Contents Definitions 1 Certificate of Inspection Authorisation 2 Eligibility IA certificate issue Recent Experience Requirement The ARA Phase 1 - Type Conformity Data plates Replacement data plates Design Changes Modifications and repairs Approved modifications and repairs Supplemental Type Certificates Modification Parts Special Category – Experimental Aircraft Summary Phase 2 Maintenance Record – Audit Aircraft Documents Maintenance Programme Approved Maintenance Programme Maintenance Requirements and Responsibility Phase 3 – General Condition Inspection ARA Documentation ARA administration 2 2 3 3 4 4 5 5 5 6 6 7 7 8 8 8 8 8 9 11 12 12 Reporting of defects – Part 12 13 Certification of conformity 13 Form 337 Distribution Frequently Asked Questions 14 14 Definitions • failure of motive power IA means the holder of a certificate of inspection authorisation. • unintentional operation of, or any inability to operate, any systems or equipment essential to the safety or operational function of the aircraft LAME means a licensed aircraft maintenance engineer. Major modification means a modification that could potentially affect the safety of an aircraft or its occupants where, as a result of its embodiment, one or more of the following may occur: • incapacitating injury to any occupant • unacceptable unserviceability or maintainability. Technical data are drawings, instructions, or other data required to be used for product certification, approvals, and authorisations under Part 21 Certification of Products and Parts or for the maintenance, modification, and repair of products, their components, and appliances under Part 43 General Maintenance Rules. • structural collapse • loss of control • failure of motive power • unintentional operation of, or inability to operate, any systems or equipment essential to the safety or operational function of the aircraft • incapacitating injury to any occupant Airworthy condition means the condition of an aircraft, including its components, fuel, and other materials and substances essential to the manufacture and operation of the aircraft, that complies with all the requirements prescribed by the Rules relating to design, manufacture, modification, repair, and safety. • unacceptable unserviceability or maintainability. Major repair means a repair that, if carried out, could potentially affect the safety of an aircraft or its occupants where, as a result of its embodiment, one or more of the following incidents may occur: • structural collapse • loss of control 1 Certificate of Inspection Authorisation • have passed an examination in airframe overhaul that is acceptable to the Director. Subject 009 is an acceptable examination in airframe overhaul for those engineers that held a licence, or held a valid credit for subjects 003 and 004 prior to 1 April 1997. For those engineers gaining a valid examination credit for subjects 003 and 004 after 1 April 1997 the successful completion of these subjects also provides a credit against the airframe overhaul examination requirement, and The annual review of airworthiness (ARA) is a monitoring process designed to ensure that aircraft maintained in under Part 43 General Maintenance Rules continue to comply with their Type Certificate or properly modified condition, and that the aircraft is maintained in an airworthy condition. • have successfully completed a course of instruction and passed a written examination on the examination of aircraft and components for conformity with the Civil Aviation Rules, conducted by an organisation certificated under Part 141 Aviation Training Organisations – Certification. The Certificate of Inspection Authorisation qualifies experienced Licensed Aircraft Maintenance Engineers to certify ARAs, and conformity of major repairs and modifications to acceptable technical data. It does not permit the holder to approve technical data. Other requirements are detailed in Part 66, rule 66.9 Issue of licences, certificates and ratings and include meeting fit and proper person criteria, competency in the English language, and ensuring that the issue of the certificate will not be contrary to the interests of aviation safety. Eligibility Candidates for an IA must: • hold a rated aircraft maintenance engineers licence issued under Part 66 Aircraft Maintenance Personnel Licensing, or an equivalent Australian aircraft maintenance engineer licence registered in New Zealand, in both aeroplane and powerplant or rotorcraft and powerplant categories, and IA certificate issue The certificate is issued separately to the aircraft maintenance engineer licence, but is designed to fit in the same laminated wallet. It is issued for five years and is renewed via application Form CAA 24066/05. As part of the renewal process, IAs are required to attend a refresher course/seminar conducted by the Director. The certificate may be suspended or revoked in accordance with the Civil Aviation Act. • at the time of application for the certificate have held the licence for at least 60 months, and met the recent experience requirements of 6 months in each 24 months over that period. (The experience may consist of exercising the privileges of the licence or supervision of aircraft maintenance in an executive capacity), and The New Zealand Gliding Association issues the certificate to its engineers. 2 These applicants must successfully complete a course and examination conducted by the Director or by an organisation certificated under Part 149 Aviation Recreation Organisations – Certification. The ARA can be conducted only within the Part 43 environment, and only by an IA. ARAs are required for: • aircraft issued with a standard, restricted or special category Airworthiness Certificate conducting private operations, and Recent experience requirement • aircraft — conducting air transport operations, with nine seats or less, excluding the pilot’s seat — which the operator elects to maintain outside of a Part 145 maintenance organisation. The recent experience requirement of Part 66, rule 66.207 Recent experience requirements may be met by conducting within the preceding 12 months: • four ARAs, or • The ARA applies to type-certificated aircraft (including gliders) as detailed in the previous paragraph, gliders, warbirds and amateur-built aircraft. • four certifications of conformity of major repairs or major modifications, or • a combination of ARAs and conformity certifications totalling four. The ARA is not required for: If the recency requirement cannot be achieved by the conduct of ARAs or conformity certification, it is acceptable to complete at least eight hours of refresher training or complete an examination acceptable to the Director. Check with the CAA that the course you are considering is acceptable. The Inspection Authorisation examination conducted by Aviation Services Ltd meets this requirement. • aircraft conducting air transport and maintained in a Part 145 organisation, or • microlight aircraft. ARAs must be conducted by IAs. No part of the review may be delegated. The IA does not need to be rated on the aircraft in question but must be familiar with that aircraft. A good example would be a turbine-powered variant of a group 1 helicopter, when the IA holds only the group 1 rotorcraft rating. To be familiar with a type, the IA must be able to demonstrate extensive practical experience to a level at least equivalent to that required for rating issue, have a good working knowledge of applicable Airworthiness Directives, service information, and the manufacturer’s maintenance manual. The ARA The ARA should not be confused with the process of maintenance review. This is carried out by air operators who maintain their aircraft at maintenance organisations certificated under Part 145 Aircraft Maintenance Organisations – Certification. It is not acceptable for an IA holding the aeroplane and powerplant categories only, to conduct an ARA on a helicopter, unless 3 that IA has rotorcraft practical experience equivalent to the level required for the aircraft maintenance engineer licence rotorcraft category and rating issue. have not been issued for older aircraft types. In these cases, airworthiness data is attached to the airworthiness certificate in the form of operating limitations. An IA must be able to demonstrate a level of familiarity with the aircraft type that will allow him or her to detect modifications to the type design. Aircraft issued with special category experimental Airworthiness Certificates are not required to meet the type conformity requirements of the ARA. These aircraft types will include warbirds, amateur-built and other non-type-certificated aircraft. Some warbird aircraft may have restricted Airworthiness Certificates. In these cases, type conformity is required. Check for an exemption against type conformity for these specific aircraft. The ARA can be considered to contain three elements: • type conformity • logbook audit • general condition inspection Data plates These three elements are required by Part 43 (rule 43.153). Identification of products and parts is required by Part 21 Certification of Products and Parts Subpart B. These rules relate to New Zealand-manufactured aircraft, engines and propellers. Phase 1 — Type conformity The aircraft under review is required to conform to its Type Certificate. It must be audited against the type certificate data sheets (TCDS) and other technical documentation that forms part of the of the approved type design. Imported products should carry the identification information required by the regulations of the country of manufacture. For example some countries may not require data plates to be installed on propellers. The data sheets (previously known as aircraft specifications) are available for many aircraft of United States manufacture on computer software. These are available from a number of outlets including the FAA web site at http://av-info.faa.gov/. In many cases propellers carry engraved or stamped identification information directly applied to the product rather than on a separate plate. (This may not be visible without removing the mounting plate.) The data sheets are less readily available for other foreign aircraft. If you have difficulty, contact the Aircraft Certification Unit of the CAA for assistance. Some older aircraft do not have data sheets or aircraft specifications. In these cases the flight and maintenance manuals should provide sufficient information. In a very small number of cases, flight manuals The first step in establishing type conformity is to locate the aircraft data plate. The rules of the country of manufacture will detail the required position of the data plate. The FAA and CAA require the plate to be located at a point near the main entrance of the aircraft or at a point on the empennage where it can be seen by a person on the ground. 4 For example, some Blanik gliders imported from the USA have the plate located near this tail position. powerplant, or similar locations, if such design changes are not recorded in the aircraft maintenance records. The plate should be assessed against the data sheets to ensure correct aircraft type, model and serial number. This should be followed by an assessment of the major components to ensure the powerplant, propeller and components agree with the data sheets, a Supplemental Type Certificate, or other approved design change. Modifications and repairs Modifications recorded in the aircraft maintenance records at the time of initial Airworthiness Certificate issue are considered to have been approved by the issue of the certificate. This acceptance method also applies to avionic installations recorded on the Form CAA 2129 at the time of the initial Airworthiness Certificate issue prior to 1 April 1997. If the aircraft or major components do not comply with the data sheets, aircraft specifications, or its properly modified condition, the aircraft does not comply with its Type Certificate, and this should be entered in the aircraft maintenance records as a discrepancy. Modifications noted during the ARA that are not recorded in the aircraft records cannot be accepted as being approved. Typical modifications, not recorded in the maintenance records, that an IA would be expected to observe during an ARA include: Replacement data plates If a data plate has been lost, replacement action must be made in accordance with Part 21 (21.807 Removal, alteration and replacement of identification information). This can be carried out only with the approval of the Director and the manufacturer. One example of a manufacturer’s procedure requires at least two affidavits and an aircraft inspection by a designated person acceptable to the manufacturer. Other manufacturers require a letter of support from the CAA. • non-standard powerplant or propeller installations • interior refurbishment • avionic installations not included on the Form CAA 2129 • installation of speed fairings, droop wing tips, or winglets • installation of camera hatches • installation of externally mounted attachments including mirrors, or handles for parachute drop operations Design changes • installation of cargo panniers or skidmounted ski racks Type conformity also means that all design changes have been approved. An IA must be sufficiently familiar with the aircraft undergoing review to identify any visible design changes. The IA cannot be expected to identify design changes that are within closed structure, internal areas of the This list is by no means complete. It is designed to provide examples of common unapproved or unrecorded modifications discovered during the first 12 months of the ARA. These discrepancies must be recorded and reported. 5 rule 91.627 Maintenance records requires the operator of an aircraft, except a class 1 microlight, to compile maintenance records for major modifications and major repairs. Modifications and repairs that are not by definition major are considered maintenance, which has the same recording requirement. Approved modifications and repairs The IA must ensure that modifications and repairs noted on the aircraft under review have been certified in the aircraft records and, where applicable, are approved. When the maintenance records show that the required approval has been gained and the certification is made in accordance with the Rules or regulations in force at the time of the certification, generally no further action is required from the IA. It is not expected that an IA should gain copies of the technical data contained in approved modifications or repairs for assessment against the installed modification or repair. Responsibility for this belongs with the operator. If unrecorded modifications or repairs are observed on an aircraft, they must be listed as discrepancies. It is not the responsibility of the IA to gain approval for these items, but the operator may contract the IA to assist with approval, using the Form CAA 337. Many aircraft will have been modified or repaired in areas that, because of the nature of the structure, will not be visible to the IA during the ARA. The IA is not expected to identify unrecorded repairs or modifications of this nature. The certification of release to service by the LAME, and reference to approval identification data at the time of embodiment of the modification or repair, provides a statement that the work has been properly carried out and that airworthiness has been maintained. The only exception is when the modification or repair is observed as not complying with technical data contained in an approved modification or repair scheme known to the IA. In cases where maintenance records have been lost or destroyed, recertification of known modifications and repairs is required. Owners/operators unable to locate historical maintenance records should contact the CAA Aircraft Certification Unit for guidance. If in doubt, the CAA can provide limited information, such as whether a listed modification or repair is approved and what the approval covered. The CAA cannot supply copies of approved technical data for confirmation purposes, as this data is proprietary and belongs to the approval applicant. Supplemental Type Certificates Some design changes, such as the addition of speed fairings or drooping wing tips, are embodied on an aircraft under the authority of a Supplemental Type Certificate (STC). STCs issued by the FAA and CASA, and Supplemental Type Approvals issued by Transport Canada, are acceptable technical data included in Appendix D to Part 21 Acceptable technical data, subject to some conditions. IAs should ensure that the maintenance records show that the A wide general knowledge of common repairs and modifications incorporated in an aircraft type is considered part of the familiarity requirement for IAs. Part 91 General Operating and Flight Rules, 6 certificate. Major repairs and major modifications to this category of aircraft do not require certification of conformity to acceptable technical data contained in Appendix D to Part 21. modification or repair is a genuine STC. A lack of complete certification in the maintenance records may indicate a locally manufactured copy. The FAA now requires the installer to have the permission of the STC holder, therefore a photocopy of STC data is not acceptable Repairs and modifications should be recorded in the maintenance records, and the method of repair or modification approval should be detailed. This category of aircraft may have modifications and repairs approved under Part 21 Subpart C Design changes, or, in some cases, via an in-flight evaluation programme (see Advisory Circular 21-3A Product certification – Airworthiness certificates in the special category). Aircraft within this category that have a type design or supporting technical data, (eg, warbirds) should be repaired or modified in a manner that ensures the aircraft retains the type design. Repairs should be carried out in accordance with manufacturer (or military operator) manuals and, when the scope of the repair falls outside of these manuals, data approval should be requested. Modification parts Parts incorporated in a modification must be approved parts as described in Part 21, Subpart K Materials, Parts, Processes, and Appliances and Advisory Circular 20-2 Acceptability of parts. Of particular interest is rule 21.303(2) Replacement and modification materials, parts, and appliances, which permits the use of parts that shall: “be manufactured for a person to install on their own product and comply with the type design of the product, including any embodied design changes”. These parts require specific product identification marking (see Advisory Circular 21.80A Identification of products and parts – Identification information, provision, and replacement) and could be installed on an aircraft at the owner’s request via Form CAA 337. Typical examples of this type of modified product that IAs may observe are the tailskids fitted to some gliders. Logbooks, or other maintenance records should document the design change. If no record exists, a discrepancy should be actioned. Amateur-built aeroplanes are issued with experimental certificates and are also subject to the above. A large number of these aircraft do not have repair manuals. Major repairs and modifications to these aircraft require that the aircraft be returned to a flight test programme to prove the repair or modification by in-flight evaluation. The repair or modification should be carried out using technical data such as FAA AC 43-13.1B Acceptable Methods, techniques and Practices – Aircraft Inspection and Repair, the original aircraft drawings, or designer supplied data, and it should be released to service by an appropriately qualified person (for details see Part 43). Special Category – experimental aircraft Aircraft issued with special category airworthiness certificates are not required to be reviewed for type conformity, as these aircraft are not supported by a type 7 Summary Aircraft documents The following items summarise the purpose and process of this phase of the ARA: The following documents are required by Part 91 (91.111 Documents to be carried) to be carried in the aircraft. The IA must ensure that they are in place: • This phase addresses the aircraft’s continued compliance with its Type Certificate. • current Airworthiness Certificate • Identify the aircraft and its major components by reference to data plates or other approved identification marking. Ensure correct type, model and serial numbers are applicable. Ensure logbooks refer to the correct aircraft or component by type, model and serial number. • current version of the Flight Manual (special category aircraft may have operating limitations in place of the Flight Manual) • Ensure observed modifications are approved and recorded. In addition to the above items, Advisory Circular 43-10 Aircraft radio station requires that the Form 2129 be placed in the flight manual. • Tech Log • Certificate of Registration for New Zealand aircraft operating overseas • Ensure observed major modifications and major repairs carried out after 1 April 1997 have been certified for conformity to acceptable technical data in the maintenance records. Maintenance programme Rule 43.153 Rule requirements requires the IA to ensure that all due maintenance specified in the applicable maintenance programme has been completed. The first step in meeting this requirement is to identify what programme the aircraft is being maintained to. Operators must provide a tech log for each aircraft. One of the mandatory items to be recorded on the Tech Log is details of the maintenance programme. The IA should check the maintenance records to verify that the aircraft is being maintained to the stated programme. This phase is carried out on aircraft issued with standard or restricted Airworthiness Certificates including gliders. This phase is not required on aircraft issued with special category Airworthiness Certificates, although modifications must still be recorded in the maintenance records including the method of approval. For amateur-built aircraft the approval may be by in-flight evaluation. Phase 2 Maintenance record – audit Approved maintenance programme The second phase of the ARA consists of an audit of the aircraft maintenance records. Usually this means the aircraft logbooks, but the records could be of any format acceptable to the Director. ‘Approved’ means approved in writing by the Director. An approved programme will contain evidence of this approval via signature or official stamp. Certain aircraft require approved maintenance programmes. 8 to the operator after an ARA. For this reason the certification of the review contains the words, “the requirements of Parts 91 and 43 have been complied with”. This statement reinforces the fact that the process is a review of the aircraft airworthiness status, it does not indicate future compliance with the rules. They are: • aircraft with a MCTOW of greater than 5700 kg • turbine powered multi-engine aircraft • turbine powered rotorcraft • aircraft issued with a special category airworthiness certificate Operator responsibilities are detailed in Part 91 (rule 91.603 General Maintenance Requirements) and include ensuring: Maintenance programmes for gliders may be approved by a Gliding Association (certificated under Part 149) as detailed in Part 104 Gliders – Operating Rules. Also, the Sport Aircraft Association of New Zealand (previously known as NZAACA) develops customised programmes for their members’ amateur-built aircraft from a master programme approved by the CAA. It is important that IAs ensure that if the approved programme for an amateurbuilt aircraft is recorded as being the Sport Aircraft Association programme, this is the inspection schedule that is being used. It is not acceptable to identify this programme but physically carry out the Part 43 Appendix C (Annual and 100-hour) inspection. • aircraft are maintained in an airworthy condition • applicable Airworthiness Directives are complied with • inspections required by Part 91 Subpart G are carried out • airworthiness limitations in a manufacturer’s maintenance manual, or contained in an approved maintenance programme, are complied with, including component finite lives • any item of equipment or any instrument permitted inoperative by rule 91.537 (Inoperative instruments and equipment) is removed, repaired or replaced at the next required inspection Maintenance requirements and responsibility Part 91 Subpart G Operator maintenance requirements places the responsibility for the maintenance of an aircraft upon the operator. In practical terms the operator is the only person that has both operational and maintenance control of the aircraft at all times. The operator may contract with a maintenance organisation for the maintenance control of an aircraft, but the overall responsibility still remains with the operator. • any permitted inoperative equipment or instruments are placarded • except when the discrepancy relates to permitted inoperative instruments or equipment, all discrepancies have been rectified in accordance with Part 43, between inspections • no person performs maintenance on the aircraft other than those persons authorised in the rules. The IA has no control over the maintenance actions that occur once an aircraft is returned The function of the IA during this phase of the ARA is to ensure that all required 9 • completion of previous annual reviews of airworthiness maintenance has been carried out and certified on time or within the specified hourly period. To satisfy this requirement, the aircraft records should be examined for release to service statements for: • rectification of discrepancies including those listed on the Tech Log • re-calculation of weight and balance information as required • inspections required by an approved maintenance programme (when the aircraft is required to be maintained under this type of programme) IAs that have computer access, may elect to subscribe to the CAA web site’s free notification service. This service will forward an email message to the subscriber when a change has occurred to rules or Airworthiness Directives that the subscriber has registered an interest in. The web site address is www.caa.govt.nz. • annual or 100-hour inspection (for aircraft not requiring an approved maintenance programme) • replacement of life-expired components in accordance with the airworthiness limitations section of a manufacturer’s maintenance manual During the review of the maintenance records the IA must also ensure that entries fully meet the requirements of rule 43.69 Maintenance records and 43.115 (2) or 43.117 (2) Recording of post inspection ground run results. These rules require the recording of parts release document information, component part and serial numbers, results of any measurements or tests carried out (including the maximum height an altimeter has been tested to), and details of post-inspection engine ground runs. • radio station test and inspection every 24 months • altimeter (if applicable to the aircraft being reviewed and no current rule exemption exists) and altitude reporting equipment test every 24 months, and when the static lines have been disassembled (other than self sealing couplings), or when maintenance on the system could have introduced data correspondence error (see rule 91.613) Weight-and-balance information contained in the maintenance records must indicate that the aircraft is within the limitations of the aircraft Type Certificate. • SSR transponder test and inspection every 24 months • ELT test and inspection every 12 months Modifications and repairs noted on the aircraft during phase 1 or 3 of this review should be researched in the maintenance records. Major modifications and major repairs carried out after 1 April 1997 must have a certification of conformity to acceptable technical data entered in the record by an IA, unless the repair or modification has been carried out by a Part 145 organisation. • repetitive or initial Airworthiness Directive completion • compass compensation as applicable • safety equipment including fire extinguishers and flotation equipment every 12 months (see Advisory Circular 43-6 Emergency equipment) • duplicate inspections when control systems have been disturbed 10 • All visible modifications and repairs are approved and have been released to service. Reference to the approved technical data for each modification or repair should be contained in the maintenance records. Modifications or repairs not recorded in the records cannot be accepted as approved. If identification of a modification is proving difficult, the CAA may be able to provide the operator with modification ownership details, but technical data contained within a modification is considered to be the property of the modification owner and cannot be released by the CAA. • Identification and markings required by Parts 47 Aircraft Registration and Marking and 26 Additional Airworthiness Requirements are in place and legible. Check whether exemptions to these requirements are in force. Modifications should be approved via the Form CAA 337 process. • The minimum instruments and equipment required by the rules meet the appropriate standards. The standards may be as contained in Part 91 Appendix A Instrument and equipment specifications, or Appendix C to Part 21, or Part 26 or alternative specifications or standards that are acceptable to the Director. The instruments and equipment must have been installed in accordance with the aircraft manufacturer’s instructions or other acceptable technical data. The instruments and equipment must be in operable condition. Phase 3 – General condition inspection The purpose of the general condition inspection is to provide the IA with confidence that the maintenance records reviewed in phase 2 reflect the actual physical condition of the aircraft under review. This inspection is not the 100-hour/annual inspection detailed in Part 43 Appendix C. However, if the IA is also carrying out the 100-hour/annual inspection, the general condition inspection could be satisfied as part of this. • Refurbished interiors are documented in the aircraft maintenance records, including evidence that the materials meet the flammability standards required for type certification of the aircraft. The general condition inspection should address the following items: • The visible aircraft structure is free from defects that should have required a nonrelease to service statement being entered in the aircraft records in respect of corrosion, wear, leakage, etc. The aircraft condition should clearly indicate that all required inspections and maintenance actions have been completed fully. The aircraft condition should fully reflect the aircraft status contained in the maintenance records. • Aircraft radio station approval (form CAA2129) reflects the actual avionics fit installed in the aircraft. • Placards required by the data sheets, specifications, CAA Rules or flight manual are correctly in place and legible. • Documents to be carried, ie, Airworthiness Certificate, Tech Log, Form CAA 2129 and Flight Manual (not required for all gliders – see Part 104) are on board and current. 11 The current Flight Manual status can be accessed from the CAA web site www.caa.govt.nz, or hard copy will be provided to IAs on request. checklist containing discrepancies as a looseleaf logbook entry is acceptable, but it is preferred that discrepancies be entered directly into the logbook. When recording discrepancies on the checklist, those items that have been rectified should be noted in the appropriate section of the form. ARA documentation Due to the extensive nature of the ARA it is important that the IA use a checklist to assist with recording each step of the review. The checklist must contain at least the information contained in the Form CAA 24066/06 for fixed-wing or CAA 24066/07 for helicopters. The checklists are available from the CAA in hard copy and on the CAA web site. If an item is worn or corroded but is within published limits or, in the absence of published limits, does not affect structural strength or other airworthiness requirements (see Part 43.53 (a)(10), it is not a defect. The IA may wish to list any item that is not a defect but does indicate deterioration of the aircraft. The checklist should clearly indicate that it is only an observation and be entered in the remarks section. The completed checklist should be forwarded to the CAA, and a copy should be passed to the owner/operator for retention with the aircraft records. The purpose of forwarding a list of discrepancies found during the ARA to the CAA, is to provide statistical data on the continuing airworthiness status of New Zealand-registered aircraft, that are subject to the review. The ARA is a snapshot of the aircraft airworthiness status at the time the review is conducted. The review should be conducted as a single process and the discrepancies noted at the completion of the review. Remember that the ARA is not maintenance, and rectification action is not part of the process. If an owner/operator requests the IA to rectify discrepancies after the review, the rectification action should be recorded in the report to the CAA. If an owner/operator chooses to have a pre-ARA survey carried out to rectify any suspected discrepancies, discrepancies encountered must be entered into the aircraft records and are subject to normal release-to -service action. ARA administration Once the ARA has been completed and discrepancies recorded, the IA must enter in the logbook or other approved technical record, the full statement contained in rule 43.155 Certifying review, the IA’s signature, IA certificate number, and the date. The date of the next ARA must be entered in the appropriate section of the Tech Log. Discrepancies noted during the ARA are to be entered into the logbook or other approved technical record, and advised to the Director. A copy of the checklist containing the discrepancies is an acceptable method of advising the Director. Placing a copy of the 12 The certification of the ARA does not rely on the discrepancies being rectified prior to its issue. It is the operator’s responsibility to ensure the aircraft is not flown with a discrepancy. IAs must ensure that the certification of the ARA is not carried out before the full review process is completed. It is not acceptable to certify a partial review. Certification of Conformity The certification of conformity of major modifications and major repairs is also a privilege of IAs. The IA may not approve technical data but does perform a conformity inspection to ensure that major repairs and major modifications conform to acceptable technical data. The certification of the review is a statement that the ARA has been completed. It says that the airworthiness requirements for the aircraft have been met over the past 12 months – it is not a release to service. LAMEs certifying release-to-service statements for repairs and modifications must assess the repair or modification against the definition of a major modification or major repair. The definition is contained in Part 1 Definitions and Abbreviations. Advisory Circular 43-9A Modifications, repairs and the Form CAA 337, provides further information and guidance on typical repairs and modifications that should be considered major. Reporting of defects – Part 12 IAs must be familiar with this AC. The Form 337 has a dual purpose: It is possible that, after the ARA has been completed, the IA may have recorded discrepancies found during the general condition inspection that are defect incidents that must be reported in accordance with Part 12 Accidents, Incidents and Statistics. The IA should be familiar with Part 12 requirements and the additional information in Advisory Circular AC12-1 Mandatory occurrence notification and information. The person discovering a defect incident (an incident that involves failure or malfunction of an aircraft or aircraft component, whether found in flight or on the ground) must forward the incident details to the CAA within 10 days. If the incident is a serious incident, the CAA must be notified as soon as practicable. • approval of technical data • conformity certificate IAs must not certify the conformity statement of the Form 337 prior to the technical data being approved. • If the Form 337 relates to a major modification or repair that utilises acceptable technical data listed in Part 21 Appendix D, the originator, (usually the LAME) should complete the Technical Data Classification block (block 5) of the form by ticking the “is approved” box and completing the information within this block. The LAME may now request the IA to conduct the conformity inspection on 13 the completed work and certify the conformity inspection in block 7. Frequently Asked Questions • If the technical data is not acceptable data as listed in Part 21 Appendix D, and therefore requires approval, the data should be attached to the Form 337 and forwarded to the CAA or a certificated design organisation for approval. In this case block 5 should be ticked to indicate approval is required. The IA must not certify conformity in block 7 at this point as the data is not approved. Once the Form 337 has been returned from the CAA or design organisation as approved, the IA may be requested to conduct and certify the conformity inspection. The following list of frequently asked questions are provided for the guidance of IAs. 1. Can an IA delegate the ARA to an appropriately rated licensed aircraft maintenance engineer? Answer: No, the IA must complete all sections of the ARA. 2. If a modification is observed and the maintenance records contain an entry for the modification that includes a reference to its approval and a release to service, does the IA need to gain a copy of the approved modification to verify it? The conformity inspection should consist of: • review of the technical data to ensure it is acceptable technical data (Part 21 Appendix D) or that the data has been approved Answer: No. However, if the IA is familiar with the modification and realises that it has been improperly carried out, it should be entered as a discrepancy. • review of the work completed to ensure that it has been carried out in accordance with the approved technical data 3. When carrying out the ARA on an amateur-built aeroplane, what form of modification approval should the IA look for? Form 337 distribution Form 337 is completed in duplicate. One copy is forwarded, once action regarding the certification of conformity is complete, to the CAA for the aircraft’s file. The second copy is retained as part of the aircraft maintenance records. Answer: Modifications to this category of aircraft may be substantiated by in-flight evaluation. If a major modification has been carried out, the owner should have contacted the CAA regarding placing the aircraft into a test programme within a restricted area. Certification of conformity of major repairs and modifications via Form CAA 337 is not required for aircraft with special category Airworthiness Certificates. 14 4. If a periodic inspection has been certified in the logbook and the entry refers to the inspection title and a work package, should the IA check that all relevant entries in the work package have been certified correctly? 7. Is an ARA required on a newly imported aircraft that is undergoing initial airworthiness certificate issue? Answer: Yes, if the aircraft is being maintained under the Part 43 ARA process. (Private operations, or air transport flights on aircraft with nine seats or less operating under Part 135.) Answer: The IA should check that all due maintenance has been carried out. The logbook entry for the inspection that contains a release-to-service statement, and refers to the inspection title and the work package, is sufficient evidence that the required inspection has been completed. It is the responsibility of the certifying Licensed Aircraft Maintenance Engineer to ensure that all entries in the work package have been correctly certified before issuing a release-to-service statement. 8. If an IA finds a defect on an aircraft during the ARA, can that defect rectification be deferred to allow the aircraft to return to base? Answer: The rules are no different in respect of an ARA to the standard defect rectification requirements of Part 43 and 91. If the aircraft does not have a Minimum Equipment List, no defect rectification can be deferred other than the items detailed in rule 91.537 (Inoperative Instruments and Equipment). Items that show deterioration that is not beyond manufacturer’s limits, or published standard practices contained in acceptable technical data (see Part 21), are not defects and may be recorded in the maintenance records and monitored in accordance with the maintenance record statement. 5. Does an IA have to use the CAA Forms 24066/06 or 07 as a checklist when completing an ARA? Answer: The use of a checklist is required as an acceptable method of recording the review actions. The CAA Forms 24066/06 or 07 are an acceptable checklist. However, IAs may design their own checklist provided they ensure that it contains at least the same information as the CAA form. Example: RH MLG Scissor link bush Part number xxxxx found worn. Bush inspected, found within manufacturers limits (refer Manual xx Fig 3). Bush to be reinspected at next 50-hour inspection. 6. Can an ARA be deferred? Answer: No. But the ARA may be completed early if realignment to other scheduled maintenance is required. 15 9. During an ARA the IA notices significant corrosion on the aircraft structure. The maintenance records indicate that the corrosion has been noted and is to be monitored. Should the IA record the corrosion as a discrepancy? record an assessment of the affected area and the basis for the aircraft being considered fit for release to service, ie, reference to acceptable technical data in respect to the assessment. If an assessment is not recorded in the maintenance records or the corrosion is believed to be affecting the aircraft’s structural strength, then a discrepancy must be entered onto the ARA checklist. Answer: This depends upon the extent and location of the corrosion, and any published limits. 10. During an ARA, the IA notes minor surface corrosion or other items which, if not addressed, may become defects, but at the time of the review, the aircraft is fit for release to service. The IA wishes to draw these items to the operator’s attention and record them for future assessment. Should these items be recorded as discrepancies. The bottom line is that defects cannot be deferred, other than items falling under Part 91, rule 91.537. Part 43, rule 43.53 requires that persons performing maintenance shall ensure that, on completion of the maintenance (this includes an inspection) the aircraft or component shall be fit for release to service, and at least equal to its original structural strength. In the absence of published limits, the LAME must ensure that the aircraft is at least equal to its original structural strength. The presence of corrosion has a direct impact on structural strength. Therefore, if corrosion is present, the maintenance records should Answer: The CAA check list Form CAA 24066/06 (fixed wing) or 07(rotorcraft) contains space in which remarks may be placed. If the item noted is not a defect it may be recorded here. It should not be recorded as a discrepancy. 16
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