This Section establishes the requirements to be met by an organisation to qualify for the issue or continuation of an approval for the maintenance of aircraft and components.
AMC 145.A.10 Scope
- Line Maintenance should be understood as any maintenance that is carried out before flight to ensure that the aircraft is fit for the intended flight.
(a) Line Maintenance may include:
— Trouble shooting.
— Defect rectification.
— Component replacement with use of external test equipment if required. Component replacement may include components such as engines and propellers.
— Scheduled maintenance and/or checks including visual inspections that will detect obvious unsatisfactory conditions/discrepancies but do not require extensive in depth inspection. It may also include internal structure, systems and powerplant items which are visible through quick opening access panels/doors.
— Minor repairs and modifications which do not require extensive disassembly and can be accomplished by simple means.
(b) For temporary or occasional cases (ADs, SBs) the Quality Manager may accept base maintenance tasks to be performed by a line maintenance organisation provided all requirements are fulfilled as defined by the competent authority.
(c) Maintenance tasks falling outside these criteria are considered to be Base Maintenance.
(d) Aircraft maintained in accordance with ‘progressive’ type programmes should be individually assessed in relation to this paragraph. In principle, the decision to allow some ‘progressive’ checks to be carried out should be determined by the assessment that all tasks within the particular check can be carried out safely to the required standards at the designated line maintenance station.
- Where the organisation uses facilities both inside and outside the Member State such as satellite facilities, sub-contractors, line stations etc., such facilities may be included in the approval without being identified on the approval certificate subject to the maintenance organisation exposition identifying the facilities and containing procedures to control such facilities and the competent authority being satisfied that they form an integral part of the approved maintenance organisation.
GM 145.A.10 Scope
This Guidance Material (GM) provides guidance on how the smallest organisations satisfy the intent of Part-145:
- By inference, the smallest maintenance organisation would only be involved in a limited number of light aircraft, or aircraft components, used for commercial air transport. It is therefore a matter of scale; light aircraft do not demand the same level of resources, facilities or complex maintenance procedures as the large organisation.
- It is recognised that a Part-145 approval may be required by two quite different types of small organisations, the first being the light aircraft maintenance hangar, the second being the component maintenance workshop, e.g. small piston engines, radio equipment, etc.
- Where only one person is employed (in fact having the certifying function and others), these organisations approved under Part-145 may use the alternatives provided in point 3.1 limited to the following:
Class A2 Base and Line maintenance of aeroplanes of 5 700 kg and below (piston engines only).
Class A3 Base and Line maintenance of single-engined helicopters of less than 3 175 kg.
Class A4 Aircraft other than A1, A2 and A3
Class B2 Piston engines with maximum output of less than 450 HP.
Class C Components.
Class D1 Non-destructive Testing.
3.1. 145.A.30(b): The minimum requirement is for one full-time person who meets the Part-66 requirements for certifying staff and holds the position of ‘accountable manager, maintenance engineer and is also certifying staff and, if applicable, airworthiness review staff’. No other person may issue a certificate of release to service and therefore if absent, no maintenance may be released during such absence.
3.1.1. The quality monitoring function of 145.A.65(c) may be contracted to an appropriate organisation approved under Part-145 or to a person with appropriate technical knowledge and extensive experience of quality audits employed on a part-time basis, with the agreement of the competent authority.
Note: Full-time for the purpose of Part-145 means not less than 35 hrs per week except during vacation periods.
3.1.2. 145.A.35. In the case of an approval based on one person using a subcontracted quality monitoring arrangement, the requirement for a record of certifying staff is satisfied by the submission to and acceptance by the competent authority of the EASA Form 4. With only one person the requirement for a separate record of authorisation is unnecessary because the EASA Form 3 approval schedule defines the authorisation. An appropriate statement, to reflect this situation, should be included in the exposition.
3.1.3. 145.A.65(c). It is the responsibility of the contracted quality monitoring organisation or person to make a minimum of 2 visits per 12 months and it is the responsibility of this organisation or person to carry out such monitoring on the basis of 1 pre-announced visit and 1 not announced visit to the organisation.
It is the responsibility of the organisation to comply with the findings of the contracted quality monitoring organisation or the person.
CAUTION: it should be understood that if the contracted organisation or the above mentioned person loses or gives up its approval, then the organisation’s approval will be suspended.
- Recommended operating procedure for a Part-145 approved maintenance organisation based upon up to 10 persons involved in maintenance.
4.1. 145.A.30(b): The normal minimum requirement is for the employment on a full-time basis of two persons who meet the competent authorities’ requirements for certifying staff, whereby one holds the position of ‘maintenance engineer’ and the other holds the position of ‘quality audit engineer’.
Either person can assume the responsibilities of the accountable manager providing that they can comply in full with the applicable elements of 145.A.30(a), but the ‘maintenance engineer’ is the certifying person to retain the independence of the ‘quality audit engineer’ to carry out audits. Nothing prevents either engineer from undertaking maintenance tasks providing that the ‘maintenance engineer’ issues the certificate of release to service. This ‘maintenance engineer’ may also be nominated as airworthiness review staff to carry out airworthiness reviews and issue the corresponding airworthiness review certificate for aircraft for which Part-ML applies in accordance with ML.A.903.
The ‘quality audit engineer’ should have similar qualifications and status to the ‘maintenance engineer’ for reasons of credibility, unless he/she has a proven track-record in aircraft quality assurance, in which case some reduction in the extent of maintenance qualifications may be permitted.
In cases where the competent authority agrees that it is not practical for the organisation to nominate a post holder for the quality monitoring function, this function may be contracted in accordance to paragraph 3.1.1.