145.A.75
In accordance with the exposition, the organisation shall be entitled to carry out the following tasks:
145.A.75(a) Scope of work
(a) Maintain any aircraft and/or component for which it is approved at the locations identified in the approval certificate and in the exposition;
145.A.75(b) Limited scope of work
(b) Arrange for maintenance of any aircraft or component for which it is approved at another organisation that is working under the quality system of the organisation. This refers to work being carried out by an organisation not itself appropriately approved to carry out such maintenance under this Part and is limited to the work scope permitted under procedures laid down in point 145.A.65(b). This work scope shall not include a base maintenance check of an aircraft or a complete workshop maintenance check or overhaul of an engine or engine module;
AMC 145.A.75(b) Subcontracting
1. Working under the quality system of an organisation appropriately approved under Part-145 (sub contracting) refers to the case of one organisation, not itself appropriately approved to Part-145 that carries out aircraft line maintenance or minor engine maintenance or maintenance of other aircraft components or a specialised service as a subcontractor for an organisation appropriately approved under Part-145. To be appropriately approved to subcontract the organisation should have a procedure for the control of such subcontractors as described below. Any approved maintenance organisation that carries out maintenance for another approved maintenance organisation within its own approval scope is not considered to be subcontracting for the purpose of this paragraph.
Note: For those organisations approved under Part-145 that are also certificated by the FAA under FAR Part-145 it should be noted that FAR Part-145 is more restrictive in respect of maintenance activities that can be contracted or sub-contracted to another maintenance organisation. It is therefore recommended that any listing of contracted or sub-contracted maintenance organisations should identify which meet the Part-145 criteria and which meet the FAR Part-145 criteria.
2. Maintenance of engines or engine modules other than a complete workshop maintenance check or overhaul is intended to mean any maintenance that can be carried out without disassembly of the core engine or, in the case of modular engines, without disassembly of any core module.
3. FUNDAMENTALS OF SUB-CONTRACTING UNDER PART-145
3.1. The fundamental reasons for allowing an organisation approved under Part-145 to sub-contract certain maintenance tasks are:
(a) To permit the acceptance of specialised maintenance services, such as, but not limited to, plating, heat treatment, plasma spray, fabrication of specified parts for minor repairs / modifications, etc., without the need for direct approval by the competent authority in such cases.
(b) To permit the acceptance of aircraft maintenance up to but not including a base maintenance check as specified in 145.A.75(b) by organisations not appropriately approved under Part-145 when it is unrealistic to expect direct approval by the competent authority. The competent authority will determine when it is unrealistic but in general it is considered unrealistic if only one or two organisations intend to use the sub-contract organisation.
(c) To permit the acceptance of component maintenance.
(d) To permit the acceptance of engine maintenance up to but not including a workshop maintenance check or overhaul of an engine or engine module as specified in 145.A.75(b) by organisations not appropriately approved under Part-145 when it is unrealistic to expect direct approval by the competent authority. The determination of unrealistic is as per sub-paragraph (b).
3.2. When maintenance is carried out under the sub-contract control system it means that for the duration of such maintenance, the Part-145 approval has been temporarily extended to include the sub-contractor. It therefore follows that those parts of the sub-contractor’s facilities personnel and procedures involved with the maintenance organisation’s products undergoing maintenance should meet Part-145 requirements for the duration of that maintenance and it remains the organisation’s responsibility to ensure such requirements are satisfied.
3.3. For the criteria specified in sub-paragraph 3.1 the organisation is not required to have complete facilities for maintenance that it needs to sub-contract but it should have its own expertise to determine that the sub-contractor meets the necessary standards. However an organisation cannot be approved unless it has the in-house facilities, procedures and expertise to carry out the majority of maintenance for which it wishes to be approved in terms of the number of class ratings.
3.4. The organisation may find it necessary to include several specialist sub-contractors to enable it to be approved to completely certify the release to service of a particular product. Examples could be specialist welding, electro-plating, painting etc. To authorise the use of such subcontractors, the competent authority will need to be satisfied that the organisation has the necessary expertise and procedures to control such sub-contractors.
3.5. An organisation working outside the scope of its approval schedule is deemed to be not approved. Such an organisation may in this circumstance operate only under the sub-contract control of another organisation approved under Part-145.
3.6. Authorisation to sub-contract is indicated by the competent authority accepting the maintenance organisation exposition containing a specific procedure on the control of sub-contractors.
4. PRINCIPAL PART-145 PROCEDURES FOR THE CONTROL OF SUB-CONTRACTORS NOT APPROVED UNDER PART-145
4.1. A pre-audit procedure should be established whereby the maintenance organisations’ subcontract control section, which may also be the 145.A.65(c) quality system independent audit section, should audit a prospective subcontractor to determine whether those services of the subcontractor that it wishes to use meets the intent of Part-145.
4.2. The organisation approved under Part-145 needs to assess to what extent it will use the sub-contractor`s facilities. As a general rule the organisation should require its own paperwork, approved data and material/spare parts to be used, but it could permit the use of tools, equipment and personnel from the sub-contractor as long as such tools, equipment and personnel meet the requirement of Part-145. In the case of sub-contractors who provide specialised services it may for practical reasons be necessary to use their specialised services personnel, approved data and material subject to acceptance by the organisation approved under Part-145.
4.3. Unless the sub-contracted maintenance work can be fully inspected on receipt by the organisation approved under Part-145 it will be necessary for such organisation to supervise the inspection and release from the sub-contractor. Such activities should be fully described in the organisation procedure. The organisation will need to consider whether to use its own staff or authorise the sub-contractor’s staff.
4.4. The certificate of release to service may be issued either at the sub-contractor or at the organisation facility by staff issued a certification authorisation in accordance with 145.A.30 as appropriate, by the organisation approved under Part-145. Such staff would normally come from the organisation approved under Part-145 but may otherwise be a person from the sub-contractor who meets the approved maintenance organisation certifying staff standard which itself is approved by the competent authority via the maintenance organisation exposition. The certificate of release to service and the EASA Form 1 will always be issued under the maintenance organisation approval reference.
4.5. The sub-contract control procedure will need to record audits of the sub-contractor, to have a corrective action follow up plan and to know when sub-contractors are being used. The procedure should include a clear revocation process for sub-contractors who do not meet the Part-145 approved maintenance organisation’s requirements.
4.6. The Part-145 quality audit staff will need to audit the sub-contract control section and sample audit sub-contractors unless this task is already carried out by the quality audit staff as stated in sub-paragraph 4.1.
4.7. The contract between the Part-145 approved maintenance organisation and the sub-contractor should contain a provision for the competent authority and EASA standardisation team staff to have right of access to the sub-contractor.
145.A.75(c) Remote locations
(c) Maintain any aircraft or any component for which it is approved at any location subject to the need for such maintenance arising either from the unserviceability of the aircraft or from the necessity of supporting occasional line maintenance, subject to the conditions specified in the exposition;
What does the term ‘occasional’ mean in 145.A.75(c)?
Within the privilege described in 145.A.75(c) an aircraft maintenance organisation (AMO) may perform line maintenance activity (Part-145) in other-than-approved locations, provided it is considered as ‘occasional’. There is no formal definition of ‘occasional’ in the regulation, AMC and GM, but this privilege should be used to support an operator with which the AMO is already in contractual relation, when this operator needs line maintenance service for a short period at a new location due to a special occasion or particular reason (e.g. one-time flights, short term contracts/flight destination, flight schedule changes, special event at a particular location such as European athletics championship in Berlin, 6-12 August 2018, etc.) or the owner needs supporting maintenance service for a short period at a new location due to a special occasion or particular reason. Subject to the approval by the Competent Authority, the maintenance organisation should develop in the MOE (e.g. Chapter 2.24 Reference to Specific Maintenance Procedures) the generic procedures to be followed in such a case: how to assess whether the maintenance can be performed, availability of tools/ equipment/ material/ components/ maintenance data, staff, adequacy of the facilities, environmental conditions, quality system, record keeping, need to report these cases to the competent authority, etc. In addition, the procedure should include the criteria (e.g. maximum service duration without gap in the continuity; limitation in the repetition of the need* at one given location) to classify the activity as ‘occasional line maintenance’. * In principle, the repetitive use of this privilege at the same location should not be considered, and for repetitive needs, an approved line station should normally be established at that location.
145.A.75(d) Line station
(d) Maintain any aircraft and/or component for which it is approved at a location identified as a line maintenance location capable of supporting minor maintenance and only if the organisation exposition both permits such activity and lists such locations;
145.A.75(e) CRS
(e) Issue certificates of release to service in respect of completion of maintenance in accordance with point 145.A.50;
145.A.75(f) Airworthiness review
(f) If specifically approved to do so for aircraft covered by Annex Vb (Part-ML), it may perform airworthiness reviews and issue the corresponding airworthiness review certificate in accordance with the conditions specified in point ML.A.903 of Annex Vb (Part-ML) to this Regulation.