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									               NPA 2007-09

               WG145.012: Single and
               multiple releases

                                 Juan Anton




05 July 2007                             Cologne
           European Aviation Safety Agency


               Current certification system

Current Part-145 requirements for certification of
aircraft maintenance:

145.A.50(a): “A certificate of release to service shall be
issued by appropriately authorised certifying staff when
it has been verified that …..”

145.A.50(b): “A certificate of release to service shall be
issued before flight at the completion of any
maintenance”.




05 July 2007            WG 145.012: Single and multiple releases   Slide 2
           European Aviation Safety Agency


               Current certification system

Currently, two different certification systems coexist in
Europe:

   Single release:
      Maintenance tasks are signed-off by authorised
      personnel.
      A final CRS is issued before flight by certifying
      staff.

   Multiple release:
      Each organisation may issue one or several CRS,
      each one of them covering one or several tasks.



05 July 2007            WG 145.012: Single and multiple releases   Slide 3
           European Aviation Safety Agency


               Current certification system

Single release system:

    Advantages:

         All actions are certified by a single person who is
         also responsible for coordination.

         The pilot knows that when the CRS is issued it
         means that all maintenance has been completed
         and the aircraft is ready for service.




05 July 2007            WG 145.012: Single and multiple releases   Slide 4
           European Aviation Safety Agency


               Current certification system

Single release system:
    Shortcomings:
      It is not clear how this system can address the
      case where several organisations are involved:
         Which organisation is responsible for the final
          CRS?
         The person issuing the final CRS must have
          capability to sign for all the work.
         The person issuing the final CRS is responsible
          for the work performed by all organisations.
      Usually, in this case, the system becomes a
      Multiple Release System where each organisation
      issues a CRS for its own work.
05 July 2007            WG 145.012: Single and multiple releases   Slide 5
           European Aviation Safety Agency


               Current certification system

Multiple release system:

    Advantages:
      From a practical point of view, the system is more
      flexible, allowing each individual to be responsible
      for his own work.
      It allows, in Line Maintenance, the use of several
      category A certifying staff, without intervention of
      B1 or B2 license holders.




05 July 2007            WG 145.012: Single and multiple releases   Slide 6
           European Aviation Safety Agency


               Current certification system

Multiple release system:

    Shortcomings:
      When several organisations or individuals are
      involved in a maintenance event, there could be
      lack of coordination (work performed in 2 engines
      requiring in some cases a flight test, functional
      tests that can not be performed until another
      organisation finishes its work….)
      It is more difficult to ensure compliance with all
      the work ordered by the operator.
      It is more difficult for the pilot to know when all
      maintenance has been completed and when the
      aircraft is ready for service.

05 July 2007            WG 145.012: Single and multiple releases   Slide 7
           European Aviation Safety Agency


               Current certification system

Issues related to the coexistence of both systems

    In addition to lack of standardisation, there may be
    safety issues:

Example:
   An operator performing maintenance in different
    countries may receive release documentation
    issued under both systems. This may lead an
    operator used to receive a final CRS to think that
    the aircraft is ready for service when receiving a
    CRS under a multiple release system, which may
    not be true.

05 July 2007            WG 145.012: Single and multiple releases   Slide 8
           European Aviation Safety Agency


               Task 145.012

    A working group was created, with members from
    Industry, NAA´s and EASA.

    12 meetings (2 full days each) were held between
    July 2005 and April 2007

    Very different points of view.

    Rulemaking action would affect only Part-145
    organisations. Subpart-F environment requires a
    much lower level of coordination (more simple
    maintenance requirements & fewer contracted
    organisations)

    Rulemaking action affects aircraft maintenance (not
    component maintenance).
05 July 2007            WG 145.012: Single and multiple releases   Slide 9
           European Aviation Safety Agency


               Possible options

    Option 1: Do nothing (coexistence of 2 systems)

    Option 2: Single CRS with coordination (currently exists):
      Base Maintenance: tasks are signed-off. Each
      organisation issues a CRS and there is a final CRS.
      Line Maintenance: tasks are signed-off and there is a
      final CRS.
      No formal concept of PMO (Primary Maintenance
      Organisation) responsible for coordination and issuance
      of final CRS.
      The final CRS certifies that the aircraft is ready for
      service but the other CRS don´t.

    Option 3: Multiple CRS (currently exists)
      One or several CRS issued by each organisation, both in
      line and base maintenance. Each CRS covers one or
      several tasks.
05 July 2007            WG 145.012: Single and multiple releases   Slide 10
           European Aviation Safety Agency


               Possible options

    Options 4a & 4b: Multiple maintenance certification and
    final CRS
       One or several MRC (Maintenance Release Certificate)
       issued by each organisation. Final CRS issued by PMO.
       Different options in line maintenance depending on
       whether the organisation issuing the final CRS is the
       one that performed the maintenance or not. May not be
       necessary the issuance of the MRC.

    Option 5:
      One MRC issued by each organisation both in line and
      base maintenance. Final CRS issued by PMO.




05 July 2007            WG 145.012: Single and multiple releases   Slide 11
           European Aviation Safety Agency


               Possible options


    A consensus could not be reached as to what option
    should be selected, and an Option 6 was proposed
    (combination of Options 2, 4a, 4b and 5). This Option
    6 was agreed by the majority of the group.

    Option 6 was based on the concepts of Maintenance
    Release Certificates (MRC) and final CRS issued by a
    Primary Maintenance Organisation (PMO) nominated
    by the operator.




05 July 2007            WG 145.012: Single and multiple releases   Slide 12
           European Aviation Safety Agency


               Option 6: Key aspects

    Initially, Option 6 consisted of:

         Base Maintenance: An MRC issued by each organisation
         and final CRS issued by PMO. Both MRC and CRS signed
         by certifying staff.

         Line Maintenance: At least 1 MRC per organisation for
         each license category and final CRS issued by PMO. Both
         MRC and CRS signed by certifying staff.

    After further development to cover cases where there is
    additional line maintenance performed after base
    maintenance, Option 6 resulted in the following concept, as
    proposed by the NPA (including a BMRC)


05 July 2007            WG 145.012: Single and multiple releases   Slide 13
           European Aviation Safety Agency

                Primary Maintenance Organisation
                             (PMO)

    The Operator nominates a PMO (M.A.708(b)7 and AMC):
         Base Maintenance: the organisation performing the majority of
         maintenance (linked to number of tasks or man-hours or
         number of affected systems). Should be the organisation with
         the broadest view and control of the base maintenance event.
         Line Maintenance: the organisation that will be responsible for
         issuing the CRS.
         Nomination may be included in the maintenance contract or in
         the work order. It can be a long term agreement or single
         event agreement.
         Between two flights the operator may nominate one PMO for
         base + line or one for base and another for line. It must be
         clear. Only 1 PMO at each particular moment.
         If the PMO is changed, the operator should provide the new
         PMO all the necessary information regarding the previous
         maintenance.


05 July 2007            WG 145.012: Single and multiple releases   Slide 14
           European Aviation Safety Agency


               Certification of aircraft maintenance


    The certification of maintenance shall include
    (145.A.50(a)):

         Maintenance Release Certificates (MRC), and

         Base Maintenance Release Certificate (BMRC), if
         applicable, and

         Certificate of Release to Service (CRS).

    A key aspect is that a single CRS must be issued before
    flight, ensuring to the pilot that the aircraft is ready for
    service (always in relation to the maintenance ordered by
    the operator, who retains the final responsibility for the
    airworthiness of the aircraft and for contracting the
    required maintenance)

05 July 2007            WG 145.012: Single and multiple releases   Slide 15
           European Aviation Safety Agency

               Maintenance Release Certificates (MRC)
                         (responsibilities)

    The MRC is issued when: (145.A.50(b)(1)
    and AMC)

         The maintenance ordered to that organisation has
         been properly carried out in accordance with Part-
         145, and

         The maintenance performed by contracted Part-
         145 organisations has been coordinated and the
         MRCs have been received, and

         Outstanding defects and non-compliances have
         been properly recorded and notified to the PMO.


05 July 2007            WG 145.012: Single and multiple releases   Slide 16
           European Aviation Safety Agency

               Maintenance Release Certificates (MRC)
                         (responsibilities)

      Other aspects of the MRC:

         The MRC does not imply that the aircraft is ready
         for service.
         Allows the certification of maintenance even if the
         aircraft has been left in a non-approved
         configuration (engine removed, crack found after
         NDT, etc).
         Not responsible for the work performed by
         contracted Part-145 organisations nor for the
         qualification of their personnel (they issue their
         own MRC).


05 July 2007            WG 145.012: Single and multiple releases   Slide 17
           European Aviation Safety Agency

               Maintenance Release Certificates (MRC)
                       (who issues the MRC)

    The MRC is issued by: (145.A.50(b)(1))

         For Base Maintenance: An MRC issued by each Part-145
         organisation, using:
           Category C certifying staff.
           Organisations other than PMO may use:
               B1/B2/A certifying staff if tasks performed under line
                maintenance approval.
               NDT certifying staff for D1 rated organisations.

         For Line Maintenance: At least one MRC issued by each Part-
         145 organisation, using:
                B1/B2/A certifying staff.
                NDT certifying staff for D1 rated organisations.



05 July 2007            WG 145.012: Single and multiple releases   Slide 18
           European Aviation Safety Agency

               Maintenance Release Certificates (MRC)
                 (comparison with current system)

   For Base Maintenance:
     The MRC is similar to the current CRS issued by
     each organisation in Base Maintenance.

   For Line Maintenance:
     The MRC is similar to the current CRS issued in:
         multiple release systems;
         single release systems prior to the issuance of
           a final CRS.
     It is also a flexible system because each
     organisation can choose whether it issues one MRC
     to cover all tasks or issues an MRC for each single
     task.


05 July 2007            WG 145.012: Single and multiple releases   Slide 19
           European Aviation Safety Agency

               Maintenance Release Certificates (MRC)
                 (comparison with current system)

Similarly to the current CRS, each organisation issuing
an MRC takes full responsibility for the work performed.

The MRC allows the certification of maintenance also in
the following cases:

          The organisation has received a Work Order that
          leaves the aircraft in a non-approved
          configuration (removal of engine, NDT inspection
          which detects a crack out of limits….)
          The organisation leaves uncompleted work to be
          finished by another organisation.

In both cases non-conformances need to be recorded
and notified to the PMO.

05 July 2007            WG 145.012: Single and multiple releases   Slide 20
           European Aviation Safety Agency

               Base Maintenance Release Certificate
                    (BMRC) (responsibilities)

    The BMRC is issued by the PMO when: (ref.
    145.A.50(b)(2) and AMC)

         All required MRCs have been issued, and

         All the maintenance ordered by the operator in a
         Base Maintenance event has been completed or
         properly deferred, and

         All activities were properly coordinated, and

         There are no non-compliances which are known
         that seriously hazard the flight safety.

05 July 2007            WG 145.012: Single and multiple releases   Slide 21
           European Aviation Safety Agency

               Base Maintenance Release Certificate
                    (BMRC) (responsibilities)

      Other aspects of the BMRC:

         The BMRC does not imply that the aircraft is ready
         for service.

         Proper coordination between organisations must
         be ensured.

         The PMO is not responsible for the work
         performed by the other Part-145 organisations nor
         for the qualification of their personnel (they issue
         their own MRC).

05 July 2007            WG 145.012: Single and multiple releases   Slide 22
           European Aviation Safety Agency

               Base Maintenance Release Certificate
                 (BMRC) (who issues the BMRC)



    The BMRC is issued by: (ref.145.A.50(b)(2))

      Category C certifying staff of the PMO.




05 July 2007            WG 145.012: Single and multiple releases   Slide 23
           European Aviation Safety Agency
               Base Maintenance Release Certificate
                (BMRC) (comparison with current
                            system)


Currently, in a pure single release system, a final CRS is
issued after Base Maintenance covering the CRS issued
by each organisation. However, it is not clear what
responsibility assumes the organisation who issues the
final CRS in relation to the work performed by the other
organisations.

In the proposed system the BMRC is issued after Base
Maintenance, without assuming the responsibility of
the work already certified by each MRC.




05 July 2007            WG 145.012: Single and multiple releases   Slide 24
           European Aviation Safety Agency
               Base Maintenance Release Certificate
                (BMRC) (comparison with current
                            system)

Question: If the BMRC is equivalent to the current final
CRS after Base Maintenance, why we don´t call it CRS?

The reason is that there are cases where, after the Base
Maintenance is finished, there is a need to perform
additional Line Maintenance, even changing
organisations.

Nevertheless, the BMRC certifies that all the work
ordered in the Base Maintenance event has been
performed or properly deferred.



05 July 2007            WG 145.012: Single and multiple releases   Slide 25
           European Aviation Safety Agency

               Certificate of Release to Service (CRS)
                          (responsibilities)

    The CRS is issued by the PMO when:
    (145.A.50(b)(3) and AMC):

         All required MRCs for Line Maintenance and the
         BMRC for Base Maintenance, as applicable, have
         been issued, and

         All the maintenance ordered by the operator has
         been completed or properly deferred, and

         All activities were properly coordinated, and

         There are no non-compliances which are known
         that seriously hazard the flight safety.


05 July 2007            WG 145.012: Single and multiple releases   Slide 26
           European Aviation Safety Agency

               Certificate of Release to Service (CRS)
                          (responsibilities)

      Other aspects of the CRS:

         If the operator nominates a PMO responsible for
         issuing the CRS different from the one that issued
         the BMRC, the operator is responsible for
         informing the new PMO about the maintenance
         already performed and any possible conflicts with
         the new maintenance to be performed.

         The PMO is not responsible for the work certified
         by the MRC´s and BMRC issued by other
         organisations nor for the qualification of their
         personnel.

05 July 2007            WG 145.012: Single and multiple releases   Slide 27
           European Aviation Safety Agency

               Certificate of Release to Service (CRS)
                        (who issues the CRS)

    The CRS is issued by the PMO using: (ref.
    145.A.50(b)(3))

         Category B1 or B2 certifying staff (any of them),
         or

         Category C certifying staff when no line
         maintenance has been performed after the
         issuance of the BMRC.

         Category A certifying staff when no Base
         Maintenance has been performed and all the Line
         Maintenance has been performed by this person.

05 July 2007            WG 145.012: Single and multiple releases   Slide 28
           European Aviation Safety Agency


                               Conclusions

    Appropriate coordination is ensured by the PMO, both
    in Line & Base maintenance.

    Each organisation issuing an MRC takes full
    responsibility for the work performed and the
    qualification of its personnel.

    The BMRC certifies that all the work ordered in a
    Base maintenance event has been completed or
    properly deferred.

    During a Base Maintenance event it is possible to
    include also Line Maintenance Tasks, and cover all of
    them within the BMRC.

05 July 2007            WG 145.012: Single and multiple releases   Slide 29
           European Aviation Safety Agency


                               Conclusions

    One single certificate can accommodate MRC, BMRC
    and CRS.

    Different types of Technical Log can be developed to
    fit current existing systems:
        Each maintenance action is issued an MRC, or
        Each maintenance action is signed-off and one or
        several MRCs are issued combining several tasks.

    The system is very flexible and does not require to
    assume responsibility for the work performed by
    other organisations.

    The system very clearly delimits the responsibility of
    each organisation.

05 July 2007            WG 145.012: Single and multiple releases   Slide 30

								
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