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Component maintenance qualification - Regulation (EU) No 1321/2014 Article 5

#1
I would like to ask several questions regarding component maintenance iaw Part-145 requirement (in EU country).

Regulation (EU) No 1321/2014 Article 5:
6. Until specific requirements for certifying staff for components are added to this Regulation, the requirements laid down in the national laws in force in the relevant Member State shall continue to apply, except for maintenance organizations located outside the Union where the requirements shall be approved by the Agency.

1st question: Could you provide the example or reference of your country's regulations regarding certifying staff for components qualification?

At this moment in our national regulations (Lithuania) there is only one option: to have component maintenance training on the component (copy-paste from EASA Foreign Part-145 approvals - Components, engines and APU certifying staff document):

Appropriate theoretical and practical component training from:
  • the OEM or;
  • the OEM recognized training organization or;
  • an appropriately rated maintenance organisation (1321/2014 Annex I Part-M Subpart F or Annex II Part-145) provided:
    • the person nominated to carry out the training can demonstrate he/she has received training to an appropriate level for the subject component;
    • the person nominated to carry out the training is appropriately authorized by the maintenance organisation and is able to demonstrate a significant experience on the relevant component maintenance; o the training syllabus has been reviewed by the Engineering Manager and/or the Quality Manager;
    • the component is available for practical training purpose;
What our national regulation missed from "EASA Foreign Part-145 approvals - Components, engines and APU certifying staff document" is the sentences:
"For simple component, the maintenance organisation may take credit of the CC/S experience and/or a previous training on a component from the same family and same technology."

However, I have not found any explanation from EASA regarding the used terminology: 'simple component', 'take credit of the CC/S experience', and 'same family and same technology'.

So, my 2nd question: Could anyone provide a reference to such terms explanation?

My 3rd question: How to be with the component, which does not have CMM and maintained iaw AMM, SRM etc.? Could such documents be used in workshop component maintenance and what qualification should have the certifying staff for components in such a situation?
Example: pax cabin sidewall panel, ashtray, dummy windows, harness.

My 4th question: Where is it possible to get training for components maintained by generic CMM (example, A320 PSU or B737 Overhead bin)?

My 5th question: Maybe someone has an example, how self-formalization with new CMM could be used by certifying staff for components when the company introduces a new component? Personally, I see a possibility to introduce some kind of generic qualification (skills) under which the component may go through self-familiarisation. For example, such certifying staff for components already have composite, sheet metal, and several component maintenance training (several CMM) - same maintenance technology and ability to read and understand maintenance data.

My 6th question: Does anyone have experience with PMA part maintenance or how to introduce PMA part into EASA Part-145 scope?

Thanks in advance and looking forward to your reply.
 
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AEOS_QA

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#2
Hi and welcome to the forum

This is very much a subject open to interpretation and acceptance by your assigned authority but the User guides for Foreign repair Stations might provide you with some additional guidance on what EASA has in mind.
For our system I used the Summary table for EASA PART-145 Component C/S qualification criteria in UG.CAO.00126-003 Components, engines and APU certifying staff and importantly also UG.CAO.00128-003 Demonstration of 6/24 months maintenance experience which has some more important information on how to demonstrate ongoing competence especially.
3.1 Duration....
"A person may have at the same time one or more EASA Part-145 C/S - S/S individual authorisation (i.e. being B1 aircraft C/S on 3 different A/C types, or being at the same time C6 and C14 C/S on different components P/N, etc.). He/she will have to record a minimum of 180 tasks (or 100 working days), regardless the number/types of EASA Part-145 C/S - S/S individual authorisation hold."

The good news is that it is up to you as an organisation to define your requirements. Try to use what Sections, departments or different workshop areas you already have and think how you train the staff up. Take into account what systems you use at the moment to sign off tasks so you can build on your job management system to show enough tasks across a variety of components.

Important - Try to keep the minimum number of different categorise so you don't get caught by spreading the tasks or jobs across too many ratings
ie. My rating MEL for Mechanical Liquid covers Hydraulic, Fuel and Water Pumps across a number of different ATA chapters or C ratings while MEG covers Mechanical Gas such as Slide Bottles, Fire Extinguishers Accumulators etc.

I used the summary table for EASA PART-145 Component C/S qualification criteria to define the "Training Plan" and then added specific skills staff needed in each "Section" or equipment they used. There is very little component training available but once you define a suitable "Matrix" it becomes much easier to add lots of relevant training material or You-Tube clips to build up a training system.

Happy to provide you with some samples just send a message.
 
#3
AEOS_QA, thanks for your reply. I have several more questions.

To obtain the MEL or MEG category in your organization what kind of training and experience should have Component certifying staff? And how you add new P/N into the capability list in such a case (a requirement for Component certifying staff to have new P/N component maintenance training? Through similarity? Through self-familirisation? Through general skill training such as sheet metal, composite, sewing etc.?)

How do you think, if a person authorized as Part-21G and Part-145 Component certifying staff, is it possible to accept Part-21G certifying staff work experience as Part-145 24/6?

As well, how do you think, can Part-21J approved organization (who is not OEM of the component, but can create a modification for such component) perform component maintenance training for Part-145 staff?

Do you have any idea how the PMA parts can be added to the Part-145 capability list?

Sorry, but I have not received any samples you have mentioned.
 

AEOS_QA

Involved In Discussions
#4
Hi FliuGer
I have gone back over my notes and documents when I established our system and used the information linked below
GM2 145.A.30(e) Competence assessment procedure
This table covers the key Human Factor and Part 145 knowledge your training system needs to cover. I used the table to create a document you can modify to suit the roles and knowledge your certifying staff needs to have. Complement it with information about your own systems, processes and MOE.

This FAQ may also What are the training requirements for personnel within a Part-145 organisation, other than those contained in Part-66? | EASA

>> How do you think, if a person authorized as Part-21G and Part-145 Component certifying staff, is it possible to accept Part-21G certifying staff work experience as Part-145 24/6? <<
My understanding is that your certifying staff need to have practical experience in the "Maintenance" aspect of your part 145 work. It can't just be a manager, you actually need to train up the workshop staff to a level where they can sign off the work they do. Part 21G Design experience may or may not be relevant to it.

>>As well, how do you think, can Part-21J approved organization (who is not OEM of the component, but can create a modification for such component) perform component maintenance training for Part-145 staff?<<
Your 145 organisation designs the training. I'm not aware of specific requirements for instructors or training staff in your 145 organisation as long as you can demonstrate that your instructors(s) has the necessary training skills. Your trainer or supervisors then have to separately assess the competency of your staff. We just document that staff have been assessed and have the required training (HF, Part145, MOE etc) and technical skills and enough experience.

>>Do you have any idea how the PMA parts can be added to the Part-145 capability list?<<
As long as you have all the Tech data, Tooling, skills etc they are added the same way the any other part in your system.
See also ED Decision 2007/003/C

Hope this helps
 

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#5
AEOS_QA, thanks a lot for your answer and examples of assessment matrix/forms. As I see, you have used UG.CAO.00126-003 methodology such as 'Component training/Bench test training/Tool training'. So are you use the 'component similarity' option in the scope of your defined rating of components?

>> I used the summary table for EASA PART-145 Component C/S qualification criteria to define the "Training Plan" and then added specific skills staff needed in each "Section" or equipment they used. There is very little component training available but once you define a suitable "Matrix" it becomes much easier to add lots of relevant training material or You-Tube clips to build up a training system.<<
'Specific section'
you mean 'Incoming Inspections/Certifying staff/Mechanics etc.' or 'Rework Group: ie. Cylinder - Assembly/Mask – Assembly/ Regulators/Stowage Boxes etc.'?
 
Last edited:

AEOS_QA

Involved In Discussions
#6
Yes consolidate the groups or ratings to the distinct work ie "composite repairs" "Fabric repairs" as they generally need the same skill sets, equipment and processes. Then you include training to explain staff how you manage variations between individual components by understanding your systems of worksheets, manuals or drawings they use for each job.
 
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