Future Defence Aviation Safety Regulation Module 4 EMAR Part 145 – Maintenance Organisations May 2015

EMAR Part 145 – Maintenance Organisations Scope EMAR Part 145 – Maintenance Organisations Overview of Part 145 Key definitions EMAR 145 Breakdown Main differences between TAREG and EMAR

EMAR Structure This is where the Requirements sit in the Airworthiness structure but 145 actually fits as more of a subset of EMAR M in reality.

145.A.10 Scope - To establish the requirements to be met by a Maintenance Organisation to qualify for the issue or continuation of an approval for the maintenance of military aircraft or components To establish the requirements to be met by a Maintenance Organisation to qualify for the issue or continuation of an approval for the maintenance of military aircraft or components

145.A.20 Terms of approval (Scope of Organisation) The Scope Of Approval will be shown in the company Maintenance Organisation Exposition EMARs use a Classification and rating system grouped into: A – Aircraft B – Engines/APU C – Components D – Specialist Services NDT, Arms, Munitions and Pyrotechnic System Specific

Classifications & Ratings

145.A.25 Facilities Appropriate for the planned maintenance activities including office accommodation Supports personnel effectiveness (working environment, human factors) Storage, segregation and access requirements for components, equipment, tools and materials

145.A.30 Personnel Requirements Accountable Manager (Corporate authority) Nominated management team Maintenance Man-hour plans and personnel competence standards Requirements for limited aircrew maintenance and one-off approvals at remote locations Accountable Manager (Corporate authority) - the AM has corporate authority for ensuring that all maintenance activities can be financed and carried out in accordance with this Part Nominated management team – Line/ Base Managers, Quality manager Maintenance Man-hour plans - maintenance man-hour plan showing that the organisation has sufficient staff to plan, perform, supervise, inspect and quality monitor the organisation in accordance with the approval. Establishment of competence standards (both for the job function and Human Factors) QTE requirements for all staff. Technical and Non-tech Requirements for limited aircrew maintenance and one-off approvals at remote locations

145.A.35 Certifying Staff and B1, B2 and B Support Staff Licenced by Authority, Authorised to certify by the organisation following competence assessment Ongoing competence / continuation training requirements Minimum age for certifying staff Licenced by Authority, Authorised to certify by organisation following competence assessment Ongoing competence / continuation training requirements – Six months OTJ in every two years, Mandated Continuation training in a two year period Minimum age for B1, B2 and B Mil staff - 21

145.A.40 Equipment ,Tools and Material Requirement to have available and use the necessary equipment, tools and material to perform the approved scope of work Use of alternate tools Equipment and tools must be permanently available. Calibration and control processes required. Requirement have available and use the necessary equipment, tools and material to perform the approved scope of work Use of alternates strictly controlled Equipment and tools must be permanently available - except in the case of any tool or equipment that is infrequently used Calibration and control processes required.

145.A.42 Acceptance of Components Segregation of serviceable and unserviceable components Control of unsalvageable/scrap/life expired items Component Marking/Labelling requirements Pre-installation requirements Fabrication of parts It is essential that only serviceable and approved components are used in the maintenance of aircraft. Therefore, a suitable method of classifying and labelling components is required. This regulation also details the requirements for an organisation to follow when arranging for a component to be fabricated.

145.A.45 Maintenance Data Approved, applicable and current maintenance data Requirement to inform author of errors with data Requirements for the limited modification of maintenance data Availability of maintenance data Maintaining the accuracy of maintenance data The use of approved and accurate maintenance data is essential for continuing the airworthiness of an aircraft or aircraft equipment.

145.A.47 Production Planning All necessary personnel, tooling, equipment, materials, maintenance data and facilities available Requirement to take into account Human Factors when planning maintenance tasks and shifts Shift and task handovers to be controlled to ensure that the organisation puts in place adequate resource to meet the maintenance requirement and also puts in place suitable working patterns and handover procedures to mitigate the risk of Human Error

145.A.50 Certification of Maintenance Certification of Aircraft & Component Release to Service (CRS) Reporting requirements to the Continuing Airworthiness Management Organisation (CAMO) for new unserviceabilities Requirements for Incomplete Maintenance tasks Use of components without appropriate certification

145.A.55 Maintenance Records Recording of maintenance work Maintenance records reporting requirements to the CAMO Retention of maintenance records Storage and protection requirements for records

145.A.60 Occurrence Reporting External (authority) reporting requirements for safety issues Internal reporting of error/hazards/unsafe conditions Trends analysis and continuous improvement requirements Reporting timeframes

145.A.65 Safety and Quality Policy, Maintenance Procedures and Quality System Requirement for a safety and quality system, including Independent auditing requirements Internal feedback and response system for addressing findings Human factors and performance management Maintenance management procedures encompassing 145.A.25-.95 Minimise multiple errors and critical systems

145.A.70 Maintenance Organisation Exposition (MOE) Approved by the NMAA Description of organisation structure, scope of approval, quality system, maintenance procedures (high level procedures), terms of reference and MOE amendment process Safety & Quality Policy Can be from an approved EASA Part 145 organisation. In order to obtain NMAA approval, the organisation must submit an MOE that defines the requested scope of approval and the procedures to which they will adhere to in order to meet the requirements set out in Part 145) series of requirements

145.A.75 Privileges of the organisation Maintain any aircraft and/or component for which it is approved at the locations identified in the approval certificate and in the MOE Subcontracting of maintenance Issue Certificate of Release to Service (CRS) as per 145.A.50 on completion of maintenance.

145.A.80 Limitations on the organisation The organisation shall only maintain an aircraft or component for which it is approved when all the necessary facilities, equipment, tooling, material, maintenance data and certifying staff are available.

145.A.85 Changes to the organisation Which changes require notification to be made to the authority Name change, location changes, management changes Anything that could affect the approval Ownership of the approved organisation.

145.A.90 Continued validity of the approval Unlimited duration based on Satisfactory handling of findings The NMAA being granted Access Certificate of approval has not been surrendered or revoked

145.A.95 Findings Level 1 and Level 2 No observations or opportunities for improvement Requirement for corrective action plan within defined timeframes

Differences between TAREG and EMAR TAREGs 4-5 EMAR Part 145 Unique to TAREGs 4-5 Common aspects that require no further explanation Common aspects that are treated differently and require further explanation Unique to Part 145

Organisational Differences Current Organisation under TAREG Possible organisation under EMAR 145 / M Notes TAR (Technical Airworthiness Regulator) NMAA (National Military Airworthiness Authority) AEO Approved Design Organisation Design Certification Possibility for some personnel performing CAMO functions in SPO’s to “move” into CAMO No single organisation Continuing Airworthiness Management Organisation (CAMO) CI Management Maintenance System (approved data) Management/selection of designs onto platform(s) CAMO created. CAMO responsible for continuing airworthiness. Some CAMO tasks currently performed by SPO / Through Life Support Contractors (Lean SPO) SQN’s. Organisational Differences

Maintenance Positions Current Position under TAREG Possible Position under EMAR 145 Notes Senior Executive Accountable Manager (AM) Normally mean Chief Executive Officer / senior military commander. AM has corporate authority for ensuring that all maintenance activities can be financed and carried out. SMM Senior Maintenance Manager (Responsible Manager) – XXX SMM’s would have defined responsibilities. For example: An entire unit/organisation, Deeper Level Maintenance, Flightline Maintenance Multiple SMMs’ is acceptable with each having specific responsibilities and no overlapping of authority. QM The QM needs to be a direct report to the AM. Maintenance Personnel Otherwise referred to as ‘support staff’ in EMARs. 

Maintenance Artefacts and Approvals Current Artefact EMAR 145 / Possible Term Notes AMO Some current AMO tasks may become the responsibility of the CAMO MMP Maintenance Organisation Exposition (MOE)   Training Records (includes Record of Training and Employment (RTE)) EMARs would permit an ADF equivalent system i.e current practice, in lieu. Solution yet to be confirmed Licences could be introduced for maintenance personnel and/or current system retained/revised, etc. Note: RTE is not Regulated by TAREG Maintenance Release Certificate of Release to Service Similar intent however, EMARs application may promote greater flexibility Maintenance records Defect Reports Occurrence reporting Derogation No direct equivalent A built in flexibility or alternate requirement

Key differences to TAREG EMAR Part 145 Key differences to TAREG Sponsor (TAREG 4.1.2). There is no Sponsor under EMAR Foreign object (TAREG 4.4.1.a(9)) and tool control (TAREG 5.4). Foreign object and tool control (ADF Unique requirement) Independent Maintenance Inspection (IMI) Certification (TAREG 5.1.3). IMI’s are not specifically covered under EMAR 145 (yet), (ADF Unique requirement) Fleet planning/maintenance scheduling. Despite there being no applicable TAREG, there is an implied AMO responsibility for these functions, which are typically the domain of the SPO, WG, Maintenance Co-ord or unit Maintenance Control Section (MCS). EMARs address these requirements under Part M. Responsibilities. Some responsibilities for functions performed at AMO’s lie with the CAMO. (Deferred Maintenance, Records Management, Pre-flight inspections) EMAR 145: Continued Airworthiness - establishes the requirements to be met by an organisation to qualify for the issue or continuation of an approval for the maintenance of aircraft and components.

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