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Aviation Safety Agreement Between The United States and The European Community This purpose of this briefing is to give an overview of the Bilateral Agreement.

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Presentation on theme: "Aviation Safety Agreement Between The United States and The European Community This purpose of this briefing is to give an overview of the Bilateral Agreement."— Presentation transcript:

1 Aviation Safety Agreement Between The United States and The European Community
This purpose of this briefing is to give an overview of the Bilateral Agreement between the European Community (EC) and the United States (FAA). Selected topics will give a picture of the Agreement pertaining to EASA, AA, and FAA understanding of specific responsibilities for Aviation Safety. Time for Questions and Answers will be allowed for at the end of this briefing.

2 Introduction Steve Douglas FAA, Acting Manager
Aircraft Maintenance Division John Benning FAA, Manager Frankfurt International Field Office Marty Bailey Repair Station Branch Manager, AFS-340 Kathrine Rask FAA, Aircraft Certification Service International Policy Office  Karl Specht EASA, Continuing Airworthiness Organisations Manager Luis Pires EASA, International Standardisation Coordinator Introduction

3 Agenda NEW Agreement & Annexes Maintenance Annex Guidance
Section A – Authority to Authority Section B – U.S. Based Repair Stations Section C – European Based Repair Stations Supplement Example

4 Introduction to the U.S./EC Aviation Safety Agreement
BETWEEN THE UNITED STATES OF AMERICA AND THE EUROPEAN COMMUNITY ON COOPERATION IN THE REGULATION OF CIVIL AVIATION SAFETY In June 2008, the United States and the European Community signed an agreement on aviation safety. This agreement covers airworthiness and environmental certification, and maintenance. An exchange of Diplomatic notes was signed on March 15th, 2011 and the new agreement was entered into force May1th, Previous bilaterals with EC Member States will be terminated. The terminated bilaterals include: Bilateral Airworthiness Agreements, and Bilateral Aviation Safety Agreements with related Airworthiness or Maintenance Implementation Procedures. 4

5 What is the Safety Agreement?
Bilateral Agreement It is a cooperative Agreement between the United States and the European Union May be required by regulations Allow FAA, EASA, and AA’s to leverage resources & mitigate undue burden Minimize duplication of effort, increase efficiency Build a partnership of competent civil aviation safety regulatory authorities The agreements allow the FAA, EASA, and AA’s to leverage resources for its international work. For instance, a bilateral agreement allows the FAA to rely on another civil aviation authority to conduct on-site work or activities in its country. By doing so, the agreement also builds efficiency because certification activities already completed by another aviation authority don’t have to be duplicated. The partnerships built, and the knowledge transferred, as a result of these bilateral agreements, significantly improve the safety of the overall international air transportation system. 5

6 What is a Safety Agreement?
Bilateral Agreement Does not relieve FAA, EASA and the AA’s of their statutory responsibilities to “make findings of compliance” with regulations; however… Does provide an alternative means for the Authorities to make its findings, using the system of the other signatory country to the maximum extent practicable Although these bilateral agreements enable the FAA and EASA to rely on the assistance of another civil aviation authority, they do not relieve the FAA and EASA of its statutory responsibilities to make findings of compliance with regulations. A bilateral agreement is not a delegation to another authority. Instead, bilateral agreements define the FAA’s cooperation with its counterpart in the other country, and enable us to give maximum credit to the other country’s regulatory system. Bilateral agreements also commit these authorities to assist in the timely resolution of safety issues, and vice versa. 6

7 Principles of Safety Agreements
Is between the United States and the European Union, not industry Promotes reciprocal acceptance of findings and approvals, not mutual recognition Is based on systems that produce equivalent results, though processes and procedures may be different Relies to the maximum extent practicable on EASA and the aviation authority Is based on acceptance of a system All of the agreements that the United States concludes are based on 5 general principles. First, the agreements are bilateral. They are between the U.S. government and the government of another country. Industry is never a signatory to the agreement. It is the FAA’s and civil aviation authority’s responsibility to inform industry of the expectations and procedures identified in the agreement, and then to hold industry accountable. Second, the agreements provide for reciprocal acceptance of findings and approvals. They recognize the work done by the other country and “give credit” to that work. It is not considered mutual recognition because the FAA still remains responsible for the issuance of FAA approvals and certifications. Third, the agreements are based on systems that produce the same results as if the FAA had done the work itself. However, the processes and procedures used may be different, and that is acceptable. It’s the results that matter. Fourth, through the bilateral agreement, we rely on our partner civil aviation authority to the maximum extent, and vice versa. Of course, there are some areas where the FAA or its bilateral partner will remain involved. Finally, the bilateral agreement is based on another country’s regulatory system and that country’s ability to maintain that system over time. 7

8 The U.S./EC Aviation Safety Agreement
The Agreement with the European Community is an agreement “On Cooperation in the Regulation of Civil Aviation Safety.” The Agreement and it’s Annexes may be found at The Executive Agreement and its Annexes are BINDING in international law The foundation of the new agreement is cooperation in regulating civil aviation safety. This is the next step forward from our past harmonization activities with Europe. The U.S. and EC governments commit in this agreement to share, communicate, and collaborate to support the exchange of aviation products and services, as well as safety of the global fleet. Several key differences make this agreement unique from BASAs. Because of the status of the agreement in U.S. and EC law, these commitments are binding on the FAA, EASA, and the Aviation Authorities. This means that any violation could end up being addressed in diplomatic and political forums. 8

9 Components of the New Aviation Safety Agreement Format
Safety Agreement between the United States and European Community Between the FAA and EASA Tier 3 Annexes Tier 2 Executive Agreement Tier 1 + Annex 1: Airworthiness and Environmental Certification Annex 2: Maintenance Technical Implementation Procedures FAA EASA Maintenance Annex Guidance In the new U.S./EC aviation safety agreement, the two tier component has been changed to three tiers as follows: Tier 1 -Executive Agreement, Tier Annexes, one for Airworthiness and one for Maintenance, and; Tier 3 -Technical Implementation Procedures for Airworthiness and Environmental Certification. This three-tiered approach is the format difference between the new agreement and a BASA. The Executive Agreement is an umbrella Agreement defining U.S./EC cooperation in aviation safety. To support this agreement, both the FAA and EASA have developed additional guidance material for their individual workforces. It is call the “Maintenance Annex Guidance” or MAG Level of detail increases with each tier

10 Executive Management Bilateral Oversight Board (BOB)
Responsible for ensuring the effective functioning of this Agreement Joint Maintenance Coordination Board (JMCB) Annex 2 - Oversight Certification Oversight Board (COB) BOB – Established by Article 3 of the Agreement Responsible for ensuring effective functioning and implementation of this Agreement The Bilateral Oversight Board is composed of representatives of: The United States of America, which shall be the Federal Aviation Administration (co-chair) The European Community, which shall be the European Commission (co-chair) assisted by the European Aviation Safety Agency COB – Established by Annex 1 of the Agreement (Airworthiness and Environmental Certification) Accountable to the BOB Established under the joint leadership of technical agents The COB includes representatives from each Technical Agent responsible for airworthiness and environmental certification, quality management systems and rulemaking JMCB – Established by Annex 2 of the Agreement (Maintenance) Established under the joint leadership of the EASA Director responsible for Organisational Approvals and the FAA Director of Flight Standards The JMCB includes Technical Agents from EASA and FAA responsible for maintenance and quality management systems and rulemaking as appropriate The JMCB is required to: Meet yearly to ensure the effective functioning of the Maintenance Annex Report unresolved issues to the Bilateral Oversight Board (BOB) Ensure the implementation of any decisions reached by the BOB The JMCB may task sub-groups as necessary to address specific technical issues The JMCB develops, revises, and approves the Maintenance Annex Guidance (MAG) as necessary Annex 1 - Oversight

11 Executive Agreement The Executive Agreement is an umbrella Agreement defining U.S./EC cooperation in aviation safety. It is unique in that the Agreement is with the EC, not with an individual country Applicable to the United States and EC Member States contained in Annex 2, Appendix 2 • In other words, this agreement is the, first aviation safety bilateral that is multilateral in its scope The Executive Agreement is a broad framework, or umbrella agreement, for cooperation in aviation safety. This leads to the second key difference between this agreement and a BASA. The “Parties” to this agreement are the government of the United States, and the government of the European Community. It is signed on behalf of the European Community, and is applicable in all 27 Member States. Therefore, this is a bilateral agreement – two signatories – that is multilateral in scope.

12 Executive Agreement The purpose of this Agreement is to:
Enable the reciprocal acceptance of findings of compliance and approval issued by the Technical Agents and Aviation Authorities Promote a high degree of safety in air transport Ensure the continuation of the high level of regulatory cooperation and harmonization between the Unites States and the European Community The purpose of this Agreement is to: Enable the reciprocal acceptance of findings of compliance and approval issued by the Technical Agents and Aviation Authorities. Promote a high degree of safety in air transport Ensure the continuation of the high level of regulatory cooperation and harmonization between the Unites States and the European Community.

13 Executive Agreement The scope of cooperation under this Agreement is:
Airworthiness approvals and monitoring of civil aeronautical products; Environmental testing and approvals of civil aeronautical products; and Approvals and monitoring of maintenance facilities The scope of cooperation under this Agreement are for: Airworthiness approvals and monitoring of civil aeronautical products; Environmental testing and approvals of civil aeronautical products; and Approvals and monitoring of maintenance facilities.

14 Executive Agreement New provisions in Executive Agreement:
For Technical Agents to develop and adopt procedures for regulatory cooperation Two Annex’s Detailed dispute resolution provisions Procedures for the acceptance and suspension of compliance findings and approvals As we look at the new provisions of the Executive Agreement, we would like to highlight several key differences between previous agreements. This is the first time that a bilateral agreement has included any reference to rulemaking cooperation. Over the past decade, we have worked with the Europeans to harmonize our standards and regulations. We want to continue this cooperative effort in an effective manner. Including this provision in the new agreement provides for the FAA to have early involvement and input into EASA’s rulemaking process, and vice versa. Another unique component of this agreement is the creation of a formal oversight board to monitor the implementation of the agreement. Under the Bilateral Oversight Board, or BOB, there will be a more formal dispute resolution process. Finally, this Executive Agreement contains procedures for the acceptance and suspension of compliance findings and approvals from Aviation Authorities.

15 Executive Agreement The Executive Agreement contains 19 articles and two annexes. Annex 1, Airworthiness and Environmental Certification Annex 2, Maintenance 19 Specific Articles make up the Executive Agreement. Articles 1 through 12, are key for understanding the agreement, and the remainder articles offer supplementary information, Articles 13 through 19. Such as: Exective Management Article 3 Regulatory Cooperation Article 6 Cooperation in Enforcement Activitives Article 8 Exchange of Safety Data Article 9 Unimpeded Access Article 13 Handling Disputes Article 17

16 Executive Management Article 3 establishes Executive Management to ensure effective functioning and implementation of the Agreement. It is called the Bilateral Oversight Board (BOB) and is composed of representatives of: The United States of America, which shall be the Federal Aviation Administration (co-chair) The European Community, which shall be the European Commission (co-chair) assisted by the European Aviation Safety Agency The Bilateral Oversight Board is composed of representatives of: The United States of America, which shall be the Federal Aviation Administration (co-chair) The European Community, which shall be the European Commission (co-chair) assisted by the European Aviation Safety Agency The Certification Oversight Board (COB) and the Joint Maintenance Coordination Board (JMCB) report to the BOB

17 Executive Management Annex 1, of the agreement establishes the Certification Oversight Board (COB) to ensure effective functioning and implementation of Annex 1. The COB includes representatives from each Technical Agent responsible for airworthiness and environmental certification, quality management systems and rulemaking The Certification Oversight Board is established under Annex 1 of the Agreement as a joint technical coordination body, that includes: Representatives from each Technical Agent responsible for airworthiness and environmental certification, quality management systems and rulemaking.

18 Certification Oversight Board
Executive Management Certification Oversight Board Annex 1 EASA Certification Director FAA Director, Aircraft Certification (AIR-1) Annex 1, of the agreement establishes the Certification Oversight Board (COB) to ensure effective functioning and implementation of Annex 1. Report unresolved issues to the Bilateral Oversight Board (BOB) Ensure of any decisions reached by the BOB are implemented In their meetings, the JMCB is required to report unresolved issues and ensure implementation of BOB decisions. They also may task sub-groups and should approve revisions to the MAG as necessary. The JMCB develops, revises, and approves the guidance developed under Annex 2 Members of the board are appointed by the leadership 18 18

19 Joint Maintenance Coordination Board
Executive Management Joint Maintenance Coordination Board Annex 2 EASA Approvals and Standardisations Director FAA Director of Flight Standards (AFS-1) The Joint Maintenance Coordination Board is established under Annex 2 of the Agreement as a joint technical coordination body with the joint leadership of: FAA’s Director of Flight Standards, AFS-1 and EASA’s Director Responsible for Organization Approvals. will appoint a team of technical specialist to review and resolve issues, develop policy and procedures, and facilitate publication in accordance with each others systems. The JMCB will meet annually to ensure the effective functioning of the Maintenance Annex (Annex 2, of New Agreement) Report unresolved issues to the Bilateral Oversight Board (BOB) Ensure of any decisions reached by the BOB are implemented In their meetings, the JMCB is required to report unresolved issues and ensure implementation of BOB decisions. They also may task sub-groups and should approve revisions to the MAG as necessary. The JMCB develops, revises, and approves the guidance developed under Annex 2 Members of the board are appointed by the leadership

20 Executive Management Consultations and Settlement of Disputes (Article 17) Either Party may request consultations with the other on any matter related to the Agreement Shall enter into consultations at a time agreed within 45 days The Parties Technical Agents shall attempt to resolve any disagreement under the Agreement If unable to resolve any disputes may refer the dispute to the Board ARTICLE 17 Consultations and Settlement of Disputes Either Party may request consultations with the other Party on any matter related to this Agreement. The other Party shall reply promptly to such a request and shall enter into consultations at a time agreed by the Parties within 45 days. The Parties' Technical Agents shall attempt to resolve any disagreement between them regarding their cooperation under this Agreement by consultation in accordance with provisions contained in the Annexes to this Agreement. C. In the event that the Technical Agents are unable to resolve disputes as provided for in paragraph B, either Technical Agent may refer the dispute to the Board, which shall consult on the matter.

21 Maintenance Annex Guidance (MAG)
The purpose of the MAG is to define the procedures and activities of the FAA, EASA, AA and the applicant for FAA and EASA part 145 approval’s under the Agreement, Annex 2 Agreement/Annex 2/Maintenance Key Points: Outlines the procedures for implementing the provisions of the Agreement that apply to maintenance Agreement between EASA or an Aviation Authority (AA) and Federal Aviation Administration (FAA) BASA/MIP’s will remain in place in France, Germany & Ireland until they are transitioned to the new Agreement

22 Maintenance Annex Guidance (MAG)
The Maintenance Annex Guidance is subdivided into sections A, B, and C The MAG details EASA, FAA, AA, and applicant actions required to be taken to be in compliance with the Agreement The Agreement between the FAA and the EC permits reliance on each others surveillance systems to the greatest extent possible The Maintenance Annex Guidance is subdivided into sections A, B, and C The MAG details EASA, FAA, and applicant actions required to be taken to be in compliance with the Agreement The Agreement between the FAA and the EC permits reliance on each others surveillance systems to the greatest extent possible

23 Agreement/Annex 2/Maintenance “Special Conditions”
The Special Conditions contained in Annex 2, Appendix 1, have been developed to eliminate duplicate activities The FAA, EASA and AA’s contained in Annex 2, Appendix 2, have numerous duplicated elements in their respective inspection, surveillance, evaluation, and certification programs The Special Conditions in Appendix 1 of the MA were developed to eliminate duplicate activities. The Special Conditions in Appendix 1 should not be confused with the Supplement which is used for Repair Stations in Appendix 3. 23 23

24 Understanding the U.S./EC Aviation Safety Agreement
Maintenance Annex Guidance Section A - Authority Interaction Guidance Section A applies to the FAA, AA’s and EASA The purpose of Section A of the MAG is to define the procedures between the Federal Aviation Administration (FAA), the European Aviation Safety Agency (EASA) and the Aviation Authorities (AAs)

25 General Communications and Training Communications between authorities
The FAA, EASA, and AA’s need to keep each other informed of significant changes within their respective systems concerning: responsibility organizational structure significant revisions to an AMO’s systems standards or procedures revision by the FAA, EASA or an AA to published materials The processes addressed for training are discussed in detail in the MAG. This should be reviewed by appropriate individuals of the FAA, EASA, Aviation Authorities, and industry. The FAA, EASA and Aviation Authorities need to keep each other informed of significant changes. The FAA or EASA may request meetings to review the need for amendment to this MAG. A list of contact points for the various technical aspects of the Maintenance Annex, including communication of urgent issues is located in MAG Section A, Appendix 1. In order to be familiar with the MAG and the requirements of the Maintenance Annex, the briefing you are now taking is provided for FAA, EASA and Aviation Authority personnel covering the maintenance annex, special conditions and certification procedures. 25

26 General Communications and Training Requirements for training
FAA, EASA, and AA personnel should receive training in: maintenance annex special conditions, and certification procedures

27 General Technical Consultations and Issue Resolutions
Technical consultations between the FAA and EASA For technical consultations the FAA Director of Flight Standards and the EASA Director responsible for Organization oversight agree to consult as necessary The FAA Director of Flight Standards and the EASA Director responsible for Organization oversight may have technical consultations. Additionally the FAA and EASA agree to resolve issues through consultation. Every effort should be made to resolve the issues at the lowest possible level. Compliance with the agreement procedures for interpretations and resolution of issues between the FAA and EASA can be found in MAG Section A.

28 General Interpretations and resolution of issues between the FAA and EASA The FAA and EASA agree to address interpretations and resolution of issues and resolve issues through consultation or any other mutually agreed-upon means (reference MAG, Section A , Part 1, Paragraph 5.0, 5.1 & 5.2) Try to resolve the issues at the lowest possible level To address interpretations and resolve issues the FAA and EASA (If an AA is involved, EASA shall ensure adequate coordination.) have agreed to use the processes addressed in the MAG, Section A, Part I, Paragraph 5 (page 9) (MAG, Section A, Part I, Paragraph 5 page 9) For facilities located in Europe, the first point of contact is the AA contact listed in Appendix 1, who is going to coordinate issues with the Eastern Region coordinator with copy to the EASA manager responsible for standardization. If resolution cannot be reached, the issue may have to be expeditiously raised to the EASA head responsible for standardization, who must` consult with the FAA National Coordinator. (3) If resolution cannot be reached, the issue must be expeditiously raised to the EASA director responsible for issuing the organizational approvals, as appropriate, who may consult with the Director of Flight Standards. (4) Issues that cannot be satisfactorily resolved between the FAA Director of Flight Standards and EASA directors on an ad hoc basis shall be added to the agenda for the next formal Joint Maintenance Coordination Board (JMCB) meeting for further consideration. (5) Issues that cannot be resolved by the JMCB must be forwarded to the Bilateral Oversight Board for resolution (The Bilateral Oversight Board is a joint executive level group responsible for effective functioning of the Agreement).

29 Cooperation in Quality Assurance and Standardization Activities
In order to promote continued understanding and compatibility in each other’s maintenance systems, FAA and EASA need to consult and share information on quality assurance and standardization activities This is achieved through these four programs, processes, and systems EASA Standardization EASA Sampling Inspection System FAA Sampling Inspection System Flight Standards Evaluation Program Part Two of MAG Section A addresses cooperation in quality assurance and standardization activities. The procedures and methods of ensuring that the FAA, EASA and the Aviation Authorities are following the agreement as contained in the MAG Section A, Part Two include: • Implementation of the EU-EASA Standardization in EU Member States • The EASA Sampling Inspection System in the US • The Flight Standards Evaluation Program, or FSEP • And the FAA Sampling System

30 FAA Sampling System FAA Responsibilities Sampling Inspection Schedule
Eastern Region Coordinator will develop the FAA Sampling System schedule using objective criteria Frequency may be tied to successful implementation of the EASA audit program of FAA Special Conditions Annual schedule must be provided to EASA for coordination with the Aviation Authorities The sampling inspection visit schedule is determined by the FAA Eastern Region Coordinator or delegated representative. The objective criteria for the sampling visit may include: EU Member States with a large concentration of FAA Certified Repair Stations A location or facility with a number of non-compliance findings from an Aviation Authority Safety Performance Analysis System, or SPAS data that indicate safety could be most at risk, or Previous FAA sampling inspection reports that indicate a particular Aviation Authority may be of FAA concern Note - Generally during sampling inspections the FAA may review the Approved Maintenance Organizations internal auditing program to ensure that additional facilities and/or line stations covered by this Agreement are meeting the FAA special conditions. The Eastern Region Coordinator will determine if visits to these facilities should be accomplished. The number of sampling inspections may be related to the successful implementation of the EASA audit program of FAA Special Conditions identified in MAG, Section A. If a change is made during the year to the annual schedule, every attempt should be made to provide ample notice to EASA and the Aviation Authority. Additionally, each Aviation Authority can expect to be visited at least once every 18 months. Supplementary visits by a sampling inspection team to an EU Member State may be required in some cases as directed by the FAA Eastern Region Coordinator.

31 FAA Sampling System FAA Responsibilities
Monitor the application of the Maintenance Annex by EASA and the Aviation Authorities Ensure that maintenance organizations meet standards in accordance with FAA Special Conditions Sampling inspection team composition Selection of AA and repair stations to be visited The fourth topic addressed in Part II of MAG Section A is the FAA Sampling System. While the EASA Sampling Inspection System and the Flight Standards Evaluation Program focus on FAA offices in the US, the FAA Sampling System applies to inspections by the FAA of EU Member State Aviation Authorities. A sampling inspection schedule is established by the FAA Eastern Region Coordinator to ensure the Agreement is being implemented in the EU Member States included in the Maintenance Annex. The sampling inspections are designed to verify that the Aviation Authorities are following the guidance provided for in Sections A and C of the MAG. This is a Safety Management Systems approach to Bilateral Agreements. The FAA Sampling System also serves to assist EASA, Aviation Authorities, and European industry in understanding the FAA Special Conditions and the procedures associated with implementation of the Bilateral Agreement as appropriate. The Eastern Region Coordinator is responsible for the composition of the team. Each team member should be trained and qualified. EASA and Aviation Authority representatives should accompany the Sampling Inspection team during the visit to ensure that no misunderstandings arise. It is recommended that the principal inspector or surveyor responsible for the Approved Maintenance Organization join the team for that visit. The FAA will identify Aviation Authority regional offices and/or field offices to be visited including a selection of CFR part 145 Repair Stations to be sampled by the FAA Sampling Inspection team.

32 FAA Sampling System AA Responsibilities Sampling Inspection Process
Assist and cooperate with the FAA Team Provide AA inspector training records Provide the FAA assistance of an AA staff member who speaks English With regards to an individual Aviation Authority, the Agreement requires the Aviation Authority to assist and cooperate with the FAA Sampling Inspection Team by allowing them to review Aviation Authority repair station surveillance records, reports, findings, and corrective actions. The FAA will review Aviation Authority procedures and processes used during surveillance and certification of repair stations under the Agreement. The Aviation Authority will provide individual Aviation Authority surveyor or inspector training records for review as well as individuals responsible for surveillance for interview. The Aviation Authority should also provide the FAA assistance by allowing an Aviation Authority staff member who speaks English to assist in reviewing the previously mentioned files in addition to assisting with interviews as necessary.

33 FAA Sampling System FAA Responsibilities Sampling Inspection Process
Complete the FAA Sample Audit of Aviation Authority form Review the FAA Annex to EASA Form 6 Select several different items on the Form for each AMO visited Every item does not need to be completed In the process of conducting sampling inspections, the FAA is required to complete the FAA Sample Audit of Aviation Authority form and the FAA Annex to EASA Form 6, located in MAG Section A, Appendices 5 and 6 respectively. The FAA sampling inspection team may select several different items on the Form for each repair station to be visited. The team should cover a representative number of items listed on the FAA Annex to EASA Form 6. These items are to be limited to areas of concern raised during the visit to the Aviation Authority. This is a Safety Management System process. The conclusion of the sampling inspection of the Aviation Authority and Approved Maintenance Organization should provide the FAA with an overall view of the countries compliance with the Agreement. Note – FAA Inspectors should reference inspector guidance contained in FAA policy and procedures. The FAA will create an annual report summarizing the results of the sampling inspection team visits conducted over the previous year. This report should be provided to the EASA Approvals and Standardisation directorate.

34 FAA Sampling System FAA Responsibilities
Sampling Inspection Process continued Create annual report summarizing the results of the sampling inspections More than one sampling inspection team may be operating in the European Union at any one time FAA Inspectors should reference additional inspector guidance contained in FAA policy and procedures

35 FAA Sampling System AA Responsibilities: Sampling Inspection Process:
AA completion, follow up and closure actions Findings concerning demonstration of continued confidence are handled in accordance with MAG A,II, 2 AA accepts actions and makes recommendations to the FAA AMO completes closure actions Annex to EASA Form 6 If good… Once satisfactory closure actions for any findings have been completed by the Approved Maintenance Organization and accepted by the Aviation Authority, a recommendation should be made to the FAA on the Annex to EASA Form 6. A review of the actions taken will formally close the Visit Report. If findings require certificate action, the FAA will initiate the necessary legal procedures. A report with closure action on findings raised with the Aviation Authority that do not affect continued confidence in their compliance with the terms of the Agreement will be forwarded to the FAA by the Aviation Authority. Any findings that are based upon the Aviation Authority’s failure to demonstrate continued confidence with the terms of this Agreement will be handled in accordance with MAG Section A, Part III, Paragraph 2.

36 Procedures for Adding and Suspending the Acceptance of Findings of Compliance and Approvals
Procedure for Adding Acceptance of Findings of an AA Procedure for Suspending Acceptance of Findings of an AA Procedure for Suspending Acceptance of Findings of the FAA EASA is to notify the FAA when EASA proposes to add a new Member State to the approved list of Member States in Appendix 2 of Annex 2 to the Agreement. EASA and the FAA are to consult on the basis for this proposal. Either EASA or the FAA may be instigate a proposed suspension of the acceptance of findings of compliance and approvals made by an AA based upon the AA’s failure to demonstrate continued confidence in accordance with the terms of the Agreement. If either the FAA or EASA proposes to suspend acceptance of findings of compliance or approvals, the JMCB must discuss this at the first opportunity. The JMCB must discuss at the first opportunity a proposed suspension of the acceptance of findings of compliance and approvals made by the FAA, based upon the FAA’s failure to demonstrate continued confidence in accordance with the terms of the Agreement..

37 In the case where a Member State has been removed from the list of approved AAs in Appendix 2 of Annex 2 to the Agreement, it is possible for such Member State to pursue re‑instatement in Annex 2. Prior to re-instatement, the Member State must first be subject to an assessment for compliance with the requirements of Annex 2 paragraph  Upon satisfactory compliance with paragraph 6.1.1, the JMCB is to make a recommendation to the Bilateral Oversight Board, who in turn will make a decision regarding the re‑instatement of the Member State and take the appropriate action. For AAs of Member States listed in Appendix 2 of Annex 2 that have no current FAA repair station certification activity, the FAA is to work with the AAs to assure that they continue to comply with paragraph 6.3.1 of Annex 2 of the agreement. Procedures for Adding and Suspending the Acceptance of Findings of Compliance and Approvals Procedure for Re-instatement and Acceptance of Findings of Compliance and Approvals Made by an AA Procedure for Continued Confidence

38 Transfer Provisions Applicable in Europe
Transfer of Surveillance - 2 yr window Manual Requirements Renewal Dates Records Time Frame Transfer provisions are applicable to EC member countries listed in The Agreement that do not have current Maintenance Implementation Procedures (MIP) Part Six of MAG Section A addresses Transfer Provisions. The FAA has a 2-year window after implementation of the Agreement in which to transfer the surveillance of maintenance organizations to the applicable Aviation Authority. Maintenance organizations are required to submit the current revision to FAA Supplement Chapter 7 to their Aviation Authority at the renewal. All FAA certificate renewal dates should be reviewed to ensure a minimum of 6 months remaining prior to expiration. The FAA transfers the most current certification and surveillance records to the applicable Aviation Authority. As soon as practical the FAA and Aviation Authorities formulate a schedule identifying maintenance organizations to be transferred and establish a target date for each. This process is intended to avoid misunderstandings and reduce unnecessarily lengthy transfer procedures. In addition to formal EASA training, the FAA may provide further technical assistance, clarification, or on-the-job training as requested. Transfer provisions of applicable member countries are listed in both the MAG and the Agreement/Annex 2/Appendix 2

39 Transfer Provisions AA Responsibilities/Actions:
Designate a liaison to FAA country coordinator Submit list of AMO’s to AA HQ Ensure AA’s Staff have Agreement & Annexes training Meet FAA to exchange information Review FAA documentation on AMO Establish communication with AMO Geographic Authorization will be converted to Line Maintenance Authorizations The Aviation Authority designates a representative to serve as a liaison to the FAA Country Coordinator at the International Field Office to coordinate and plan the transfer of the certificates. The agreed-upon list of maintenance organizations is forwarded to the Aviation Authority headquarters from for approval, and a copy should be forwarded to EASA to monitor progress. The Aviation Authority ensures its inspectors and surveyors have training in the Agreement, MAG procedures, and FAA Special Conditions prior to the transfer. The Aviation Authority representatives also meet with the FAA to exchange information and accept transfer of certificates and documents. FAA documentation concerning the AMOs is reviewed with the Aviation Authority. Communications are established with the AMO and they are advised of the transfer and document requirements. For AMOs that currently have Geographic Authorizations located in EU Member States, the FAA converts those Authorizations to Line Maintenance Authorizations in accordance with guidance contained in the MAG Section C. If an issue or concern cannot be resolved between the Country Coordinator and the Aviation Authority representative it is raised to the level of the JMCB.

40 Transfer Provisions FAA Responsibilities/Actions:
JMCB make final determination for exemptions Exchange of information between FAA and AA FAA sends out notices to AMO’s of transfer Transfer the responsibility for acceptance of FAA Manuals Those Repair Stations that have a CFR exemption or no equivalent rating within the EASA system are reviewed on a case by case basis. The JMCB makes the final determination to include or not to include the repair stations that meet these criteria. Arrangements are made for the Principal Inspectors to meet with the Aviation Authorities to provide an opportunity for the FAA and Aviation Authority to exchange information referenced in MAG Section A, Part Six, Paragraph Notices to the maintenance organizations are sent by the FAA informing them of the transfer and new renewal date, if applicable. This notice will also advise the certificate holder to provide the Aviation Authority with a renewal application and revised Chapter 7 of the Maintenance Organization Exposition. It is not necessary for the Aviation Authority to review the maintenance organization’s FAA accepted repair station manuals as long as the maintenance organizations have had previous FAA acceptance prior to the transfer process. The aviation authority has the responsibility to review and accept revisions to the FAA manuals after the transfer.

41 Transfer Provisions FAA Responsibilities/Actions:
Ensure Aviation Safety Inspector’s (ASI) and Surveyors have Agreement & Annexes training Appoint a country coordinator Country coordinator establishes communication with AA Review repair station renewal date Submit target dates to FAA Eastern Region Coordinator The FAA Flight Standards Aircraft Maintenance Division (AFS-300) Ensure outstanding findings have corrective action plan The FAA has responsibilities and actions within the transfer process. One of the responsibilities includes ensuring FAA Aviation Safety Inspectors receive training in the Agreement and MAG procedures prior to the transfer in accordance with the agreement. A country coordinator is appointed to the International Field Office for each EU member state. These country coordinators establish communications with the appropriate Aviation Authority. All FAA certificate renewal dates are reviewed to ensure there is a minimum of 6 months remaining prior to expiration. Certificate renewal dates may be extended provided the certificate certification does not exceed 24 months from the last renewal. Once the list and target dates of repairs stations or AMOs are agreed to, they are submitted to the FAA Eastern Regional Coordinator and to the FAA Flight Standards Aircraft Maintenance Division. The FAA must ensure all outstanding findings have a corrective action plan agreed upon by the FAA and the Aviation Authority.

42 Transition to the New Agreement
Geographic Authority Geographic authorizations located within the EU member states should be changed to Line Maintenance Authorizations Within 6 months after entry into force of the Agreement or prior to the next renewal, the Principal Maintenance Inspector should change geographic authorizations to Line Maintenance Authorizations for those AMO’s located in the EU Member States listed in Appendix 1 of MAG Section A. Geographic Authorizations located outside the EU Member States remain the same.

43 Transition to the New Agreement
AA Responsibilities: FAA Supplement to the Maintenance Organization Exposition (MOE) Acceptance of the FAA Supplement by the AA AA provides notification to the FAA country coordinator that the AMO’s supplement has been accepted When the Aviation Authority has accepted the FAA supplement and is satisfied that it meets the applicable requirements, they include the new supplement requirements in their surveillance program. The Aviation Authority provides notification to the FAA country coordinator that the AMO’s supplement has been accepted. The FAA may maintain a current list of all Aviation Authority accepted supplements within the respective country.

44 Transition to the New Agreement
FAA Responsibilities: FAA Eastern Region Coordinator provides a sample letters Principal Maintenance Inspector (PMI) must prepare a letter to his or her repair stations Letter advises Repair Station to contact local AA inspector This transition is only applicable to France, Germany, and Ireland Part Seven of MAG Section A addresses Transition requirements and procedures. Each Principal Maintenance Inspector prepares a letter to 14 CFR part 145 certificate holders located in France, Germany and Ireland. The FAA Eastern Region Coordinator provides a sample transition letter to the International Field Office. This sample letter is used to tailor correspondence with the repair stations. The letter advises the respective repair station to contact its local Aviation Authority inspector and advise him or her of the approximate timeframe when they intend to have the revised FAA supplement ready for Aviation Authority approval in accordance with Aviation Authority procedures. This process is complete

45 Understanding the U.S./EC Aviation Safety Agreement
Maintenance Annex Guidance Section B - Certification Process for U.S.‑Based Repair Stations Section B applies to U.S. Based Repair Stations

46 Understanding the U.S./EC Aviation Safety Agreement
Maintenance Annex Guidance Section C - Certification Process For EC Based Maintenance Organizations Section C applies to EC Based Repair Stations

47 MAG Section C Introduction
How an EASA approved maintenance organization located in an EC member state… … may qualify for FAA approval This Guidance details how an EASA approved Part-145 maintenance organization located in one of the EU member states listed in the Maintenance Annex Guidance (MAG) Section A, Appendix 1 and subject to the terms of the Bilateral Agreement (BA) and MAG concluded between the USA and Europe, may qualify to be approved in accordance with FAA CFR part 145. Note that while the Agreement is between the United States and the European Community, mention of the European Union, or EU, refers to the European Community, or EC. 47

48 Overview Certification Process for EC Based Maintenance Organizations
Section C Initial Certification Process Renewal Certification Process Change / Amendment Certification Process Revisions to the FAA Supplement Revocation, Suspension and Surrender Appeal and Conflict Resolution We will examine the parts of MAG Section C. They include: • Initial Certification Process • Renewal Certification Process • Change / Amendment Certification Process • Revisions to the FAA Supplement • Revocation, Suspension, and Surrender • Appeal and Conflict Resolution

49 Initial Certification Process
First Step: Determine if the applicant can show a need for an FAA Repair Station, as follows:

50 Show of Need Requirement
A letter or contract from a U. S. Operator, a Foreign Operator operating U.S. registered aircraft, a certified air agency or a distributor/leasing company that the maintenance is intended to be performed or traceable to a U.S.- registered aircraft or a foreign- registered aircraft operated under 14 CFR 121 or 135, or articles for use on those aircraft. The pertinent regulation, Title 14 Code of Federal Regulations (14 CFR) part (c)(1)(i)(ii)[1], states that the applicant for a repair station certificate must demonstrate a need so that it may work on U.S.- registered aircraft or articles. [1] (c) In addition to meeting the other applicable requirements for a repair station certificate and rating, an applicant for a repair station certificate and rating located outside the United States must meet the following requirements: (1) The applicant must show that the repair station certificate and/or rating is necessary for maintaining or altering the following: (i) U.S.-registered aircraft and articles for use on U.S.-registered aircraft, or (ii) Foreign-registered aircraft operated under the provisions of part 121 or part 135, and articles for use on these aircraft. The intent of the perceived need requirement included in the guidance was to provide for flexibility. The FAA recognized that contracts frequently move from repair station to repair station and inadvertently may cause a repair station to have a lapse in being able to meet the need requirement while new customers or contracts are being negotiated. The perceived need was not intended to relieve repair stations from being able to demonstrate or show traceability to maintenance and /or alterations being performed for a U.S. registered aircraft or a foreign registered aircraft operated under 14 CFR 121 or 135. 50

51 Show of Need Requirement
If the applicant can not demonstrate a need for FAA certification, do not proceed with the certification process until you are satisfied they meet the requirement. If the applicant can not demonstrate NEED, they are not eligible for FAA certification. This also applies to certificate renewal.

52 Initial Certification Process
To apply for a CFR part 145 repair station certificate under the provisions of the BA Maintenance Annex, an applicant Approved Maintenance Organization (AMO) must: Be located in a country that is part of this Bilateral Agreement (BA) (Listed in MAG Section A, Appendix 1) Have an EASA Part 145 approval Show a need to have an FAA certification Pay fees in accordance with 14 CFR part 187 The applicant must contact the Aviation Authority of the Member State in which the organizations principal place of business is located in order to start the certification process. The maintenance organization must: • Be located in a country that is part of this Bilateral Agreement • Have an EASA Part 145 approval • Show a need to have an FAA certification, and • Pay fees in accordance with 14 CFR part 187 Note that the Aviation Authority should inform the applicant that if a member of its management team has been involved in an enforcement action that resulted in the revocation of an FAA certificate, the FAA may not process the application at the FAA Administrator’s discretion under 14 CFR part 145 for a minimum of 12 months from the date of the certificate action. The applicant should be informed that all costs associated with FAA sampling inspections and independent inspections, including visits to Aviation Authorities for the purposes of auditing, will be charged to the AMO’s being inspected. Associated costs include at least travel, lodging, and inspector time. 52 MAG A, Appendix 1 52

53 Initial Certification Process
Upon initial inquiry from an applicant AMO: The Aviation Authority (AA) should provide the applicant: Copy of MAG Section C FAA Form (PASI) and (Application) The AA should also advise that the applicant: Submit an FAA Supplement to the AA. Provide a “statement of need” to the AA. Provide required documentation in the English language to the AA, which the AA will forward to the FAA. Ensure that the AMO does not have any outstanding findings of noncompliance from the AA. A key element in this application process is that the applicant shall submit a statement of need to perform maintenance or alteration/modification on aeronautical products subject to U.S. airworthiness regulations. The applicant AMO can substantiate this perceived need by including a statement from an operator of U.S. registered aircraft or a company that maintains or alters items to be installed on U.S. registered aircraft. The perceived need also can be established with documentation from a leasing company, a supplier, or a distributor for whom the applicant AMO can confirm in writing is doing business with operators of U.S. registered aircraft. 53 53

54 Initial Certification Process
After review of the guidance material (MAG) the applicant will submit the pre-application statement of intent (PASI) and the Vital Information System (VIS) data to the AA (Section C, Appendix 4) The AA will review submitted documents to insure proper completion, then forward to FAA for a precertification number. FAA will review the submitted documents. Upon satisfactory review, FAA will provide a pre-certification number to the AA. It is the applicants responsibility to complete the pre-application statement of intent and Vital Information Subsystem, or VIS data and submit these documents in the English language. Once the Aviation Authority reviews the submitted package and ensures it is complete, it should forward a copy to the responsible FAA office. Upon receipt of the information, the Certificate Holding District Office will obtain the pre-certification and final numbers to be forwarded to the Aviation Authority for distribution. The pre-certification number should be used for all correspondence regarding the application for tracking purposes. The information contained in the VIS data should be entered into VIS. Additional Guidance The actions of all three organizations pertain to the same form, FAA Form FAA VIS information is located in MAG Section C, Appendix 4 54 54

55 Initial Certification Process
The AA should notify the applicant of the pre-certification number and inform them it must be referenced in related correspondence to facilitate tracking. The AA should review the requirements for additional fixed locations or line stations and advise the applicant as necessary. The Aviation Authority should notify the applicant of the pre-certification number for inclusion on future correspondence. The Aviation Authority may also give the AMO the final number and advise the AMO that it should only be used for the creation of forms and the supplement to support the final certification. In cases where there are additional fixed locations or line stations located in another EU Member State subject to the MAG, the Aviation Authority responsible for the organization where the principle place of business is located must ensure that the FAA Annex to Form 6 is submitted to the FAA. Line stations located in an EU Member State not part of this agreement must be audited by an Aviation Authority listed in MAG Section A, Appendix 1. Copies of the FAA annex to Form 6 for each location must be forwarded to the FAA. Note that EASA uses the term Line Stations, while the FAA uses the term Line Maintenance Authorization in relation to CFR part This note is to advise the reader that these terms are synonymous when applied under the terms of the agreement. MAG A, Appendix 1 Note: EASA uses the term Line Stations, while the FAA uses the term Line Maintenance Authorization in relation to CFR part 145 55 55

56 Initial Certification Process
Applicant should submit a formal application package to The AA with the following enclosures: FAA Form Block 4 must include a list of maintenance functions contracted to an outside agency A written statement of need An FAA supplement to the Maintenance Organization Exposition (MOE) A letter that employees have Hazardous Materials (Hazmat) training The formal application package submitted by the AMO to the Aviation Authority must contain the items presented here. Note that the Aviation Authority and the FAA should be aware that the list of maintenance functions contracted to an outside agency identified in block 4 of FAA Form , the Application for Repair Station Certificate and/or Rating, meets the FAA special conditions. A letter certifying that its employees have been trained in the transportation of dangerous goods in accordance with ICAO standards is required if the AMO is involved with the transport of dangerous goods. If the AMO is involved in the loading of dangerous goods on a US air carrier’s aircraft, the AMO’s employees must be trained in accordance with the air carrier’s Hazardous materials training program. Additional AMO fixed locations must be located within an EU Member State listed in MAG Section A, Appendix 1. The FAA will only recognize line stations located in an EU member state when that line station is under the direct surveillance of an Aviation Authority listed in MAG Section A, Appendix 1 and holds an EASA line station approval. The AMO manager or director of quality control or equivalent position should be identified in the VIS. 56

57 Initial Certification Process
Formal Application Package continued A list of addresses for each additional fixed location, if applicable. A list of all line stations within the EU member states where the FAA certificate will be used. The name of the person identified as the manager or director of quality control. Copy of EASA Form 3 Approval certificate and scope of work

58 Initial Certification Process
AA Review of Formal Application Package Review application package for completeness and correctness Review the proposed FAA supplement Review submitted information and documentation for acceptability Conduct an oversight audit using the FAA Annex to EASA Form 6 Notify the applicant of any required fees for the performance of this audit Address deficiencies in an AMO’s application package The Aviation Authority must review the proposed FAA Supplement and compare it to the example FAA Supplement in Section C, Appendix 3. The supplement does not have to be identical to the example but should reflect the intent of the example. If the information including the FAA Supplement that the AMO submits is acceptable, the Aviation Authority should conduct an oversight audit for compliance with Aviation Authority requirements and FAA Special Conditions using the FAA Annex to EASA Form 6. If the Aviation Authority has recently completed a successful oversight audit of the AMO, the guidance in MAG Section C, Part I, paragraph 8 should be followed. If the Aviation Authority discovers deficiencies in an AMO’s application package, the Aviation Authority may process findings in accordance with EASA requirements. Completion of corrective actions shall not exceed 6 months. If the applicant fails to correct the deficiencies on time, the Aviation Authority will terminate the application process and notify the FAA. In the event of unusual circumstances, the Aviation Authority will notify the FAA which may agree to extend the period upon mutual agreement for a reasonable period of time, if the applicant demonstrates an ability and willingness to correct the noted deficiencies. If corrective action must be taken, the applicant should notify the Aviation Authority in writing when all deficiencies have been corrected. The FAA cannot issue a certificate with open deficiencies. A copy of the application package must be retained by the Aviation Authority in accordance with EASA requirements and made available to the FAA on request. 58 58

59 Initial Certification Process
The AA will send to the FAA: FAA Form with Blocks 7, 8 and 9 completed A copy of the completed FAA Annex to EASA Form 6 A list of additional fixed locations (OpSpecs A101), if applicable A list of line stations authorizations as applicable (OpSpecs D107) A letter certifying that employees have been trained in dangerous goods (Hazmat) if required A copy of the EASA AMO certificate and scope of work When the applicant completes all the requirements, the Aviation Authority will complete Blocks 7, 8 and 9 of FAA Form This also approves the list of functions to be contracted to an Contract maintenance provider on behalf of the FAA. The EASA Form 6 will include the AMO and each additional fixed location and line station authorization that will use the CFR part 145 privileges including the Aviation Authority signed recommendation. If applicable, a list of fixed locations and line station authorizations will be provided to the FAA for listing on the Operations Specifications. Note - The FAA Annex to EASA Form 6 may be in the national language. The Aviation Authority will submit the applicant’s letter certifying that its employees have been trained in the transportation of dangerous goods. Note: The written statement of need and FAA supplement to the MOE in English are not required to be submitted to the FAA but must be retained at the Aviation Authority office in the applicants file and made available to the FAA on request. 59 59

60 Initial Certification Process
FAA will Review the documents submitted by the AA to ensure the package is complete Review FAA Annex to EASA Form 6 and ensure there are no open findings Ensure the information contained in the FAA Vital Information System (VIS) is complete and updated Verify any special authorizations and limitations that need to be entered in paragraph A004 of the Operations Specifications The FAA reviews documents in the certification package to ensure no open findings are noted on FAA Annex to EASA Form 6 or any of the documents submitted to the FAA. The FAA recognizes that several languages are involved in Bilateral Agreement and Maintenance Annex programs and minor discrepancies may occasionally be noted. These minor discrepancies must be discussed with the Aviation Authority, but must not delay the issuance of the FAA certificate. Note that when the applicant’s FAA Supplement is included in the maintenance organization exposition which has been approved by the Aviation Authority, the FAA considers the manual acceptable in accordance. Also note that at this time the FAA Inspector should verify if there are any special authorizations and limitations, such as electronic record keeping systems for example, that will need to be entered in paragraph A004 of the Operations Specifications. When all of the application documentation is reviewed and the appropriate fees have been paid, the FAA Inspector will prepare the Air Agency certificate which will include the FAA rating. The FAA Operations Specifications will include the EASA certificate number located on EASA Form 3, and the current date. There is no need to include FAA ratings on the Operations Specifications except in special circumstances discussed in MAG Section A, Appendix 7. NOTE: The principle inspector should ensure that the ratings of the EASA Part-145 certificate are consistent with the CFR part 145 certificate ratings. The FAA will forward a copy of the operations specifications with a cover letter requesting the appropriate AMO official sign and return a copy to the FAA Certificate Holding District Office by mail or fax. 60 MAG A, Appendix 7 60

61 Initial Certification Process
FAA will invoice the AMO as required by 14 CFR Part 187 and FAA Advisory Circular 187. Upon payment of the appropriate fee, the following will be accomplished: 1. FAA will complete Block-10 of FAA Form 2. FAA will Forward FAA Form (Air Agency Certificate) and Operations Specifications with the appropriate ratings to the AMO FAA will identify a single point of contact for each AA to send an electronic copy of the FAA Certificate and Operations Specifications. This will facilitate local recordkeeping, archiving, tracking, etc. FAA will also send an electronic copy of the documents to the AMO, and will put a hard-copy in the post.

62 Initial Certification Process
AMO Responsibility Sign and date the Operation Specifications and return a signed copy to the FAA Frankfurt IFO. Provide the AA with a signed copy of the operations specification and the certificate For FAA Principal Inspectors, PTRS information and administrative information can be found in FAA Order AMO should consult with th AA to determine if an electronic copy is acceptable. 62 62

63 FAA Supplement Overview / Contents
List of Effective Pages Revision Procedures Introduction Accountable Managers Statement Extent of Approval Summary of Management and Quality Systems Approval For Return To Service And Maintenance, Alteration, Reporting Of Unairworthy Conditions To The FAA Additional operating locations Contracting/Subcontracting Contract Maintenance Provider (CMP) Major Repairs and Major Alterations Compliance with U.S. Air Carrier Continuous Airworthiness Maintenance Program Compliance with Manufacturers’ Maintenance Manuals Or Instructions For Continued Airworthiness (ICA) Qualifications of Personnel (English Language Requirement) Forms Work away from a fixed location This is a sample table of contents of areas that may be covered in the supplement.

64 FAA Supplement - Revision Procedures
Procedures the organization will use to ensure that the FAA Supplement remains current Identifies by title, the person responsible for revising the FAA Supplement Copies of revisions are provided to the AA Incorporates revisions to the FAA Supplement into the quality monitoring system The revision procedures section of the FAA supplement describes how the organization will ensure that the Supplement remains current. It should identify, by title, the person responsible for revising the Supplement. It also should describe the procedures the organization will use to ensure that copies of any revisions are provided to the Aviation Authority before implementation. The FAA requires that at least one copy be retained by the Aviation Authority. All revisions must be incorporated into the internal quality audit system or quality monitoring system. MAG Section C: Appendix 3 – Example FAA Supplement

65 FAA Certificate Renewal Process
Applicant Action Overview Apply to AA for repair station certificate renewal with FAA Form Follow required time frames for application and renewal package submission (60-90 days before expiration) Initial certification is valid for 12-months. FAA certificate may be renewed for up to 24 months thereafter. The applicant is required to apply for renewal of its repair station certificate 12 months after the initial certification and every 24 months thereafter. The renewal package should be submitted to the Aviation Authority no less than 60 days and no more than 90 days before the AMOs current certificate expires. Note that if the FAA has not received the application for renewal at least 30 days before the certificate expiration date, the AMO must follow the initial certification process. 65 65

66 FAA Certificate Renewal Process
Renewal package content requirements FAA Form , Application for Repair Station Certificate and/or Rating Statement of Continued Need An updated FAA Supplement to the MOE (if required) Letter certifying that employees have been trained in dangerous goods (Hazmat) if required Any changes to the VIS elements The renewal package must contain: • A new FAA Form application for each location • Documentation that demonstrates continued need • Updated FAA Supplement to the MOE that reflects any changes to procedures • An updated letter certifying that its employees have been trained in the transportation of dangerous goods, in accordance with ICAO standards. • Any changes made that affect the VIS elements described in Appendix 4. 66 66

67 FAA Certificate Renewal Process
For AMOs that have Line Stations within the EU and/or Additional fixed locations within the EU: The AA must provide recommendations on a separate FAA Annex to EASA Form 6 for each location. A repair station may have additional fixed locations without certificating each facility as a stand alone or satellite repair station. For AMOs that have line stations and/or additional fixed locations under one certificate located in another EU Member State subject to the MAG and listed on FAA operation specification A101 and/or D107, the Aviation Authority must provide their recommendation for each location on a completed FAA Annex to EASA Form 6 as part of the renewal process. An FAA Annex to EASA Form 6 for each location must be forwarded to the FAA. Those line stations located in an EU Member State not subject to this agreement must be audited by an Aviation Authority who is part of the Agreement. The Aviation Authority where the certificate is held will collect the FAA Annex to EASA Form 6 for each location and forward a copy to the FAA. The renewal package must also contain the addresses of all additional fixed locations within an EU Member State listed in the MAG. This also applies to the addresses of line stations authorizations, if any, and the name of the air carrier or operator of the US registered aircraft. Additional Guidance The AA responsible for the principal base of operations must obtain all required documentation. MAG C, I.6 & MAG C, I.7.5 – I.7.6 (Information for additional fixed locations and line station authorizations) 67 67

68 FAA Certificate Renewal Process
Aviation Authority review renewal package content: FAA Form (Ensure block 4 is current and correct) Statement of continued need Completed FAA Annex to EASA Form 6 AA Acceptance of the FAA supplement AMO application deficiencies addressed. Level 1 and Level 2 findings addressed Certificate renewal recommended as applicable. The Aviation Authority should review the renewal package and FAA Form They will specifically look for a revision to Block 4 regarding functions contracted to an Contract maintenance provider. If a review of the AMO’s statement fails to establish continuing need, the Aviation Authority will advise the applicant that the FAA will renew the AMO’s certificate based on its previous statement. If the AMO is still unable to show continuing need at the time of its next renewal, the FAA may require the repair station to adjust their capabilities list or rating accordingly. The Aviation Authority ensures the safe operation of the certificate holder with regards to EASA Part-145 and FAA Special Conditions through routine surveillance and verifies the AMO’s compliance with the FAA Supplement. As part of the renewal process, the Aviation Authority completes an FAA Annex to EASA Form 6. 68 68

69 FAA Certificate Renewal Process
Aviation Authority Submits the following documents to the FAA: A completed FAA Form A copy of the AMO’s amended AA certificate and limitation document FAA Form application for each new line station or additional facility detailing additions or deletions Completed copy of the FAA Annex to EASA Form 6 for each location The Aviation Authority will submit the documents to the FAA at least 30 days before the expiration date of the certificate. Note: The AA responsible for the principal place of business for the applicant organization operations must obtain all required documentation 69 69

70 FAA Certificate Renewal Process
Aviation Authority Submits the following documents to the FAA (Continued): Letter certifying that employees have been trained in dangerous goods (Hazmat) if required Changes made to the repair station that affect the VIS elements.

71 FAA Certificate Renewal Process
Frankfurt IFO will review the documentation submitted by the Aviation Authority If incomplete or for minor deficiencies (typographical or grammatical errors or lack of clarity), FAA will contact the AA for resolution. For major deficiencies, FAA will notify the AA in writing. When all documentation meets the requirements, and fees are paid: Complete Block 10 of FAA Form Prepare and send Air Agency Certificate and Operations Specifications (not to exceed EASA ratings). The Certificate Holding District Office reviews the documentation submitted by the Aviation Authority to determine whether the appropriate information has been entered and is acceptable. Any outstanding issues must include an Aviation Authority approved corrective action plan. If the documentation contains major deficiencies, the FAA will notify the Aviation Authority. All major deficiencies must be addressed before the certificate expiration date. When the application is found to meet the requirements of the maintenance agreement and the AMO has paid the appropriate fee, the FAA Inspector will complete block 10 of FAA Form The FAA will send the Air Agency Certificate and the Repair Station Operations Specifications to the AMO. The FAA will forward a copy of the Operations Specifications with a cover letter requesting the AMO sign and return a copy to the FAA Certificate Holding District Office. 71 FAA Form MAG A, Appendix 7 71

72 FAA Certificate Renewal Process
AMO Responsibility Sign and date the Operation Specifications and return a signed copy to the FAA Frankfurt IFO. Provide the AA with a signed copy of the operations specification and the certificate For FAA Principal Inspectors, PTRS information and administrative information can be found in FAA Order AMO should consult with th AA to determine if an electronic copy is acceptable. 72 72

73 Significant Findings Noted Between Certificate Renewals
AA notification to the FAA of significant findings against an FAA approved AMO. FAA acts on notification that an EASA Approval has been revoked or suspended by an AA FAA acts on notification of a limitation imposed on an EASA Form 3, approval schedule. Action is made against an additional fixed location or Line Station. FAA notification to the AA of action taken If significant findings are noted between certificate renewals, both the Aviation Authority and the FAA have to take specific actions. When an Aviation Authority raises significant safety related issues against an FAA approved AMO which will revoke, limit or suspend the EASA approval, the Aviation Authority shall complete an FAA Annex to EASA Form 6 non recommendation and immediately forward the form to the FAA for action. On notification that a certificate has been revoked or suspended, the FAA Certificate Holding District Office will take action in accordance with Part V, Revocation, Suspension, and Surrender. The appropriate action will be taken by the Certificate Holding District Office when EASA has imposed limitations with regard to amending FAA Operations Specifications. The FAA should ensure the new Operations Specifications are modified to show changes to an additional fixed location or Line Station authorization. The Certificate Holding District Office will notify the Aviation Authority of the action taken by forwarding a copy of the revised Operations Specifications. MAG C, 6.0, page 122 73 73

74 Change/Amendment Certification Process
Situations that require the AMO to apply for a change in a repair station certificate: A request to add or amend a rating Change in the housing and facilities A change in ownership or name change Additional fixed locations or line station authorizations MAG Section C Part 3, Change / Amendment Certification Process addresses when an AMO applies for a change in a repair station certificate using FAA application Form Be advised that under the Agreement, an applicant may not apply for a change or amended certificate without first having appropriate EASA ratings on EASA Form 3. Situations that require the AMO to apply for a change in a repair station certificate include: • Changes in the AMO’s housing and/or facilities • If the holder of a repair station certificate sells or transfers its assets, the new owner must apply for an amended certificate. • Name changes also require an application and certificate change. • Addition or deletion of additional fixed locations or line station authorizations.

75 Change/Amendment Certification Process.
AMO has the following responsibility Forward a completed FAA Form to the AA Documentation submitted should be available in the English language Submit a duplicate document in the national language if required by the AA Submit changes to the AMO’s FAA Supplement to the AA Provide updated FAA VIS information. Reference: MAG Section C, Appendix 4 These are the procedures that should be followed concerning the AMO’s responsibilities for a change/amendment certification process. MAG C, Appendix 4 75

76 Change/Amendment Certification Process
Aviation Authority take the following action. Inform the FAA of all proposed changes to the location, housing or facilities that would affect the current FAA certificate May recommend, after consulting the FAA, that the AMO continue operations under CFR part 145 while changes are being made The Aviation Authority will immediately inform the FAA of all proposed changes to the location, housing, or facilities of the repair station that would affect the conditions of the current certificate. After discussions with the FAA, the Aviation Authority may recommend that the AMO be permitted to continue operating as a CFR part 145 repair station while the proposed changes are being made. If the AMO requests a change involving rating or facilities, the Aviation Authority will conduct an on-site review. The Aviation Authority will review the documentation submitted by the AMO and will forward them to the FAA, if satisfactory. These documents must be in the English language. Personnel training in dangerous goods and hazardous materials must meet the required guidance including the certifying letter.

77 Change/Amendment Certification Process
Aviation Authority (AA) Conduct an on-site review of the AMO for requests involving a change in ratings or facilities, and review and forward to the FAA submitted documentation including: FAA Form The AMO’s amended EASA certificate and limitation document/Approval Schedule The FAA Annex to Form 6 including a signed recommendation If the AA discovers deficiencies in an AMO’s application for renewal or after conducting an oversight audit, the AA will follow the corrective action requirements of EASA Part‑145, Section B. If the AA finds the written plan for corrective action is acceptable, the AA will attach the plan to the FAA Annex to Form 6. Once the AA has found the renewal to be acceptable, the appropriate recommending AA inspector/official will complete Blocks 7, 8 and 9 of FAA Form 8310‑3. The AA should review the renewal package and FAA Form 8310‑3 specifically for a revision to Block 4 regarding functions contracted to an outsource maintenance provider.

78 Change/Amendment Certification Process
Aviation Authority (AA) Conduct an on-site review of the AMO for requests involving a change in ratings or facilities, and review and forward to the FAA submitted documentation continued: A list of line station locations and/or additional fixed locations. Reference: MAG Section C Part I Para. 6 Updated letter certifying that employees have been trained in dangerous goods (Hazmat) if required

79 Change/Amendment Certification Process
Organization Action FAA Reviews AMO’s documentation to ensure that it is complete Forwards Certificate and OpSpecs to the AMO Responsibility AMO Signs and dates the OpSpecs, sends copies to the FAA The FAA Certificate Holding District Office reviews the documentation for completeness and forwards the Air Agency Certificate and the Operations Specifications to the AMO. The AMO signs and dates the Operation Specifications and returns a copy to the Certificate Holding District Office. The FAA provides the Aviation Authority with signed copies of the Certificate and the Operation Specifications, and retains the appropriate information in the office file. The Aviation Authority should retain copies of all the documents supporting the change. Action FAA Provides AA with a signed copy of the OpSpecs and the Certificate 79

80 Revisions to the FAA Supplement
Organization Action AA Retains copies of all documents supporting the change Responsibility Submits revisions to their FAA Supplement to the AA for review and acceptance before implementation in accordance with AA procedures AMO Action Part 4 of MAG Section C addresses AMO revisions to the FAA Supplement. For an AMO, revisions that reflect changed procedures, but do not change the nature of the AMO’s FAA CFR part 145 certificate or ratings must be submitted to the Aviation Authority for review before implementation. Aviation Authority procedures require the AMO to submit revisions to its maintenance organization exposition. These revisions are considered accepted by the FAA unless notified otherwise by the Aviation Authority or the FAA. If the Aviation Authority finds the nature of the changes do not meet the FAA Special Conditions, the Aviation Authority will reject the revision and advise the repair station as soon as possible in writing. AA Reject the revision and advise the repair station as soon as possible in writing if changes do not meet the FAA Special Conditions 80

81 Revocation, Suspension, and Surrender
A CFR part 145 certificate may be suspended or revoked by the FAA if the certificate becomes invalid under the conditions specified in the Agreement, Annex 2 or MAG The FAA will notify the holder of an CFR part 145 certificate in writing about any suspension or revocation. The FAA will also notify the appropriate AA of the action Where a company surrenders its FAA certificate to the AA, then the AA should inform the FAA by mail and attach the FAA certificate This part addresses the revocation, suspension, and surrender of a CFR part 145 certificate. In the event of a revocation or suspension by the Aviation Authority of an EASA Approved Maintenance Organization, the Certificate Holding District Office shall investigate and take appropriate action. Any FAA certificate action involving suspension or revocation will be carried out by the Certificate Holding District Office in accordance with FAA Order 2150 procedures. It should be noted that the certificate can also be suspended or revoked in the event of non-payment of FAA required fees.

82 Appeal and Conflict Resolution
If the Repair Station Certificate holder does not accept the suspension or revocation of its Part 145 Certificate, persons may appeal in accordance with Title 14 Code of Regulations Part 13 However, There is no right of appeal to the FAA when the Aviation Authority revokes or limits any EASA Part 145 maintenance organization approval Reference: MAG Section VI, Page 127. MAG Section C, Part 6 addresses the right of appeal in the event of CFR part 145 suspension or revocation.

83 Why is Conflict Resolution So Important?
Both governments are committed to a smoothly functioning Agreement The FAA is committed to continuous improvement. This extends to our international relationships as well as domestic ones The FAA’s stakeholders, US, EC and industry expect to benefit from the reciprocal acceptance under this Agreement With the ink barely dried on the new aviation safety agreement, it may seem strange to be talking about conflict. However in our professional relationships, differences of opinion are natural. This bilateral agreement has built-in mechanisms for the resolution of differences at both the technical and political levels. As you can see on the slide, the U.S. government, our own AVS organization, and our stakeholders expect that we will work to address conflict situations. Conflict resolution begins with each of us.

84 Where Can I Find The Agreement?
The Agreement, Annexes and Maintenance Annex Guidance You may download copies of the bilateral agreements from these FAA websites.

85 Where Can I Find Bilateral Agreements?
EASA - Bilateral Agreement, Annexes and Maintenance Annex Guidance:

86 Maintenance Annex Guidance
Appendix 3 Example of FAA Supplement We’ve covered the parts of MAG Section C that addressed the certification processes. Now let’s look at MAG Section C Appendix 3, Example FAA supplement.

87 Agreement/Annex 2/Maintenance “Special Conditions”
The Special Conditions contained in Annex 2, Appendix 1, have been developed to eliminate duplicate activities The FAA, EASA and AA’s contained in Annex 2, Appendix 2, have numerous duplicated elements in their respective inspection, surveillance, evaluation, and certification programs The Special Conditions in Appendix 1 of the MA were developed to eliminate duplicate activities. The Special Conditions in Appendix 1 should not be confused with the Supplement which is used for Repair Stations in Appendix 3. 87 87

88 Understanding the FAA Supplement to an MOE
This example FAA Supplement gives guidance on the subjects which need to be addressed and developed into working procedures to ensure compliance with FAA Special Conditions The Supplement must therefore be customized to satisfy the specific Aviation Maintenance Organization In this section we will discuss the content of the Example FAA supplement to a Maintenance Organisation Exposition found in Appendix 3 of MAG Section C. The cover page of the FAA Supplement should include the intent of the following statement: • The Aviation Authority may require the supplement to be submitted in duplicate: one in English for FAA sampling, the second in the national language for Aviation Authority review. In either case, the Approved Maintenance Organization, or AMO, must always retain at its primary place of operation a current copy of this FAA Supplement in English and provide it to the FAA upon request. • This supplement is required for European based FAA repair stations covered under the Agreement. • The member countries’ Aviation Authority is responsible for ensuring that the FAA supplement meets the requirements of this sample supplement. Note: If any items identified in the Table of Contents for this supplement exist in English in the maintenance organization exposition, then reference to the appropriate maintenance organization exposition manual, section and pages is all that is needed to meet the supplement requirements. MAG Section C: Appendix 3 – Example FAA Supplement

89 Supplement Overview / Contents
List of Effective Pages Revision Procedures Introduction Accountable Managers Statement Extent of Approval Summary of Management and Quality Systems Approval For Return To Service And Maintenance, Alteration, Reporting Of Unairworthy Conditions To The FAA Additional operating locations Contracting/Subcontracting Contract Maintenance Provider (CMP) Major Repairs and Major Alterations Compliance with U.S. Air Carrier Continuous Airworthiness Maintenance Program Compliance with Manufacturers’ Maintenance Manuals Or Instructions For Continued Airworthiness (ICA) Qualifications of Personnel (English Language Requirement) Forms Work away from a fixed location This is a sample table of contents of areas that may be covered in the supplement. The rest of this lesson will examine them in more detail.

90 List of Effective Pages
A list of the sections it contains The page number of each section The revision dates of each section This screen is self-explanatory.

91 Revision Procedures Procedures the organization will use to ensure that the FAA Supplement remains current Identifies by title, the person responsible for revising the FAA Supplement Copies of revisions are provided to the AA Incorporates revisions to the FAA Supplement into the quality monitoring system The revision procedures section of the FAA supplement describes how the organization will ensure that the Supplement remains current. It should identify, by title, the person responsible for revising the Supplement. It also should describe the procedures the organization will use to ensure that copies of any revisions are provided to the Aviation Authority before implementation. The FAA requires that at least one copy be retained by the Aviation Authority. All revisions must be incorporated into the internal quality audit system or quality monitoring system.

92 Introduction Indicate that the organization is performing work under the terms of the Agreement State what the Maintenance Annex permits concerning certification and renewal as a foreign repair station under 14 CFR part 145 Addresses the purpose of the FAA Supplement The FAA Supplement describes the methods and procedures the organization uses to ensure FAA Special Conditions are met It is important that the AMO prepare their Supplement Introduction in accordance with the sample supplement because it demonstrates understanding of the compliance requirements. This supplement, along with other chapters in the approved Maintenance Organisation Exposition defines the procedures in accordance with the applicable regulations.

93 Accountable Manager’s Statement
The accountable manager is the individual responsible for the organization’s compliance with EASA regulations and requirements and the FAA Special Conditions. The EASA accountable manager may also be the FAA accountable manager Accountable managers must sign the FAA statement Statement must be reissued and signed each time an accountable manager is changed The accountable manager is the individual responsible for the organization’s compliance with 14 CFR. Such compliance is demonstrated by adhering to EASA regulations, requirements and associated material, and the FAA Special Conditions in the Maintenance Annex. This section must contain the signed statement by the accountable manager. The signed statement agrees that the organization will comply with the conditions specified in the FAA Supplement. The accountable manager’s statement is accepted in lieu of the letter of compliance. Note: The Accountable Managers statement must reflect the intent of the sample statement in the supplement.

94 Extent of Approval The extent of FAA approval will not exceed the ratings and scope of work permitted under EASA and AA regulations and requirements. Occasions when EASA ratings exceed FAA ratings Issuance of limited rating for specialized service The Extent of Approval section of the Supplement states that FAA approval will not exceed the ratings and scope of work permitted under EASA requirements. The extent of FAA approval also will not exceed the scope of approval set forth in the organization’s 14 CFR part 145 repair station certificate and Operation Specifications. There are some occasions when the EASA rating may exceed the FAA rating; in these cases the FAA will add an additional limited rating to cover the extent of the EASA rating. When the FAA issues a specialized services rating, the AMO is required to have FAA approved process specifications. The process specifications require adherence to procedures the AMO will use to ensure all work performed under the provisions of specialized services rating is done in accordance with FAA approved data. Only FAA approved processes will be used on U.S. registered aircraft or products intended for installation on U.S. registered aircraft.

95 Extent of Approval Supplement procedures for using a capabilities list (CL) CL must include an introduction that references a document identifying an article by make, model or other nomenclature Components or subassemblies identified on the CL do not require listing of their individual parts Use the AMO’s quality monitoring system for revisions to the CL The Extent of Approval section of the Supplement may also contain a capabilities list, the elements of which are described in this section. A capabilities list refers to a limitations document that identifies articles that the AMO is authorized to maintain. These articles are identified by make, model, or other manufacturer’s nomenclature. After the Aviation Authority has approved the AMO’s quality monitoring system, the AMO can use these procedures for revisions to a capabilities list.

96 Summary of the Quality System
The summary should contain an overview of how the AMO will include FAA Special Conditions in its quality monitoring system The primary concern is that the FAA special conditions are identified and included in the AMO’s quality monitoring system audits of each location This section of the Supplement should include a version in English of the organization’s management system and a summary of its quality system covering the main site, additional fixed locations, and line maintenance authorizations as appropriate. The primary FAA concern here is that the FAA special conditions are identified and included in the AMO’s quality monitoring system audits of each location.

97 Approval for Return to Service and Maintenance, Alteration and Modification Records
Return to service of a U.S. registered aircraft Acceptable release statements for articles that meet FAA special conditions and EASA Form 1 dual release Acceptability of components In this section of the Supplement, the AMO defines its return to service procedures. Procedures for return to service of a U.S. registered aircraft must include a description of work performed, the date of completion of the work, signature of the person authorized by the repair station to return the aircraft to service, FAA certificate numbers, additional requirements specified by the operator and the specific recordkeeping requirements for major repairs and major alterations. Procedures for return to service of articles describe acceptable release statements that meet the FAA Special Conditions on EASA Form 1 with a dual release. Note that 14 CFR parts 43 and 145 do not restrict an AMO from only using one form for return to service. The regulations and the Maintenance Annex allow an FAA certificated facility to provide their customer with the customers requested document, provided that document meets 14 CFR requirements. For component parts or articles, use of a dual release EASA Form 1 for AMOs in countries listed in Appendix 1 of MAG Section A should be used. This section should describe procedures regarding the acceptability of components authorized for use during maintenance. Procedures should meet the intent of MAG Section C, Paragraph 7(c). This paragraph identifies the new and used components that may be fitted during maintenance that have the proper traceability.

98 Reporting of Unairworthy Conditions to the FAA
The AMO must have procedures to: Report a malfunction or defect Report suspected unapproved parts This section of the Supplement should explain the procedures the organization will use to submit a Malfunction or Defect Report in a form and manner acceptable to the FAA in English. EC Annex 2, Section meets the Intent of the SUPs program when a copy of the report is forwarded to the FAA in English.

99 Additional Operating Locations
Additional fixed locations within the EU Member States Line Stations Authorization located within the European Community If the AMO has additional fixed locations located in an EU Member State listed in Appendix 1 of MAG Section A, and operating under one Aviation Authority approval certificate, the sites can operate under one FAA certificate and Operation Specifications. The AMO may have line stations located within the European Community and operating under one EASA part 145 certificate that provide services for operators of US registered aircraft. If so, the FAA will recognize those line stations that are listed on FAA Operations Specifications and are located within the European Community. Note that MAG Section A requires that line stations located in a European Community member state that is not listed in Appendix 1 may be accepted provided surveillance is performed by an Aviation Authority that is included in the agreement. This section of the supplement must address the procedures the AMO will use to ensure each additional fixed location and/or line station operates under the same maintenance organization exposition and FAA Supplement as the parent facility. The procedure must also demonstrate how each separate additional fixed location and/or line station is under the full control of the parent facility and its quality monitoring system.

100 Additional Operating Locations
Work away from the principle base of operation (principle place of business) Procedures to ensure compliance with the MAG How repair station will perform maintenance on a U.S. registered article inside the territories of the United States Performing work away from station for a one time special circumstance or recurring basis Work away from station for extended periods This subsection describes the procedures for conducting work away from the repair station to ensure compliance with the MAG. The procedures should address how a repair station will perform work at a place other than its fixed location when the occasion or the need arises by moving material, equipment, and technical personnel to perform specific maintenance functions. This process cannot be used to establish a permanent location. When performing maintenance on a U.S. registered aircraft or article located inside the territories of the United States, the repair station must also have procedures in this section of the supplement that describe how the repair station will comply with the U.S. operator’s requirements including its drug and alcohol program. If the repair station manual does not have a written procedure for work away from station, then the repair station must notify the FAA in advance of doing the work. If it has procedures in the FAA Supplement, the FAA will issue Operations Specification D100. Continuous operation at a permanent facility other than the repair station’s fixed location must not occur without the appropriate authorization.

101 Contracting/Subcontracting Maintenance Provider (CMP)
3 Elements: Quarterly Utilization Report QUR (This requirement is being removed, revision initiated) List of Contractor / CMP Qualifying and Auditing CMP There are 3 elements to the contracting and sub-contracting section referred to as the Contracting/Subcontracting Maintenance Provider provisions of the MAG. The AMO supplement must have a procedure to submit a quarterly utilization report that identifies the top 10 contracting/subcontracting maintenance providers directly to the FAA on AC Form Note that repair stations that normally do not Contract maintenance may be relieved from filing a quarterly utilization report. However, the FAA Principal Inspector will make this determination based on the record for that repair station in the Vital Information Subsystem. The FAA recognizes EASA Part-145 requirements for the maintenance organization exposition to contain a list of all contracting maintenance providers used by the AMO and approved by the Aviation Authority as part of the maintenance organization exposition. The list contains the name, address, certificate and rating if applicable. The list of contracting maintenance providers must also be made available to the FAA in the English language on request. The FAA recognizes the EASA Part-145 quality monitoring system and requirements for qualifying and auditing of contracting maintenance providers when the quality monitoring system includes the FAA special conditions as described in MAG Section C, Appendix 3, paragraph 10c.

102 Major Repairs and Major Alterations
Automatically approved data Procedures the AMO uses to ensure data is approved Determining when approved data is required Obtaining FAA approved data for major repairs and alterations Forms used All procedures shall ensure English version of FAA Form 337 is provided All repair design data approved by EASA and organizations or persons approved under EASA Part-21 for use on an U.S. registered aircraft and related articles are considered FAA approved in accordance with FAA Order This does not apply to critical component repair design data developed by organizations or persons which are not the Type Certificate or Supplemental Type Certificate holder. The procedures describe how the AMO will ensure that the data used to support major repairs and/or alterations on a U.S. customer’s product are approved. The AMO Supplement should describe the procedures the organization will use to determine when FAA approved data is required. It should also describe procedures for obtaining FAA approved data for major repairs and/or major alterations, and the forms used for recording them. The Supplement should include procedures the organization will follow to ensure that an English version of FAA Form 337 is provided directly to the FAA when required. Lesson 6 addressed the approved data issue, and additional guidance can be found in the FAA sample supplement.

103 Compliance with U.S. Air Carrier Continuous Airworthiness Maintenance Program (CAMP) or 14 CFR part 125 Operator Inspection Program How the AMO will comply with the Operator’s CAMP Procedures for Required Inspection Items (RII) This procedure describes how the AMO will comply with appropriate portions of a U.S. air carrier’s Continuous Airworthiness Maintenance Program or part 125 operator’s manual, manufacturers’ manuals, instructions for continued airworthiness, and the U.S. operator’s instructions to the AMO. This section of the supplement should also state that required inspection items identified in the U.S. Operator’s Manual must be accomplished by authorized personnel who are not involved in performing the work on the item to be inspected. The required inspection item qualified inspectors must work under the quality control system and/or inspection organization of the repair station. The repair station should state how the separation between maintenance and inspection is managed, and that the required inspection item findings cannot be overruled by the repair station organization or the maintenance department of the air carrier. Finally, the supplement should include the organization’s procedures to ensure that any person performing required inspection items is trained, qualified, and authorized by the air carrier for which the required inspection items are being conducted.

104 Compliance with Manufacturers’ Maintenance Manuals or ICA
How the AMO will comply with: Manufacturer’s maintenance manuals or ICA Converting technical data into a national language Operator’s work order and manual including deviations FAA Airworthiness Directives A description of how the organization will comply with manufacturer’s maintenance manuals or instructions for continued airworthiness should be included in the FAA supplement procedures. An English language copy of the technical data should be retained. However, the AMO may convert technical data such as instructions for continued airworthiness, manufacturer’s maintenance manuals or type certificate holder’s continued airworthiness data into internal documents such as work cards, work sheets, and shop travellers in a language other than English. All maintenance performed for a U.S. air carrier, including all major repairs and major alterations, must be recorded in accordance with that air carrier’s manual. In most cases, the Aviation Authority requires the AMO to comply with the operator’s work order and manual. The FAA recognizes the Aviation Authority’s requirement; therefore, a reference to the section of the manual that addresses this issue is acceptable, provided that section is written in English and can be made available to the FAA upon request. Any deviations will be coordinated with the air carrier to determine if the deviation requires FAA approval. The supplement should also explain how the organization will ensure it has all FAA Airworthiness Directives applicable to the work it is performing under the ratings it holds.

105 Qualifications of Personnel
The personnel requirements section should include: The name, title, telephone numbers, of person who will act as the organizations liaison The procedures the organization uses to ensure that its personnel have been trained The procedures the organization will use to ensure that required personnel can read, write, and understand English The title of each person authorized to review a final work package In addition to the personnel requirements presented here, the AMO procedures should ensure that personnel who are approving an aeronautical product for return to service, and are responsible for the supervision or final inspection of work on a U.S. registered aircraft or article to be installed on a U.S. registered aircraft can read, write, and understand English.

106 Forms The forms section should include copies of all forms referred to in the Supplement. EASA Form 1 FAA Form 337 FAA Form FAA Form FAA Form FAA Form FAA Annex to EASA Form 6 AC Form The forms section of the supplement should include copies of all forms referred to in the Supplement, for example, EASA Form 1, FAA Form , and FAA Form 337, including procedures for completing the forms. This concludes the presentation of Lesson 13: Certification Process for EU Based Maintenance Organizations. We’ve completed an overview of MAG Section C and it’s Appendix 3, the Example FAA Supplement. We’ve completed an overview of the Example FAA Supplement. The following screen will check your knowledge of an aspect of that Supplement.

107 Questions?


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