This consultation asked people to identify key issues to be addressed in the post implementation review of Part 145. The consultation has now closed, and a summary of the feedback is provided below.
About this consultation
Prior to the consultation, a number of known issues with Part 145 regulation and associated Manual of Standards were identified and grouped into three themes:
The consultation survey asked respondents if they had experienced any issues regarding the identified themes, and if so to provide detail (including the kind of issues, their impact and/or whether they relate to a specific item of legislation) and to suggest possible solutions.
Respondents were also asked to provide input on any other issues they would like considered by the post implementation review.
A copy of the survey is available here.
Respondents
We received a total of 43 responses to the consultation survey and some of them were received as written submissions.
24 submissions officially represent organisations, including approved maintenance organisations (AMO’s), continuing airworthiness management organisations (CAMO’s), related industry consultants and associations. 22 respondents consented to having their response published on the CASA Consultation Hub.
Summary of feedback
The majority of known and new issues have varying degrees of overlap and complexities and may be common to one of or a combination of the survey themes. A range of the issues is summarised below:
CASR 1998 Continuing airworthiness legislation and associated advisory material:
Specialist Maintenance:
Qualifications and Competency
Certification and Authorisations:
AMO Contracting and Sub-Contracting privileges:
Maintenance at non-listed locations:
Fatigue / Human Factors (HF) / Safety Management Systems (SMS):
Exposition:
Training:
Next steps
The Aviation Safety Advisory Panel (ASAP) is the primary advisory body through which CASA directs its engagement with industry. CASA anticipates the ASAP will establish a technical working group to contribute relevant technical expertise and industry sector insight to:
View submitted responses where consent has been given to publish the response.
CASA is carrying out a comprehensive post-implementation review of Part 145 of the Civil Aviation Safety Regulations 1998 (CASR) and associated legislation. As a first step, we would like to hear about the issues you want addressed and your ideas for possible solutions.
Part 145 was first introduced in June 2011 as part of the regulatory program to transition the requirements of aircraft or aeronautical product maintenance certificates of approval from the Civil Aviation Regulations 1988 (CAR) to CASRs.
CASA believes that some elements of the legislation could be simplified, and some requirements could be less restrictive, whilst still maintaining full compliance with the International Civil Aviation Organization (ICAO), international technical arrangements, and harmonisation with other national aviation authorities (such as the European Aviation Safety Agency).
The post implementation review of Part 145 provides the opportunity to ensure the legislation effectively addresses the relevant safety risks as well as identifying and addressing any errors, omissions, gaps, unintended consequences or implementation issues.
The review will also include relevant aspects of regulations associated with Part 145, such as CASR Part 42 (e.g. certification requirements) and definitions in the CASR 1998 dictionary.
CASA is aware of a number of CASR and Manual of Standards requirements which need to be addressed as a priority. Issues identified so far relate to at least one of the following three themes:
Responses to this consultation will help to inform the development of interim measures to provide temporary relief from known issues (such as specialist maintenance complexities) until longer term changes are implemented.
The Part 145 post implementation review will evaluate Part 145 of CASR, the Part 145 MOS and applicable CASR, including the respective acceptable means of compliance, advisory and associated guidance material.
The objectives are to:
Visit the CASA website to access the related regulations, Manual of Standards, and Acceptable Means of Compliance Guidance Material including:
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