NPRM 1528SS - Completion of maintenance by a Part 145 AMO conducting maintenance processes (Form 2 proposal)
When a Part 145 Approved Maintenance Organisation (AMO) holds a D rating, it has been approved to provide one of the specialist maintenance processes or techniques that may be applied to an aircraft or aeronautical product. Such an approval is not subject to limitations by aircraft and aeronautical product type. Examples of the specialist maintenance approval class include non-destructive testing, welding and other specialist maintenance functions such as composite repairs and painting.
A D-rated AMO may carry out specialist maintenance on a wide range of type-rated aircraft types. In some cases this situation (e.g. multiple different type-rated aircraft being painted) can become problematic as the D-rated AMO would need appropriate Part 66 licence holder(s) for each aircraft to be issued with a Certificate of Release to Service (CRS).
The civil aviation legislation does not allow an AMO to release an aircraft post-maintenance unless a CRS has been issued. For a D-rated AMO, the CRS issue would require the employment of individuals who are not only competent to carry out the maintenance for which the AMO is approved, but also qualified under paragraph 145.A.30 (k) of CASR for each and every type-rated aircraft type for which the AMO might provide the maintenance service.
CASA believes that, where a D-rated AMO has been engaged by an A-rated AMO (an AMO approved for the maintenance of the particular type-rated aircraft type), a CRS in relation to the specialist maintenance is not necessary. Given that a maintenance certification for the specialist maintenance would already have been made by the D-rated organisation at the completion of the specialist maintenance, the final aircraft CRS can safely be provided by the A-rated AMO controlling the overall aircraft maintenance event.
How to respond
Please forward your response to the Project Leader David Skeoch, by close of business 29 January 2016.