Brief Introduction to EASA Regulatory Changes - What has happened on 24 March 2020?

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1. Part M is split into 2 Part ML & Part M

A long time coming Part M one size fits all was not working in the best way so EASA took the initiative and created Part M Light - EASA Part ML (Annex Vb). Part ML is a stripped down version of Part M requirements and is only applicable for private aircraft up to 2730 KGS.

Note 1 other Private Aircraft must follow Full PART M.

2. What is Part ML All About? Part-ML simplifies existing maintenance rules and offers a less prescriptive approach to maintenance programmes, airworthiness reviews, defects deferments and Time Between Overhauls (TBO) extensions. It also provides additional privileges for pilots, owners, independent certifying staff and small maintenance organisations.

For example:

The CAA will no longer be involved in the approval of maintenance programmes for Light Aircraft.

A new Airworthiness Review Certificate (EASA Form 15c) is introduced that can be issued by the CAA, by an approved organisation or by independent Part-66 engineers with an appropriate authorisation.

Part-ML applies to the following aircraft when not listed in the air operator certificate (AOC) of an air carrier licensed in accordance with regulation (EC) No 1008/2008 and not classified as a complex motor-powered aircraft. (It is applicable to both private and commercial operations of aeroplanes):

Aeroplanes of 2730 kg maximum take-off mass (MTOM) or less Rotorcrafts with a 1200 kg MTOM or less, certified with a maximum of 4 occupants.

Other EL2 aircrafts (Note - This means that all sailplanes and balloons are also included.)

3. Main Benefits of Part-ML Light

The main benefits are that:

- It is simple to understand.

- It does not require the approval of the maintenance program by the national authorities and deviations to the manufacturer recommendations are possible.

- Airworthiness reviews can be performed also by maintenance organizations and independent certifying staff - The pilot can defer certain defects without the involvement of maintenance personnel.

Note - Part ML does not include either a quality (compliance) or safety system - SMS is NOT required and Compliance is covered by Part CAO Organisation Approval.

4. No More Part M Subpart F or Part M Subpart G

Both their approvals are no longer available and will be transitioned through to September 2021 in the meantime they remain valid for existing holders. Part M Subpart F will be known as Part MF until fully transitioned. Part M Subpart G will be known as Part MG until Fully transitioned.

5. What happened to Part M Subpart F?

Actually it has been rebranded as PART CAO (Part Continuing Airworthiness Organisation ) but this is only ½ the story as it is possible to combine with CAMO approval and to “manage the aircraft Continuing airworthiness” but only for Non Complex & Private Aircraft.

6. What happened to Part M Subpart G? 

It will be replaced by Part CAMO which is essentially the management system approach applied to the CAMO environment. PART CAMO is mandatory for Large Private Aircraft & ALL Commercial Air Transport (Air Carrier) Aircraft.

7/ PART CAO includes What? Everything to manage the maintenance on Non Complex aircraft using up to 2730Kg Part ML and over 2730 to include all Non Complex Aircraft using Part M. Plus it provides an opportunity to also manage Airworthiness Reviews for Non Complex Aircraft using EASA Form 15C.

Note - Part CAO includes a Quality System but does not include a Safety System.

8. Part CAMO is for What? 

For all large aircraft regardless and for all Commercial Air Transport (Air Carrier) Aircraft, It is based on the EASA Management System Configuration (SMS & Compliance).

Note - there is no Part CAMO -“Small” so if your aircraft is Non – complex then you still need to demonstrate full compliance with Part CAMO.

9. So where is the Safety Management System - SMS?

SMS is found in Part CAMO along with Compliance Management and mandatory/voluntary reporting.

Note - there is NO SMS associated with Part CAO or Part ML.

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