EASA Competent Authority Regulatory Obligations related to Aircraft Maintenance Program (AMP) Compliance

Sofema Online (SOL) www.sofemaonline.com considers the Regulator Oversight of Aircraft Maintenance Programs (AMP)

Introduction

The Agency is, on behalf of the Member States, the competent authority for initial airworthiness as per Article 77(1) of Regulation (EU) 2018/1139 (the EASA ‘Basic Regulation’). Following M.A.302(d)(2), ICA shall be the basis to develop an AMP. 

Whilst the Member State’s CA is responsible for approving the AMP, they should not normally impose such as national requirements, in addition to the instructions for continuing airworthiness (ICA) issued by the design approval holder during the certification process with the Agency.

» CA May issue alternate instructions to ICA when such instructions aim to offer flexibility to the operator [AMC M.A.302(d) point (2)].
» CA may issue where no ICA issued by DAH 

AMP Review

The AMP shall be reviewed annually. 

Such a review allows determining if an AMP revision is necessary to still comply with the obligations of M.A.302(h), and ensure that the AMP continues to be valid in light of the operating experience. 

Note - As a minimum, point (3) of AMC M.A.302 states it should be at least annually.

» Should not prevent amending the AMP outside of this formal periodic review, when a specific need arises.

o   In-service experience (e.g. adverse trend),

o   Instruction revisions (e.g. significant reduction of TBO (time between overhaul)),

o   Number of instruction revisions (amount of affected tasks)

o   Source of instruction revisions (e.g. MRBR, ALS, etc.)     

Note – for an ALS more restrictive task EASA will issue AD – AMP should be reviewed

» For approved AMP, the review can be done either by the Airworthiness Review Staff (ARS) during the airworthiness review or by the CAMO itself.
» Any discrepancies on the aircraft linked to deficiencies in the content of the aircraft maintenance program, the AMP must be amended.
» CA shall be informed in the case where the ARS does not agree with the measures taken to amend the AMP.  

In accordance with M.A.302(h), the Aircraft Maintenance Programme (AMP) shall be subject to ‘periodic reviews’ and amended accordingly when necessary.  

This means that the owner/operator/CA(M)O should review at a regular interval: 

» New/modified maintenance instructions by the TC holder, 
» Modifications and repairs embodied in the particular a/c, which may require compliance to additional maintenance instructions (by Design Approval Holder),
» In-service experience collected for the particular a/c or for the fleet and

changes in the type and specificity of operations. 

Such a review allows determining if an AMP revision is necessary to still comply with the obligations of M.A.302(h), and ensure that the AMP continues to be valid in light of the operating experience. 

AMP Revision Policy - When managed by a CAMO

» Describe the AMP revision policy (including ‘periodic review’)

o   1.2 [Appendix V to AMC M.A.704],

o   1.2 [AMC1 CAMO.A.300]  

o   D.3 [AMC1 CAO.A.025]

» In the event of AMP – “Source Document Change – With No Relevant Effect ” use Indirect approval (if granted) - M.A.302(c) to amend source document references in the AMP. 

AMP Task Interval Amendment

» AMP continues to be valid in light of the operating experience [M.A.302(h)
» Analysis of the effectiveness of the AMP (if required by M.A.301(e)),

o   AMC M.A.301(e) Continuing airworthiness tasks - ED Decision 2020/002/R - The CAMO managing the continuing airworthiness of the aircraft should have a system to analyze the effectiveness of the maintenance program, with regard to spares, established defects, malfunctions, and damage, and to amend the maintenance program accordingly.

» AMP procedure to manage escalation [AMC M.A.302 point (4) and point (2) of AMC M.B.301(c)].
» Supported by a formal reliability program if required by M.A.302(g) or voluntarily implemented [AMC M.A.302(d) point (6)] or collection and analysis of in-service experience.

Escalation Approval Notes

» Escalation of mandatory tasks represents a change of the initial type design and therefore must be discussed and agreed between the DAH and the Agency (Following a positive evaluation, direct approval of the AMP revision will be issued by the competent authority, as stated in M.A.302(e).
» De-escalation of task intervals (i.e. ‘more restrictive intervals’). Regardless of the source of the task, this may be eligible for indirect approval
» The operator selected or voluntary basis  or manufacturer recommendations outside ICA  - Indirect approval
» Additional and de-escalated tasks may originate from the reliability program as indicated in point (4) of AMC M.A.302(g).
» Concerning changes in task type GVI to DVI  or OP Chk to FNC Chk related to Safety should be approved by CA  (For Non-Safety - eligible for Indirect Approval)
» Indirect approval procedures used for non-safety-related tasks

o    De-escalated tasks

o   Additional tasks (editorial issues, typos, etc., (No effect on the AMP content)

o   Ref M.A.302(c) and M.B.301(c), the CAME (Continuing Airworthiness Management Exposition) a procedure describing as a minimum:

» Which AMP amendments are eligible for indirect approval;
» Who in the organization is responsible to issue the indirect approval;
» How the amendments are controlled; and
» How and when the competent authority is informed of an AMP amendment.

Next Steps

Sofema Aviation Services (www.sassofia.com) and Sofema Online (www.sofemaonline.com) provide EASA Compliant Maintenance Planning Regulatory & Vocational Training – please see the websites or email team@sassofia.com