Airtime Maintenance - ‘Safety in the air begins with quality maintenance on the ground’

Part M

Airtime Aviation now holds EASA Part M approval to review, issue, renew and extend Airworthiness Review Certificates under approval number UK.MG.0473.

Airtime now has two separate approvals:

• Part 145 approval (UK.145.00467) to carry out maintenance, repairs, engine overhauls, etc….
• Part M Subpart G approval (UK.MG.0473) to be a “Continuing Airworthiness Management Organisation” or a “CAMO” and to issue Airworthiness Review Certificates.

Part M introduces a number of changes of which owners should be aware:

Owners should have a contract with a Part M Subpart G approved organisation, a CAMO, to manage the aircraft’s “continuing airworthiness”. A contract with a CAMO makes future extensions / renewals of the ARC (Airworthiness Review Certificate) much easier. If owners do not have a contract with a CAMO, the ARC will have to be renewed annually.

To enable Airtime to manage an aircraft, the aircraft’s records should be held by Airtime.

ARC Renewals

ARC renewals are not simply a replacement for the old Certificate of Airworthiness Renewals as there are a number of differences.

In the past, the maintenance company (who under a single approval looked after both the aircraft and the aircraft records) carried out a Star Annual following which it was the maintenance company who made a recommendation to the CAA that the aircraft should be issued with a new C of A. The CAA issued the C of A (and the CAA effectively took responsibility).

Under Part M, the maintenance company is split into two under different approvals – the Part 145 only carries out maintenance, repairs, engine overhauls, whilst the Part M now looks after the aircraft records.

The renewal of the ARC comes under the Part M approval but, instead of making a recommendation to the CAA, a company with Part M approval can hold the privilege to issue ARC’s without any reference to the CAA. That privilege brings with it some responsibility for status of the aircraft.

As mentioned above, in the past, the CAA were responsible for the issue of the Certificate of Airworthiness (and, more recently, the transition to the Airworthiness Review Certificate or ARC) and the issue of the C of A was based on a recommendation from a maintenance organisation. Under EASA relegations, when the CAMO (Continuing Airworthiness Management Organisation) issues an ARC (Airworthiness Review Certificate), the CAMO takes full responsibility for the Airworthiness of the aircraft.

The CAMO therefore has to be 100% satisfied of the status of the aircraft before the CAMO can issue the first ARC to that aircraft. The CAMO should not (and, in Airtime’s recent experience, cannot) rely on the fact that the CAA has issued a C of A as confirmation that everything was in order with the aircraft at that time.

For the CAMO to be 100% satisfied, the first Airworthiness Review with a CAMO for the issue of an Airworthiness Review Certificate (ARC) has to be “back to birth”. The purpose of the “back to birth” review is, amongst other things,

1. to ensure that all Airworthiness Directives have been carried out
2. all modifications (from minor radio changes to major STC’s) have been carried out correctly and are approved
3. any accident damage has been repaired in accordance with approved procedures, etc
4. all lifed items (propellers, vacuum pumps, etc.) are within stated life limits
5. all the requirements of the manufacturer’s maintenance manual have been complied with
6. all maintenance has been correctly released to service.

The fact that an aircraft was acceptable to the CAA when it was imported cannot be used as a starting point for an ARC review.

Nearly all of the problems Airtime has encountered whilst carrying out Airworthiness Reviews are from lack of proper records – missing log books (especially those before the aircraft was on the UK register), missing modification documentation (such as STC certification) and other missing information. If the embodiment of an Airworthiness Directive cannot be found with a CRS (Certificate of Release to Service) in the aircraft log book or proof that a modification was approved is missing, these omissions are enough to stop the ARC being issued.

Airtime has a process in place which can be used where log books are missing and, the CAA have stated that a well documented “back-to-birth” review CAN be used in the future as a reference point, saving any CAMO in the future having to repeat what Airtime has to carry out now.

The views expressed above are Airtime’s interpretation of the existing EASA regulations. An article expressing similar views has appeared in the June issue of “Flyer” magazine and that article was produced with the knowledge of the CAA.