Maintenance Annex Guidance Contracting Requirements

Sofema Online (SOL) www.sofemaonline.com considers the requirements to comply with Maintenance Annex Guidance (MAG) change 8

Introduction      

Contracting to EASA-approved Facilities

If the repair station sends an article to another organization that is EASA-approved and FAA-certificated, and that person or entity exercises the privileges of its certificate by assuming responsibility for approving for return to service each item on which it has worked, that process is not considered contracting (Ensure the contracted organization is properly certificated to perform that work.)

The FAA accepts EASA Part 145 requirements for the MOE to contain a list of all contractors utilized by the AMO and approved by the AA as part of the MOE.

>> The list contains the name, address, certificate and rating if applicable.

o The AMO to identify contractor(s) the AMO will use to support maintenance activities for U.S.-registered aircraft or aeronautical products & make the list available to the FAA in the English language on request.

Contracting FAA Approval is required when

>> Entering into an agreement with another person or entity (FAA-certificated or non-certificated) to perform maintenance functions on an article; and
>> The repair station chooses to exercise the privileges of its certificate and assumes responsibility for the work performed by the contracted person or entity.

An FAA-certificated part 145 repair station may contract an approved maintenance function pertaining to an article to an outside source.

Note 1: Contracting is sometimes referred to as subcontracting. For the purposes of this section, the term contracting includes subcontracting). There are two elements to the contracting provisions of the MAG.

Note 2: (EASA recognizes contracting as a transfer of responsibility & subcontracting retention of responsibility so the possibility of confusion ref Note 1)

Qualifying and Auditing The Contractor

The repair station will qualify and audit contractors performing maintenance functions.

>> If the repair station contracts a maintenance function to a non-EASA-approved source, the repair station must be appropriately rated to perform the work.
>> Any non-EASA-approved contractor to which work is contracted must be under the control of the repair station’s QAS.

o Compliance with this supplement must be ensured for each contracted maintenance function.

Auditing Requirements 

>> Procedures the organization uses when auditing contractors and the frequency of such audits.
>> Procedures for recording the results of such audits, include the record-retention period for the results of each audit.
>> Procedures the organization will use to ensure that contractors comply with operators’ manuals, manufacturers’ manuals, and ICA.
>> Describes how contractors are informed of any changes to these manuals and procedures.

Note: If the originating repair station must disassemble the article/item on which the maintenance function was performed under contract in order to determine the quality of the work performed, then the maintenance function should not be contracted to a non-EASA-approved source.

Contracting to FAA-Certificated Facilities

If the AMO contracts a maintenance function to another organization that is FAA-certified responsibility transfers.

The organization will determine that the FAA-certificated organization to which work is contracted is properly certificated to perform that work. 

Receiving Inspections

>> The organization’s procedures for inspecting the work performed by a contractor on an item that has been approved for release or return to service.
>> The procedures the organization uses to provide technical training for receiving inspection personnel who inspect contracted work.
>> The procedures the organization will use to ensure that items on which contracted work has been performed are properly processed through the organization’s receiving inspection procedures.
>> Receiving inspection procedures in enough detail to enable a receiving inspector to make an airworthiness determination of any item received based on a technical review of the contractor’s source documentation.
>> Identify the method of recording the contractor’s work and the record retention period.

Next Steps

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