U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Repair Station Guidance for Compliance with the Safety Agreement between the United States and the European Union Date: 11/28/12 AC No: 145-11A Initiated by: AFS-300 Change:
1. PURPOSE. This advisory circular (AC) provides information and guidance regarding a repair station located in the United States obtaining, renewing, or amending a European Aviation Safety Agency (EASA) Part 145 approval and an Approved Maintenance Organization (AMO) located within the European Union (EU) obtaining, renewing, or amending a Federal Aviation Administration (FAA) repair station certificate under the provisions of the U.S./EU aviation safety agreement (the Agreement).
2. AUDIENCE. This AC is applicable for AMOs located in a country listed in the Agreement, Annex 2, Appendix 2 who want FAA repair station privileges to maintain U.S.-registered aircraft and associated parts. This AC is also applicable for repair stations located within the United States who want EASA Part 145 privileges to maintain European-registered aircraft and associated parts.
3. CANCELLATION. This AC cancels AC 145-11, Repair Station Guidance for Compliance with the Safety Agreement between the United States and European Union, dated March 9, 2012.
4. RELATED REGULATIONS.
a. FAA Regulations. Title 14 of the Code of Federal Regulations (14 CFR) parts 43, 145, and 187.
b. EASA Regulations. European Commission Regulation (EC) No. 2042/2003, Annex 2 and EC No. 593/2007.
5. ACRONYMS AND DEFINITIONS. Appendix 1 of this AC contains relevant acronyms and definitions.
6. RELATED READING MATERIAL (current editions).
a. ACs. You can obtain current editions of the following documents from the FAA Web site at http://www.faa.gov/regulations_policies/advisory_circulars/.
• AC 00-44, Status of Federal Aviation Regulations.
• AC 00-58, Voluntary Disclosure Reporting Program.
• AC 20-62, Eligibility, Quality, and Identification of Aeronautical Replacement Parts.
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• AC 21-29, Detecting and Reporting Suspected Unapproved Parts.
• AC 145-10, Repair Station Training Program.
• AC 187-1, Flight Standards Service Schedule of Charges Outside the United States.
b. FAA Orders. You can obtain current editions of the following documents from the MyFAA employee Web site at https://employees.faa.gov/. Inspectors can access these documents through the Flight Standards Information Management System (FSIMS) at http://fsims.avs.faa.gov. Operators can obtain these documents at http://fsims.faa.gov. The public can access these documents at http://www.faa.gov/regulations_policies/orders_notices/.
• FAA Order 8130.2, Airworthiness Certification of Products and Articles.
• FAA Order 8130.21, Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag.
• FAA Order 8900.1, Flight Standards Information Management System (FSIMS).
c. EASA Documents. You can obtain all related EASA documents on the EASA Web site at http://www.easa.europa.eu/document-library.
d. Joint Documents. You can obtain the following documents from the FAA Web site at http://www.faa.gov/aircraft/repair/.
• Agreement Between the United States of America and the European Community on Cooperation in the Regulation of Civil Aviation Safety (the Agreement).
• Maintenance Annex Guidance Between the Federal Aviation Administration for the United States of America and the European Aviation Safety Agency for the European Union (the MAG).
7. BACKGROUND.
a. U.S./EU Aviation Safety Agreement.
(1) The Agreement was signed on June 30, 2008. The Agreement’s official title is “Agreement Between the United States of America and the European Community on Cooperation in the Regulation of Civil Aviation Safety.”
(2) The Agreement allows the FAA and EASA to rely on each other’s surveillance systems, minimize the duplication of efforts, increase efficiency, and conserve resources to the greatest extent possible. As stated in Article 5 of the Agreement, areas of reciprocal acceptance, and technical differences are specified in the Annexes; Annex 1 pertains to airworthiness and environmental certification, while Annex 2 pertains to maintenance.
(3) Annex 2 of the Agreement contains a mandate in paragraph 3.2 for the Joint Maintenance Coordination Board (JMCB) to develop, approve, and revise detailed guidance for processes covered by the Annex.
(4) The detailed guidance described in Annex 2 is contained in “Maintenance Annex Guidance Between the Federal Aviation Administration for the United States of America and the
Par 7 Page 3 European Aviation Safety Agency for the European Union,” which is commonly referred to as the MAG.
b. Contents of the MAG. The MAG contains three sections (A, B, and C) that address the processes and procedures agreed to between EASA and the FAA. The sections are as follows:
(1) Section A—Authority Interaction (Not Applicable to Industry). This section applies to the FAA, EASA, and aviation authorities (AA). It provides the coordination and communication process for the regulatory agencies. It also includes FAA sampling and independent inspections as well as blank forms for the coordination process.
(2) Section B—Certification Process for U.S.-Based Repair Stations. This section identifies the requirements and processes for repair stations located in the United States to follow for obtaining an EASA approval.
(3) Section C—Certification Process for EU-Based Maintenance Organizations. This section identifies the requirements and processes for an EU-based AMO to follow for obtaining FAA certification and renewal. Additionally, it contains the responsibilities of both the FAA aviation safety inspector (ASI) and the AA.
8. THE AGREEMENT, ANNEX 2, MAINTENANCE.
a. General Information. Persons in the United States and EU maintaining both U.S. and EU aeronautical products should be familiar with the Agreement and the MAG.
b. Special Conditions. Particular attention should be focused on the differences between 14 CFR part 145 and EASA Part 145 which are identified as “special conditions” in Annex 2, Appendix 1 of the Agreement. An FAA-certificated repair station (CRS) located in the United States, when in compliance with EASA-published maintenance special conditions, may apply for EASA approval. Likewise, an EU-based AMO, when in compliance with published FAA maintenance special conditions, may apply for FAA approval.
c. Unimpeded Access. For the purposes of surveillance and inspections, the FAA and EASA (and AAs) will help each other gain unimpeded access to repair stations/AMOs subject to their respective jurisdictions. It is incumbent upon you to provide unimpeded access to EASA and the FAA to all work areas having civil aviation application. If you provide maintenance for both civil and military products, you should ensure, where possible, that there is clear delineation between work areas with civil and military applications within the repair station/AMO.
d. Training Program Requirements. For U.S. repair stations that have an EASA Part 145 approval, the human factors (HF) training is an EASA special condition requirement.
(1) Training should center on the scope of work you perform. You should also ensure the training program is controlled and developed per the FAA Repair Station Manual (RSM)/EASA supplement.
(2) For details regarding training development, affected repair stations, and additional information, refer to AC 145-10.
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9. GUIDANCE FOR A REPAIR STATION LOCATED IN THE UNITED STATES TO OBTAIN EASA APPROVAL. Repair stations in the United States should refer to Section B of the MAG.
10. GUIDANCE FOR AN EU-BASED AMO TO OBTAIN FAA APPROVAL. AMOs should refer to Section C of the MAG.
11. REQUEST FOR INFORMATION. The Repair Station Branch (AFS-340) developed this AC. For information concerning this AC, contact AFS-340 at 202-267-1675. Direct comments regarding this AC to:
Federal Aviation Administration Aircraft Maintenance Division, Repair Station Branch, AFS-340 5th Floor, 950 L’Enfant Plaza, S.W.
Washington, DC 20024
Michael Zenkovich Deputy Director, Flight Standards Service
Appendix 1 Page 1 (and 2) APPENDIX 1. ACRONYMS AND DEFINITIONS
1. ACRONYMS. The following are acronyms as applied to this AC, the Agreement, and applicable guidance material.
AA Aviation Authority AMO Approved Maintenance Organization ASI Aviation Safety Inspector BOB Bilateral Oversight Board CFR Code of Federal Regulations EASA European Aviation Safety Agency EU European Union FAA Federal Aviation Administration JMCB Joint Maintenance Coordination Board MAG Maintenance Annex Guidance MOE Maintenance Organization Exposition OpSpec Operations Specification QCM Quality Control Manual RSM Repair Station Manual SIS Sampling Inspection System TA Technical Agent TIP Technical Implementation Procedures for Airworthiness U.S. United States
2. DEFINITIONS. Specific terms are defined in Article 1 of the Agreement and Section A, Part IV of the MAG.