M.A.301 Continuing airworthiness tasks

PRE-FLIGHT INSPECTIONS

1.With regard to the pre-flight inspection, it is intended to mean all of the actions necessary to ensure that the aircraft is fit to make the intended flight. These should typically include but are not necessarily limited to:

(a)a walk-around type inspection of the aircraft and its emergency equipment for condition including, in particular, any obvious signs of wear, damage or leakage. In addition, the presence of all required equipment including emergency equipment should be established.

(b)an inspection of the aircraft continuing airworthiness record system or the aircraft technical log system, as applicable, to ensure that the intended flight is not adversely affected by any outstanding deferred defects and that no required maintenance action shown in the maintenance statement is overdue or will become due during the flight.

(c)a control that consumable fluids, gases etc. uplifted prior to flight are of the correct specification, free from contamination, and correctly recorded.

(d)a control that all doors are securely fastened.

(e)a control that control surface and landing gear locks, pitot/static covers, restraint devices and engine/aperture blanks have been removed.

(f)a control that all the aircraft’s external surfaces and engines are free from ice, snow, sand, dust etc. and an assessment to confirm that, as the result of meteorological conditions and de-icing/anti-icing fluids having been previously applied on it, there are no fluid residues that could endanger flight safety. Alternatively to this pre-flight assessment, when the type of aircraft and nature of operations allow for it, the build-up of residues may be controlled through scheduled maintenance inspections/cleanings identified in the approved maintenance programme.

2.Tasks such as oil and hydraulic fluid uplift and tyre inflation may be considered as part of the pre-flight inspection. The related pre-flight inspection instructions should address the procedures to determine where the necessary uplift or inflation results from an abnormal consumption and possibly requires additional maintenance action by the approved maintenance organisation or certifying staff as appropriate.

3.In the case of air carriers licensed in accordance with Regulation (EC) No 1008/2008, the CAMO should publish guidance to maintenance and flight personnel and any other personnel performing pre-flight inspection tasks, as appropriate, defining responsibilities for these actions and, where tasks are contracted to other organisations, how their accomplishment is subject to the quality system of M.A.712 or the management system required by CAMO.A.200. It should be demonstrated to the competent authority that pre-flight inspection personnel have received appropriate training for the relevant pre-flight inspection tasks. The training standard for personnel performing the pre-flight inspection should be described in the continuing airworthiness management exposition.

1.The operator should have a system to ensure that all defects affecting the safe operation of the aircraft are rectified within the limits prescribed by the approved minimum equipment list (MEL), configuration deviation list (CDL) or maintenance data, as appropriate. Also that such defect rectification cannot be postponed unless agreed by the operator and in accordance with a procedure approved by the competent authority.

2.When deferring or carrying forward a defect rectification, the cumulative effect of a number of deferred or carried forward defects on a given aircraft and any restrictions contained in the MEL should be considered. Whenever possible, deferred defect rectification should be made known to the pilot/flight crew prior to their arrival at the aircraft.

3.In the case of aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008 and of complex motor-powered aircraft, a system of assessment should be in operation to support the continuing airworthiness of an aircraft and to provide a continuous analysis of the effectiveness of the CAMO defect control system in use. The system should provide for:

(a)significant incidents and defects: monitor incidents and defects that have occurred in flight and defects found during maintenance and overhaul, highlighting any that appear significant in their own right.

(b)repetitive incidents and defects: monitor on a continuous basis defects occurring in flight and defects found during maintenance and overhaul, highlighting any that are repetitive.

(c)deferred and carried forward defects: Monitor on a continuous basis deferred and carried forward defects. Deferred defects are defined as those defects reported in operational service which are deferred for later rectification. Carried forward defects are defined as those defects arising during maintenance which are carried forward for rectification at a later maintenance input.

(d)unscheduled removals and system performance: analyse unscheduled component removals and the performance of aircraft systems for use as part of the maintenance programme efficiency.

MAINTENANCE IN ACCORDANCE WITH THE AMP The owner, CAO or CAMO, as applicable, should have a system to ensure that all aircraft maintenance checks are performed within the limits prescribed by the approved aircraft maintenance programme and that, whenever a maintenance check cannot be performed within the required time limit, its postponement is allowed in accordance with a procedure agreed by the appropriate competent authority.

The CAMO managing the continuing airworthiness of the aircraft should have a system to analyse the effectiveness of the maintenance programme, with regard to spares, established defects, malfunctions and damage, and to amend the maintenance programme accordingly.

OPERATIONAL DIRECTIVES Operational directives with a continuing airworthiness impact include operating rules such as extended twin-engine operations (ETOPS) / long range operations (LROPS), reduced vertical separation minima (RVSM), MNPS, all-weather operations (AWOPS), RNAV, etc. Any other continuing airworthiness requirement established by the Agency includes TC-related requirements such as: certification maintenance requirements (CMR), life-limited parts, airworthiness limitations contained in CS-25 Book 1, Appendix H, paragraph H25.4, fuel tank system airworthiness limitations including Critical Design Configuration Control Limitations (CDCCL), etc. The operator is responsible for the incorporation of operational directives (ODs) and in cases where there is an impact on the continuing airworthiness, the CAMO has to assess this and take appropriate actions to ensure the continuing airworthiness. The process to incorporate the ODs should be detailed in an arrangement or common procedure.

MAINTENANCE CHECK FLIGHTS (MCFs)

(a)The definition of and operational requirements for MCFs are laid down in the Air Operations Regulation and are carried out under the control and responsibility of the aircraft operator. During the flight preparation, the flight and the post-flight activities as well as for the aircraft handover, the processes requiring the involvement of the maintenance organisations or their personnel should be agreed in advance with the operator. The operator should consult as necessary with the CAMO in charge of the airworthiness of the aircraft.

(b)Depending on the aircraft defect and the status of the maintenance activity performed before the flight, different scenarios are possible and are described below:

(1)The aircraft maintenance manual (AMM), or any other maintenance data issued by the design approval holder or the declarant of a declaration of design compliance, requires that an MCF be performed before completion of the maintenance ordered. In this scenario, a certificate after incomplete maintenance, when in compliance with M.A.801(f) or 145.A.50(e), should be issued by the maintenance organisation and the aircraft can be flown for this purpose under its airworthiness certificate. Due to incomplete maintenance, for aircraft used in commercial air transport, it is advisable to open a new entry on the aircraft technical log system to identify the need for an MCF. This new entry should contain or refer to, as necessary, data relevant to perform the MCF, such as aircraft limitations and any potential effect on operational and emergency equipment due to incomplete maintenance, maintenance data reference and maintenance actions to be performed after the flight. After a successful MCF, the maintenance records should be completed, the remaining maintenance actions finalised and the aircraft released to service in accordance with the maintenance organisation’s approved procedures.

(2)Based on its own experience and for reliability considerations and/or quality assurance, an operator or CAMO may wish to perform an MCF after the aircraft has undergone certain maintenance while maintenance data does not call for such a flight. Therefore, after the maintenance has been properly carried out, a certificate of release to service is issued and the aircraft airworthiness certificate remains valid for this flight.

(3)After troubleshooting of a system on the ground, an MCF is proposed by the maintenance organisation as confirmation that the solution applied has restored the normal system operation. During the maintenance performed, the maintenance instructions are followed for the complete restoration of the system and therefore a certificate of release to service is issued before the flight. The airworthiness certificate is valid for the flight. An open entry requesting this flight may be recorded in the aircraft technical log.

(4)An aircraft system has been found to fail, the dispatch of the aircraft is not possible in accordance with the maintenance data, and the satisfactory diagnosis of the cause of the fault can only be made in flight. The process for this troubleshooting is not described in the maintenance data and therefore scenario (1) does not apply. Since the aircraft cannot fly under its airworthiness certificate because it has not been released to service after maintenance, a permit to fly issued in accordance with Regulation (EU) No 748/2012 is required. After the flight and the corresponding maintenance work, the aircraft can be released to service and continue to operate under its original certificate of airworthiness.

(c)For certain MCFs the data obtained or verified in flight will be necessary for assessment or consideration after the flight by the maintenance organisation prior to issuing the maintenance release. For this purpose, when the personnel of the maintenance organisation cannot perform these functions in flight, the maintenance organisation may rely on the crew performing the flight to complete this data or to make statements about in-flight verifications. In this case, the maintenance organisation should appoint the crew personnel to play such a role on their behalf and, before the flight, brief appointed crew personnel on the scope, functions and the detailed process to be followed, including required reporting information after the flight and reporting means, in support of the final release to service to be issued by the certifying staff.

MANAGEMENT OF AIRCRAFT CONFIGURATION

(a)For each individual aircraft, aircraft configuration is the consistent set of the aircraft’s functional and physical characteristics, as defined in the applicable documentation and as present on the aircraft, including any hardware or software component. The aircraft configuration is established based on the following elements, as defined and approved in accordance with the applicable regulations and bilateral agreements:

(1)the aircraft, engine and propeller type design;

(2)the embodied changes; for example, minor and major changes, STCs and standard changes;

(3)the embodied repairs;

(4)unintentional deviations from the approved type design occurring in production, sometimes referred to as ‘concessions’, ‘divergences’ or ‘non-conformances’;

(5)design-related requirements established in applicable ADs;

(6)exemptions, waivers or derogations affecting the elements listed above, if appropriately approved. These configuration elements of an individual aircraft are the baseline for determining the aircraft’s conformity with its approved design. A clear understanding of the aircraft configuration is essential to ensure its continuing airworthiness. Additionally, some elements of the configuration of an individual aircraft may influence the environmental certification of the aircraft or engines, or the contents of the aircraft maintenance programme (AMP), the flight manual, etc.

(b)The person or organisation that is responsible for the continuing airworthiness of the aircraft is responsible for managing the aircraft configuration. This includes ensuring that: — all data necessary to determine the approved configuration is available; — no conflicts exist between the configuration elements referred to above that could affect the airworthiness of the aircraft; — the aircraft conforms to its approved design.

CONFLICT BETWEEN CONFIGURATION ELEMENTS

(a)Ensuring that there are no conflicts between the different configuration elements involves identifying any potential conflicts with previously embodied configuration elements prior to the embodiment of a new configuration element, such as a new modification or repair. This is necessary because the design approval holder, or declarant of a declaration of design for a particular modification or repair, cannot in all cases be expected to be aware of all the possible configuration elements embodied on all aircraft of a given type. In many cases, this verification may be limited to ensuring the absence of interfaces between configuration elements. For example, this may apply to repairs carried out in accordance with the SRM in areas where no other structural modifications or repairs are present. In addition, in some cases, the absence of conflicts may be ensured in cases in which a modification or repair has been specifically designed for an individual aircraft, taking into account its configuration during the design process. In concerns arise, and the person or organisation responsible for the continuing airworthiness of the aircraft is unable to determine the absence of conflicts affecting the airworthiness of the aircraft, assistance from an appropriately approved design organisation should be sought.

(b)The following list, although not exhaustive, provides examples of combinations of installations which have the potential to create compatibility issues; for example, the installation of: — autopilots on aircraft with other modifications that alter flight characteristics, including the lift, drag, weight and thrust of aircraft. The cumulative effect of multiple modifications that individually increase drag should not be disregarded; — multiple accessories mounted on the skid tubes of helicopters; — changes to or the introduction of new operating limitations or procedures. This would include multiple flight manual supplements affecting the same or interconnecting systems; — multiple modifications to the same structure (the superposition of stresses, changes in stiffness, or changes to safe life, fail safe, or damage tolerance characteristics should be considered); — any software changes in interdependent systems; — modifications to light-emitting or reflecting characteristics (internal and/or external) of aircraft with night vision imaging system (NVIS) lighting systems; — automatic dependent surveillance-broadcast (ADS-B) Out equipment with previously installed GPS antennas or upgrades of global positioning system (GPS) antennas/navigators that may affect ADS-B Out function (performance); — highly integrated avionics components (e.g.,one multi-function display (MFD) and one primary-function display (PFD) in cases in which interconnectivity was changed, added or removed); — modifications to items that affect ditching certification (e.g. replacement windows with different construction or push-out window STCs, changes to waterline location, or the installation or relocation of equipment, such as valves, below the waterline); — Equipment whose use under normal operation could damage other equipment in close proximity (e.g. heat from a searchlight mounted next to skid-mounted float bags on helicopters); — any modification near attitude and heading reference system (AHRS) magnetic field sensors (flux valves, etc.); — multiple modifications to the same primary structure that include the use of blind fasteners; — multiple changes affecting ice protection system operation; — de-icing boots with structural changes that could impinge on the ability of the boots to expand; — multiple changes to the interior aircraft configuration (seats, emergency lighting, etc.) which may affect emergency evacuation of occupants and occupant protection; — multiple modifications installing equipment that applies electrical loads on the same aircraft electrical generating system; or — multiple modifications installing equipment that requires an assessment of electromagnetic compatibility.