overview of initial findings from european military...
TRANSCRIPT
Overview of initial findings from European Military Airworthiness Requirements (EMAR) 66 study
Mr Bob Simmons – Technical Director
MAWA Airworthiness ConferenceWarsaw - July 2011
Scope
• Maintenance system background
• Progress
• Level 1 Questionnaire & Initial Analysis
• Next Phase
• Level 2 Questionnaire
• Key Dates
• Summary
• Questions
© Baines Simmons Limited 2011 2
Parts Tag / Certificate
Engineer’s License
Work Order / Contract
Approved data
Maintenance SystemBackground
© Baines Simmons Limited 2011 3
MaintenanceOrganisation
(Part 145)
ProductionOrganisation
(Part 21G)
Maintenance Training School
(Part 147)
LicensedEngineer(Part 66)
DesignOrganisation
(Part 21J)
ApprovedDesign / Data
ApprovedParts
CtAw ManagementOrganisation –
CAMO (Part M - G)
ApprovedMaintenanceProgramme
Organisation approval codes are designed to
cohesively fit together and enable mutual acceptance
through standardisation
Maintenance SystemBackground
© Baines Simmons Limited 2011 4
MaintenanceOrganisation
(Part 145)
ProductionOrganisation
(Part 21G)
Maintenance Training School
(Part 147)
DesignOrganisation
(Part 21J)
CtAw ManagementOrganisation –
CAMO (Part M - G)
Approved organisations are standardised through Competent Authorityoversight and EASA standardisation audits. This enables the
organisations to accept the flow of people, parts, design data and work instructions without further showing
Parts Tag / Certificate
Engineer’s License
Work Order / Contract
Approved data
Maintenance SystemBackground
© Baines Simmons Limited 2011 5
MaintenanceOrganisation
(Part 145)
The flow of people, parts, design data and work instructions between the various parties in the system is facilitated by certificates and contracts.
The License issued to an engineer allows the maintenance organisation to authorise that person, with the confidence that they have met basic
knowledge, experience and training requirements.
The basis of the EASA Part 66 License
The EASA Part 66 Maintenance Engineers Licenses has multiple uses:• Demonstration that a minimum level of knowledge has
been achieved by the holder to support the issue of a Part 145 Certifying Staff Authorisation
• When Type Rated to cover specific aircraft types (or groups), may be used as authority to certify maintenance completed on those non-commercial light aircraft
The same uses may not be needed for EMAR-66
© Baines Simmons Limited 2011 6
Study progress
Phase 1 data gathering commenced in February• Note that 50+ responses were possible, as some pMS
have different authorities for Air Force, Army, Navy & State Aircraft maintenance
• Phase 1 report has been presented to TF3. the report presents a high-level analysis of the data collected
Phase 2 data gathering from TF3 members is nearing completion• Analysis to commence in July
Phase 3 development of recommendations • Planned for commencement in mid - July
© Baines Simmons Limited 2011 7
Objectives of Phase 1
Establish pMS regulatory structure for maintenance
Understand pMS maintenance arrangements
Ascertain types of aircraft systems being maintained by pMS
Ascertain pMS ‘Basic’ maintenance certification qualifications
Ascertain pMS ‘Type’ maintenance certification qualifications
Establish opinion on potential for a common minimum requirement for a maintainer licensing or qualification system
© Baines Simmons Limited 2011 8
Initial Analysis (1) – Key Points
Data supplied was of good quality
Data provides working overview of current pMS systems
Illustrates diversity between pMS:
• Maintenance terms
• Aircraft trade structures
• Qualification and certification systems
• Contractual arrangements
© Baines Simmons Limited 2011 9
Initial Analysis (2) – Key Points
A significant number of pMS already use EASA or an adaption of EASA regulations:
© Baines Simmons Limited 2011 10
Initial Analysis (3) – Key Points
A number of pMS already use EASA Part 145 (or an adaptation) for their contracted out maintenance contracts:
© Baines Simmons Limited 2011 11
Initial Analysis (4) – Key Points
Adaptation of EASA Part 66 is already underway in some pMS (for basic and type qualifications):
….for example, France uses FRA 66 (again based upon EASA Part 66).
This is similar for civilian staff, but no pMS incorporates a specific ‘B Mil’ weapons trade:
© Baines Simmons Limited 2011 12
Initial Analysis (5) – BenefitsSo, pMS are currently training their personnel based upon EASA
Part 66 or their own national requirement.....but no formal recognition of other pMS certifying qualifications:
EMAR 66 would provide a minimum requirement, for training and examination prior to qualification, to assure airworthiness.These qualifications would be considered when issuing licences and/or
Part 145 authorisations.
Potential for cross-servicing opportunities exist, with several aircraft types already identified:
© Baines Simmons Limited 2011 13
Initial Analysis (6) – BenefitsSnapshot of charts of aircraft cross-serving opportunities:
© Baines Simmons Limited 2011 14
Initial Analysis (7) – BenefitspMS show support for component maintenance under EMAR 66,
with potential for cross-servicing and/or shared inventories:
….but there are reservations about the difficulty with the inclusion of component maintenance staff and about the benefits of doing this.
Opportunities would exist for joint aerospace programmes:
© Baines Simmons Limited 2011 15
Phase 2 data gathering(1) - Outline
Phase 2 data gathering:
• Include subjects, identified from the Level 1 questionnaire, which need to be clarified further
• Explore any problem areas identified by TF 3
• Detailed questions about maintenance certification authorisation
• Using EASA Part 66 as a baseline
• Proposed target date for responses: 30th June 2011
© Baines Simmons Limited 2011 16
Level 2 Questionnaire (2) - Training
Conducted with ten pMS, with more detail about their ‘Basic’ and ‘Type’ training schemes:• Who provides training?
• How are courses approved?
• Where is training conducted?
• Are there any pre-requisites for training?
• What is taught?
• How are examinations conducted?
• Is post-course accreditation controlled?
© Baines Simmons Limited 2011 17
Level 2 Questionnaire (3) - Authorisations
Detail about their certification authorisation procedures:• How are certification authorisations issued?
• Which Competent Authority provides procedural oversight ?
• How are procedures reviewed and amended?
• How are the procedures audited?
What are their certifying staff maintenance privileges?
Do they recognise continued validity of authorisations?
How are authorisations recorded?
How do they revoke, suspend or limit authorisations?
© Baines Simmons Limited 2011 18
Level 2 Questionnaire (4) - Authorisations
More detail about their certification authorisation procedures:
• What are the minimum competency requirements?• Qualification, Knowledge, Experience
• Are partial credits awarded / taken into account?• Non-aircraft maintenance experience
• Ex-military rank and experience
• Protected ‘grandfather’ rights
• Previous examination credits
Is there a procedure to convert previous authorisations?
© Baines Simmons Limited 2011 19
Level 2 Questionnaire (5) - AML
Aircraft Maintenance Licences (AML) – if used:
What is the application procedure?
How are the following aspects controlled?• Examinations prior to AML issue
• AML initial issue, renewals or conversion
• Amendment of AML ‘Basic’ category / sub category
• Amendment of AML ‘Type’ category
• AML revocation, suspension or limitation
© Baines Simmons Limited 2011 20
Level 2 Questionnaire (6) – Knowledge
How is ‘Basic’ training divided up?• Standardised knowledge modules , bespoke courses, etc
What are their ‘Basic’ and ‘Type’ trade standards based upon?
What subjects are controlled by ‘Basic’ trade standards?• Maths, physics, electrics, electronics, materials, etc
What subjects are controlled by ‘Trade’ standards?• Zonal areas, airframe structure, air supply, hydraulics, etc
What rules apply to their ‘Basic’ and ‘Type’ trade examinations?• How often are examination questions revised?
© Baines Simmons Limited 2011 21
Summary
Phase 1 data gathering has returned useful information to date....we did not seek to develop solutions at this stage!
Similar methodology has been used for Phase 2 data gathering
Early indications show pMS support for EMAR 66....whatever form it takes!
• Any questions?
© Baines Simmons Limited 2011 22