QCM
In this Newsletter    
Editorial   Dear Readers, 

   

Welcome to our September edition.  

How come the summer is over already? It feels like it has not even started yet and already the leaves are changing colour and the chilly winds are back. Thankfully I have a nice, hot cup of tea next to me to help me keep warm. I hardly ever drink hot tea on a plane after I witnessed my seat neighbour spilling his coffee all over himself when we hit an unexpected turbulence. Luckily I was too bussy reading the latest Harry Potter novel to order anything to drink at all.

This month Georg Stöcker discusses responsibility of airworthiness directives in the
 main article.

Also included are a couple of short topics.

In the not so distant future there are our courses, of course. Please have a look at the open course status and our course updates.

This month we have one 
job offer but you can of course continue to send us your job offers.

Have a lovely golden October.
   



Tina Cameron
Q.C.M

 
Main Article
Newsflash

I. Notices of Proposed Amendments (NPAs)

II. Fire brought down Asiana 747F in just 18 Minutes

III. FAA and Germany to cooperate in alternative aviation fuels


 
Course Updates

I. Open Course Status October -December 2012

II. Open Course Status EASA Part-147 Type Trainings
Job Market
   





Airworthiness Directive Responsibility

In my last newsletter article I raised a question which is often discussed.
Who is responsible to ensure that all airworthiness directives are complied with?
Is it the person or organisation carrying out maintenance or is it the person or organisation who accomplishes the tasks associated with continuing airworthiness?

Also here, similar to the last subject discussed in the August 2012 Newsletter – critical tasks and flight sensitive maintenance tasks – it is a "shared" responsibility.

Why a "shared" responsibility?
In the first instance it is the responsibility of the owner or operator and it continues with the person or organisation who accomplishes the tasks associated with continuing airworthiness and the person or organisation carrying out maintenance, respectively issuing the release to service.


 

1. Owner

It all starts with the person or organisation responsible for the continuing airworthiness. This is in the first instance the owner. According to M.A.201(a) the owner is responsible for the continuing airworthiness. And it is the owner's responsibility to ensure that a flight only takes place if the aircraft is maintained in an airworthy condition.

M.A.201(a):  The owner is responsible for the continuing airworthiness of an aircraft and shall ensure that no flight takes place unless:
1. the aircraft is maintained in an airworthy condition, and; ...

But, what does "airworthy condition" mean?
Commission Regulation (EC) No 2042/2003 Article 2(d) defines:

Article 2(d): ‘continuing airworthiness’ means all of the processes ensuring that, at any time in its operating life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation;
Taking this definition we can say, an aircraft is in an airworthy condition when it

 

  • complies with the airworthiness requirements in force

and
 

  • is in a condition for safe operation.

What does it mean "condition for safe operation"? Here I refer to M.A:801(h) and AMC M.A.801(h).

M.A.801(h):  A certificate of release to service shall not be issued in the case of any known non-compliance which endangers flight safety.

AMC M.A:801(h):   ‘Endangers flight safety’ means any instance where safe operation could not be assured or which could lead to an unsafe condition. It typically includes, but is not limited to, significant cracking, deformation, corrosion or failure of primary structure, any evidence of burning, electrical arcing, significant hydraulic fluid or fuel leakage and any emergency system or total system failure. An airworthiness directive overdue for compliance is also considered a hazard to flight safety.

So, consequently the owner is responsible to ensure that all applicable airworthiness directives are complied with. This is also stipulated in M.A.301 which requires:

M.A.301: The aircraft continuing airworthiness and the serviceability of both operational and emergency equipment shall be ensured by:

M.A.301-5:   the accomplishment of any applicable:
(i) airworthiness directive, ...

In addition it is also reflected in M.A.303 which requires:

M.A.303: Any applicable airworthiness directive must be carried out within the requirements of that airworthiness directive, unless otherwise specified by the Agency.


 

2. Operator

But, very often this responsibility is transferred in accordance with M.A.201(b):

M.A.201(b):  When the aircraft is leased, the responsibilities of the owner are transferred to the lessee if:
1. the lessee is stipulated on the registration document, or;
2. detailed in the leasing contract.
When reference is made in this Part to the ‘owner’, the term owner covers the owner or the lessee, as applicable.

Based on that, we usually say that the continuing airworthiness is the responsibility of the "owner/operator".

How can the owner/operator proof that the aircraft complies with all applicable airworthiness directives?
The evidence for compliance is a status of airworthiness directives which forms part of the continuing airworthiness records.

M.A.305(d):  The aircraft continuing airworthiness records shall contain the current:
1. status of airworthiness directives and measures mandated by the competent authority in immediate reaction to a safety problem; ...

AMC M.A.305(d):   The current status of AD should identify the applicable AD including revision or amendment numbers. Where an AD is generally applicable to the aircraft or component type but is not applicable to the particular aircraft or component, then this should be identified. The AD status includes the date when the AD was accomplished, and where the AD is controlled by flight hours or flight cycles it should include the aircraft or engine or component total flight hours or cycles, as appropriate. For repetitive ADs, only the last application should be recorded in the AD status. The status should also specify which part of a multi-part directive has been accomplished and the method, where a choice is available in the AD.
 

 

3. Person or organisation accomplishing the tasks associated with continuing airworthiness

But what about the person or organisation accomplishing the tasks associated with continuing airworthiness and the person or organisation carrying out maintenance?
According to M.A.201(e) the person or organisation who accomplishes the tasks associated with continuing airworthiness is responsible for proper accomplishment of the tasks associated with continuing airworthiness and is not responsible for the continuing airworthiness.

M.A.201(e):  In order to satisfy the responsibilities of paragraph (a),
(i) the owner of an aircraft may contract the tasks associated with continuing airworthiness to a continuing airworthiness management organisation approved in accordance with Section A, Subpart G of this Annex (Part M). In this case, the continuing airworthiness management organisation assumes responsibility for the proper accomplishment of these tasks. ...

One of these tasks associated with continuing airworthiness is to ensure that all applicable airworthiness directives are applied.

M.A.708(b):  For every aircraft managed, the approved continuing airworthiness management organisation shall: ...
5. ensure that all applicable airworthiness directives and operational directives with a continuing airworthiness impact, are applied, ...

The evidence for the proper accomplishment of the task to "ensure that all applicable airworthiness directives are applied" is the establishment of the airworthiness directives status (see M.A.305(d)1).

It is the person or organisation accomplishing the tasks associated with continuing airworthiness who must evaluate all published airworthiness directives for applicability and, if one is applicable, ensure that it is accomplished by the person or organisation carrying out maintenance. A clear work order must be issued to the person or organisation carrying out maintenance requesting the accomplishment of the applicable airworthiness directive.

Once the airworthiness directive is carried out the person or organisation who performed that work must issue appropriate maintenance records, issue the release to service for that work performed and transfer all corresponding records and the release to service to the person or organisation issuing the work order.

After receipt of these records, including the release to service, the person or organisation who accomplishes the tasks associated with continuing airworthiness must establish/update the airworthiness directives status. This provides the owner with the evidence that the aircraft is in an airworthy condition in regards to that airworthiness directive.
 

 

4. Person or organisation issuing the release to service

What is the responsibility of the person or organisation carrying out maintenance, respectively issuing the release to service?
Every person or organisation carrying out maintenance is only responsible for the tasks performed.

M.A.201(c):  Any person or organisation performing maintenance shall be responsible for the tasks performed.

Therefore, if the person or organisation who accomplishes the tasks associated with continuing airworthiness does not issue a work order to the person or organisation carrying out maintenance requesting the performance of an airworthiness directive the person or organisation carrying out maintenance is not allowed to carry out an applicable airworthiness directive, even if this airworthiness directive is overdue.

A release to service must be issued after any maintenance and as long as the person or organisation carrying out maintenance does not know about an applicable airworthiness directive being overdue the release to service can be issued after performing the tasks.

M.A.305(a):  At the completion of any maintenance, the certificate of release to service required by point M.A.801 or point 145.A.50 shall be entered in the aircraft continuing airworthiness records. ...

M.A.801(b):  No aircraft can be released to service unless a certificate of release to service is issued at the completion of any maintenance, when satisfied that all maintenance required has been properly carried out, ...

But, there is one restriction. As we have seen above, if the person or organisation carrying out maintenance knows about a non-compliance which endangers flight safety (see M.A.801(h) and AMC M.A.801(h)) a release to service cannot be issued.

And here the little word "know" is the key word. The person or organisation carrying out maintenance does not normally know the detailed status of the aircraft. The situation might occur where a release to service is issued and there is an airworthiness directive overdue. If the person or organisation carrying out maintenance is not aware of this it cannot be blamed.

But there is an area where the person or organisation carrying out maintenance is responsible for the airworthiness directives status. This is with respect to storage of articles. We have situations where the person or organisation carrying out maintenance owns a certain stock of articles. In this case it is the responsibility of the person or organisation carrying out maintenance to ensure that all articles in the store comply with the airworthiness requirements, and one issue is complying with all applicable airworthiness directives.

Therefore, even the person or organisation carrying out maintenance need to establish a procedure defining how airworthiness directives are evaluated to ensure that all articles are airworthy prior to installation.

M.A.501(b):  Prior to installation of a component on an aircraft the person or approved maintenance organisation shall ensure that the particular component is eligible to be fitted when different modification and/or airworthiness directive configurations may be applicable.

AMC M.A.501(b):   1. The EASA Form 1 identifies the airworthiness status of an aircraft component. Block 12 "Remarks" on the EASA Form 1 in some cases contains vital airworthiness related information (see also Part-M Appendix II) which may need appropriate and necessary actions.

2. The fitment of a replacement components should only take place when the person referred to in M.A.801 or the M.A. Subpart F or Part-145 maintenance organisation is satisfied that such components meet required standards in respect of manufacture or maintenance, as appropriate.

3. The person referred to under M.A.801 or the M.A. Subpart F or Part-145 approved maintenance organisation should be satisfied that the component in question meets the approved data/standard, such as the required design and modification standards. This may be accomplished by reference to the (S)TC holder or manufacturer's parts catalogue or other approved data (i.e. Service Bulletin). Care should also be [taken] in ensuring compliance with applicable ADs and the status of any service life limited parts fitted to the aircraft component.
 

 

5. Conclusion

So, if we talk about compliance with applicable airworthiness directives, everybody involved in continuing airworthiness, including the performance of maintenance, has a certain responsibility.

Appropriate procedures must be established to ensure that there is evidence that any applicable airworthiness directive is complied with.


 



 




Notice of Proposed Amendments (NPAs)
 

TITLE
 
DATE PUBLISHED
END OF COMMENT
NPA 2012-14
AMC and GM to Part-SERA

 
2012-09-24 2012-12-24
NPA 2012-13
Additional Requirements for Operations

 
2012-09-13 2012-12-13
NPA 2012-12
Transfer of JAA cabin safety tasks

 
2012-08-29 2012-11-29
NPA 2012-11
Recognition of ED-12C/DO-178 in EASA AMC 20-115 

 
2012-08-22 2012-11-22
NPA 2012-10
Transposition of Amendment 43 to Annex 2 to the Chicago Convention on remotely piloted aircraft systems into common rules of air

 
2012-08-21 2012-10-15
NPA 2012-09
CS GENERIC MMEL for other-than-complex motor-powered aeroplanes

 
2012-08-16 2012-11-16
NPA 2012-08
Maintenance check flights

 
2012-07-30 2012-10-30
NPA 2012-07
Guidance material on volcanic ash safety risk assessment

 
2012-07-19 2012-10-19
NPA 2012-06
Sterile Flight Deck Procedures

 
2012-07-11 2012-10-11
NPA 2012-05
Certification Specifications for Flight Crew Data

 
2012-07-06 2012-10-08





Fire brought down Asiana 747F in just 18 Minutes


Korean investigators have revealed only 18min elapsed between detection of fire on board an Asiana Airlines Boeing 747-400F, and the fatal loss of the aircraft in the sea. But while the inquiry has disclosed more details of the dangerous cargo on board the aircraft, it has yet to reach conclusions over the origin of the fire.

The cargo jet, operating Seoul-Shanghai on 28 July 2011, crashed about 130km (70nm) west of Jeju while attempting to divert to the island. Preliminary findings by Korea's Aircraft and Railway Accident Investigation Board show the aircraft was 50min into its flight and had just been transferred to Shanghai area control centre when it made the emergency call.

RUDDER DIFFICULTIES
One of the pilots mentioned an aft cargo fire and that the aircraft was descending to 10,000ft (3,050m). It turned north-east, requesting radar vectors to Jeju.
Data from Seoul Incheon area centre indicates the aircraft, travelling at about 400kt (740km/h), continued to descend to about 8,000ft before climbing again, in an unstable vertical profile.
(Source: Flight International)





FAA and Germany to Cooperate in Alternative Aviation Fuels  

The FAA and the German Federal Ministry of Transport, Building and Urban Development (BMVBS) signed a Declaration of Cooperation at a ceremony during the ILA Berlin Air Show in September to work together in facilitating the promotion, development and use of sustainable alternative aviation fuels in the United States and Germany.

“Together, we can leverage our research, our knowledge and our greatest resource — our experts — to work toward creating new sustainable alternative jet fuels,” said Philip D. Murphy, U.S. Ambassador to the Federal Republic of Germany, who signed the Declaration on behalf of the FAA with Dr. Peter Ramsauer, Federal Minister for Transport Building and Urban Development. “This, and other Declarations of Cooperation with international partners, such as Australia and Brazil, will enable us to better share and exchange technologies and that will benefit aviation on a global level.”

The goals of the Declaration are to exchange ideas, information, skills and techniques and to collaborate on problems and projects of mutual interest in relation to sustainable alternative aviation fuels development and use.   The Declaration identifies specific areas in which the FAA and the BMVBS may cooperate, which include exchanging information about research results, publications, funded research and development activities and the sharing of best practices in alternative jet fuel conversion research and development and deployment. The Declaration also enables the FAA and the BMVBS to explore the possibilities for cooperation in other areas, such as researching the lifecycle impact of the use of candidate alternative fuels on atmospheric emissions, and research leading to cost reductions in the production of alternative aviation fuels.
(Source: FAA)
 
 
 




Please find below our open courses with seats available.

If you are interested in participating in these or any other training please do not hesitate to contact us.
  I. Open Course Status October 2012 - December 2012 
  Course Date Seats  Instructor
  Stock Management 04. - 05.10 12 open Georg Stöcker
  EASA Part-21 POA Basic (Vienna) 04. - 05.10.12 open Christian Schusser
 EASA Part-21 DOA Basic 08. - 10.10.12 open Christian Schusser
  EASA Part-21 POA Differential 11.10.12 open Christian Schusser
  Human Factors Initial 16. - 17.10.12 5 Anton Bürgi
  Safety & Quality Management Systems
in Aviation
22. - 25.10.12 full Markus Friedli
  NiCad Batteries 23. - 24.10.12 full Anton Bürgi
  EASA Part-66/147 05. - 06.11.12 open Jürgen Feldhoff
  EASA OPS / EASA FCL Airplanes 13. - 14.11.12 open Patrick Sutter
  EASA Part-M Subpart G Refresher 14.11.12 3 Paul Baumann
  Aviation Legislation 15.11.12 open Paul Baumann
  Fuel Tank Safety Phases 1 and 2 20.11.12 open Paul Baumann
  EWIS 21.11.12 open Paul Baumann
  FAA Part 145 27. - 28.11.12 open Georg Stöcker
  Internal Auditor 27. - 29.11.12 open Markus Friedli
  EASA Part-145
(course language German)
04. - 06.12.12 open Georg Stöcker
  EASA Part-M Subpart G
(course language German)
10. - 12.12.12 open Paul Baumann
  Airworthiness Review for ARC Signatories
(course language German)
13.12.12 open Paul Baumann
 If not stated otherwise, courses take place in our facilities in Belp/Berne.
Please click on the Course title for detailed information







  II. Open Course Status EASA Part-147 Type Trainings
  Course title Date
Seats
available
Instructor
 Learjet 35/36 B1.1/T1 08. - 29.10.2012 open TBD
  Learjet35/36 B2/T2 Extension 30.10 - 03.11.2012 open TBD
  Cessna 560XL B1.1/T1 October/November 2012 open TBD
 If not stated otherwise, courses take place in our facilities in Belp/Berne.
Please click on the Course title for detailed information


  




Q.C.M. Maintenance AG is looking for a EASA B1 engineer:

Qualification
- EASA Part 66 B1 licence, cat C is an advantage.
- Type rating on Cessna 525 and/or 550/560 and/or 560 XLS.
- Good knowledge of English spoken and written, knowledge of German is an advantage.
- Flexible, able to work under pressure and a team player
- High sense of responsibility is a must
- Motivation to perform a broad variety of tasks
- Willingness to work odd working hours.
- The position may involve some overseas travelling

Experience
At least 3 years’ experience within a maintenance organisation (Line or Base Maintenance).

Description/Tasks
- The EASA Licensed Engineer will performs work on complex aircraft systems, including trouble shooting, functional and operational checks in accordance with ratings and experience.
- Service and maintain aircraft systems
- Customer AOG Response.

Please provide a copy of your EASA license with a required type rating along with updated copy of your CV in Word format and send it to:


Mr Erlendur Gudmundsson

Erlendur@qcm-mx.ch

Q.C.M Maintenance AG
Eichholzweg 20-24
CH-3123 Belp

www.qcm.ch

 


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