m.014 also known as npa 2010-09 also known as part m ... … · 11/07/2012 andré wallimann for eha...

11/07/2012 André Wallimann for EHA 1

M.014

also known as NPA 2010-09

also known as Part M Subpart J

view of the EHA


Responses from five typical helicopter CAMOs

� Part 145� Part 147� Part 21 Subpart I� non approved CAMO for privat Ops only

� Part 145� Part 21 Subpart I� non approved CAMO for sub-contr. tasks

� Bristow CAMO is the subcontracted organisation for Bristow Norway

� AOC � Part 145� Part 147� Part 21 Subpart I� Part M Subpart G (CAMO)

� AOC � Part 145� Part 147� Part 21 Subpart I� Part M Subpart G (CAMO)


Reminder: What’s the Helibusiness like?


64%12%

12%

6% 3%

2%

1%

Fleet of 1

Fleet of 2

Fleet from 3 to 5

Fleet from 6 to 10

Fleet from 11 to 20

Fleet from 21 to 50

Fleet > 50

European Operators

Western and Eastern Europe

Total Fleet (units) 7.187

Nr. of Companies 2.045


64%12%

12%

6% 3%

2%

1%

Fleet of 1

Fleet of 2

Fleet from 3 to 5

Fleet from 6 to 10

Fleet from 11 to 20

Fleet from 21 to 50

Fleet > 50

European Operators

Western and Eastern Europe

Total Fleet (units) 7.187

Nr. of Companies 2.045

� Conclusion: averaged 3.5 Helicopters per Company


SOME EXAMPLES


Fleet:� 1 Lama (smallest CAT Operator)

Operation:� Aerial Work = CAT

Required to have its own:� CAMO (tasks sub-contr. to MRO)� SMS� QM


Fleet:� 1 Robinson R44, 1 Ecureuil, 1 EC130

Operation:� Schooling, Taxi, Aerial Work =CAT

Required to have its own:� CAMO (tasks sub-contr. to two different MROs)� SMS� QM

� One QM with a 20% employment has to monitor:3 different helicopters, 2 MROs, 2 sub-contracted organisations…


Fleet:� none

Operation:� not Subpart G approved office unit performing sub-contr. tasks for:

� 12 different Operators (CAMOs), mostly CAT� 26 Helicopters� 8 different helicopter models (13 sub-models)

Challenge:� 4 employees, computer hard- and software, office accommodation, OEM subscriptions� Average affordable price per helicopter = approx. 4000 Euros (experienced value)

� costs do not meet revenue!�working against the work processes of 12 different CAMEs!


EHA comments to Issue 1 of the attachment

to Patrick Goudou´s Letter (14.03.2012)

or

Why Part M subpart G is seen as a burden by

helicopter operators


Use of subcontracting

„A small operator basically does not have the in-house expertise or resources to manage his own continuing airworthiness, so it sub-contracts as much as it can. But, it also does not have a powerful quality system, so its quality activities tend to be a 'fill in the papers' rather than real oversight.“ Daniele Gosetti – Helicopters Italia

„In the helibusiness many operators are too small to have enough in-house know-how in the maintenance sector. Most CAM tasks require a deep MRO knowledge.“ André Wallimann – RUAG Schweiz AG


Advantages of subcontracting (and contracting)

� merge into fleets � building of a Center of Excellence � better results with less effort� Justification of IT, office and OEM manual subscription costs� Economy of scale� CAM may be performed where the know-how lays (MRO, bigger Operators, profi CAMOs)


Disadvantages of subcontracting

� Trust between Operator (CAMO) and subcontracted org. is a primary requirement or ” pre-requisite”

� The subcontracted org. has to work according too many different foreign/external process� CAME and subcontractor agreements are both authority approved but may interfere� Long communication ways + unclear responsibilities = unsafe condition� Two more audits per AC per agreement


EHA comments to Issue 2 of the attachment

to Patrick Goudou´s Letter (14.03.2012)

or

Why is the Subpart J still seen as a burden by

helicopter operators


Use of contracting

„The idea of being able to 'contract out' the tasks, and indeed the responsibility, is attractive to the small operator, but as the NPA is written, any benefit from contracting out will be negated by the level of oversight written into the NPA. Small operators think this is overly onerous – they would be better off as things stand now…“ Ian Robinson – Patriot Aerospace Group

„The situation described in Subpart J is basically what we do now as best practice…

Instead of simplifying Subpart G, EASA creates a Subpart J which is basically the same as Subpart G was before and Subpart G is made even more stringent.“ André Wallimann – RUAG Schweiz AG


Todays’ Situation: Part M Subpart G


New Situation: Part M Subpart G or J


Conclusion:

Please stop “simplifying” things!


EHA recommendations

or

How to reduce the burden


Recommendation 1: Forget about the M.A.C.� Small operators would be forced to establish and maintain an additional document

� The proper operation of a CAMO should be ensured through the following means:

� one CAMO Audit at least every two years by the Authority

� at least one mandatory Liaison Meeting per year if contracting or sub-contracting is inplace

� investigation of the technical documentation of an aircraft during its Airworthiness Review .

� no maintenance without Work Order signed by the operator. Work Orders can be raised either by the operator, the CAMO or the subcontracted organisation.

� a more stringent PCA Assessment : If an operator has not the capability of performingCAM, contracting should be mandatory.

� Contract: CAMO Agreement…


Recommendation 2: Forget about the CACE

� All necessary process are laid down in the CAME of the CAMO.

� The communication process and means of control between operator and CAMO can be fully laid down within the Agreement ! The agreement is authority approved and part of the CAMO Audit. � create agreement template analogue to Appendix II to AMC M.A.201(h)1


Recommendation 3: Reduce Interfaces

� Do not involve too much organisation to enhance safety.

� no further sub-contracting

� only one contr. CAMO per operator & A/C type

� The regulations need to ensure that a CAMO has sufficient qualifiedstaff.


Keep it lean!

� Part 145 � Part M

Thank you!

m.014 also known as npa 2010-09 also known as part m ... … · 11/07/2012 andré wallimann for eha...

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