AMC to Part-M — Amendment 5
ED Decision 2009/006/R 24/03/2009
Annex 1 to Decision 2009006/R
AMC to PartM
Paragraph 4 of AMC M.A.201(h) is amended as follows:
AMC M.A.201 (h) Responsibilities
… 4. An operator should therefore have adequate knowledge of the design status (type specification, customer options, airworthiness directives (AD), airworthiness limitations contained in CS25 Book 1, Appendix H, paragraph H25.1, fuel tank system airworthiness limitations including Critical Design Configuration Control Limitations (CDCCL), modifications, major repairs, operational equipment) and required and performed maintenance. The status of aircraft design and maintenance should be adequately documented to support the performance of the quality system. … AMC M.A.3015 is amended as follows:
AMC M.A.3015 Continuing Airworthiness Tasks
…
Any other continued airworthiness requirement made mandatory by the Agency includes TC related requirements such as: certification maintenance requirements (CMR), certification life limited parts, airworthiness limitations contained in CS25 Book 1, Appendix H, paragraph H25.1, fuel tank system airworthiness limitations including Airworthiness Limitation Items (ALI) Critical Design Configuration Control Limitations (CDCCL), etc.
Paragraph 3 of AMC M.A.501(b) is amended as follows:
AMC M.A.501(b) Installation
… 3. The person referred to under M.A.801 or the M.A. Subpart F approved maintenance organisation should be satisfied that the component in question meets the approved data/standard, such as the required design and modification standards. This may be accomplished by reference to the TC holder or manufacturer's parts catalogue or other approved data (i.e. Service Bulletin). Care should also be exercised in ensuring compliance with applicable ADs and the status of any service life limited parts fitted to the aircraft component. as well as compliance with Critical Design Configuration Control Limitations.
ED Decision 2009/006/R 24/03/2009 Paragraph 7 of AMC M.A.501(d) is removed as follows:
AMC M.A.501(d) Installation
….
7. When using raw or consumable material on an aircraft or component near, or adjacent to, or that directly impacts an identified Critical Design Configuration Control Limitation item, it should be ensured that the CDCCL has not been compromised.
AMC M.A.706(f) is amended as follows:
AMC M.A.706(f) Personnel requirements
Additional training in fuel tank safety as well as associated inspection standards and maintenance procedures should be required of continuing airworthiness management organisations’ technical personnel, especially the those technical support staff involved with the management of CDCCL, Service Bulletin assessment, work planning and maintenance programme management. EASA guidance is provided for training to Continuing Airworthiness Management Organisations’ continuing airworthiness personnel in Appendix XII to AMC to M.A.706(f) and M.B.102(c).
Paragraph 1.6 of AMC M.B.102(c) is amended as follows:
AMC M.B.102(c) Competent authority – Qualification and training
1.6 knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course, including Fuel Tank Safety (FTS) training as described in Appendix XII to AMC to M.A.706(f) and M.B.102(c). These courses should be at least at a level equivalent to Part66 Appendix III Level 1 General Familiarisation. “Relevant sample” means that these courses should cover typical systems embodied in those aircraft being within the scope of approval.
Appendix XII to AMC to M.A.706(f) and M.B.102(c) is replaced by the following:
Appendix XII to AMC to M.A.706(f) and M.B.102(c)
Fuel Tank Safety training
This appendix includes general instructions for providing training on Fuel Tank Safety issues.
A) Effectivity:
· Large aeroplanes as defined in Decision 2003/11/RM of the Executive Director of the Agency (CS25) and certified after 1 January 1958 with a maximum type certified passenger capacity of 30 or more or a maximum certified payload capacity of 7500 lbs (3402 kg) cargo or more, and
ED Decision 2009/006/R 24/03/2009
· Large aeroplanes as defined in Decision 2003/11/RM of the Executive Director of the Agency (CS25) which contains CS25 amendment 1 or later in their certification basis.
B) Affected organisations:
· M.A. Subpart G approved organisations involved in the continuing airworthiness management of aeroplanes specified in paragraph A). · Competent authorities responsible for the oversight as per M.B.704 of aeroplanes specified in paragraph A) and for the oversight of the M.A. Subpart G approved organisations specified in this paragraph B).
C) Persons from affected organisations who should receive training:
Phase 1 only: · The quality manager and quality personnel. · Personnel of the competent authorities responsible for the oversight as per M.B.704 of aeroplanes specified in paragraph A) and in the oversight of M.A. Subpart G approved organisations specified in paragraph B).
Phase 1 + Phase 2 + Continuation training: · Personnel of the M.A. Subpart G organisation involved in the management and review of the continuing airworthiness of aircraft specified in paragraph A);
D) General requirements of the training courses
Phase 1 – Awareness The training should be carried out before the person starts to work without supervision but not later than 6 months after joining the organisation. The persons who have already attended the Level 1 Familiarisation course in compliance with ED decision 2007/001/R Appendix XII are already in compliance with Phase 1.
Type: Should be an awareness course with the principal elements of the subject. It may take the form of a training bulletin, or other self study or informative session. Signature of the reader is required to ensure that the person has passed the training. Level: It should be a course at the level of familiarisation with the principal elements of the subject. Objectives: The trainee should, after the completion of the training:
1. Be familiar with the basic elements of the fuel tank safety issues.
2. Be able to give a simple description of the historical background and the elements requiring a safety consideration, using common words and showing examples of non conformities.
3. Be able to use typical terms.
ED Decision 2009/006/R 24/03/2009 Content: The course should include: a short background showing examples of FTS accidents or incidents, the description of concept of fuel tank safety and CDCCL, some examples of manufacturers documents showing CDCCL items, typical examples of FTS defects, some examples of TC holders repair data some examples of maintenance instructions for inspection.
Phase 2 Detailed training A flexible period may be allowed by the competent authorities to allow organisations to set the necessary courses and impart the training to the personnel, taking into account the organisation’s training schemes/means/practices. This flexible period should not extend beyond 31 December 2010. The persons who have already attended the Level 2 Detailed training course in compliance with ED decision 2007/001/R Appendix XII either from a M.A. Subpart G approved organisation or from a Part147 training organisation are already in compliance with Phase 2 with the exception of continuation training. Staff should have received Phase 2 training by 31 December 2010 or within 12 months of joining the organization, whichever comes later.
Type: Should be a more indepth internal or external course. It should not take the form of a training bulletin or other self study. An examination should be required at the end, which should be in the form of a multi choice question, and the pass mark of the examination should be 75%. Level: It should be a detailed course on the theoretical and practical elements of the subject. The training may be made either: in appropriate facilities containing examples of components, systems and parts affected by Fuel Tank Safety (FTS) issues. The use of films, pictures and practical examples on FTS is recommended; or by attending a distance course (elearning or computer based training) including a film when such film meets the intent of the objectives and content here below. An elearning or computer based training should meet the following criteria: A continuous evaluation process should ensure the effectiveness of the training and its relevance; Some questions at intermediate steps of the training should be proposed to ensure that the trainee is authorized to move to the next step; The content and results of examinations should be recorded; Access to an instructor in person or at distance should be possible in case support is needed.
A duration of 8 hours for phase 2 is an acceptable compliance.
ED Decision 2009/006/R 24/03/2009 When the course is provided in a classroom, the instructor should be very familiar with the data in Objectives and Guidelines. To be familiar, an instructor should have attended himself a similar course in a classroom and made additionally some lecture of related subjects.
Objectives: The attendant should, after the completion of the training: have knowledge of the history of events related to fuel tank safety issues and the theoretical and practical elements of the subject, have an overview of the FAA regulations known as SFAR (Special FAR) 88 of the FAA and of JAA Temporary Guidance Leaflet TGL 47, be able to give a detailed description of the concept of fuel tank system ALI (including Critical Design Configuration Control Limitations CDCCL, and using theoretical fundamentals and specific examples; have the capacity to combine and apply the separate elements of knowledge in a logical and comprehensive manner; have knowledge on how the above items affect the aircraft; be able to identify the components or parts or the aircraft subject to FTS from the manufacturer’s documentation, be able to plan the action or apply a Service Bulletin and an Airworthiness Directive. Content: Following the guidelines described in paragraph E).
Continuation training: The organisation should ensure that the continuation training is performed in each two years period. The syllabus of the training programme referred to in the Training policy of the Continuing Airworthiness Management Exposition (CAME) should contain the additional syllabus for this continuation training. The continuation training may be combined with the phase 2 training in a classroom or at distance. The continuing training should be updated when new instructions are issued which are related to the material, tools, documentation and manufacturer’s or competent authority’s directives.
E) Guidelines for preparing the content of Phase 2 courses.
The following guidelines should be taken into consideration when the phase 2 training programme are being established: a) understanding of the background and the concept of fuel tank safety, b) how the mechanics can recognise, interpret and handle the improvements in the instructions for continuing airworthiness that have been made or are being made regarding fuel tank systems, c) awareness of any hazards especially when working on the fuel system, and when the Flammability Reduction System using nitrogen is installed. Paragraphs a) b) and c) above should be introduced in the training programme addressing the following issues:
ED Decision 2009/006/R 24/03/2009 i) The theoretical background behind the risk of fuel tank safety: the explosions of mixtures of fuel and air, the behavior of those mixtures in an aviation environment, the effects of temperature and pressure, energy needed for ignition etc, the ‘fire triangle’, Explain 2 concepts to prevent explosions: (1) ignition source prevention and (2) flammability reduction, ii) The major accidents related to fuel tank systems, the accident investigations and their conclusions, iii) SFAR 88 of the FAA and JAA Interim Policy INT POL 25/12: ignition prevention program initiatives and goals, to identify unsafe conditions and to correct them, to systematically improve fuel tank maintenance), iv) Explain briefly the concepts that are being used: the results of SFAR 88 of the FAA and JAA INT/POL 25/12: modifications, airworthiness limitations items and CDCCL, v) Where relevant information can be found and how to use and interpret this information in the various instructions for continuing airworthiness (aircraft maintenance manuals, component maintenance manuals…), vi) Fuel Tank Safety during maintenance: fuel tank entry and exit procedures, clean working environment, what is meant by configuration control, wire separation, bonding of components etc, vii) Flammability reduction systems when installed: reason for their presence, their effects, the hazards of an Flammability Reduction System (FRS) using nitrogen for maintenance, safety precautions in maintenance/working with an FRS, viii) Recording maintenance actions, recording measures and results of inspections. The training should include a representative number of examples of defects and the associated repairs as required by the TC / STC holders maintenance data.
F) Approval of training
For M.A. Subpart G approved organisations the approval of the initial and continuation training programme and the content of the examination can be achieved by the change of the CAME exposition. The modification of the CAME should be approved as required by M.A. 704(b). The necessary changes to the CAME to meet the content of this decision should be made and implemented at the time requested by the competent authority.