EASA’s Part-145 Regulation Simplified

EU Regulation 1321/2014 – Continuing Airworthiness

In my first article I gave an overview of constitutes . EU Regulation  stipulates all the legal requirements to be met to ensure that an aircraft is airworthy whilst in service. EU Regulation 1321/2014 has got five Annexes with the fifth Annex being split in four parts (Va, Vb, Vc and Vd).

In this article I will be focusing on the Second Annex of EU Regulation 1321/2014 – Annex II (Part – 145).

Annex II (Part-145)

Part-145 has been around way before the initial issue of EU Regulation 1321/2014 was published by EASA which was published to incorporate all the activities related to continuing airworthiness of civil aircraft under one cover regulation and in this re-structuring Annex II was included accordingly.

Part-145 “establishes the requirements to be met by an organization to qualify for the issue or continuation of an approval certificate for the maintenance of aircraft and components” – 145.A.10.

Basically, any organisation who wants to provide maintenance services or perform maintenance on in-service commercial or complex motored powered aircraft civil aircraft registered in EASA member state needs to be compliant and certified in accordance with EASA Part – 145 regulation by the competent airworthiness authorities before starting operations and once certified, these maintenance and repair organisations are obliged to remain compliant.

Before proceeding any further, I feel the need to highlight, for correctness sake, that in some specific cases, it may be possible to perform aircraft maintenance with a Part – CAO approval as defined in ANNEX Vd of EU Regulation 1321/2014, but this is beyond the scope of this article.

The below table extracted from EASA’s GM for Articles 3 and 4 of EU Regulation 1321/2014 gives a better understanding when a Part-CAO is enough and when a Part-145 is necessary.

Capability

In order to be certified, an aircraft maintenance and repair organisation needs to demonstrate it is capable of performing the intended scope of works.

But what is Capability?

In order to explain the concept of capability I will use an everyday example.

So, I have an easy question for you,

What do you need to have in place to cook and prepare a delicious meal for you, your family or friends ?

Well you need at least to have the following in place:

1. A Kitchen or a place where you can actually cook or prepare the meal.
2. A Cook or Chef to actually prepare the meal. In normal everyday situation the cook might be as well yourself if you like cooking.
3. You need the Ingredients to be able to prepare the intended meal.
4. You need to have the appliances, pots, oven and whatever kitchen tools and equipment might be necessary for you to prepare the meal.
5. Last but surely not least you need the recipe containing a set of instructions so as you can execute it to prepare the delicious meal you intend to serve to your family or friends.

Capability for an approved part-145 organisation can be defined In a very similar way i.e. the things / elements you need to have in place to be able to perform aircraft maintenance. And similarly to the above listed items that give you the capability to cook and prepare a delicious meal you need to have the following in place to be able to perform aircraft maintenance adequately and to the required and expected standards:

1. Facilities – Hangar Space, workshops and offices where your organisation intends to carry out aircraft maintenance.
2. Personnel – You need to have the right amount of competent qualified of employees that would be responsible for planning, performing, supervising, monitoring and administering the intended aircraft maintenance operations.
3. Tools and Equipment – The MRO need to ensure that all the tools (specific and non-specific), access platforms, genie booms, lifters, and docking structures are available so as to put the responsible personnel to accomplish maintenance to the required standards.
4. Parts – Aircraft maintenance require the availability of spare parts depending on the intended scope of work
5. Maintenance Data – Aircraft maintenance is always to be performed in accordance with the approved and applicable maintenance data containing all the necessary instructions so as the maintenance performed on aircraft is of the required quality, controlled, monitored and recorded.

EASA's Part-145 regulations regarding capability

Part-145 provides the requirements for each element constituting capability as follows:

1. Facilities: 145.A.25(Facility requirements)
2. Personnel: 145.A.30(Personnel requirements), 145.A.35(Certifying Staff and Support Staff), 145.A.37(Airworthiness Review Staff).
3. Tools and Equipment: 145.A.40(Equipment and Tools)
4. Parts: 145.A.42(Components)
5. Maintenance Data: 145.A.45 (Maintenance Data)

Now Part-145 regulations does not only include requirements related to capability, keep in mind that here we are not running a domestic kitchen but a commercial enterprise delivering maintenance services on in-service aircraft and therefore the planning, monitoring and control of the organisation’s  maintenance operations and capabilities is an equally important element required to maintain the high aviation safety standard we have today which is why EASA has the below additional requirements for an EASA Part-145 Maintenance Repair and Organisation:

• 145.A.47 – Production Planning.
• 145.A.48 - Performance of Maintenance.
• 145.A.50 – Certification of Maintenance.
• 145.A.65 – Maintenance Procedures.

Management System Requirements

What is a management system?

A management system is the way in which an organisation manages the interrelated parts of its business in order to achieve its objectives.

In simplified laymen terms it is an organised way of doing things in an organisation.

A strong and robust management system is a necessity to ensure that an organisation adapts, improves and is able to monitor and ensure its performance, compliance and maintenance of the required high aviation safety standards. When looking closely at Part – 145 regulations as published by EASA, one can sees similarities between Part-145's management system requirements  and standard management systems implemented in various other industries such as

• ISO 9001 – Quality management Systems.
• ISO 27001 – Information security Management System.

In addition to the above an important element of the management system of a Maintenance Repair and Organisation is a Safety Management System as required by ICAO’s ANNEX 19 Appendix 2 which is based on the fundamental principles of identifying, assessing and mitigating aviation safety risks proactively rather than reacting to incidents and accidents when and as they occur.

EASA’s approach is to harmonize all these different management system elements in one integrated and harmonized management system simply referred to as the “Management System”. EASA’s Part-145 Management System Requirements are stipulated as listed below:

• 145.A.60 Occurrence reporting.
• 145.A.85 Changes to the organisation.
• 145.A.95 Findings and observations.
• 145.A.120 Means of compliance.
• 145.A.155 Immediate reaction to a safety problem.
• 145.A.200 Management system.
• 145.A.200A Information security management system.
• 145.A.202 Internal safety reporting scheme.
• 145.A.205 Contracting and subcontracting.

The maintenance organisation exposition (MOE)

The purpose of the MOE is to specify the scope of work and show the organisation intends to comply with the Part-145 requirements and to provide all the necessary information, Maintenance procedures and Management procedures adopted by the maintenance and repair organisation.

The initial issue and any subsequent major changes of the MOE is to be approved by the competent airworthiness authority and the organisation is obliged to keep the MOE always updated.

EASA's Part – 145 requirements in relation to the MOE are stipulated in 145.A.70.

The maintenance and repair organisation's certification and privileges

Once the elements described above are in place the organisation needs to apply for a maintenance organisation certificate as stipulated in 145.A.15.

Once a maintenance organisation receives it certification by the competent airworthiness authority it will remain valid as stipulated in 145.A.90 as long as the organisation remains compliant with all the applicable Part – 145 requirements and as long as the airworthiness competent authority is granted access to the organisation as stipulated 145.A.140.

As long as the certification of the organisation is valid, it may exercise its privileges as stipulated in 145.A.75 in line with its approved scope of work as defined in accordance with the requirements set forth in 145.A.20.

Want to know more or gain deeper insight on EASA's Part-145 maintenance requirements?

Our Part-145 training course are designed to support aircraft maintenance professionals gain a deep understanding of the requirements set-forth in EU Regulation 1321/2014 ANNEX II (Part-145).

Look at our Part-145 regulation course below.