Foreign Part 147 approvals Technical investigation process / Doc # / WI.CAO.00013-002
Approval Date / 09/11/2011
Foreign Part 147 approvals
WI.CAO.00013-002
Name / Validation / Date
Prepared by: / Alessandro ZANUZZI / Validated / 13/10/2011
Verified by: / Karl SPECHT / Validated / 13/10/2011
Reviewed by: / Oscar FERREIRA / Validated / 13/10/2011
Approved by: / Wilfried SCHULZE / Validated / 25/10/2011
Authorised by: / Francesco BANAL / Validated / 09/11/2011
European Aviation Safety Agency / Work Instruction
Foreign Part 147 approvals Technical investigation process / Doc # / WI.CAO.00013-002
Approval Date / 09/11/2011
DOCUMENT CONTROL SHEET
Reference documents
a) Procedures
PR.CAO.00005 - Foreign Part 147 approval
b) Internal documents
Log of issues
Issue / Issue date / Change description
001 / 09/11/2011 / First issue
002 / 01/09/2014 / Migration of Quality documents in compliance with Convergence project
European Aviation Safety Agency / Work Instruction
Foreign Part 147 approvals Technical investigation process / Doc # / WI.CAO.00013-002
Approval Date / 09/11/2011
0. INTRODUCTION
0.1 Table of contents
0. INTRODUCTION 3
0.1 Table of contents 4
0.2 Definitions and Abbreviations 5
0.3 Scope 6
0.4 Purpose 6
0.5 Communication 6
0.6 General principles 6
1. Technical investigation 7
1.1 Approval of the MTOE in accordance with Part 147.B.110 & Part 147.A.140 8
1.2 Acceptance of Management Personnel in accordance with 147.A.105 (a), (b) and (g) 9
0.1.1 9
1.3 Approval of courses (for type training and basic training) 10
1.4 Audit of a Part 147 Maintenance Training Organisation. 11
1.5 Part 147 Audit report 12
1.6 Auditors’ qualification requirements 12
2. Management of findings 13
2.1 Level 1 findings 14
2.2 Level 2 findings 16
2.3 Tracking and closure of Level 1 and Level 2 findings: 17
3. Recommendation of an approval 18
3.1 Contact points when recommending an approval 19
3.2 Recommendation package 20
3.2.1 Completion 20
3.2.2 Quality check 21
4. General time frames 22
4.1 Time frame for an Initial Part 147 Approval 23
4.2 Time frame for continuation of Part 147 Approval 24
5. Administrative issues 25
5.1 Team size & frequency of audit 26
5.2 Working hours 27
5.3 Record keeping 27
6. Forms 28
6.1 EASA Form 22 Foreign 29
6.2 MTOE/F4 Technical Visa (FO.CAO.00095) 29
6.3 Surveillance Plan (TE.CAO.00096) 29
6.4 Part 147 Course Approval Forms 29
7. User Guides 30
7.1 UG.CAO.00009“Foreign Part 147 approvals User guide for NAA /QE / EASA” 31
7.2 UG.CAO.00014 “Foreign Part 147 approvals - User guide for Maintenance Training Organization Exposition” 31
7.3 UG.CAO.00015“Foreign Part 147 approvals - User guide for Applicants 31
0.2 Definitions and Abbreviations
AAM Administrative Arrangement on Maintenance (TCCA/EASA)
AAM-G Administrative ArRangement on Maintenance Guidance
A&P Applications and procurements services
AMC Acceptable Means of Compliance
AMO approved MAINTENANCE ORGANISATION
BASA Bilateral Aviation Safety Agreement (US/Europe)
CAA Continuing Airworthiness Authority
CAMO Continuing Airworthiness Management Organisation
CAMOC Continuing Airworthiness Management Oversight Coordinator
CAN145 CANADIAN PART 145
CAOM Continuing Airworthiness Organisations Manager
CAO Continuing Airworthiness Organisation
DA Designated Authority
EASA European Aviation Safety Agency
EASATL EASA TEAM LEADER
EU EUROPEAN UNION
F145 FOREIGN PART 145
F147 FOREIGN PART 147
FAA Federal Aviation Administration
GM EASA Guidance Material
MAST Maintenance Standardisation Team
MAG Maintenance ANNEX GUIDANCE
MIST Maintenance International Standardisation Team
MOA Maintenance Organisation Approval
MOAP Maintenance Organisation Approval PROCEDURES
MOC Maintenance Oversight Coordinator
MOE MAINTENANCE ORGANISATION EXPOSITION
MOR MANDATORY OCCURRENCE REPORTING
MTO Maintenance Training Organisation
MTOA Maintenance Training Organisation Approval
MTOAP Maintenance Training Organisation Approval PROCEDURES
MTOC MAINTENANCE TRAINING OVERSIGHT COORDINATOR
MTOE MAINTENANCE TRAINING ORGANISATION EXPOSITION
NAA National Airworthiness Authority
NAATL Naa TEAM LEADER
PE Panel of Experts
QE Qualified Entity
TCCA Transport Canada Civil Aviation
US145 US PART 145
WG WORKING GROUP
WHOC WORKING HOURS EASA OVERSIGHT COORDINATOR
European Aviation Safety Agency / Work InstructionForeign Part 147 approvals Technical investigation process / Doc # / WI.CAO.00013-002
Approval Date / 09/11/2011
0.3 Scope
The CAO Section is responsible for managing the oversight of Part 147 Organisations based outside the EU Member States (hereafter referenced as “Foreign Part 147 organisations”).
This work instruction is complementary to the requirements of Implementing Rule - Regulation EU 2042/2003 Annex IV, Part-147 and AMC “as amended” does not supersede or replace the information defined within this document.
0.4 Purpose
The purpose of this work instruction is to assist the NAA TL and the EASA TL in the management of the “Technical investigation” for:
· Initial approval
· Change of approval
· Continuation of approval
0.5 Communication
All documents and correspondences between the Applicant, the overseeing authority and EASA shall be in the English language unless otherwise agreed by EASA.
0.6 General principles
The Oversight of a foreign MTO could be either carried out directly by an EASA Team Leader, by an Accredited NAA or a Qualified Entity. However EASA remains the competent authority responsible for the final approval and associated document as per section B of Part 147.
This work instruction:
· Is therefore aimed to detail the procedure to be implemented by either EASATL, or NAA/QE TL when acting on behalf of EASA, on foreign 147 approvals. Where the process differs between EASA TL and NAA/QE TL separate columns will be used.
· Defines the various stages of initial, continuation, change, suspension and revocation of EASA approval certificates.
· Provides a list of forms and associated user guides to be used when dealing with Foreign Part 147 approvals.
The forms, checklists and user guides addressed within the text and that have to be used by stakeholders are highlighted in green.
The two last chapters of this Work Instruction provide:
· a list of forms and checklist,
· a list of user guides
1. Technical investigation
1.1 Approval of the MTOE in accordance with Part 147.B.110 & Part 147.A.140
Part 147 Requirement / EASA / Accredited NAA/QEPart 147.B.110 §a(1)
Part 147.A.140
Part 147 AMC Appendix I
The competent authority shall formally review Initial issue of the Exposition / The EASATL or NAA/QE TL verifies the compliance of the Exposition with Part 147 requirements.
When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC.
The review of MTOE should also include the associated procedures and lists when managed separately.
Part 147.A.140 & AMC 147.A.140
Direct Approval of MOE amendments / The EASATL or NAA/QE TL verifies the compliance of the Exposition with Part 147 requirements.
When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC.
The review of MOE should also include the associated procedures and lists when managed separately.
EASA
Formal MTOE approval notification / The approval of the Exposition is formally notified in writing to the applicant by using the Letter F7 10 “Approval of MTOE”
The approval of MOE should also include the associated procedures and lists when managed separately.
Part 147.A.140 §(c)
Indirect Approval of MTOE amendment / The indirect approval consists in the MTO Quality System approving documents in accordance with a procedure included to the MTOE and therefore to be approved by the Authority.
· The “indirect approval” privilege shall be based upon the NAA/QE TL or the EASATL confidence on the organisation structure and ability of the quality system to comply and remain compliant with the regulation.
· This “indirect approval” cannot be granted at the time of the initial approval and in any case cannot be granted before the first 2 year period has been completed and found satisfactory.
· Such a procedure for indirect approval can only apply to minor changes.
· The overseeing authority must receive a copy of such minor changes when “indirectly” approved.
· The NAA/QE TL or EASATL should acknowledge receipt in writing of the amendment to the Organisation. EASA MTOC shall be copied in.
Part 147.B.110 §a(1)
Part 147.A.140
Part 147 AMC Appendix I
Verification that the MTOE procedures comply with Part 147 / The EASATL or the NAATL verifies that the procedures specified in the Exposition comply with Part 147 by using UG.CAO.00014 “Foreign Part 147 approvals - User guide for Maintenance Training Organisation Exposition” as reference material.
1.2 Acceptance of Management Personnel in accordance with 147.A.105 (a), (b) and (g)
0.1.1
Part 147 Requirement / EASA / Accredited NAA/ QE147.A.105 §(b) and & (g) AMC 147.A.105 §(b) and & (g)
Formal acceptance of the management personnel / The EASATL or NAA/QE TL verifies the compliance of the Form 4’s with Part 147 requirements.
When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC.
EASA
Formal acceptance of the management personnel / The acceptance of the management personnel is formally notified in writing to the applicant by using the Letter F7 11 “Acceptance of nominated personnel” and by signing the Form 4s’.
147.A.105 §(a)
Acceptance of the Accountable Manager / Provided the requirements of Part 147.A.105 (a) are complied with, acceptance of the Accountable Manager is formalized by the approval of the Maintenance Training Organisation Exposition containing the Accountable Manager’s signed commitment.
However the MTO may also provide an EASA F4 to demonstrate compliance of the Accountable Manager with the relevant Part 147 requirements.
In any case when satisfied, he/she recommends the approval using the “MTOE/F4 Technical Visa - FO.CAO.00095” and sends it to the EASA MTOC.
EASA
Formal acceptance of the Accountable Manager / The acceptance of the Accountable Manager is formally notified to the applicant by using the Letter F7 10 “Approval of MTOE”. However when provided the F4 shall be signed and attached to the letter.
147 B 115 & GM 147.B.115
Changes of Management Personnel / The EASATL or NAA/QE TL verifies the compliance of the Form 4’s with Part 147 requirements.
When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC (1).
147 B 115 & GM 147.B.115
Changes of Management Personnel / The acceptance of the management personnel is formally notified in writing to the applicant by using the Letter “F7 11 “Acceptance of nominated personnel” and by signing the Form 4s’.
Note: The EASATL or NAA/QE TL should have adequate control established through the MTOE procedure that they are timely informed by the Organisation of any change of the Management personnel.
Note: The EASATL or NAA/QE TL shall hold a meeting with the Accountable Manager at least once during the investigation for initial approval to ensure he/she understands his/her responsibilities under Part 147. The Accountable Manager should be met minimum once during the 2 year surveillance cycle.
Note: For any management personnel change the organisation shall supply EASATL or NAA/QE TL with an amendment to the MTOE. The approval of the MTOE shall be done according to paragraph. 1.1 of this work instruction.
1.3 Approval of courses (for type training and basic training)
EASA / Accredited NAA/ QEReview of the Course Material / A cross reference should be made to the submitted Form 12 supporting the application to ensure the correct course material has been submitted. The detailed training programme, Multi Choice Questions and essay questions where applicable, MTOE revision (using the relevant EASA Course Approval Forms listed on the first page of this Working instruction) and course notes as provided by the applicant should be examined in accordance with the relevant Part 147, Part 66 requirements, this working instruction and the G.M.
Approval of the submitted material / Once satisfied the submitted material is compliant with the current regulations and this technical procedure, the submitted course approval form should be signed by the EASA nominated CATL or the NAA/QE Team Leader (NAA/QE TL). A copy of the form will be annexed to the form 22 recommending the course approval. A copy should be made for the company file to be kept by the NAA responsible for that approval. The submitted material may be sent back to the applicant or held on file at the NAA/QE. Where an NAA/QE has the oversight of a large Part 147 approved company offering courses on a number of aircraft it is acceptable not to keep these documents.
Changes to an approved Course / Changes to an approved course shall be notified by the applicant to the nominated CATL or the NAA/QE Team Leader (NAA/QE TL) by using a course approval form. This form shall be reviewed and accepted by the nominated CATL or the NAA/QE Team Leader (NAA/QE TL). A copy shall be kept in the organisations file of the nominated CATL or the NAA/QE Team Leader (NAA/QE TL)
1.4 Audit of a Part 147 Maintenance Training Organisation.
As soon as the draft of the MTOE, the EASA Forms 4, the associated documents, the Quality Assurance Manager statement, the audit report if requested, are deemed acceptable, the accredited NAA/QE TL or EASATL initiates the on site investigation in accordance with Section B of Part 147, its associated Acceptable Means of Compliance (AMC) / Guidance Material (GM) and Internal CAO procedures and work instructions.
EASA / Accredited NAA/ QEPreparation / The audit plan should be prepared by the Auditor/Team Leader by taking into account the available resources (audit team) and the scope of work of the Organisation. The plan should include compliance checking against the particular regulation and the current MTOE revision by auditing a cross section of the Organisation’s activities. The audit plan should be notified to the Organisation.
For initial approvals and changes of approval, a Statement signed by the Organisation Quality Assurance Manager shall always be provided before the audit takes place confirming that processes, facilities, documentation, training devices and personnel subject to the application have been reviewed and audited showing compliance with all applicable requirements. The relevant audit report shall be requested by the EASATL or NAA/QE TL.
The following points should be considered when preparing the audit plan:
o Any follow-up actions from previous audits where necessary;
o Dates and places where the audit activities are to be conducted
o Audit scope, including identification of the organisational and functional units and processes to be audited;