Further Considerations Related to EASA Maintenance Check Flights (MCF) & Incomplete Maintenance

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Concerning Certificate of Release to Service issued following incomplete Maintenance Ref Commission Implementing Regulation (EU) 2020/270 & AMC M.A.801(g)(f) Aircraft certificate of release to service

Although of course, the applicable Maintenance Organisation is responsible for the signing of the Certificate of Release to Service, All Continuing Airworthiness Management Organisations (CAMO’s) should ensure that they fully understand their roles and responsibilities related to MCF and that their procedures related to managing and coordinating such MCF are fully integrated into their organisations documented process and procedures to ensure continued compliance as well as the required levels of safety.

Incomplete Maintenance

Certain maintenance data issued by the design approval holder (e.g. aircraft maintenance manual (AMM)) require that a maintenance task be performed in flight as a necessary condition to complete the maintenance ordered.

Within the aircraft limitations, the person authorized to certify the maintenance per M.A.801 should release the incomplete maintenance before this flight.

Authors Note – This is essential to establish that all “other” Maintenance Tasks have been completed – to preclude the danger of the aircraft taking off for a Maintenance Check Flight (MCF)

GM M.A.301(i) describes the relations with the aircraft operator, which retains the responsibility for the MCF. After performing the flight and any additional maintenance necessary to complete the maintenance ordered, a certificate of release to service should be issued in accordance with M.A.801.

Certification of Incomplete Maintenance

Being unable to establish full compliance with sub-paragraph M.A.801(b) means that the maintenance required by the aircraft owner, CAO or CAMO could not be completed due either to running out of available aircraft maintenance downtime or because the maintenance data requires a flight to be performed as part of the maintenance, as described above

Responsibility to Ensure Certification

The aircraft owner, CAO or CAMO is responsible for ensuring that all required maintenance has been carried out before flight.

Therefore, an aircraft owner, CAO or CAMO should be informed and agree to the deferment of full compliance with M.A.801(b).

The certificate of release to service may then be issued subject to details of the deferment, including the aircraft owner, CAO or CAMO authorisation, being endorsed on the certificate.

Note: If a CRS is issued with incomplete maintenance a record should be kept stating what action the mechanic, supervisor and certifying staff should take to bring the matter to the attention of the relevant aircraft owner, CAO or CAMO so that the issue may be discussed and resolved with the aircraft owner, CAO or CAMO.

Next Steps

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