Identifying the issues - Part 145 continuing airworthiness - approved maintenance organisations

Closed 16 Feb 2018

Opened 18 Dec 2017

Results Updated 7 Aug 2018

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:

  • specialist maintenance (6 issues)
  • complexity (10 issues)
  • international harmonisation (2 issues).

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:

  • complexity of Part 42 regulations and associated CASR 1998 Dictionary definitions
  • complexity of the Part 145 MOS
  • lack of true harmonisation with EASA (as originally intended)
  • lack of clarity, understanding and complexities of the Part 145 regulations, Part 145 MOS, AMC/GM, associated documentation, and legislation
  • continued use of two sets of regulations (Civil Aviation Regulations 1988 (CAR) and CASR).

Specialist Maintenance:

  • lack of clarity on how specialist maintenance is defined
  • understanding of the D rating applicability
  • complexities for the D rating organisations to provide on-wing aircraft maintenance
  • understanding of what specialist maintenance is required to be performed under the A, B and C rating approvals
  • extent of classification for composite repairs as specialist
  • understanding the scope of specialist tasks under Part 66.

Qualifications and Competency

  • understanding what are suitable qualifications for responsible management positions
  • NDT qualifications - lack of clarity for alternative provisions
  • clarification for competence assessment requirements
  • complexities for authorisation renewal experience requirements.

Certification and Authorisations:

  • lack of understanding and complexities for authorisation systems for levels of maintenance certifications and CRS
  • complexities for aircraft certification by contracted AMO's.

AMO Contracting and Sub-Contracting privileges:

  • complexities for engaging other service providers
  • lack of understanding of definitions.

Maintenance at non-listed locations:

  • restrictive and limiting legislative provisions.

Fatigue / Human Factors (HF) / Safety Management Systems (SMS):

  • lack of detail and guidance on fatigue management
  • lack of guidance on sufficient manning levels
  • understanding of HF when manpower planning
  • understanding the application of HF to production planning systems
  • lack of understanding the requirements of SMS.

Exposition:

  • clarifying expectations of exposition format, content and use
  • understanding and expectation of other associated organisation documents
  • complexities and variations with other NAA similar exposition requirements.

Training:

  • understanding applicability and approval for permitted training
  • understanding applicability and approval for A Category tasks and associated training
  • understanding aeronautical product workshop training requirements.

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:

  • the analysis and review of the identified issues
  • the development of proposed solutions
  • the formulation of recommendations for improvements to the existing Part 145 of CASR, Manual of Standards, associated continuing airworthiness legislation and advisory material.

Published Responses

View submitted responses where consent has been given to publish the response.

Overview

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.

Why We Are Consulting

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:

  • specialist maintenance
  • complexity
  • international harmonisation.

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

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:

  • ensure that the legislation effectively addresses the relevant safety risks
  • maintain compliance with ICAO standards
  • improve international harmonisation
  • reduce the complexity of the legislation
  • improve the harmonisation between related CASR legislation
  • improve, where applicable, scalability of the requirements 
  • fix any anomalies in the legislation and address unintended consequences
  • remove ambiguities and generally streamline the legislation
  • resolve policy and functionality requirements for specialist maintenance
  • identify and provide interim measures to alleviate some of the complexities and burdensome requirements until changes are implemented. 

Visit the CASA website to access the related regulations, Manual of Standards, and Acceptable Means of Compliance Guidance Material including:

  • CASR Part 145 (Volume 4 of the CASR 1998)
  • Part 145 Manual of Standards
  • CASR Part 42 (Volume 1 of the CASR 1998)
  • Acceptable Means of Compliance and Guidance Material for Parts 42 and 145
  • Dictionary (Volume 5 of the CASR 1998) 

Audiences

  • Airworthiness organisations
  • Engineers

Interests

  • Airworthiness / maintenance
  • Licensing