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Parts 42 & 145 Questions and answers
Please find below a selection of frequently asked questions and answers on Parts 42 and 145. Click on each question to open up or close a corresponding answer.
Q. Is Part 42 applicable to organisations who maintain helicopters over 3175kg MTOW?
A. Part 42 is only mandatory for regular public transport (RPT) aircraft. Currently Part 42 is not mandatory for any rotorcraft, although the operator of any large rotorcraft may elect to bring their rotorcraft under Part 42. CASA proposes to extend the compulsory applicability of Part 42 to large rotorcraft—rotorcraft that are type certificated in the Transport Category and that are greater than 3175 kg MTOW or more than nine passenger seats.
Q. What is the relevance of CAO 100.5 in relation to the application of Part 42 to an aircraft?
A. Provisions of CAO 100.5 are made under Civil Aviation Regulations (CAR) 1988 and are therefore applicable for CAR maintenance, including CAR maintenance carried out under a Part 145 approval by an approved maintenance organisation.
CAO 100.5 is applicable to all Australian aircraft with a current certificate of airworthiness, except those to which Part 42 applies. Where a Part 145 Approved Maintenance Organisation (AMO) carries out CAR maintenance—maintenance on aircraft to which Part 42 does not apply—the CAO is applicable.
A Part 145 AMO’s exposition must include a system of certification that demonstrates how the AMO will comply with the maintenance certification provisions of CAR 1988.
Q. When is an operator of an aircraft no longer able to source a holder of a CAR 30 certificate for aircraft maintenance?
A. When Part 42 of Civil Aviation Safety Regulations (CASR) 1998 becomes applicable to an aircraft a Continuing Airworthiness Management Organisation can no longer use holders of CAR 30 Certificate of Approval for aircraft and aeronautical product maintenance—they must source the services of a Part 145 Approved Maintenance Organisation.
Q. It is mandatory for operators of regular public transport (RPT) to source a Part 145 Approved Maintenance Organisation to maintain their aircraft and aeronautical products. Does this also apply to operators of aircraft used for charter and aerial work?
A. No. Part 42 of Civil Aviation Safety Regulations (CASR) 1998 only becomes applicable to an aircraft when legislation mandates that it is. Part 42 is currently only applicable to aircraft approved to operate under an Air Operator’s Certificate issued for the purposes of 206(1) (c) of Civil Aviation Regulations (CAR) 1988 (RPT) or if a registered operator elects to make their aircraft applicable under Part 42. For all other aircraft CAR 1988 still applies.
Q. I am a Part 145 Approved Maintenance Organisation maintaining aircraft used in regular public transport (RPT) do I also need to become a Continuing Airworthiness Management Organisation (CAMO)?
A. No. Part 42 of Civil Aviation Safety Regulations (CASR) 1998 is applicable to an aircraft that is approved to operate under an Air Operator’s Certificate issued for the purposes of 206(1)(c) of Civil Aviation Regulations (CAR) 1988 (RPT). Part 42 mandates that maintenance must be carried out by a Part 145 Approved Maintenance Organisation (AMO)—see Regulation 42.295. An AMO is a standalone organisation that is approved by CASA to maintain aircraft or aeronautical products. A CAMO is an organisation that has an approval to manage the continuing airworthiness of aircraft. For aircraft in RPT this means that the operator must be an approved CAMO—see subregulation 42.040 (1).
Q. Can a Part 145 Approved Maintenance Organisation elect Part 42 if they operate aircraft over 5700kg?
A. Part 42 approval relates to the operator of aircraft (Air Operator’s Certificate holder) not a maintenance organisation. It includes continuing airworthiness management requirements for an aircraft to which it is applicable. One of the requirements of Part 42 is that aircraft are maintained by a Part 145 Approved Maintenance Organisation (AMO)—see regulations 42.295–42.305 of Civil Aviation Safety Regulations 1998. Currently the only aircraft to which Part 42 applies are those used in regular public transport (RPT)—these aircraft and their aeronautical products are maintained by a Part 145 AMO.
Legislation made since the introduction of the mandatory applicability of Part 42 to RPT has enabled the operators of aircraft used in charter and aerial work elect to have their aircraft maintained by a Part 145 AMO.
In addition, legislation has been made to enable a Part 145 AMO to apply to CASA for approval to carry out CAR maintenance (maintenance under CAR 1988) of aircraft to which Part 42 does not apply.
Q. I am a Part 145 Approved Maintenance Organisation can I carry out maintenance on an aircraft to which Part 42 is not applicable?
A. An application can be made to CASA for approval under Part 145 to carry out not only maintenance on aircraft to which Part 42 applies, but it may also apply for approval to carry out maintenance on aircraft to which Part 42 is not applicable—CAR maintenance. Your Part 145 approval will enable your organisation to carry out maintenance on aircraft that are not under Part 42, in accordance with your exposition and CAR 1988 provisions. As you will have a Part 145 approval certificate you will no longer need to maintain your CAR 30 certificate of approval.
Q. I have a current CAR 30 Certificate of Approval (COA) and I would like to transition to a Part 145 Approved Maintenance Organisation (AMO) Approval Certificate without any change to the scope of the maintenance I am approved to do. Am I eligible for a fee waiver?
A. Applications requesting like-for-like transitions to a Part 145 AMO Approval Certificate, providing the applicant is the holder of an approval under CAR 30, will be granted a 1:1 fee waiver.
Q. I don’t have a current CAR 30 COA and I would like to apply for a Part 145 AMO Approval Certificate. Am I eligible for a fee waiver?
A. When applying for an initial approval for a Part 145 AMO Approval Certificate, or seeking additional privileges on a Part 145 AMO Approval Certificate, CASA will issue a fee estimate after review of the application.
Q. I am varying the scope of my CAR 30 COA, will I also be charged to vary the scope of the Part 145 Approved Maintenance Organisation (AMO) Approval Certificate?
A. Yes, a fee estimate will be provided for the change of scope to your Part 145 AMO Approval Certificate. However, as a result of recent regulatory changes the scope of any CAR 30 COA can now be carried out, if approved, by a Part 145 AMO. Using your approved significant/non-significant change process the variation of scope can be incorporated into your Part 145 AMO Approval Certificate.
Consideration should be given to transitioning the full scope of the CAR 30 COA to the Part 145 AMO Approval Certificate and cancelling the CAR 30 COA to remove duplication and minimise costs.
Q. In order for a Continuing Airworthiness Management Organisation (CAMO) to be compliant with Part 42 do they need to submit an exposition?
A. Yes. An application for approval and the exposition will be assessed for compliance to legislation by CASA. Once approved, the CAMO must comply with what has been outlined in its exposition and legislation.
Q. Will the holder of a CAR 30 COA for Distribution be required to transition it a Part 145 AMO certificate for Distribution?
A. No, although a CAR 30 COA for Distribution still exists for aircraft covered under Civil Aviation Regulations (CAR) 1988, this function is achieved within the scope of the Part 145 AMO under the Civil Aviation Safety Regulations (CASR) 1998.
Part 145 AMOs are responsible for ensuring that aeronautical products (e.g. components, parts, appliances, materials) are accompanied by the appropriate paperwork and for rejecting any aeronautical products that do not meet the relevant requirements of Subpart 42.E of the CASR 1998.
Q. Can an initial application for aircraft or aeronautical product maintenance be submitted for a Part 145 AMO or must a CAR 30 COA application be submitted first?
A. A new applicant can apply to become a Part 145 AMO without already holding a CAR 30 COA. Once the Part 145 AMO approval is received, the Part 145 AMO can carry out maintenance under a single certificate for aircraft and aeronautical products that are subject to either the CASR or CAR requirements.
More information on a Part 145 AMO undertaking CAR maintenance activities is provided in Division 202.GE.2 of Part 202 of CASR 1998 and Regulation 340 of CAR 1988.
Q. With regard to specialist maintenance, can I hold a Part 145 AMO approval for Non-Destructive Testing or composite repairs only?
A. Yes, a Part 145 AMO certificate for specialist maintenance can be issued for process specific maintenance. This includes—but not limited to:
- D1 – Non - Destructive Testing
- D2 – Welding
- D3 – Aircraft Surface Finishing
- D3 – Aircraft Structural Repair
Note: Other maintenance can be approved as specialist maintenance after review by the CASA Standards Division.
Part 145 Manual of Standards (MOS) Appendix I (8): a category D rating means that an AMO can provide maintenance services for specialist maintenance on an aircraft or an aeronautical product without holding a category A rating for aircraft maintenance or a category B or C rating for aeronautical product maintenance.
Q. What are line maintenance and base maintenance?
A. Line maintenance for a Part 145 AMO is maintenance on an aircraft that CASA has approved in the organisation’s exposition as being line maintenance by that organisation. (see CASR Dictionary Part 3).
MOS AMC 145.A.10 - Line maintenance: An acceptable means of compliance would be for a Part 145 AMO to describe its line maintenance as being any maintenance that is carried out before flight to ensure that the aircraft is fit for the intended flight.
MOS GM 145.A.10 - Base maintenance: maintenance tasks falling outside the criteria for line maintenance above are considered to be base maintenance.
Q. When must a Part 145 AMO define the difference between line and base maintenance?
A. A Part 145 AMO must define the difference between line and base maintenance when seeking approval to maintain:
- aeroplanes requiring A1 rating on their approval certificate
- rotorcraft requiring A3 rating on their approval certificate that:
- are certificated in the Transport Category, or
- are above 3175 kg MTOW, or
- has more than nine passenger seats.
Where this definition is not required, all aircraft maintenance can be taken to be line maintenance.
Q. How will CASA maintain consistency of exposition assessments?
A. The assessment handbook and worksheets have been developed to directly correspond with the appropriate legislation and acceptable means of compliance (AMC) together with the use of a sample exposition and appropriate training and peer review ensures consistency of assessments.
Q. There is a legislative requirement for a Part 145 AMO to determine that an individual has six months experience in the previous two years, prior to issuing an authorisation. How is this calculated?
A. A Part 145 AMO can determine the means by which the period of experience is calculated. However, the result should equate to six months of full-time employment in aircraft or aeronautical product maintenance, carrying out maintenance or exercising certification privileges on at least some of the aircraft type systems or aeronautical products for which the authorisation is to be given.
Example A: three months full-time aircraft maintenance + six months part-time (50 per cent full- time equivalent) aeronautical product maintenance = acceptable.
Example B: three months full-time aircraft maintenance + five months part-time (50 per cent full-time equivalent) aeronautical product maintenance + one month part-time (50 per cent full-time equivalent) maintenance certification = acceptable.
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