I will begin the overview of the airworthiness regulations by a quick look at the European laws as created by EASA and put in force by the European Commission. The result of this process is European Commission Regulation EC No. 2042/2003 with all its further amendments, and in particular – EASA Part M of this regulation which specifies airworthiness requirements for EU based carriers and aircraft.
First of all, I believe that for those of you who are not EU citizens it may not be quite clear how the legislative process in the Union actually works. This is normally the way things are done with aviation (but not only aviation) legislation in the EU:
- An European Agency (such as EASA – the European Aviation Safety Agency) creates a draft to a law / legislation which is intended to be applied throughout the European Member States
- The European Commission releases the work of the Agency in the form of a Commission Regulation, by means of which the contents of that work actually become binding law within the European Union (although most often with a vacatio legis of sorts – a period before the law actually kicks in, allowing member states, companies and individuals to prepare themselves for the new regulations.
- The member states (as in all the European countries) must adjust their national regulations to match the Commission Regulations which has been issued by the European Commission.
- Companies and/or individual have to obey by the new law.
So that’s generally how it’s done. Of course, there are plenty of problems with this process as many countries tend to be slower at implementing the EU laws and some, at times, may even refuse to implement it altogether. But that’s certainly outside the scope of this post.
To make a long story short, in 2003 the European Commission has released Commission Regulation EC No. 2042/2003 “on the continuing airworthiness of aircraft and aeronautical products, parts and appliances and on the approval of organizations and personnel involved in these tasks.” A hell of a title, is it not?
This regulation has a few annexes to it, more commonly known as “parts” (they’re actually called that in the regulation itself – so you get Annex I to EC 2042/2003 – Part M – go figure). Here are the four parts which most likely will be of interest to readers on Airline Basics:
- EASA Part M – Continuing Airworthiness Requirements
- EASA Part 145 – Maintenance Organization Approvals
- EASA Part 66 – Certifying Staff
- EASA Part 147 – Technical Training Organizations and Requirements
There’s also Part 21 – with two parts to it, for design and production organizations. We will probably get into that eventually, but not anytime soon as we are dealing mainly with airlines here.
For those of you familiar with the FAA system, the idea will probably be nothing new and neither will the separate “parts” for different regulations, but the numbers are all mixed up. Too bad, it would have been much more congruent otherwise.
Before we go over EASA Part M, which is the main subject of this post, you should also know that each of the aviation regulations (such as EASA Part M) have also two “helpers” in the actual legislation which are known as:
- AMC – Acceptable Means of Compliance – those are quite helpful when setting up a new organization and they give you a look and feel for what the legislator actually expects. The problem is, that even though they do not have to be strictly obeyed (you can do things differently but you need to assure your CAA that your method presents an equivalent safety level) many CAA’s still consider them to be law (or as close to it as possible) and actually penalize airlines for doing things their way. Nevertheless, you better look at them if you want to develop something in accordance with the law.
- GM – Guidance Material – this is not law. In fact, this is more of a story on how to build your time airworthiness department (or maintenance department for that matter). It shows you how you can satisfy the complex requirements in simple but effective ways. However, following those guidelines directly will work only for really small operations (even a “one man show” I dare say). For more complex organizations you need more invention, but still – those are helpful.
OK, I believe that now that I bored you to death with the legislative stuff we can move forward to the actual EASA Part M requirements. The document consists of two main sections. Section A (called the “Technical Requirements” is actually the law which you must obey). Section B (called the “Procedure for Competent Authorities”) is just that – for your CAA. It makes sense to read it through, but it doesn’t apply to you directly, so we won’t be bothering ourselves with it.
Section A of EASA Part M is divided into subparts. Depending on what scope of business you’re in, you will need to work will all of those or just some. Below is a list of all the subparts with a brief explanation on what they are all about and when you may need them:
- Subpart A – General – this is pretty self-explanatory. It tells you what this law is, who it is directed at and so on. Very short subpart, with no actual influence on your operations.
- Subpart B – Accountability – this part defines who is accountable for the oversight of the organization and also how to go about occurrence reporting (who to report to).
- Subpart C – Continuing Airworthiness – this is a very important subpart, as it defines the “meat” of what your airworthiness organization will be all about. It specifies the tasks that need to be done and the AMC will tell you how to do them. Here you will find requirements for a maintenance program, how to handle airworthiness directives and how to keep track of all your airworthiness records. Important part, it’s your airworthiness bible.
- Subpart D – Maintenance Standards – specifies what you need to assure is done during the maintenance of your aircraft. It will also tell you what maintenance manuals and other associated data to use.
- Subpart E – Components – this part was quite overlooked, as it didn’t actually appear with the very first edition of the legislation. It deals with requirements towards components which you install on your aircraft, the certificates which they must have and how to keep track of their records. Furthermore – what’s quite important but often not treated with the right respect – how to handle your unserviceable components (the broken ones, which you just took off your plane).
- Subpart F – Maintenance Organization – this subpart applies only if you are running a maintenance organization for small aircraft not used in commercial aviation. I have no idea why EASA decided to put that particular piece of legislature into this document, as it has nothing to do with airworthiness as such. Still, this is basically the entire EASA Part 145 rewritten and simplified for the smaller guys and put under this one subpart. If you don’t do maintenance on small, non-commercial aircraft – don’t worry about it.
- Subpart G – Continuing Airworthiness Management Organization – this section applies to organizations which want to be EASA Part M certified. In reality, you’re being certified in accordance with EASA Part M Subpart G. This subpart defines certification requirements, what staff you need to employ and how the responsibilities and accountability is divided. It also defines the quality system requirements for the organization (very important) and the privileges a certified entity will have. Does it apply to everyone? Technically no, because in some cases (like one privately owned, non-commercially used small aircraft) the airworthiness tasks may be carried out by the owner without a specific approval. However, for the purpose of this website let’s assume that we’re working with airlines, and each airline need to be certified for EASA Part M Subpart G.
- Subpart H – Certificate of Release to Service – CRS – defines the requirements for a CRS (both for aircraft and components). The CRS is a document which confirms that all maintenance has been done correctly (i.e. in accordance with applicable law) and that the aircraft or a components is fit for service (with respect to that maintenance).
- Subpart I – Airworthiness Review Certificate – the airworthiness review process under EASA is quite complicated and I will try to write a separate article on that. However, the Airworthiness Review Certificate (ARC) is required to accompany the aircrafts Certificate of Airworthiness (C of A) and gives the most basic confirmation that the aircraft is airworthy. This subpart defines how to do the airworthiness review, who can do it, how the certificate is issued and how to transfer it when the aircraft is being moved from operator to operator.
That’s all you’re going to find in EASA Part M. For my liking, this is quite enough
If you want to get the actual legislation, there are two ways:
- You can get the consolidated versions (current, reflecting the actual law at this date) from EASA directly here. The books are great, you get the regulation and the AMC and the GM all in one place and nicely put together. The drawback is, you have to pay for it.
- You can get partially consolidated versions from EUR LEX. Here is the link to the original EC No. 2042/2003. Keep in mind that this regulation has been revised a number of times since it has been originally released, and you need to check all those changes and apply them on your own. They consolidate every now and then, but you can never be sure.
One tip – the title page of the EASA consolidated book gives you all the additions which have been applied to the original regulations and this is available for free here. So you can take a look at that and then search for those updates on EUR LEX. Still annoying, but at least you know you’ll get it right.