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CAR 573 and the AMO Welcome
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Dennis Lyons PRM/PRMC FAST AIR LTD
Introductions with company and role if group not too large
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GOALS Review CAR 573 and how it affects AMO’S
Provide options on how to meet the intent of the regulations Answer your questions Use example of an AME starting AMO and how they use it virtually every day. Please see the Regulation and Standard for details
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CAUTION Your AMO may have a different way of complying. This is okay!
Talk with your PRM to see why you do it the way you do for things that are different
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MPM vs MCM MPM deals with how maintenance is done
MCM deals with what maintenance is done and when How – standards, who etc. What scheduled or unscheduled, fix, defer, flight permit etc. MSA, AD and the list goes on. Give example of how I explain it to our pilots
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QUICK REVIEW CAR 573 STANDARD 573
We will be hitting the highlights and not necessarily every item in the Regulation
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MPM All AMO’s require it
The contract with TC on how you will maintain compliance with the applicable regulations Home of all policies (MPM) This is what you will be judged on. Usually easiest to find errors. Why? Why – policies change over time but the manual is usually the last to change and to bring Human Factors into it “Negative Norms” creep in
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MPM Can be combined with other manuals Recommend you do not. Why?
Manual now affects both certificates potentially. Can create confusion such as can an AME Defer a defect or who has authority to defer a defect? What do you do?
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MPM Documents Incorporated by Reference DIR Usually procedures
Can be capabilities list Very useful for anything that can be changed regularly IF you are not doing this I recommend you seriously look at it. A means to put everything in one place.
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MPM Insert LEP from DIR Example
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AMO TYPES Non Specialized Aircraft and their component parts
Example Fast Air Ltd. Examples have been pulled from the TC website for AMO’s
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AMO TYPES Specialized Radio – Prairie Helicopters
Auto Flight – MB Aero Instrument – Midwest Avionics Engine – Aero Recip Propeller – Prop Works Structures Wooden – Portage Aircraft Maintenance
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AMO TYPES Structures Sheet Metal – Missinippi Air
Structures Tubular – Adventure Air Structures Composite - ACS Component – Custom Helicoters Welding – Cadorath Aerospace NDT - Perimeter Point out the great diversity we have in Manitoba for AMO services
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TRAINING INITIAL UPDATE ADDITIONAL
Briefly discuss each one and how to document
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TRAINING New AMO Update Training must be carried out within three years Regulation specific on “minimum” required Regulation allows for “continuous” training program provided your QA program supports it Remember intent of Regulation when choosing which to use Update training is specific and can be used for new equipment etc
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TRAINING Additional Training
Used to address audit findings etc, change in regulation or some non compliance
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TRAINING Record everything you do training on
Place in file and provide trainee with copy Must be kept for minimum of two years after they leave This is a great way to make sure the person knows that they have been trained. It is not surprising when an auditor asks if they have had training and they answer no until you ask them remember when we talked about…
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TRAINING ACA Training must be completed and documented prior to issue
M1 aircraft suggest developing simple exam that covers all systems. Determine how to record review of capability of AME to receive ACA Hint put it in a DIR M2 aircraft require type course or MPM approved type training
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TRAINING SCA Training Can be used by Specialized or Unspecialized AMO’s Training must meet intent of the regulation for the work and authorization sought Mostly used by specialized AMO’s or to document things like ELT recert and authorizations
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MAINT ARRANGEMENTS Who decides what gets fixed?
The aircraft owner. PRMC. Use the example I use for pilots about the discussion I have with myself
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MAINT ARRANGEMENTS Work cannot proceed until owner tells you what to do Owner tells you what documents to use This is usually found in the MSA Defects found during maintenance are controlled by the owner Note discuss work done outside of AMO ie: subcontract avionics amo or specialized maintenance
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PARTS AC Documentation Required for the Installation for Parts onto Canadian Registered Aircraft Issued recently As an AME you need to read this document Supports your MPM and is detailed
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TECHNICAL RECORDS AMO required to keep copies of virtually everything for two years Check your MPM for what you need to keep. Minimum, maintenance release but can become quite large depending on what work was done This can easily be forgot if you have an AOC and AMO when you sell an aircraft
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QUALITY ASSURANCE The purpose of QA is to ensure compliance with the Regulation It is not something that someone else does You, are the first link in Quality Assurance Applies to all aspects of the AMO Functional areas
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QUALITY ASSURANCE Best way is to build a system that has a question for every line of the applicable Regulations and Standards Remember, you will have two types of questions One for your manuals One for are you doing it
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QUALITY ASSURANCE (3) For the purposes of this Section, where an AMO has a maintenance arrangement for the performance of work with an organization other than an AMO, "direct supervision" means that the person from the AMO tasked with certifying the work personally ensures compliance with Section of the CARs. Discuss what audit questions might you need for this STD 573 item. Is it covered in the MPM, individual question for each part of MPM dealing with are they doing this?
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QUALITY ASSURANCE This is the first place TC will look Keep it simple
If possible have someone who is not involved with your organization be the auditor Please cooperate with the Auditor. A good auditor will save you time and money Findings can become additional training Discuss concept of independence
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SMS Applicable to AMO’s who support 705 operations
See your MPM if this is applicable
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QUESTIONS
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THANK YOU
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