looks at Maintenance Oversight and Compliance with FAR 25 / CS 25

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SofemaOnline (SOL) is a service provided by Sofema Aviation Services, offering a range of EASA compliant online video regulatory courses.

SOL is supported by European Aviation Institute (EAI) an EASA Part 147 approved Maintenance Training Organization (MTO) with Certificate of Approval No RO.147.0003.

An essential role of the Part M CAMO organization is to provide oversight of the 145 process. There are a number of ways to look at this.

Consider the Part M Obligations of Maintenance Oversight

The relationship between the Operator’s Part M and the 145 organization is contractual – means that the 145 is responsible to deliver the maintenance fully in compliance with all requirements and on completion to provide a CRS for the maintenance which is performed.

The Operator “must” at all costs minimize its exposure and risks including any associated with the maintenance product.

Should anything happen then it is the good name of the operator rather than the maintainer which is damaged.

In accordance with the requirements of M.A.712 Quality system, The Operators CAMO has a direct responsibility to ensure compliance with the following:

- Monitoring that all activities carried out under Section A, Subpart G of this Annex (Part M) are being performed in accordance with the approved procedures
- Monitoring that all contracted maintenance is carried out in accordance with the contract
- Monitoring the continued compliance with the requirements of this Part

So where is the exposure? In fact there is a significant exposure which derives from the standards that the EASA approved 145 organization follows.

There are a number of “holes” or exposures – even though EASA have been lobbied many times there are no “specific regulatory requirements associated with the training standard associated with the inspection of the aircraft.

Consider the requirements of CS 25.1707 System Separation; EWIS (See AMC 25.1707)

Put simply systems & wiring do not chafe overnight, it takes a long time for pipes, tubes and electrical wire to rub together. Typically this is more than sufficient time if the competence of the inspectors is maintained to the highest level.

But what is “the highest level” In fact the 145 organization in the final analysis is left to determine this for itself.

So the challenge thus becomes to train assess evaluate the aircraft inspectors – to maintain the standards and to manage the system in an efficient and effective way.

It therefore becomes a relatively simple task for the Part M Quality System – both in respect of QC & QA to assess whether the 145 organization really has got to grips with the management of Inspection standards.

But how often is this element audited in depth by the operator?

The answer is not often enough and after the event it is too late off course.

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