Module 10: Aviation Legislation

Module 10: Aviation Legislation

1. Overview of Module 10

Module 10 of the EASA Part-66 basic knowledge syllabus provides the regulatory framework that governs the maintenance, continuing airworthiness, and certification of aircraft within the European Union. This module is essential for all certifying staff as it establishes the legal basis for their licence, privileges, and responsibilities. The module covers the structure of the European Aviation Safety Agency (EASA) regulatory system, the key regulations—specifically Regulation (EU) No 1321/2014 (which contains Part-66, Part-145, Part-M, and Part-CAMO)—and the relationship between the various approved organisations and licensed personnel.

The syllabus is structured to ensure that certifying staff understand not only what they are permitted to do but also the legal and procedural context in which they operate. This includes the conditions for issuing a Certificate of Release to Service (CRS), the limitations of each licence category, the requirements for maintaining licence validity, and the obligations of maintenance organisations.

2. Key Concepts Explained in Detail

2.1 The EASA Regulatory Framework

The European Union aviation safety system is built upon a hierarchy of regulations. The foundational regulation is Regulation (EU) 2018/1139, which established EASA and set out the basic principles for civil aviation safety. Under this framework, the Commission adopts implementing rules, the most relevant for maintenance being Regulation (EU) No 1321/2014. This regulation contains several annexes, each referred to as a "Part":

• Part-66: Certifying Staff – defines the licensing requirements for aircraft maintenance personnel.
• Part-145: Approved Maintenance Organisations – sets the requirements for organisations performing maintenance.
• Part-M: Continuing Airworthiness Requirements – governs the ongoing airworthiness of aircraft, including the Aircraft Maintenance Programme (AMP) and the Technical Log.
• Part-CAMO: Continuing Airworthiness Management Organisations – requirements for organisations managing continuing airworthiness.

These Parts are supported by Acceptable Means of Compliance (AMC) and Guidance Material (GM), which provide non-binding but recommended methods for complying with the regulations. The AMC and GM are essential for understanding the intent of the regulations and for developing compliant procedures.

2.2 The Part-66 Aircraft Maintenance Licence (AML)

The Part-66 AML is the legal document that authorises a person to certify maintenance on aircraft. It is issued by the competent authority of an EASA Member State.

Eligibility Requirements (Part-66.A.15 and Part-66.A.30):

• The applicant must be at least 18 years of age.
• The applicant must have completed the required basic knowledge training and passed the corresponding module examinations.
• The applicant must have completed the required practical maintenance experience (e.g., 2 years for Category A in a maintenance environment, or 3 years for Category B1/B2, with specific reductions for those who have completed an approved training course).
• The applicant must demonstrate the appropriate practical competence.

Licence Categories:

The Part-66 licence is divided into categories and subcategories, each with specific privileges:

• Category A: Line maintenance certifying staff. Privileges are limited to simple scheduled line maintenance tasks and simple defect rectification within the limits specified in Part-66.A.20(a)(1).
• Category B1: Line and base maintenance certifying staff for aeroplane airframe and engine (mechanical systems). They can certify a wider scope of tasks, including complex troubleshooting and repairs.
• Category B2: Line and base maintenance certifying staff for avionics systems.
• Category B3: Certifying staff for non-pressurised piston-engine aeroplanes below 2 000 kg MTOM.
• Category C: Base maintenance certifying staff. They certify the release to service of an aircraft after base maintenance, but only when the work has been performed by appropriately qualified staff (e.g., B1/B2).

Validity of the Licence (Part-66.A.10):

The AML is issued with unlimited validity; it does not have an expiry date. However, the licence holder must meet recent experience requirements to exercise the privileges. Specifically, the holder must have:

• Performed at least 6 months of relevant maintenance experience in the preceding 2 years.
• If this requirement is not met, the holder must undergo refresher training or an assessment before exercising privileges.

2.3 Privileges of Category A Certifying Staff (Part-66.A.20)

Category A is the entry-level certification privilege. The scope of tasks that a Category A holder may certify is strictly defined and limited. The key principle is that the tasks must be simple, scheduled line maintenance tasks and simple defect rectification within the limits of tasks specifically listed in the certifying staff's privileges.

Permitted Tasks (Part-66.A.20(a)(1)):

• Scheduled line maintenance checks (e.g., daily checks, turnarounds, night stops).
• Simple defect rectification (e.g., replacing a wheel and brake unit, replacing a landing gear door latch).
• Tasks that are repetitive, have clear instructions, and do not require extensive troubleshooting.
• Lubrication and servicing tasks that are listed as line tasks in the Aircraft Maintenance Programme.
• Tasks defined by the maintenance organisation's procedures as being within the scope of Category A.

Prohibited Tasks:

• Base maintenance tasks.
• Complex tasks requiring extensive troubleshooting or special test equipment.
• Tasks that are beyond the scope of the specific aircraft type rating held.
• Tasks that are not specifically listed in the certifying staff's scope of work as defined by the Part-145 organisation.

Critical Principle – Direct Supervision:

A Category A certifying staff member may only issue a CRS for tasks they have personally performed or directly supervised. Direct supervision means being physically present and overseeing the work to ensure it is performed correctly. General presence on a shift is not sufficient. Signing a CRS for work that was not personally performed or directly supervised is a serious regulatory violation.

2.4 The Certificate of Release to Service (CRS)

The CRS is the formal document that certifies that maintenance has been performed correctly and that the aircraft is released to service. It is a legal record and must be completed in accordance with Part-145.A.50 and Part-M.A.801.

Conditions for Issuing a CRS:

• The certifying staff member must hold the appropriate Part-66 licence category and type rating for the aircraft.
• The certifying staff member must be authorised by the Part-145 organisation in writing (Part-145.A.35).
• The work must have been performed using approved data (e.g., AMM, task cards).
• The work must have been performed by the certifying staff member or under their direct supervision.
• The aircraft must be in a condition for safe operation.

2.5 The Part-145 Maintenance Organisation

A Part-145 approval is required for any organisation performing maintenance on EU-registered aircraft. The organisation must comply with the requirements of Part-145, which include:

• Facilities and Tooling (Part-145.A.25 and A.30): The organisation must have appropriate facilities, tooling, and materials to perform the maintenance.
• Maintenance Data (Part-145.A.45): Maintenance must be performed using approved data, such as the AMM, task cards, and service bulletins.
• Certifying Staff (Part-145.A.35): The organisation must employ certifying staff who hold the appropriate Part-66 licence and have been authorised in writing by the organisation.
• Quality System (Part-145.A.60): The organisation must have a quality system that includes an audit programme. Internal quality audits must be performed at least once every 12 months to verify compliance with the approved procedures.
• Maintenance Organisation Exposition (MOE): The organisation must have an MOE that describes its procedures and scope of work.

2.6 Third-Country Organisations

Maintenance of EU-registered aircraft may be performed by an organisation located in a third country only if that organisation is approved by EASA or is recognised through a bilateral agreement or equivalent arrangement between EASA and the third country. A national approval from the third country alone is not sufficient.

2.7 The Aircraft Maintenance Programme (AMP)

The AMP is a document that contains the scheduled maintenance tasks and their frequencies. It is developed in accordance with:

• The type certificate holder's instructions (e.g., the Maintenance Planning Document (MPD) or the Airworthiness Limitations Section (ALS)).
• Any additional requirements from the operator or the competent authority.

The AMP is the basis for planning and performing maintenance to maintain the aircraft's airworthiness. It is managed by the Continuing Airworthiness Management Organisation (CAMO) or the owner/operator under Part-M.

2.8 Airworthiness Limitations and the ALS

The Airworthiness Limitations Section (ALS) is a mandatory part of the Instructions for Continued Airworthiness (ICA) for an aircraft type. It contains:

• Mandatory life limits for components (e.g., landing gear, engine parts).
• Mandatory inspection intervals.
• Certification maintenance requirements.

The ALS is defined by the type certificate holder and approved by the authority. It is the primary reference for determining airworthiness limitations and is legally binding.

2.9 Defect Recording and Deferral

When a defect is found during a line maintenance check, the certifying staff must follow the correct procedure:

1. Within Limits: If the defect is within the limits specified in the AMM, it is not a defect requiring rectification. The condition must be recorded in the Technical Log, and the aircraft can be released to service.
2. Outside Limits: If the defect is outside the AMM limits, it must be rectified or deferred.

• Deferral: The defect may be deferred if it is listed in the Minimum Equipment List (MEL). The MEL may have an "M" (Maintenance) procedure, which defines specific maintenance tasks that must be accomplished before dispatch. The certifying staff member may perform the "M" procedure and issue a CRS for that task.
• Rectification: If the defect is not in the MEL, it must be rectified before the aircraft can be released.

The Technical Log is the primary document for recording defects, maintenance actions, and the release to service. It is a legal record that must be completed in accordance with Part-M and Part-145.

3. Important Regulations and Procedures

3.1 Key Part-66 Clauses

3.2 Key Part-145 Clauses

3.3 The Certification Process

The process for certifying a line maintenance task is as follows:

1. Task Identification: The task must be within the scope of the certifying staff's licence privileges and the organisation's approval.
2. Data Availability: The appropriate approved data (e.g., AMM, task card) must be available.
3. Performance/Supervision: The task must be performed by the certifying staff member or under their direct supervision.
4. Defect Assessment: Any defects found must be assessed against the AMM limits and the MEL.
5. CRS Issuance: The CRS is issued in the Technical Log, stating that the maintenance has been performed correctly and the aircraft is released to service.

4. Common Relationships Between Concepts

• Licence Category ↔ Task Scope: The category of the Part-66 licence directly determines the scope of tasks that can be certified. A Category A licence is limited to simple line tasks; a B1/B2 licence covers a wider scope; a C licence is for base maintenance release.
• Type Rating ↔ Aircraft Eligibility: A certifying staff member can only certify work on an aircraft type for which they hold a valid type rating. Experience on other types does not confer eligibility.
• Direct Supervision ↔ CRS Validity: A CRS is only valid if the certifying staff member personally performed or directly supervised the work. Signing a CRS without this is a violation.
• Defect Condition ↔ Release Decision: The decision to release an aircraft depends on whether a defect is within AMM limits (record and release), outside limits but in the MEL (defer with "M" procedure), or outside limits and not in the MEL (rectify before release).
• Organisation Approval ↔ Personnel Authorisation: A certifying staff member cannot exercise privileges without both a valid Part-66 licence and a written authorisation from the Part-145 organisation.

5. Typical Exam Focus Points

Based on the source questions, the exam focuses on the following areas:

• Category A Privileges: Understanding the precise limits of Category A certification, including what is permitted (simple line tasks) and what is not (complex tasks, base maintenance, tasks outside the type rating).
• Direct Supervision: The definition and importance of direct supervision for issuing a CRS. General presence is not sufficient.
• CRS Requirements: The conditions for issuing a CRS, including personal performance or direct supervision, appropriate licence and type rating, and organisation authorisation.
• Licence Validity and Recent Experience: The AML has unlimited validity, but the holder must meet the 6-months-in-2-years recent experience requirement to exercise privileges.
• Minimum Age: The minimum age for an AML is 18 years.
• Defect Handling: The correct procedure for handling defects found during line maintenance, including the use of the AMM, MEL, and Technical Log.
• Third-Country Organisations: The requirement for a bilateral agreement or equivalent arrangement for a third-country organisation to be recognised.
• Quality Audits: The minimum frequency for internal quality audits in a Part-145 organisation is once every 12 months.
• Aircraft Maintenance Programme: The purpose and basis of the AMP.
• Airworthiness Limitations: The ALS as the primary reference for life limits and mandatory inspections.
• Organisation Authorisation: The requirement for a written authorisation from the Part-145 organisation in addition to the Part-66 licence.