, the maintenance status, the status of life-limited parts and time-controlled components, weight and centre of gravity schedule including equipment list; (e) the modification and repair status of the aircraft detailing elements such as owner/operator designed modifications and repairs, STCs, and parts needing European parts approval (EPA); (f) the aircraft cabin configuration such as emergency equipment fitted, cockpit configuration, placards, instrument limitations, cabin layout; (g)(3) tThe maintenance needed for import, such as embodiment of modifications needed to comply with the EASA type certificate approved design and the, bridging check necessary to for the transition to comply with the new maintenance programme AMP approved in accordance with point M.A.302. It should be noted that the type certificate data sheet (TCDS) or airworthiness data sheet, may contain specific conditions that need to be met for the aircraft to be in accordance with the EASA-approved design. It may also include limitations associated with particular serial numbers (S/N) or registration eligibility; (h) the avionics such as, but not limited to, radio and navigation equipment, instrument flight rules (IFR) equipment, digital flight data recorder (DFDR)/cockpit voice recorder (CVR) test, emergency locator transmitter (ELT) 406 MHz code and identification; (i) the compass compensation; (j) special operating rules such as extended twin-engine operations (ETOPS)/long range operations (LROPS), reduced vertical separation minima (RVSM), minimum navigation performance specifications (MNPS), all weather operations (AWOPS), area navigation (RNAV); (k) the aircraft survey including verification of conformity with the flight manual and the datasheet, presence of fire proof identification plates, conformity of markings including registration, presence and serviceability of emergency equipment, internal and external lighting systems, and (l) maintenance check flight including check of control system/cockpit ground check/engine run up.
(4) If applicable, the information included in the evaluation report as required by point M.A.906(c). (b) If unusual circumstances exist (e.g. long-term storage, significant aircraft damage, other event determined to be relevant by the competent authority of the Member State of registry) and the aircraft has not been operated since, functional checks may be necessary to verify the proper functioning of the aircraft systems and controls. Such checks may include, for example, engine run-ups or maintenance check flights when the satisfactory operation of the required functions cannot be verified on the ground. Any such functional checks should be carried out in accordance with the DAH’s instructions. 3.(c) If there is no CAO or CAMO or maintenance organisation approved for the airworthiness review of the specific aircraft type available, the competent authority may carry out the airworthiness review in accordance with this paragraph points M.A.906 and the provisions M.A.901(g) and M.B.902 M.B.901. In this case, the airworthiness review should be requested to the competent authority with a 30-day notice. (d) The applicant should coordinate with the competent authority to allow for possible participation of its personnel in the airworthiness review. For this purpose, the applicant should inform the competent authority of the planned time and location of the airworthiness review within a time frame agreed with the competent authority, which normally should not be less than 10 working days in advance.
AMC1 M.A.907 Findings
For the purpose of point M.A.907, demonstrating the implementation of the correction and obtaining acceptance from the competent authority is sufficient to close a finding with regard to the aircraft as required by point M.B.907(c). Nevertheless, the person or organisation that is responsible for the continuing airworthiness of the aircraft is still required to determine and implement a corrective action plan. If the continuing airworthiness of the aircraft is managed by a CAO or a CAMO, the findings should be addressed through the CAO’s or CAMO’s compliance monitoring function or quality system, as applicable, in accordance with AMC4 CAMO.A.200(a)(6) and AMC1 CAO.A.100(a). The corrective action plan should include the correction of the issue, the root-cause analysis, the corrective and preventive actions to be taken, and a timeline for the implementation of these actions.
AMC1 M.B.104(g) Record-keeping
The minimum content of the records for airworthiness review staff and authorised personnel that assess recommendations should include the following: — name, — date of birth, — basic education, — experience, — aeronautical degree and/or Part-66 qualification, — initial training received, — type training received, — continuation training received,
— experience in continuing airworthiness and with the competent authority, — responsibilities of their current job.
AMC1 M.B.105(a) Mutual exchange of information
One typical case where in which the mutual exchange of information is necessary is when an aircraft is transferred inside the EU in accordance with point according to M.A.9035. When notified of such a transfer, a competent authority should inform the competent authority where the aircraft will be registered of any known problems with the aircraft being transferred. Furthermore, the competent authority where the aircraft will be registered should ensure that the former competent authority has been properly notified that the aircraft is leaving being transferred.
AMC1 M.B.9021(bc) Airworthiness review certificate issued by the competent authority
[…] 4. To hold a position with appropriate responsibilities means the airworthiness review staff should have a position within the competent authority that authorises that person to sign on behalf that competent authority. 5.4. A person in the competent authority carrying out airworthiness reviews or airworthiness certificate renewal inspections in a Member State, prior to the date of entry into force of Part-M should be considered as complying with M.B.9021(bc).
AMC1 M.B.9021(bc)(1) Airworthiness review certificate issued by the competent authority
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AMC1 M.B.9021(bc)(2) Airworthiness review certificate issued by the competent authority
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AMC1 M.B.9012 Assessment of recommendations
1. The result of the verification and the investigation of a recommendation should be sent to the applicant within 30 days. If corrective action has been requested before the issuance of an airworthiness review certificate, the competent authority may decide a further period for the assessment of the requested corrective action. 2.(a) The verification of the recommendation’s content, compliance statement as required by point M.B.9012(b), and the investigations under point M.B.902(c), are not intended to repeat or replace does not mean repeating the airworthiness review itself.
(b) However, During the verification of the recommendation’s content, the competent authority should verify that the CAMO/CAO has carried out a complete and compliant and accurate assessment of the airworthiness of the aircraft.
This includes, for example, verifying that:
(1) all required documentation for a recommendation has been provided; (2) the reasons for issuing the recommendation, instead of an ARC, are justified; (3) the recommendation contains the information specified in AMC1 M.A.901(b); (4) any associated findings have been closed; (5) all required items have been reviewed during the airworthiness review, and that the number of samples checked is appropriate given the risks associated with the particular aircraft; (6) for cases in which no airworthiness certificate has been issued in accordance with Regulation (EU) No 748/2012, that the content of AMC1 M.A.906 has been taken into account. The content of the recommendation may be verified by a qualified person that is not authorised as airworthiness review staff, provided that that person is competent, appropriately qualified and trained for that task. 3.(c) The competent authority should conduct sufficient investigations to validate the accuracy of the recommendation. The investigations should be conducted by airworthiness review staff, as specified in point M.B.902(c). The level of investigation required should be determined on a case-by-case basis, taking into account the results of the verification of the recommendation’s content, as outlined in point (b), and the specific risks associated with the aircraft. These may include the aircraft’s operational and maintenance history, the nature and number of findings identified during the airworthiness review, and previous experience with the persons or organisations involved in the continuing airworthiness management and airworthiness review. Therefore, it is recommended, where applicable, that the competent authority involve the person responsible for the oversight of those organisations in the investigation process. Depending on the content of the recommendation, the history of the particular aircraft, and the knowledge of the CAMO/CAO making the recommendation in terms of experience, number and correction of findings and previous recommendations the extent of the investigation will vary. Therefore, whenever possible the person carrying out the investigation should be involved in the oversight of the CAMO/CAO making the recommendation. The investigations may vary from a desktop review of the aircraft’s historical records to conducting physical investigation of the aircraft. 4. In some cases, the inspector may decide that it is necessary to organise: — a physical survey of the aircraft, or — a full or partial airworthiness review. In this case, the inspector should inform the CAMO/CAO making the that has issued the recommendation should be informed with sufficient notice, along with the person or organisation that is responsible for managing the continuing airworthiness of the aircraft, if different, to ensure that the conditions outlined in point M.A.901(e) are met, as necessary. it may organise itself according to M.A.901(i). Furthermore, this part of the investigation should be carried out by appropriate airworthiness review staff in accordance with M.B.902(b).
5.(d) Only when satisfied that the aircraft is airworthy, should the inspector issue an airworthiness review certificate The result of the verification and the investigation of a recommendation should be sent to the applicant within 30 days. If applicable, any findings should be included, along with the corresponding time frame for their correction. (e) If applicable, the investigations referred to in point M.B.902(c) may be conducted in conjunction with those required for the issuance of the airworthiness certificate, as specified in point 21.B.320(a) of Annex I (Part 21) or point 21L.B.161(c) of Annex Ib (Part 21 Light) to Regulation (EU) No 748/2012. The investigations referred to in point M.B.902(c) may be partially or fully reduced if the competent authority participates in the airworthiness review, as specified in point (4) of AMC1 M.A.906.
AMC M.B.902(c) Airworthiness review by the competent authority
The minimum content of the airworthiness review staff record should be:
− Name, − Date of Birth, − Basic Education, − Experience, − Aeronautical Degree and/or Part-66-qualification, − Initial Training received, − Type Training received, − Continuation Training received, − Experience in continuing airworthiness and within the organisation, − Responsibilities of current job.
GM1 M.B.905 Transfer of aircraft registration within the Union
INTRODUCTION OF TRANSFERED AIRCRAFT IN THE ACAM PROGRAMME
Following the issuance or amendment of the ARC, the competent authority should consider including the aircraft in the ACAM programme for a near future inspection, following a risk-based approach. For a risk-based approach, factors such as the following may be taken into account: (a) the type of operation; (b) the situation of the former operator, CAMO or CAO that may affect the aircraft’s airworthiness; for example, if the organisation that manages the continuing airworthiness of the aircraft or the aircraft operator has recently declared bankruptcy; (c) the number of different persons or organisations that have recently managed the aircraft’s continuing airworthiness;
(d) previous experience with organisations involved in the continuing airworthiness management or airworthiness review; (e) whether the aircraft was recently issued with an airworthiness certificate after being outside the scope of Regulation (EU) 2018/1139, or following the revocation or surrender of its previous certificate; (f) results or feedback from any bridging checks, if applicable.
GM1 M.B.905(a) Transfer of aircraft registration within the Union
COORDINATION AMONG COMPETENT AUTHORITIES
The competent authority of the Member State where the aircraft is currently registered should inform the competent authority of the Member State where the aircraft will be registered about the following: (a) whether the airworthiness certificate has been surrendered, revoked or suspended; (b) whether there are any concerns regarding the certificate’s validity; and (c) any other information that may be relevant for the transfer and registration process. It is recommended that the registration and de-registration processes are coordinated to avoid that the aircraft remains de-registered for an extended period. Further guidance on the risks associated with aircraft being without registration is provided in GM2 21.A.174(b)(3)(ii)(A) to Regulation (EU) No 748/2012.
GM1 M.B.905(b) Transfer of aircraft registration within the Union
AMENDMENT OF THE ARC
Several practices have been adopted by competent authorities to amend ARCs, with a common one being to manually cross out the former registration and write in the new one. Although this practice is widely used, it may raise concerns regarding the validity of the certificate when reviewed by thirdcountry entities, such as during ramp inspections. Moreover, this practice may not be suitable for electronically issued ARCs and could lead to several issues, including: — increased risk of human error, including irreversible mistakes in the certificate; — practical complications when the ARC needs to be amended multiple times due to frequent registration changes. Notwithstanding these limitations, competent authorities may continue to use this method. However, as a means of addressing the aspects described above, the following alternative approach may be considered when amending ARCs: (a) issuing a new ARC (EASA Form 15a), completed with: (1) information from the new competent authority; (2) the new aircraft registration; (3) the new ARC reference;
(4) all other information from the former ARC is copied into the new one, except for the fields labelled ‘Signed’ and ‘Authorisation No’; in the ‘Signed’ field(s), which are completed in the original ARC, the following statement should be added: ‘This ARC amends: [former ARC reference] on [date of amendment] by [signature].’ The corresponding ‘Authorisation No’, if applicable, should reflect the number of the person that makes the amendment. (b) The new ARC should always be accompanied by the original ARC. (c) For cases in which an aircraft undergoes multiple registration changes during the validity of its ARC, only the information in the most recent amendment is used to issue the new ARC. In such cases, the applicant must submit the original ARC along with all subsequent amendments to the new competent authority. (d) The competent authority amending the ARC keeps a copy of both the former and the new ARC issued for traceability reasons. (e) Subsequent extensions of the ARC are recorded in the most recent amendment.
GM2 M.B.905(b) Transfer of aircraft registration within the Union
APPROVAL OF THE AMP DURING TRANSFER
Except for an AMP indirectly approved as specified in point M.A.302(c), if, during the transfer of an aircraft, there are no significant changes to the aircraft itself, to the way its continuing airworthiness will be managed or to the nature of its future operations, it is not expected that the content of the previously approved AMP will change significantly. This may be the case, for example, where the aircraft is to be transferred to another Member State, while the operator and the CAMO are to remain unchanged. In such circumstances, the competent authority of the new Member State of registry may take into account the existing AMP and choose not to conduct a full review of it. A more comprehensive verification may be deferred to a later occasion, such as during the next AMP annual review. Alternatively, the competent authority may also approve an incomplete AMP, as described in AMC M.B.301(b)(7).
GM1 M.B.906(b) Airworthiness review of aircraft without an airworthiness certificate issued in accordance with Regulation (EU) No 748/2012
EXCHANGE OF INFORMATION AMONG COMPETENT AUTHORITIES
In certain cases, following the revocation or surrender of an airworthiness certificate issued by a Member State (MS1) under Regulation (EU) No 748/2012, the aircraft may subsequently be registered in another Member State (MS2) without the issuance of a new airworthiness certificate. When an applicant later seeks to register the aircraft and obtain a new airworthiness certificate from a different Member State (MS3), it is essential to exchange relevant information not only with the previous competent authority (MS2), but more importantly with the authority that revoked the previous airworthiness certificate or accepted its surrender (MS1). That authority was effectively responsible
for the oversight of the aircraft’s continuing airworthiness and can provide more details regarding the aircraft’s history.
Appendix III to GM1 M.B.303(b) — KEY RISK ELEMENTS
[…]
− M.A.710(a)2 − M.A.710(c)2
[…]
− M.A.501 − M.A.710(c)
− AMC M.A.603(c)
[…]
Fotnoter
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- Not e to re ad e r s
- ‘Agency’ and ‘EASA’ are used interchangeably, and this is most visible in consolidated texts. In all cases, both terms refer to the European Union Aviation Safety Agency.
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- WORK TO BE UNDERTAKEN TO ESTABLISH AIRWORTHINESS
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- B.2 Flight Manual A manual, associated with the certificate of airworthiness, containing operational limitations, instructions and information necessary for the flight crew members for the safe operation of the aircraft.
- Supporting information Typical inspection items
- The Flight Manual needs to reflect the current status/configuration of the 1. Check the conformity of the Flight Manual (FM), latest issue, with aircraft configuration, aircraft. When it does not, it may provide flight crew members with wrong including modification status, (AD, SB, STC etc.). information. 2. Check: This may lead to errors and/or to override limitations that could − the FM approval, revision control, Supplement to FM; contribute to severe failure. − the impact of modification status on noise and weight & balance; − additional required manuals (QRH/FCOM/OM-B etc.); − FM limitations. Reference documents: EASA − 21.A.174(b)2(iii), (b)3(ii)(C) − 21.A.204(b)1(ii), (b)2(i) − 21L.A.143 − 21L.A.163 − M.A.305, AMC M.A.305(d)
- − AMC M.A.710(a)1 − AMC M.A.901(d) and (g) AMC1 M.A.903(b);(c) − M.A.902(b)3 − AMC M.A.904(a)(2) points 2(c) and 2(k) − AMC M.A.904(b) point (c)
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- B.4 Markings & placards Markings and placards are defined in the individual aircraft type design. Some information may also be found in the TCDS, data sheet for airworthiness (Part 21 Light Subpart C), the Supplemental Type Certificates (STCs), the FM, the AMM, the IPC, etc.
- Supporting information Typical inspection items
- Markings and placards on instruments, equipment, controls, etc. shall 1. Check that the required markings and placards are installed on the aircraft, especially include such limitations or information as necessary for the direct the emergency exit markings instructions and passenger information signs and placards. attention of the crew during flight. 2. Check that all installed placards are readable. 3. Check the Flight Manual versus the instruments. Markings and placards or instructions shall be provided to give any (General Aviation usually). information that is essential to the ground handling in order to preclude 4. Check registration markings, including State of Registry fireproof nameplate. the possibility of mistakes in ground servicing (e.g. towing, refuelling) that 5. Check product data plates. could pass unnoticed and that could jeopardise the safety of the aircraft in subsequent flights. Examples of markings & placards: − door means of opening, Markings and placards or instructions shall be provided to give any − each compartment’s weight/load limitation/placards stating limitation on information essential in the prevention of passenger injuries. contents, National registration markings must be installed. They include − passenger information signs, including no smoking signs, registration, possible flag, fireproof registration plate. − emergency exit marking, − pressurised cabin warning, Product data plates must be installed. − calibration placards, When markings and placards are missing, or unreadable, or not properly − cockpit placards and instrument markings, installed, mistakes or aircraft damages may occur and could subsequently − O² system information data, contribute to a severe failure. − accesses to the fuel tanks with flammability reduction means (CDCCL), − fuelling markings (fuel vent, fuel dip stick markings), − EWIS identification, − towing limit markings, − break-in markings, − inflate tyres with nitrogen, − RVSM + static markings. Reference documents: EASA − 21.A.175 − 21.A.715 − 21.A.801 − 21.A.803 − 21.A.804 − 21.A.805
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- − 21.A.807 − 21L.A.253 − 21L.A.254 − 21L.A.255 − relevant CS for the aircraft type being inspected
- − AMC M.A.504(e)
- − AMC M.A.904(a)(2) points 2(f) & 2(k) AMC1 M.A.903(b);(c)
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