1. Release to service and eligible persons
Only natural or legal persons entitled to release to service an aircraft after maintenance in accordance with Part-M, Part-145 or Part-CAO are considered as an eligible installer responsible for the embodiment of a SC/SR when in compliance with applicable requirements.
For aircraft where there is no Part-66 licence applicable, the release to service of an aircraft after embodiment of a SC/SR is only possible by holders of an appropriate certifying staff qualification valid in a Member State (national qualification), with the following conditions:
− If the holder signs the release to service on behalf of an Approved Maintenance Organisation (AMO), this is valid for aircraft registered in any Member State.
− If the holder signs the release to service as an independent certifying staff (not on behalf of an AMO), this is only valid for aircraft registered in the Member State responsible for such certifying staff qualification.
Depending on its nature, for certain SCs/SRs, the Certification Specification CS-STAN might restrict the eligibility for the issuance of the release to service to certain persons.
Since the design of the SC/SR does not require specific approval, the natural or legal person releasing the aircraft to service after the embodiment of the change or repair takes the responsibility that the applicable Certification Specifications within CS-STAN are fulfilled while being in compliance with Part-M, Part-145 and/or Part-CAO and not in conflict with TC holders’ data. This includes responsibility in respect of an adequate design, the selection/manufacturing of suitable parts and their identification, documenting the change or repair, generation or amendment of aircraft manuals and instructions as needed, embodiment of the change/repair, releasing the aircraft to service and record-keeping.
2. Parts and appliances to be installed as part of a SC/SR
The design of the parts and appliances to be used in a SC/SR is considered a part of the change/repair, and, therefore, there is no need of a specific design approval. However, it is possible that for a particular SC, these Certification Specifications specifically require the use of parts and appliances that meet a technical standard. In this case, when the parts and appliances require to be authorised as an ETSO article, other articles recognised as equivalent by means of an international safety agreement or grandfathered in accordance with Regulation (EU) No 748/2012 are equally acceptable.
Normally, a SC/SR shall not contain specifically designed parts that should be produced by a production organisation approved in accordance with Part-21 (POA). However, in the case that the change or repair would contain such a part, it should be produced by an approved Production Organisation (POA), and delivered with an EASA Form 1. An arrangement in accordance with 21.A.122(b) is not applicable.
Eligibility for installation of parts and appliances belonging to a SC/SR is subject to compliance with the Part-21 and Part-M, Part-145 and Part-CAO related provisions, and the situation varies depending on the aircraft in/on which the SC/SR is to be embodied, and who the installer is. The need for an EASA Form 1 is addressed in Part-21 and Part-M. Furthermore, Part-M Subpart F, Part-145 and Part-CAO contain provisions (i.e. M.A.603(c), 145.A.42(c) and CAO.A.020(c)) allowing maintenance organisations to fabricate certain parts to be installed in/on the aircraft as part of their maintenance activities.
3. Parts and appliances identification
The parts modified or installed during the embodiment of the SC/SR need to be permanently marked in accordance with Part-21 Subpart Q.
4. Documenting the SC/SR and declaring compliance with the Certification Specifications
In accordance with Part-M, Part-CAO or Part-145 (e.g. AMC M.A.801 (e) and AMC 145.A.50(b)), the legal or natural person responsible for the embodiment of a change or a repair should compile details of the work accomplished. In the case of SCs/SRs, this includes, as necessary, based on its complexity, an engineering file containing drawings, a list of the parts and appliances used for the change or repair, supporting analysis and the results of tests performed or any other evidence suitable to show that the design fulfils the applicable Certification Specifications within CS-STAN together with a statement of compliance and amendments to aircraft manuals, to instructions for continuing airworthiness and to other documents such as aircraft parts list, wiring diagrams, etc., as deemed necessary. EASA Form 123 is prepared for the purpose of documenting the preparation and embodiment of the SC/SR. The aircraft logbook should contain an entry referring to EASA Form 123; both EASA Form 123 and the release to service required after the embodiment of the SC/SR should be signed by the same person.
Form 123 and all the records listed on it should follow elementary principles of controlled documentation, e.g. contain reference number of documents, issue dates, revision numbers, name of persons preparing/releasing the document, etc.
The legal or natural person responsible (see paragraph 1. above) for the embodiment of the change/repair should keep the records generated with the SC/SR as required by Part-M or Part-145 and CS-STAN.
In addition, M.A.305 requires that the aircraft owner (or CAMO, if a contract i.a.w. M.A.201 exists) keeps the status of the changes/repairs embodied in/on the aircraft in order to control the aircraft configuration and manage its continuing airworthiness.
With regard to SCs/SRs, the information provided to the owner or CAMO may be listed in Form 123 and should include, as required, a copy of any modified aircraft manual and/or instructions for continuing airworthiness. All this information should normally be consulted when the aircraft undergoes an airworthiness review, and, therefore, a clear system to record the embodiment of SCs/SRs, which is also easily traceable, would be of help during subsequent aircraft inspections.
6. Instructions for continuing airworthiness
As stipulated in M.A.302, the aircraft owner or CAMO needs to assess if the changes in the instructions for continuing airworthiness of the aircraft require to amend the aircraft maintenance programme and to obtain its approval.
7. Embodiment of more than one SC
The embodiment of two or more related SCs described in Subpart B of CS-STAN is permitted as a single change (the use of one Form 123 only) as long as adequate references to and records of all SCs embodied are captured. Restrictions and limitations of the two (or more) SCs would apply. It is permitted to issue a single release to service containing adequate traceability of all the SCs embodied.
8. Acceptable form to be used to record the embodiment of SCs/SRs
Original remains with the legal or natural person responsible for the embodiment of the SC/SR.
The aircraft owner should retain a copy of this form.
The aircraft owner should be provided with copies of the documents referenced in boxes 5 and 7 and those in box 6 marked with an asterisk ‘*’.
The ‘relevant paragraphs’ in boxes 9a and 9b refer to the applicable paragraphs of ‘Subpart A
– General’ of CS-STAN and those of the SC/SR quoted in box 2.
For box 12, when the aircraft owner has signed a contract i.a.w. M.A.201, it is possible that the Continuing Airworthiness Management Organisation (CAMO) representative signs box 12 and provides all relevant information to the owner before next flight.
Use English or the official language of the State of registry to fill in the form.
1. Identify the SC/SR with a unique number and reference this number in the aircraft logbook.
2. Specify the applicable EASA CS-STAN chapter including revision (e.g. CS-SCxxxy or CS-SRxxxy) & title. Provide also a short description.
3. Identify the aircraft (a/c) registration, serial number and type.
4. List the parts’ numbers and description for the parts installed. Refer to an auxiliary document if necessary.
5. Identify affected aircraft manuals.
6. Refer to the documentation developed to support the SC/SR and its embodiment, including design data required by the CS-STAN: design definition, documents recording the showing of compliance with the Certification Specifications or any test result, etc. The documents’ references should quote their revision/issue.
7. Identify instructions for continuing airworthiness that need to be considered for the aircraft maintenance programme review.
8. To be used as deemed necessary by the installer.
9a., 9b., 10. and 12. Self-explanatory.
11. Give full name details and certificate reference (of the natural or legal person) used for issuing the aircraft release to service.