EIMG Briefing for EM.TEC Meeting 5 June 2018 Cologne EASA HQ RMT.0251 SMS Phase II Why are they doing the Task; To introduce SMS Requirements (ICAO Annex 19) and related authority oversight and management system requirements for Part 145 organizations. What are they doing; Working on the amendments to Part 145 IR, using PART-CAMO opinion but keeping the Part 145 numbering / structure, except for new management system related provisions. An NPA is expected Q3/2018 and rather ambitiously an Opinion Q2/2019 followed by IR Decision Q2/2020. We received a presentation from EASA asking for the groups feedback on the desirability of implementing voluntary SMS programmes in advance of rulemaking. Both ARSA via Marshall Filler and the AEA via Ric Peri the EM.TEC Chair expressed reservations that voluntary SMS programmes are being designed for large aerospace companies that would become unduly burdensome for SMEs to scale down/fit their limited operations. All present agreed that a more proportionate voluntary SMS programme more suited to SMEs which represent a significant majority of aerospace companies, whilst encouraging larger companies to scale up. Part 145.A.25 Facility Requirements/Hangarage Werner Luehmann representing Airlines for Europe (A4E) raised the issue Part 145 organizations (A1 Rated), may perform work outside of its hangar in circumstances that would not impact the Airworthiness of the work performed. This is permissible under FAA rules, however EASA and some EU NAAs have issued interpretations that requires all Base Maintenance activities to be performed in a hangar. The EM.TEC approved a draft FAQ for posting on the EASA website clarifying that certain Base Maintenance tasks maybe performed outside of a hangar. EASA agreed to evaluate the draft and advise the group of its outcomes. A lot of time was taken debating this issue which will possibly in the long-term lead to AMC changes. The group encouraged EASA to take a perspective based on the tasks being performed safely outside of a hangar iaw procedures within the organizations MOE. EIMG were very proactive in this matter and Simon Annetts thanks those EIMG/UKOTG members who contributed by e-mail so that we could put our combined view forward accordingly.
Brexit The group received a Brexit briefing provided by Erik Moyson (AIRE Airlines International Representation in Europe) based upon the ECs notice to stakeholders dated 13 April 2018. EASA refused to have Brexit on the agenda but this was raised as AOB. Whilst Brexit is in the hands of the politicians, industry must develop contingency plans if a hard brexit occurs next March. All companies are encouraged to perform their own RA on the effect on their particular business. EASA has a web page dedicated to Brexit as does the UKCAA. Standardization Briefing provided by Kyle Martin GAMA Brussels Simon Annetts has been representing EIMG on a GAMA EU Maintenance Workshop committee over the past year which culminated on 12 April 2018 in Kyle Martin being the only industry presenter at the 1 st ever EASA/NAA Standardization meeting. Good feedback was received from EIMG/UKOTG members and 2 items- Lack of UKCAA proactivity in issuing Part 66 licences vs their EU counterparts and the CAA insistence on using the foreign 145 user guide to write an MOE, were included in the 25 or so slides presented. The idea was to highlight the challenges faced by Industry in the EU with the differing NAAs RMT.0018 Cross Ref NPA 2017-19 Parts Without EASA Form 1 Why are they doing the Task; Components can only be installed if accompanied with EASAForm1 or equivalent (except standard parts and raw material). Some parts are not designed or manufactured specifically for aviation use (lightbulbs, fire axes, smoke detectors etc etc). This task assesses a more, proportionate and efficient requirements to allow the installation of components based on the safety consequences should the component fail. What are They Doing; Allow that parts with lower criticality as identified by the TC Holder would not need an EASA Form 1 when used as spare part for installation during maintenance. In practice, the parts would be classified into different manufacturing criticality levels. As such only those parts with higher criticality levels would have to be accompanied by an EASA Form 1. The outcome of this rulemaking is potentially important for both European and US industry as changes to EAS rules may well impact the parts documentation requirements in the
EU/US MAG. Where currently the MAG requires that an Authorized Release Certificate accompany all new parts to be installed during maintenance subject to the MAG, except for standard parts and parts fabricated during maintenance. Industry comments are in process of review with an opinion expected Q4/2018 and an IR Decision expected Q4/2019. Cybersecurity (CS)- Meetings 13 March and 15 June 2018 Note: EIMG are members of the Executive Committee representing the Maintenance Sector RMT.0648 TOR 17 May 2016, NPA/Q3/2018 Product Certification CS-25, the need to include CS-29, 27, 23, CS-E, CS-ETSO & CSS-P will also be considered. RMT.0720 TOR expected Q3/2018, NPA Q4/2018 Introduces Security Management Systems for organizations. 21G, 21J, 145, OPS, ATM/ANS and ADR. X3 workstreams in operations, Regulatory, Charter and STORM (Shared Trans Organizational Risk Management).Charter finally agreed/voted on during the 15 June meeting in Brussels but will need to be ratified at the High Level Conference 14/15 Nov 2018 in Toulouse. Recent EPAS contains elements linked to research on CS- EPAS Strategy will include Information Sharing, Research & Studies, Event Investigation/Response, Knowledge/Competence building, International co-operation/harmonization, Regulatory activities and development of Industry Standards. European Centre for Cybersecurity in Aviation (ECCSA) ECCSA is an initiative supported by EASA aimed at increasing collaboration and information sharing amongst aviation stakeholders, a key enabler for implementing a resilient aviation cyberspace. Pilot phase now launched to test infrastructure and sharing of info (9-12 moths) and then become operational. Research into threats on critical aircraft systems. New BR coming, which gives new competences to EASA. The agency is evaluation impact on resources with regard work in the field of CS ICAO Annex 17 standard 49.1 will be enshrined into EU Law.
Update on the Status of the Comitology process for the following Opinions. Pending Adoption B2L and L licences package contains: New B2L and L Part-66 licences (ref. Opinion 05/2015). Procedures Part-145 organisations in order to control suppliers of spare parts (ref. Opinion 12/2013). Limitation of the Part-147 privileges related to stand-alone basic examinations (ref. Opinion 07/2015). Exemption for twin turbo-prop aeroplanes <5700 Kg MTOM. Text already agreed by the European Council and European Parliament in summer 2016 (voting EASA Committee of 17/18 February 2016). Written procedure (from 16 March to 10 April 2018). Text at the Parliament and Council. Adoption expected in August 2018. Applicability of Above B2L licence: 6 months after adoption. L-licence: 01 October 2019 (obligation for NAAs to start issuing them) and 01 October 2020(obligation for all certifying staff to have it). Procedures for control suppliers of spare parts: 6 months after adoption. Limitation of the Part-147 privileges related to stand-alone basic examinations: Immediate effect after adoption. Exemption for twin turbo-prop aeroplanes <5700 Kg MTOM: Immediate effect after adoption. Pending Adoption GA + SMS package covers: Part-M General Aviation Task Force (Phase II): Opinion05/2016 issued on 13 April 2016. New Part-ML New Part-CAO (without SMS) SMS for CAMOs (RMT.0251 PhaseI): Opinion 06/2016 issued on 12May2016. New Part-CAMO (with SMS) and management system for NAAs in relation to CAMOs. Technical Records (RMT.0276): Opinion13/2016 issued on 17 November 2016. To be initially discussed during the next EASA Committee. No date as to when these will be adopted as issues remain between EASA and the EC
Other Tasks Update RMT.0106 CS-MCSD (Maintenance Certifying Staff Data) Part 21.A.91-NPA planned Q3/2018, Opinion Q3/2019 and IR/Decision Q3/2020 RMT.0217 CAMO/145 Responsibilities- NPA 2014-27 Refers-Opinion Q2/2020 with IR/Decision Q2/2021 RMT.0097 B1/B2 Support Staff- NPA 2014-11, Opinion Q2/2019 with IR/Decision Q2/2020 RMT.0278 Import of aircraft from another regulatory system NPA 2016-08, Opinion Q2/2020? With IR/Decision Q2/2021 RMT.0018 Parts without EASA Form 1- NPA issued 14 Dec 2017 (2017-19), Opinion Q4/2018 and IR/Decision Q4/2019 RMT.0325 HEMS (Subtask on Maintenance Authorization) NPA issued 18 June 2018 (2018-04), Opinion Q3/2018 and IR/Decision Q4/2019 RMT.0209 (M.014) Contract CAW Activities- Long and very controversial task. Divergent views on the adequacy and need of the amendment. This task has been deleted as a result of the strategic priorities identified in the EPAS to prioritize the work. An opinion will be issued to close the task, which will include the analysis of the impacts of the deletion. RMT.0281 New Teaching and Training Tech. NPA 2014-22, Opinion Q1/2020 with IR/Decision Q1/2021 RMT.0521 Airworthiness Review Process NPA 2015-17, Opinion Q2/2020? With IR/Decision Q2/2021- Controversial Issues are transfer of aircraft between member states and description of the content of the Airworthiness Review (ie) Operational items. RMT.0541 Aircraft Type Ratings for Part 66 AML-NPA Q4/2018 and Decision Q2/2019 RMT.0588 ACAM Key Risk Elements- NPA Q1/2020, Opinion Q1/2021 with IR/Decision Q1/2022 RMT.0255/RMT.0544 Part 66 & Part 147- NPA Q3/2020, Opinion Q3/2021 with IR/Decision Q3/2022 Next Meeting 13 November 2018 in Cologne. Also note next SM ICG Industry Day is also at EASA HQ same day ---------------------------------------------------------------End------------------------------------------------------------