Considering Changes introduced by COMMISSION IMPLEMENTING REGULATION (EU) 2019/1383 of 8 July 2019
Considering Changes introduced by COMMISSION IMPLEMENTING REGULATION (EU) 2019/1383 of 8 July 2019 amending and correcting Regulation (EU) No 1321/2014 as regards safety management systems in continuing airworthiness management organizations and alleviation's for general aviation aircraft concerning maintenance and continuing airworthiness management.
Sofema Aviation Services considers the new regulation
Subjects Covered
Related to Commission Regulation (EU) No 1321/2014 & the introduction of simplified Continuous Airworthiness (CAW) requirements corresponding to the lower risks associated with light aircraft in general aviation, which is not listed in the air operator certificate of an air carrier.
Related to Aircraft Maintenance Programmes (AMP) airworthiness reviews and deferment of defects.
As a consequence, a new organization approval with less stringent requirements and combined privileges for maintenance, continuing airworthiness management and airworthiness reviews and permits to fly should be introduced. (Contracting to Part 145 is allowed.)
Safety Risk Management within the CAMO
The CAMO has a responsibility as part of the operators AOC to manage Safety in accordance with 965 /2012 (and ultimately ICAO Annex 19 - author's note!)
Subpart G of Annex I does not currently contain any requirements for safety risk management within the CAMO.
Therefore, a management system of CAMOs, including safety risk management for organizations that manage the continuing airworthiness of aircraft used by AOC holders, should be introduced.
Note - There is nothing new here and this obligation has been visible in ICAO since January 2009 and visible in EASA since the issue of 965/2012.
That management system should apply to all CAMOs that manage the continuing airworthiness.
A sufficient transition period should be provided for organizations involved in the continuing airworthiness of aircraft and components to ensure compliance with new rules and procedures introduced by this Regulation.
Note - EASA does not state the transition nor provide guidance in the way that was originally provided by NPA 2013- 01 (over 6 years ago).
Never make the mistake of treating EASA compliance as a destination it is a step on the journey!
Alleviation
In order to ensure proportionate rules for aircraft other than complex motor-powered aircraft and not listed in the air operator certificate of an air carrier licensed in accordance with Regulation (EC) No 1008/2008, safety management principles should not apply to combined airworthiness organizations.
It is also appropriate to align the requirements for the competent authorities with the developments of safety management concepts by the International Civil Aviation Organisation, in particular as regards the introduction of the authority management system, as well as the implementation of the state safety program and ensuring coordination between authorities.
A wrong airworthiness assessment of the aircraft due to incomplete continuing airworthiness records can pose a risk to flight safety. Therefore, the existing rules related to continuing airworthiness records should be amended.
Final Note - It appears that EASA has issued a regulation that is telling itself to issue requirements related to SMS in a Part M CAMO.
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