8.1.1 This chapter is intended to provide additional guidance on continuing airworthiness regulations to supplement the DASR (DASP Manual Volume 2). This chapter provides additional guidance on aviation safety outcomes that may incorporate compliance with multiple regulations.
8.1.2 The sub-chapters within this chapter are associated with Continuing Airworthiness Management, Maintenance Organisations, Maintenance Licencing and Maintenance Training Organisations. These sub-chapters will also reference, where appropriate, other chapters and sub-chapters within DASP Manual Volume 3 for common aviation safety elements (e.g. occurrence reporting). Other DASP content relevant to continuing airworthiness will also be referenced where possible.
8.1.3 This chapter will contain information that has historically been communicated via Factsheets, Advisory Circulars (ACs) and Frequently Asked Questions (FAQs). In some instances, these historical methods of communicating guidance will remain – particularly for guidance that has a limited period of applicability or when inclusion in DASP Manual Volume 3 is not an intuitive way to communicate specific information. Use of separate Factsheets, enduring ACs and FAQs will be the exception, with the intent that DASP Manual Volume 3 to be the central repository for continuing airworthiness guidance outside of DASR.
8.1.4 The content in this chapter will evolve as the need for additional guidance is identified, with new content and/or new sub-chapters being added over time to support optimal capability outcomes. Accordingly, DASA welcomes any suggestions for future continuing airworthiness guidance noting that awareness training is available via the DASA website.
Introduction
8.2.1.1 The following chapters provide additional guidance on DASR M regulations – they cover activities such as Deferment of Defects, Acceptance of Components and Aircraft Maintenance Programs.
8.2.1.2 The Continuing Airworthiness Management Organisation (CAMO) should be principally located within the aircraft's operational organisation, although the majority of DASR M functions may be outsourced/assigned to other organisations or service providers.
8.2.1.3 Continuing airworthiness management regulation is summarised in the requirements of DASR M.A.101 as ‘This [DASR M] establishes the measures to be taken to ensure that [continuing] airworthiness is maintained, including maintenance. It also specifies the conditions to be met by organisations involved in such continuing airworthiness management’.
8.2.1.4 Referenced content relevant to, but not directly related to, continuing airworthiness will be found in other areas of the Defence Aviation Safety Program including other chapters of DASP Manual Volume 3.
DASR M - Continuing Airworthiness Management
8.2.1.5 CAMOs are required to ensure all their maintenance service providers have access to ICA (and ICA supplements) to the extent necessary for the scope of maintenance services being provided. The scope of continuing airworthiness management activities should be in accordance with the Operating Organisation’s policy and procedures defined in the Continuing Airworthiness Management Exposition (CAME). The CAME is approved by DASA and sets out the procedures, means and methods of how the CAMO intends to comply with the requirements of DASR M. A list of key management positions will be listed in the CAME. The CAME also includes all functions and privileges required to ensure the aircraft are maintained in an airworthy condition, the issue of Military Airworthiness Review Certificates (MARC), and/or changes to the Aircraft Maintenance Programme (AMP). Additional Information on gaining DASA approval to become a CAMO can be found in Chapter 5.3 Annex H –CAMO.
8.2.1.6 CAMOs are responsible for ensuring that maintenance of aircraft is performed by an organisation approved by DASA or another organisation acceptable to DASA. A maintenance organisation is acceptable to DASA if its services are accessed in accordance with the terms of a recognition certificate.
8.2.1.7 Recognition certificates may enable a CAMO to fulfil the aircraft Certificate of Release to Service (CRS) requirement using a maintenance organisation not approved by DASA. These provisions are applicable where DASA has recognised another airworthiness authority in the area of aircraft maintenance. Chapter 6.5, Recognition of Other Aviation Safety Authorities, provides further guidance on the application of recognition.
8.2.1.8 Recognised systems may include an artefact equivalent to an aircraft CRS; however, maintenance organisations may be prevented from issuing a native artefact against a Defence-registered aircraft by legal or policy constraints. Instead, the CAMO should request an artefact that meets the requirements set out in DASR M.A.801.
Airworthiness Directives
8.2.1.9 Airworthiness Directives (ADs) mandate actions to be performed on an aircraft to restore an acceptable level of safety. Furthermore it is mandatory that CAMOs comply with any AD applicable to its aircraft, guidance on Airworthiness Directives can be found in Section 7.4.3 – Airworthiness Directives.
Data for modifications and repairs
8.2.1.10 DASR M.A.304(d) provides for the consumption of data already approved within a recognised airworthiness framework. A CAMO may consume data for repairs and ‘minor’ modifications when the data is produced by an organisation accepted by DASA. An organisation is accepted by DASA if its design products are being accessed in accordance with the terms of a recognition certificate and a suitable procedure. Direct consumption of data is subject to a suitability assessment (see AMC and GM to DASR M.A.304(d)) in accordance with the scope, conditions and caveats of the relevant recognition certificate. The suitability assessment will consider, among other things, the effect of the design classification and its compatibility with the ADF Configuration, Role and Environment (CRE). Additional guidance can be found in Section 7.2.4 – Repair Designs.
Aircraft continuing airworthiness record system
8.2.1.11 An Authorised Release Certificate is necessary for the release to service of either new or used components. It is a document issued by an entity that has the applicable privilege and attests that a new or used component has been produced or maintained in accordance with the approved design data/standard, modification standard or applicable maintenance data. Additional guidance on tracking status of service life-limited components and other usage data for aircraft structures and propulsion systems can be found in Chapter 6.6.4.
Airworthiness review staff
8.2.1.12 Airworthiness review entails a full documented review of the aircraft records and a physical survey of the aircraft. Airworthiness Review Staff are authorised by the CAMO and accepted by DASA to perform Airworthiness Reviews on aircraft which are listed on the CAMO approval certificate.
Introduction
8.2.3.1 This chapter provides additional guidance on acceptance of components – specifically the acceptance of alternate documentation, where components are not supplied with a DASA Form 1 or equivalent recognised document.
8.2.3.2 The introduction of DASRs brought with it a change to the information requirements accompanying components to be consumed on ADF aircraft. DASRs require that components be supplied with a DASA Form 1, or recognised equivalent, that declares the airworthiness of a component.
8.2.3.3 This chapter relates to the acceptance of new and used aircraft components, which are listed by the appropriate design organisation as eligible for installation in/on a product and included in the design data approved by the Authority11. The term components broadly covers any product (other than complete aircraft), part or appliance that is, or is intended by its manufacturer to be, a part of or used in operating an aircraft in flight, or is installed in or attached to a product. This may include any self-contained part, combination of parts, assembly, subassemblies or units, which perform a distinctive function necessary to the operation of the airframe, engine, or propeller, or may include any other instrument, mechanism, equipment, apparatus, software or accessory, including communications equipment.
8.2.3.4 Although alternate artefacts are consumed by a DASR 145 Approved Maintenance Organisation (AMO), DASA requires the relevant CAMO to seek approval for and manage the ongoing validity of alternate artefacts for their respective platforms. Further detail on alternate artefacts can be found in Chapter 8.3.4 – Acceptance of Aircraft Components
What constitutes an ‘alternate artefact’ accepted by DASA?
8.2.3.5 DASA may agree that an AMO may consume an alternate artefact other than a DASA Form 1, or recognised equivalent Authorised Release Certificate, that is produced by an organisation accepted by DASA. A CAMO can seek approval of an Alternate Artefact from DASA using DASR Form 155 – Application for Acceptance of Alternate Artefact. AMC to DASR M.A.201(g) and M.A.802(c) provide detail on when an alternate artefact would be acceptable. Chapter 8.3.4 – Acceptance of Aircraft Components provides further detail.
Consumption of United States (US) Department of Defence (DoD) products
8.2.3.6 There has been confusion with consumption of US DoD supplied products where associated documentation, such as DD Form 250, does not meet the requirements of a DASA Form 1 or recognised equivalent. The DASR provide a path for the regulated community to accommodate the consumption of products where the product supplied does not meet the requirements of a DASA Form 1. This is:
AMOs and CAMOs comply with DASR 145.A.42 and DASR M.A.201 (g) (e.g. via direct recognition or DASR Form 155 Application for Acceptance of Alternate Artefact).
Where (a) above is not reasonably practicable, CAMOs can develop a procedure within their exposition to demonstrate to DASA how these products can be consumed whilst maintaining an equivalent level of protection. DASA will then assess this procedure against the requirements of DASR GR.80(b), and if appropriate, approve the procedure for use.
Where (a) is not reasonably practicable, and an equivalent level of protection cannot be ensured (b), CAMOs can develop a procedure within their exposition to demonstrate to DASA how these components will be consumed; accompanied by a demonstration that the resultant risks are appropriately managed by the applicable MAO. DASA will then assess this procedure against the requirements of DASR GR.80(c), and if appropriate, allow the use of the procedure.
Introduction
Aircraft Maintenance Programme (AMP)
8.2.4.2 DASR M.A.302(a) requires that maintenance of each aircraft shall be organised in accordance with an AMP. The AMP encompasses the actual maintenance programme in its entirety. An AMP provides the scheduled maintenance tasks, their associated maintenance procedures and standard maintenance practices that are applied to the maintenance of an aircraft. The RP, which continually reviews the applicability of the AMP to the aircraft and operator, is also considered a part of the AMP.
Introduction
Background
8.2.6.2 Under certain conditions the required level of safety can be maintained with specific aircraft components being unserviceable, for a limited period of time, until repairs can be made. Many aircraft also have equipment installed that is not required for safe operation under certain operating conditions (e.g. aircraft with multiple VHF radios can operate with single radio if operations do not require the use of the systems associated). Equipment, such as entertainment systems, galley equipment, mission equipment or systems, may have no impact of flight safety.
8.2.6.3 An MMEL is a document created specifically to permit the continued operation of an aircraft type with unserviceable equipment, based on the aircraft type certification. An MEL consists of an approved list of the specific unserviceable equipment for a particular aircraft by serial and registration mark, based on the MMEL and the Operator’s Configuration, Role and operating Environment (CRE).
8.2.6.4 An MEL can be used as the first step in a defect management process in accordance with procedures developed by the CAMO and approved by the DASA to meet the requirements of DASR M.A.301 (a) 2, for the deferral of defects.
EASA Rules for Master Minimum Equipment List (CS-MMEL)
DASA Regulatory Basis
8.2.6.6 DASR GM 21.A.15(a) - Application for a Military Type Certificate may include the MMEL as Operational Suitability Data (OSD) that may be approved as part of Type Certification and form part of the Military Type Certificate (MTC) .
8.2.6.7 DASR M.A.301 Continuing airworthiness tasks, refers to MEL and Configuration Deviation List (CDL) for use in the deferment of defect rectification.
8.2.6.8 DASR AO Gen.05 Management of OIP, ORO.05 Conduct of Flying Operations and ORO.30 Flight Authorisation support discharging flight operations requirements referred to in this chapter.
Configuration Deviation List
8.2.6.9 A Configuration Deviation List (CDL) is a listing of regulator-approved non-structural external parts that may be missing but the aircraft remains airworthy. A CDL provides options to dispatch an aircraft for flight when listed parts may be missing, provided the necessary performance corrections are adhered to (including limits or restrictions if required and specified rectification periods). Refer DASR M.A.301(a)2 and associated AMC/GM.
8.2.6.10 CDLs are part of the certified type for any civil derivative aircraft (certified by the European Aviation Safety Agency (EASA) or the Federal Aviation Administration (FAA)). Within the ADF context, as part of Military Type Certification, the CDLs are presented as part of the Aircraft Flight Manual (AFM) for approval during Type Certification. Usually, they are contained in a standalone section of the AFM. The AFM is approved as part of Military Type Certification (DASR 21 Subpart B) and changes would be approved under (DASR 21 Subpart D).
8.2.6.11 The CDL should not be confused with the Minimum Equipment List (MEL). While the MEL describes the limitations of aircraft operation in case of a system being inoperative or having malfunctioned (e.g. transponder failure), the CDL deals with situations where external parts of an aircraft are missing (e.g. fairings, aerodynamic seals or panels).
MMEL
What is a MMEL?
8.2.6.12 A MMEL is a document created specifically to permit the continued operation of an aircraft type (e.g. C-130J-30) with unserviceable equipment. It is a list of items of equipment that may be temporarily unserviceable under certain conditions and limitations, while still maintaining the level of safety intended in the design standards. The MMEL does not take into account the operating circumstances of individual operators of that type. The MMEL cannot, in itself, be regarded as providing operational permission. It can, however, be the basis for the development of an individual Operator’s MEL.
MMEL Characteristics
8.2.6.13 Aircraft Type. MMEL relief for a particular item may be unique to a specific aircraft type. Therefore, MMEL relief for an item for one aircraft type may not be the same as the relief allowed for the same item found in another aircraft type.
8.2.6.14 Items required by an Airworthiness Directive (AD) are prohibited. An MMEL will not include items that an AD requires to be operative, unless the AD specifically allows them.
8.2.6.15 Variable Number of Items Required for Dispatch. A MMEL may depict a variable number of items required for dispatch based on various makes and models of the same series aircraft. The MMEL must clearly articulate which makes and models each MMEL item is applicable to.
8.2.6.16 Multiple Versions of the Same Item. A MMEL may contain multiple versions of particular items (e.g., very high frequency (VHF) communications systems and fire extinguishers) that are installed on different models or series of the aircraft covered by the MMEL. The MMEL must clearly articulate which versions each MMEL item is applicable to.
8.2.6.17 Repair Categories. A MMEL will contain a repair category for each item. Each repair category allows for a certain amount of time until repairs must be accomplished.
8.2.6.18 Prohibited Items. A MMEL will not include items of the aircraft that are required for basic flight (wings, flaps, rudder, etc.), nor will it include instruments and equipment required for specific operations.
What is a MEL?
8.2.6.19 A MEL is a document created specifically to manage the continued operation of an aircraft with unserviceable equipment consisting of an approved list of the specific unserviceable equipment for a particular make and model of aircraft by serial/production number and registration mark (e.g. C-130J-30, 5440, A97-440) as applicable. Its use is authorised by accepting the associated application procedures contained in an operator’s Continuing Airworthiness Management Exposition (CAME) and/or operations manual, or other appropriately documented procedures.
MEL Transferability
8.2.6.20 An approved MEL for an aircraft is a non-transferable document, i.e. if the MAO of the aircraft changes, then a new approval for the MEL is required even if the aircraft retains the same registration mark.
8.2.6.21 If an aircraft moves from one Military Air Operator Certificate (MAOC) holder to another, the new MAOC holder cannot automatically use the approved MEL for the aircraft. The new MAOC holder will be authorised by DASA only if they have acceptable associated application procedures contained in their CAME and/or operations manual and have assessed the operator's CRE.
MMEL/MEL Considerations for Use
8.2.6.22 The MMEL/MEL is an alleviating document. Its purpose is not to encourage the operation of aircraft with unserviceable equipment. It is never desirable that aircraft continue operations with unserviceable equipment. Such operations are permitted only as a result of careful analysis of each item to ensure that the required level of safety is maintained. A fundamental consideration in permitting the operation of aircraft with unserviceable equipment is that the continued operation of an aircraft in this condition is to be eliminated or otherwise minimised so far as reasonably practicable (SFARP).
Invoking the MEL
8.2.6.23 The Aircraft Captain or appropriately licenced and authorised Military Aircraft Maintenance Licence (MAML) holder invokes the MEL on behalf of the CAMO. It is the decision of the Aircraft Captain to accept the aircraft for flight with unserviceable systems or equipment listed in the MEL. The overriding principle is that, notwithstanding the provision of an approved MEL, a MAML holder should not release an aircraft for flight, and the Aircraft Captain should not accept an aircraft for flight, if it is considered unsafe for a particular flight.
8.2.6.24 A MAO may authorise Aircraft Captains to invoke MEL items through provisions in the Operations Manual. Where an Aircraft Captain is not authorised to invoke a MEL item the Aircraft Captain is to refer to local procedures for actions required to invoke the MEL item.
MMEL Development Options
8.2.6.25 Existing CAA/MAA MMEL as part of Operational Suitability Data (OSD). As part of the introduction of a new type to Defence the initial certification package may contain a MMEL that has been developed by the OEM as part of the OEM state of design certification process. This MMEL document can be submitted as OSD, as part of the Australian MTC certification package and be assessed for approval as the DASA approved MMEL. Similarly, for an existing type with no DASA approved MMEL, an existing Civil Aviation Authority (CAA) / Military Aviation Authority (MAA) approved MMEL may be submitted for approval as a change to the type certificate.
8.2.6.26 In both cases above, foreign CAA/MAA approval of a MMEL does not constitute automatic approval under DASRs. DASA issues its own sovereign Military Type Certificates (MTC) for each aircraft type and does not ‘accept’ foreign civil or military TCs. Therefore, in order for a MMEL to be approved under DASRs it must be approved under the initial issue of, or as a change to, the DASA issued MTC and be included on the DASA issued Type Certificate Data Sheet (TCDS).
8.2.6.27 MEL submitted in lieu of MMEL. If the operator has access to an existing, or has developed, a MEL for the type, for which no MMEL exists, the operator may submit the MEL through the Military Type Certificate Holder (MTCH), for assessment as a MMEL. If the MEL is submitted, DASA will consider it a MMEL submission and assess it as such. It may then be used as the basis for acceptance as a MEL.
8.2.6.28 Development of a new MMEL. A MTCH may elect to submit a new MMEL to DASA for approval. DASA does not stipulate any specific format and/or contents of a MMEL. However, the Certification Programme must propose an appropriate Certification Basis that the MMEL will comply to, and that may include content and format requirements. Establishing the Certification Basis early and following the associated format will avoid delays in assessment and approval of the MMEL.
8.2.6.29 Suitable Certification Specifications. The Certification Programme should be submitted to DASA, proposing a Certification Basis for the MMEL. The following two certification specifications will likely be suitable for development of MMELs:
EASA CS-MMEL. CS-MMEL is the Certification Specification (CS) mandated by EASA for MMEL development and is likely to provide an acceptable basis for MMEL approval for Defence aircraft.
FAA FOEB process. FAA policy for MMEL approval is through the Flight Operational Evaluation Board process. MMEL document templates, guidance on specific systems, general format requirements, and guidance on justification requirements are available on the FAA FSIMS website. (Reference ICAO Manual – MMEL/MEL5 and Flight Standards Information Management System).
8.2.6.30 Alternate Certification Bases may be proposed in the Certification Programme but will require further justification.
MMEL development process
8.2.6.31 As the MMEL forms part of the Military Type Certificate, any MMEL change is to be classified IAW the guidance in DASR 21.A.91. On initial issue of the MMEL or identification of a MMEL change as Major, the Major Change to Type Certificate process as per DASR 21 subpart D applies. Minor changes to MMELs are to be processed IAW DASR 21.A.95. This process is depicted at Appendix 2.
8.2.6.32 MMEL Change Classification Criteria. The following guidance for classification of MMEL changes elaborates upon the generic classification advice in GM to DASR 21.A.91.
8.2.6.33 Conditions requiring classification of a MMEL change as Major:
Where the change requires an adjustment of the MMEL certification basis;
Where the applicant proposes changes to the Means of Compliance (MoC) with the requirements for the MMEL certification basis (i.e. MMEL safety assessment methodology);
Where the extent of substantiation data and the degree to which the substantiation data has to be assessed and evaluated is considerable, in particular but not only when:
The substantiation data involving review of failure conditions that are classified as hazardous or catastrophic has to be evaluated;
The assessment of the failure effects (including next worst failure/event effects) on crew workload and the applicable crew procedures has to be evaluated; or
The capability of the aircraft to perform types of operation (e.g. Defence Long Range Operations (DLRO), Instrument Flight Rules (IFR)) under MMEL is extended.
8.2.6.34 Conditions where the MMEL change can be considered Minor:
Modifications to an item/s when:
The change is only to the applicability of an item for configuration management purposes;
The change is the removal of an item;
The change is an increase in the number of items required for dispatch; and
The change is a reduction in the rectification interval of an item.
Addition of a new item when:
It is considered as non-safety related IAW FAA MEL Requirements for 14 CFR Parts 91 Subpart K (Part 91K), 121, 125, 125 LODA, 129, and 135 Operations CS-MMEL GM2 MMEL.110; or
It is indicated as eligible for minor change classification in FAA MEL Requirements for 14 CFR Parts 91 Subpart K (Part 91K), 121, 125, 125 LODA, 129, and 135 Operations, GM1 CS MMEL.145.
8.2.6.36 If the conditions and limitations applied against a MMEL item are assessed as insufficient to fully eliminate the associated risk, or an Equivalent Safety argument cannot be made that the risk meets the level of safety inherent in the applicable design standards in the aircraft Type Certification Basis (TCB), the MMEL item is NOT to be included in the MMEL.
8.2.6.37 Operational endorsement should be sought from the MAO (e.g. Hazard Tracking Authority or Standards Officer (STANDO) for any operational conditions or limitations identified against MMEL items. The MTCH in developing the MMEL considers the operational conditions/limitations of the aircraft against the type certification. The MMEL operational procedures are not specific to an individual Operator’s Configuration Role and operating Environment (CRE).
8.2.6.38 Relief from Development of Compliance Demonstration Evidence. Relief from the requirement to develop compliance demonstration evidence can be sought on an item by item basis for MMELs. The requirements for leveraging prior certification from another CAA/MAA as per AMC to DASR 21.A.20 still apply when relief is applied in this manner.
MMEL approval process
8.2.6.39 Initial Type Certification
The applicant for initial DASA MTC would submit the MMEL as part of the application package.
8.2.6.40 MMEL for an aircraft with an existing DASA MTC
An MTCH submitting a MMEL for DASA approval must do so in accordance with the Change to Type Design process as described in DASR 21
Refer to Appendix 2: for the process flow to seek DASA approval of a MMEL.
Developing a MEL using an existing/relevant MMEL
8.2.6.41 DASA do not stipulate any specific format and/or contents of a MEL. Using an international recognised format could avoid delays in assessing the MEL. In the development of an MEL, DASA recommends that the MEL be developed in accordance with international standards as referenced in the Certification Programme from the MMEL (detailed above).
8.2.6.42 The MEL should be developed from the latest issue of the applicable MMEL on an item-by-item basis and keeping in view the relevant regulatory requirements.
8.2.6.43 If an operator chooses to add items that are not found in the MMEL (due to its particular type of operation) an assessment of those items must be carried out. This assessment is required to ensure that these items do not affect the design standards or safe operation of the aircraft and are not in conflict with the flight manual and any DASR requirements. Refer to the International standards as referenced in the Certification Programme from the MMEL for guidance on how to assess the criteria for these items.
8.2.6.44 In general, a MEL should be as, or more, restrictive than the applicable MMEL for the type of aircraft. If a certain item(s) of the applicant’s MEL is less restrictive than the applicable MMEL, DASA will require an extensive qualitative and/or quantitative analysis to substantiate the proposed departure from the MMEL.
MEL Development with no MMEL
8.2.6.45 If a platform has no MMEL or MEL available from the manufacturer or other CAA/MAA and the operator wants to utilise the flexibility that a MEL affords, the Operator may choose to engage the MTCH to develop a MMEL from previously available deferment options.
8.2.6.46 The MMEL should be developed in accordance with the guidance provided earlier in this chapter.
8.2.6.47 Once the MMEL is approved by DASA the operator can seek approval of the MMEL for use as an MEL from DASA.
MEL approval process
8.2.6.48 An Operator submitting a MEL for approval must provide DASA with:
A minute of application from the CAMO requesting approval of the MEL;
Digital access to a copy of the proposed MEL;
All OIP created for use of the MEL; and
If the MEL has no associated DASA approved MMEL, the MEL must be submitted for approval as a MMEL.
8.2.6.49 A MEL may cover more than one aircraft of the same type. However, all differences in the equipment/systems installed, if any, should be clearly identified by the aircraft registration mark.
8.2.6.50 Refer to Appendix 1: for the DASA process flow of MMEL/MEL approval.
Application for amendment to the MEL
8.2.6.51 Amendments to MELs are either mandatory or voluntary, depending upon the particular circumstances. Mandatory amendment of a MEL is required either:
When the applicable MMEL is amended so as to become more restrictive; or
When required by DASA in light of in-service experience.
8.2.6.52 Voluntary amendment of a MEL may be carried out when either:
The MMEL is amended so as to become less restrictive; or
As required by the operator, provided the proposed change is no less restrictive than the MMEL; or
Regulatory changes occur.
8.2.6.53 An application for amendment to an approved MEL, together with appropriate substantiation, should be forwarded to DASA.
MMEL/MEL Development Considerations
Operations and maintenance procedures
8.2.6.54 The objective of operations ((O)) and maintenance ((M)) procedures is to provide everyone using the document with clear and concise directions on how they are to proceed in case of unserviceability. The (O) and (M) procedures form part of the approved MEL.
8.2.6.55 (O) Procedures: Where the (O) symbol appears in the MMEL, an operations procedure must be developed that provides clear direction to the flight crew. These procedures may be included in the MEL. Where they are not included in the MEL, they must be available to the aircrew in another document that is always available to the aircrew (i.e. an operations manual or in an approved electronic form). In these cases, the MEL shall refer to a section of the appropriate document(s).
8.2.6.56 (M) Procedures: The MMEL may identify items that require a maintenance procedure. If this is the case, the operator must ensure that relevant (M) procedures have been developed for the MEL. These procedures must provide clear direction to the maintenance personnel.
Procedures for the use and guidance of flight crews and maintenance personnel
8.2.6.57 The operator must establish procedures for the use and guidance of flight crews and maintenance personnel, in relation to the MEL. These procedures must agree with those in the operator’s CAME, Aircraft Maintenance Program (AMP), operations manual, and other operating documents. These procedures should include, but are not limited to, procedures for:
Deferring rectification action or invoking MEL item(s) for unserviceable equipment;
Placarding requirements as per the MEL;
Ensuring that a dispatched aircraft with an invoked MEL item(s) complies with the limits and conditions of the MEL;
Ensuring that existing deferred defects / MPTF / Command Clearances do not impact invoking of MEL provisions;
Controlling categorised repair intervals; and
The training of organisations personnel who are responsible for compliance with MEL procedures.
8.2.6.58 Procedures for invoking MEL items are normally contained in the operator’s CAME, operations manual or an alternative document. Prior to issuing a MEL approval, DASA will ensure that the MEL references these procedures in the CAME, operations manual or similar document, if not already included in the MEL. If no procedures for the invoking of MEL items exist within the operator’s organisation, then DASA will, in addition to vetting the MEL, require amendment to the CAME/MOE and/or operations manual.
8.2.6.59 A placarding procedure should be established and set out in the CAME/MOE and operations manual or, at least, within the approved MEL document.
8.2.6.60 When invoking a MEL item, the person responsible must:
Identify, in the aircraft technical log or appropriate document/maintenance information system, that this action has occurred;
Identify the item with its MEL number; and
Ensure that an unserviceable label is placed in an appropriate location (where applicable).
8.2.6.61 A procedure documenting the above requirement in the appropriate operator’s documentation is acceptable for compliance purposes.
Repair intervals
8.2.6.62 Each item of a MEL must be repaired within the specified repair interval. These intervals are set to limit the maximum time an aircraft may fly with an unserviceable item(s) of equipment, and are designated Category ‘A, B, C or D’. The definition of repair intervals should align with the selected certification basis for the MMEL as defined at para 8.2.6.29.
8.2.6.63 The operator must establish procedures whereby the maintenance support periodically reviews the deferred items. This is done to ensure that any accumulation of deferred items neither conflict each other nor present an unacceptable increase in crew workload. Notwithstanding the categorisation of item repair intervals, it should be the aim of each MEL document holder to ensure that unserviceable items are repaired as quickly as possible.
Repair interval extension
8.2.6.64 Each operator’s MEL management program needs to contain procedures for controlling extensions to item repair intervals. Procedures must include the limitations of each extension and the method by which the operator approves an extension.
MEL training program
Training Requirement
8.2.6.65 The operator should as part of the introduction of a process for the use of a MEL develop a MEL training program for maintenance personnel and flight crew, which should be in place prior to an operator commencing operations with a MEL. The operator, when required, should conduct recurrent training, or put in place a controlled method to alert staff to any changes in MEL procedures. This will ensure company personnel remain current with those procedures.
Maintenance Personnel Training
8.2.6.66 The training for maintenance personnel should include those sections of the CAME procedures dealing with:
The use of, and compliance with, the MEL;
Placarding of unserviceable equipment;
Return to service of an aircraft;
Dispatching an aircraft; and
Any other MEL related procedures.
Flight Crew Training
8.2.6.67 The flight crew training should include, but not be limited to, the following:
The purpose and use of a MEL;
Instruction on operator’s procedures for the use and guidance of flight crew;
The process and procedures required for supervision and flight authorisation; and
The Aircraft Captain’s responsibility with respect to the above procedures.
Introduction
8.3.1.1 This section provides additional information and guidance to DASR 145 Approval Holder Organisations and those organisations that are applying for approval under DASR 145. Further guidance on applying for a Maintenance Organisation approval can be found in Section 5 Annex G – AMO.
8.3.1.2 For information on maintenance service providers that are approved though other means (i.e. not DASR 145 approval), refer to Chapter 6.5, Recognition of other Aviation Safety Authorities and to Chapter 8.2, Continuing Airworthiness Management.
8.3.1.3 This chapter does not include information already presented at Volume 2 (DASRs), but represents additional guidance material. Referenced content relevant to, but not directly related to, continuing airworthiness will be found in other areas of the Defence Aviation Safety Program including in other chapters of DASP Manual Volume 3.
DASR 145 – Requirements for Maintenance Organisations
8.3.1.4 The Defence Aviation Safety Regulations (DASR) requires individual DASR 145 Approved Maintenance Organisations (AMOs) to define their own line and base maintenance activities in their Maintenance Organisation Exposition (MOE).The scope of maintenance of aircraft and components activities should be in accordance with the Maintenance Organisation’s policy and procedures defined in the MOE.
Acceptance of components
8.3.1.5 The AMO must ensure that components are accompanied by appropriate documentation attesting to the legitimacy of the component’s maintenance or production history. This is underpinned by the regulatory requirement for the AMO to obtain a DASR Form 1 or equivalent documentation prior to fitment of such components. Where an unserviceable or unsalvageable component is the subject of an occurrence report, the DASR 145 organisation should quarantine the component until the investigation has determined that the component is not required to be retained for further examination Additional information can be found in Chapter 8.3.4 – Acceptance of Components.
Certification of maintenance
8.3.1.6 Maintenance carried out on an aircraft, its systems and its components must be certified at completion and prior to its return to service. The instrument used to achieve this outcome is the Certificate of Release to Service (CRS) that must be issued at the completion of maintenance and before the next flight. Additional guidance for Certification of maintenance can be found in Chapter 8.3.3 - Certification of maintenance.
Introduction
8.3.2.1 This chapter provides additional guidance on the performance of maintenance including guidance on line and base maintenance, and specialist maintenance qualifications.
8.3.2.2 Not all maintenance personnel in a DASA 145 MO need to be authorised as certifying and/or support staff. Acting as certifying or support staff is intrinsically a hands-off activity (in contrast to the performance of maintenance being physical hands-on aircraft maintenance). DASA 145 MO personnel perform maintenance under a Task Sign-Off (TSO) authorisation. On-aircraft TSO is overseen, managed and later certified (issue of CRS) by authorised certifying staff.
8.3.2.3 Except for a few speciality areas (e.g. composite repairs), DASA does not prescribe knowledge / experience standards for the performance of maintenance. On-aircraft TSO provides an attestation that the maintenance task has been carried out to the required standard.
8.3.2.4 A DASA 145 MO has flexibility to determine their own Qualification, Training and Experience (QTE) requirements when assessing and authorising personnel to perform the vast majority of maintenance (less some specialist qualifications where DASA will specify acceptable means of compliance). It is up to a DASA 145 MO to determine the scope that maintenance personnel can be authorised to perform, and may also mandate the level of supervision maintenance personnel require – noting supervision can be performed by authorised persons who are not necessarily certifying staff – see GM2 DASR 145.A.35(e). Maintenance personnel do not need to hold a MAML, of any category, to be authorised to perform maintenance.
8.3.2.5 DASA oversight of DASA 145 MOs, in the context of foreign trained maintenance personnel employed to perform maintenance, will focus on the procedure that identifies knowledge and experience requirements, to determine the authorised scope of maintenance and supervision required.
8.3.2.6 For information on maintenance service providers that are approved though other means (i.e. not DASR 145 approved), refer Chapter 6.5, Recognition of other Aviation Safety Authorities and Chapter 8.2, Continuing Airworthiness Management.
8.3.2.7 For information on the performance of maintenance relates to the certification of maintenance, see Chapter 8.3.3 – Certification of Maintenance.
Line and Base Maintenance
Background
8.3.2.8 The Defence Aviation Safety Regulations (DASR) requires individual DASR 145 Approved Maintenance Organisations (AMOs) to define their own line and base maintenance activities in their Maintenance Organisation Exposition (MOE). Feedback from the regulated community indicates that there is insufficient DASR guidance on what types of activities constitute line and base maintenance. This chapter describes types of maintenance activities constituting line and base maintenance and describes the intended outcomes in relation to line and base maintenance as interpreted by DASA.
8.3.2.9 The DASR Glossary of Terms describes line and base maintenance as:
Line Maintenance: Carried out before flight to ensure that the aircraft is fit for the intended flight.
Base Maintenance: Maintenance tasks falling outside the criteria for line Maintenance.
8.3.2.10 A more detailed definition of aircraft line maintenance is provided in AMC 145.A.20, together with a list of activities which “may” be considered as line maintenance. The word “may” is used because it is not possible to establish a provision giving a strict demarcation between line and base maintenance, having general applicability to all cases.
8.3.2.11 To assist civil MOs, the European Aviation Safety Agency (EASA) has developed an EASA 145 User Guide chapter on ‘Privileges and limitations of line maintenance’. This guide provides detailed guidance on what constitutes line and base maintenance. This Annex is has been developed based on the EASA User Guide to provide an EASA aligned approach to guide DASR 145 MOs in defining line and base maintenance.
Organisation responsibilities
8.3.2.12 The maintenance organisation should ensure prior to any intended maintenance event that the activity can be carried out under its line maintenance scope of approval (refer to AMC 145.A.20) and does not fall under paragraph 14 ‘Examples of maintenance activities considered to be base maintenance’ of this Chapter.
8.3.2.13 This assessment may not need to take place each time, but be based on already established MOE procedures (i.e. the fact that a daily check is a line maintenance task is obvious and does not need to be assessed each time).
8.3.2.14 Even if this assessment confirms that the activity is line maintenance, the maintenance organisation should also verify if this activity requires other means than the ones already in use at a line maintenance location.
When to assess the maintenance activity
8.3.2.15 The maintenance organisation`s assessment to decide if any maintenance event falls within the definition of line or base maintenance, may be needed in two different situations:
for an initial/change of approval, when evaluating the scope of work the maintenance organisation is applying for (refer paragraph 11); or
for an already approved maintenance organisation, when evaluating if maintenance requested by the customer (e.g. a new Service Bulletin (SB), defect rectification or work package requested by the customer, etc.) falls within the approved line maintenance scope of work.
Assessment of the intended scope of work (initial/change of approval)
8.3.2.16 It is the responsibility of the maintenance organisation to demonstrate to DASA that the intended scope of work may be carried out in a line maintenance environment, under its line maintenance scope of approval. The main criterion for this assessment is to consider the level of maintenance to be carried out under the line maintenance scope of approval, where the following general criteria apply:
Trouble shooting, Defect Rectification. Those unscheduled tasks required for the daily operation of an Aircraft and not falling under ‘Examples of maintenance activities considered to be base maintenance’;
Minor scheduled line maintenance. Those scheduled tasks not exceeding the weekly check as specified in the Aircraft Maintenance Program (AMP);
Scheduled checks. Those scheduled tasks which exceed the weekly check (or equivalent as determined by the Authority). In this case, the organisation needs to analyse each of the routine tasks intended to be included in the line maintenance scope of work and identify a clear limit. This assessment needs to be performed using the Type Certificate Holder (TCH) data such as the manufacturer’s Maintenance Planning Document (MPD), and/or the operator’s AMP. The outcome of this exercise is to identify the intended limitation of the line maintenance scope of approval, in terms of scheduled maintenance checks. In particular, the following is expected:
Depending on the AMP logic (i.e. MSG 2, MSG 3, etc) a clear limitation to the line maintenance scope of work may be normally expressed in one of the following ways:
“up to and excluding X check” (i.e. X= R1, R2, etc) for a MPD, where letter checks are identified;
“up to and excluding “X FH / Y FC / Z calendar time”, for a MPD, where progressive task intervals are defined in terms of FH/FC/calendar time (i.e. X=3000FH, Y=750 FC, Z=12 months, etc);
The identified limit, to be indicated in the MOE, should be such that all the related routine/scheduled tasks are excluding any of the tasks listed in ‘Examples of maintenance activities considered to be base maintenance’
A “decision making process” (refer paragraph 12 for example) needs to be established in the MOE in order to assess
(the need to access the hangar (even if the activity is permitted under a line maintenance scope of approval), considering in particular the type of aircraft, the maintenance event type/complexity, the environmental and weather conditions;
any work order / work package received from the customer operator to ensure it may be fully performed under a line maintenance scope of approval, taking into account additional works to the original work package that may be added, leading out to the line maintenance scope of work, such as:
addition of previously deferred maintenance tasks; or
defects raising from the routine tasks (these defects are not known in advance, however, the related risk in terms of number and level of defects needs to be taken into account and estimated in advance).
8.3.2.17 Example of ‘decision making process’. A R1 maintenance check on the Boeing Business Jet (BBJ) aircraft type is normally considered “line maintenance” when the routine tasks are assessed as per the manufacturer MPD/operator AMP. Therefore a maintenance organisation may be approved to perform this check under a line maintenance scope of work. However, a work order to perform the “R1 check”, where the customer operator would request the performance of works in addition to the “R1” routine tasks, such as the addition of Airworthiness Directives (ADs), SBs, deferred tasks, will need to be carefully assessed by the maintenance organisation with the use of the “decision making process”.
8.3.2.18 This type of maintenance check may easily fall within the examples given in Paragraph 14 ‘Examples of maintenance activities considered to be base maintenance’ having the result to be considered as base maintenance and being outside the maintenance organisation scope of work. In such a case, the outcome of the “decision making process”, may be for example:
The impossibility to accept such work order from the operating organisation, being outside the scope of work of the maintenance organisation; or
to agree with the operating organisation a revised work order, to remove the works which have been identified as base maintenance tasks (e.g. removal of a SB which was requiring extensive disassembly and modification of flight controls, etc.).
Examples of maintenance activities considered to be base maintenance
8.3.2.19 When any of the following tasks are required to be carried out (regardless if contained in a scheduled maintenance check or arising from a defect rectification/AOG situation), a base maintenance scope of approval is needed:
High number of different type of tasks to be carried out, even if taken singularly those tasks may still fall under the definition of line maintenance (i.e. a combination of routine task cards, non-routine task cards issued following defects discovered during the check, out of phase tasks, deferred items from previous maintenance, minor repairs, minor modifications, component replacement, etc). Such cases require base maintenance production planning support and/or a base maintenance release to service process (category C Certifying Staff supported by B1/B2 support staff) in order to ensure that all the maintenance ordered has been carried out before issuing the CRS;
Replacement of any major component where the related maintenance procedures address the need of a hangar environment requiring special ground support equipment and/or structured production planning and/or complex and lengthy maintenance, such as for example a full landing gear replacement, simultaneous replacement of two engines, etc;
Any scheduled maintenance task (i.e. routine task from the AMP) which requires extensive disassembly of the aircraft and/or extensive in depth inspection;
Major repairs and/or major modifications;
Trouble shooting and/or defect rectification requiring special ground support usually relevant to base maintenance (e.g. special equipment, structured production planning, complex and lengthy maintenance);
A scheduled maintenance event, which in the planning phase has been already identified as significant in terms of duration and/or man-hours (i.e. an aircraft down time above 72 hours or four shifts, whichever is less);
A work package requiring a complex team composition in terms of high number and categories (avionic, structure, cabin, NDT qualification and skills, etc) of staff involved per shift; or
The management of the event by B1 and B2 support staff and the release by a C certifying staff.
8.3.2.20 For AMOs that do not hold a base maintenance approval, the AMO remains responsible to ensure that even if each individual work order constitutes a line maintenance activity, a maintenance event cumulating several of these work orders remains within the AMO’s line maintenance scope of approval.
Assessment of maintenance task by an already approved maintenance organisation
8.3.2.21 For AMOs that do not hold a base maintenance approval, the AMO remains responsible to assess if any maintenance requested by the operating organisation falls within the approved line maintenance scope of work. This assessment is expected to be performed based on the “decision making process” described above.
Specialist Task Qualifications
8.3.2.22 Introduction. DASR 145.A.30(f) relates to MO personnel who carry out Non-Destructive Testing (NDT) and other specialised tasks such as composite repair and welding. Definitions pertaining to the scope of DASR 145.A.30(f) are as follows:
Particular non-destructive test means any one or more of the following; Penetrant Testing (PT), Magnetic Testing (MT), Eddy current Testing (ET), Ultrasonic Testing (UT), Radiographic Testing (RT), Thermographic Testing (TT) and Shearographic Testing (ST) methods (refer GM 21.A.30(f)). Boroscoping and other techniques such as manual tap testing are non-destructive inspections rather than non-destructive testing (refer AMC 145.A.30(f)).
8.3.2.23 DASR 145.A.30(f) requires that the MO must ensure that personnel who carry out NDT and other specialised tasks are appropriately qualified in accordance with recognised standards. The following paragraphs provide guidance on the standards recognised by DASA and other aspects of personnel training and certification.
8.3.2.24 It should be noted that the training standards required to perform specialist tasks might exceed the training standards to certify this maintenance. For example a licence persons with no structural repair exclusions could certify for a complex composite repair but may not be qualified to perform the maintenance. In this case the certifying staff may require separate specialist supervision in order to very the maintenance has been performed properly.
Qualification of Personnel for Non-Destructive Testing (NDT)
8.3.2.25 Recognised NDT Qualification Standards. DASA recognises the following standards for qualification of personnel who carry out and/or control NDT of aircraft structures and/or components (refer DASR 145.A.30(f)):
European Standard EN4179 - Qualification and Approval of Personnel for Non-destructive Testing is the primary NDT standard recognised by DASA
NAS410 – NAS Certification & Qualification of Non-Destructive Testing Personnel is also recognised by DASA.
8.3.2.26 NAS410 is the only NDT qualification standard DASA recognises as being equivalent to EN4179. Organisations that wish to use an alternative NDT personnel qualification system should apply to DASA with a proposed Alternate Means of Compliance (AltMoC). Note that Australian Standard AS3669 and ATA Spec 105 have been assessed as non-equivalent to EN4179 (refer GM 145.A.30(f)) and will not be approved as AltMoC by DASA.
8.3.2.27 NDT Personnel Training and Certification. The appointed NDT Responsible Level 3 (RL3) for each DASR 145 MO is responsible for establishing a training and certification system which supports awarding of task authorisations to NDT personnel working within the DASR 145 MO. This training and certification system should be established in line with EN4179. In cases where the minimum training and experience hour requirements stipulated in EN4179 Section 6 do not align with Defence’s requirements, a competency based training program can instead be used, provided the course program is approved by DASA. Refer to GM 145.A.30(f).
8.3.2.28 For details of the approach to NDT training and certification implemented in support of ADF DASR 145 MOs, refer to Volume 3 Section 4.2.3.
8.3.2.29 Appointment of NDT Responsible Level 3. AMC 145.A.30 stipulates that the NDT RL3 for a DASR 145 organisation is a nominated management position, and is accepted by DASA through a DASR Form 4 application. Each DASR 145 organisation should only have one appointed NDT RL3. The DASR Form 4 requires applicants to submit details and supporting documentation of relevant qualifications and experience. Specific to NDT RL3 applications:
Applicants are requested to provide a copy of all personnel certification records that DASR 145 organisations are required to retain under EN4179 Para 8.2 to demonstrate they meet the EN4179 requirements to be certified as a Level 3.
If the applicant holds certifications in multiple methods, only evidence from one NDT method is required. The employer is to ensure that certification records for all other methods are retained, as required by EN4179 Para 8.2.
Note: that DASA may request evidence of ongoing EN4179 compliance for NDT RL3s in the course of oversight and enforcement activities.
8.3.2.30 DASA does not require the involvement of the Australian National Aerospace NDT Board (NANDTB) in the certification of Level 3 staff. DASA will not request or rely on NANDTB recognition when assessing NDT RL3 Form 4 applications.
8.3.2.31 For questions about NDT RL3 Form 4 application evidence please email: dasa.dca@defence.gov.au
8.3.2.32 Responsibility for appointment of NDT RL3 personnel is as follows:
ADF DASR 145 MOs: the Directorate of Aviation Engineering (DAVENG), as Defence’s Structural Integrity Centre of Expertise33, performs the Defence NDT RL3 function (refer to Section 4.2.3 for further details).
Non-ADF DASR 145 MOs (i.e. contractor organisations): are responsible for appointing their own NDT RL3 personnel.
8.3.2.33 Notwithstanding the fact that Level 3 personnel may be qualified via EN4179 to establish and authorise methods, techniques, etc., this does not permit such personnel to deviate from the methods and techniques published in the Instructions for Continuing Airworthiness (ICA)44 unless the ICA expressly permits such deviations (refer AMC 145.A.30(f)). Although it is recommended that Level 3 personnel have a role in NDT ICA deviations or changes (refer DASP Manual Volume 3 Section 7.2.5), NDT ICA deviations or changes must be approved in accordance with DASR 21.
Qualification of Personnel for Composite Repairs
8.3.2.35 SAE AIR4938 Revision C includes requirements for both initial training and on-going certification. Superseded revisions of SAE AIR4938 do not include the requirements for ongoing certification, and also omit the training curriculum for bolted composite repairs. Superseded revisions of SAE AIR4938 should not be used without approval from DASA.
supervision requirements
OEM or aircraft type specific training
8.3.2.37 Applications to DASA to officially recognise alternate qualification standards should demonstrate that the alternate standard:
provides an equivalent level of training to SAE AIR 4938; or
is suitable in the context of the specific MO and the scope of the maintenance activities to be performed. In such cases, the application should clearly state the scope of the activities being performed, how the training is suitable for that scope, and the means by which the scope is to be controlled.
8.3.2.39 DASR 145 MOs can utilise any training course that demonstrates compliance to the standard. Note that DASA-DAVENG, as Defence’s Structural Integrity Centre of Expertise, conducts the certification (initial and re-certification) for all ADF DASR 145 MO staff who perform composite repairs (refer to DASP Manual Volume 3 Section 4.2.3 for further details).
8.3.2.40 DASR 145 MOs are responsible for establishing training and authorisation systems to ensure that personnel who conduct composite repairs are appropriately qualified. Further guidance for ADF and non-ADF DASR 145 MOs is as follows:
ADF DASR 145 MOs: The MO should verify that technicians hold a valid PMKeyS proficiency (refer DASP Manual Volume 3 Section 4.2.3) for composite repair prior to authorising them to conduct composite repairs within an ADF DASR 145 MO. MO authorisations should only remain valid for the validity period of the applicable PMKeyS proficiency.
Non-ADF DASR 145 MOs: The MO should document their certification/re-certification process in their MOE. The standard does not impose specific requirements on who can conduct certification.
Qualification of Personnel for Aircraft Welding
8.3.2.41 The following paragraphs are applicable to DASR 145 MOs that perform aircraft welding repairs.
8.3.2.42 Welding is used in the repair of critical and non-critical airframe and engine components within Defence. As a specialist task, personnel conducting welding operations must be appropriately qualified in accordance with officially recognised standards.
8.3.2.43 CASA Civil Aviation Advisory Publication (CAAP) 33-1 (1) Aircraft manual welding: Approvals and qualifications provides information on how to apply for the initial issue or renewal of an aircraft welding authority under Civil Aviation Regulations. DASA has determined that a CASA welding authority, granted in accordance with CAAP 33-1 (1), is an appropriate qualification for Defence purposes.
8.3.2.44 DASR Requirement. DASR 145 MO that perform aircraft welding repairs must comply with DASR 145.A.30(f), which requires “Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised Standards.”
8.3.2.45 Acceptable Means of Compliance. DASA considers a CASA welding authority, granted in accordance with CAAP 33-1 (1), is an appropriate qualification in accordance with DASR 145.A.30(f).
8.3.2.46 Organisations choosing to utilise welders qualified in accordance with CAAP 33-1 (1) must:
Ensure technicians hold a valid Civil Aviation Safety Authority (CASA) issued aircraft welding authority prior to task authorisation.
Ensure technicians are only authorised to carry out those types of welding processes that are specified in the welding authority document.
Ensure MO authorisations only remain valid for the validity period of the CASA-issued welding authority (i.e. renewal is required every 2 years IAW CAAP 33-1 (1)).
Aircraft Welding Questions and Answers
8.3.2.47 Q: What does a DASR 145 MO need so that it can use welders with a CASA welding authority?
8.3.2.48 A: The DASR 145 is required to:
Identify the scope of welding repairs that it requires (that is included in its overall maintenance scope).
Update the DASR 145 MO Orders, Instructions and Publications (i.e. MOE and any other associated documentation), to show compliance to DASR 145.A.30(f) and implement the required management framework. The aircraft welding repair training and qualification requirements should be specified in the MOE.
Authorise technicians who have obtained CASA welding authority
Ensure that authorised staff maintain their competency and CASA welding authority currency.
8.3.2.49 Q: How does a person achieve CASA welding authority?
8.3.2.50 A: CAAP 33-1 (1) details the framework that CASA applies to provide a welding authority, which is granted to applicants that have:
Successfully completed a relevant Australian Quality Training Framework recognised course; and
Passed the welding testing set out in the CASA Welding Syllabus.
8.3.2.51 Additional training may be required dependent on the specific work scope required by the DASR 145 MO. CASA will confirm any specific training requirements during the application for the welding authority.
8.3.2.52 DASR 145 MOs are responsible for organising CAAP 33-1(1) compliant renewal assessments for their personnel when required. There are a number of commercial organisations who employ CASA-authorised aircraft welding assessors (queries should be addressed to Contact us | Civil Aviation Safety Authority
8.3.2.53 CASA charge a fee to apply for the initial issue and for renewal of a welding authority. Applicants will also require a CASA Aviation Reference Number (ARN) prior to applying for a welding authority.
8.3.2.54 Q: Do welders require renewal of their CASA welding authority?
8.3.2.55 A: Yes. CAAP 33-1(1) requires a two yearly renewal in order to remain current. DASR 145.A.30(f) requirement that “Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised Standards” requires a current CASA authorisation.
8.3.2.56 Q. Who covers the cost of gaining a CASA welding authority and renewal?
8.3.2.57 A: For:
Defence Maintenance Organisations, initial authority for ASTTECHs is covered within the Welder Aircraft Course at RAAFSTT, all subsequent renewal costs are to be supported though unit, or parent command funding.
Contractor Maintenance Organisations, refer to arrangements detailed in your contract.
8.3.2.58 Q: Can a non-welder supervise the conduct of a renewal welding assessment?
8.3.2.59 A: No. CASA requires that a CASA-authorised assessor supervise the conduct of welding examinations, and DASA has adopted this position.
8.3.2.60 Q: Can an organisation authorise welders with a different qualifications (in lieu a CASA welding authority)?
8.3.2.61 A: Yes. DASR 145 MOs who wish to use an alternative qualification to that stipulated in AMC1 145.A.30(f) should seek approval from DASA (as AltMoC).
8.3.2.62 For further information refer to the following:
For issues relating to the use of CASA welding authority within the DASR context please contact the DASA Desk Officer assigned to your organisation or email dasa.dca@defence.gov.au.
For queries related to gaining and maintaining CASA welding authority and the application of CAAP 33-1 (1), refer Contact us | Civil Aviation Safety Authority
Introduction
8.3.3.1 This chapter provides guidance in relation to the Certificate of Release to Service (CRS) process for aircraft maintenance. The document aims to consolidate the applicable requirements from different sections of the DASR and describes the intended outcomes in relation to Sign-off & subsequent CRS at the completion of maintenance.
Background
8.3.3.2 Maintenance carried out on an aircraft, its systems and its components must be certified at completion and prior to its return to service. The instrument used to achieve this outcome is the CRS which must be issued before flight at the completion of maintenance. The CRS should contain as a minimum (AMC 145.A.50(b)):
Basic details of the maintenance that was carried out;
Date such maintenance was completed;
Identity of the organisation and person issuing the CRS; and
Limitations to airworthiness or operations, if there are any.
8.3.3.3 The requirements for CRS reside across multiple regulation subsections (DASR M and DASR 145) that collaboratively inform the regulated community of DASA's requirement. This chapter summarises the applicable requirements for CRS to assist the community in meeting the DASR.
Certification of Maintenance Responsibilities
Continuing Airworthiness Management Organisation responsibilities
8.3.3.4 CAMO responsibilities are described in detail within DASR M and include:
the CAMO is responsible for all activities aimed to determine the airworthiness status of the aircraft and to appropriately plan and coordinate maintenance.
ensuring that all maintenance requirements (Airworthiness Directives (AD), Aircraft Maintenance Program (AMP) requirements, defect rectification, etc...) are complied with and released by a DASR 145 Maintenance Organisation (DASR 145 MO) (or equivalent (M.A 708(b)).
the CAMO is responsible for planning and ordering all required maintenance and for ensuring that all ordered maintenance conducted by the DASR 145 MO or equivalent is complete and has a CRS. The CAME must explain how this is achieved.
DASR 145 Maintenance Organisation responsibilities
8.3.3.5 The DASR 145 MO (or equivalent) responsibilities are described in detail in DASR 145 and include:
the development of ‘certification of maintenance’ procedures that ensures all maintenance actions have been properly coordinated and the CRS is issued within a reasonable timeframe after the actual performance of the tasks;
issuing a CRS following maintenance; and
the CRS issued has to be recorded in the Continuing Airworthiness (CA) record system. This information shall be available to the aircraft captain (refer to DASR M.A.306 and AMC DASR M.A.306(a), who is ultimately responsible for accepting the aircraft before a flight takes place.
DASR 145 maintenance personnel responsibilities
8.3.3.6 The completion of maintenance requires two actions. They are:
a ‘sign-off’; and
a CRS.
8.3.3.7 These two actions may be performed by a singular person or group of people dependent upon maintenance complexity, qualifications and authorisations.
Maintenance Authorisation
8.3.3.8 A person can only be authorised when they have met all the organisation’s applicable qualification requirements, and only for the scope of work applicable to that qualification detailed in the DASR 145 Maintenance Organisation Exposition (MOE). A person can carry out maintenance and sign-off tasks that they have performed for a particular maintenance activity, and also be a support or certifying staff for another. As an example, a person may be authorised to sign-off on an aircraft type, and certifying and/or support staff on a different aircraft type.
8.3.3.9 DASR 145.A.35 (i) requires the maintenance organisation to nominate an individual66 responsible on behalf of the maintenance organisation for issuing certification authorisations to certifying staff.
Sign-off Authorisation.
8.3.3.10 This is exercised by a competent (IAW AMC1 145.A.30(e)) and appropriately authorised person, that the maintenance has been completed to the standard required in accordance maintenance data specified in DASR 145.A.45.
8.3.3.11 AMC 145.A.65(b)(3)3 states that, in order to prevent omissions, every task or group of tasks should be signed-off by authorised personnel after its completion. It also states that a sign-off relates to one step in the maintenance process and is different from a ‘release to service’ (CRS). Importantly, a sign-off is a statement by the competent person performing or supervising the work, that the task or group of tasks has been correctly performed.
8.3.3.12 Furthermore, this AMC states that work by ‘unauthorised personnel’ (temporary staff, trainee/apprentice) must be witnessed by the authorised person before they sign-off. This means the authorised person signing off the task is responsible for the task.
8.3.3.13 IAW AMC1 145.A.30(e) personnel performing the sign-off, “shall be able to carry out tasks to any standard specified in the maintenance data, and will notify supervisors of mistakes requiring rectification to re-establish required maintenance standards”.
8.3.3.14 Nevertheless, holding a sign off authorisation doesn’t mean that the authorised person can sign off all tasks. It means that they can sign off tasks within the scope of their authorisation, depending on the qualifications, training and experience held, and in accordance with a procedure described in the MOE. Sign-off authorisation does not need to be restricted to singular tasks where the technician is required to/has demonstrated a degree of competence for that task. In contrast, the technician shall demonstrate competence in performing or supervising work applicable to their training and qualifications.
8.3.3.15 Further details related to task completion and sign-off can be found in Chapter 8.3.2 – Performance of Maintenance.
Certificate of Release to Service
8.3.3.16 In executing the obligations of DASR 145.A.50(a) the organisation must have procedures in place that ensure:
the individual issuing the CRS is appropriately authorised to do so;
the individual issuing the CRS has ensured the maintenance has been carried out correctly using appropriate procedures IAW DASR 145.A.45(b); and
as a result of the maintenance conducted there are no defects which are known to ‘endanger flight safety’.
8.3.3.17 A CRS is an attestation made by Certifying Staff by way of a certification signature after the completion of maintenance within their authorisation scope. The certification signature creates a ‘certificate’ and thus accountability, signifying that the maintenance or group of maintenance activities can be released to service. In Line maintenance the holder of a category A, B1 or B2 MAML may issue a CRS within the scope of their MAML and authorisation. In Base Maintenance the holder of a category C MAML is required to issue the CRS after the completion maintenance within the scope of their MAML and authorisation. Issue of a CRS in Component Maintenance can be done by appropriately authorised certifying staff, in this instance the individual does not need to hold a MAML.
8.3.3.18 There are two elements that need to be fulfilled by the authorised Certifying Staff before the issuance of a CRS is possible:
Ensure. Verify through oversight and management to ensure that the maintenance has been properly carried out; and
Assessment. Ensuring that no non-compliances which are known to exist that could ‘endanger flight safety’
How do Certifying Staff “ensure that the maintenance ordered/tasked has been properly carried out”?
8.3.3.19 Verification through the supervision of the maintenance task. Certifying Staff ensure that maintenance has been properly carried out by ensuring maintenance has been conducted in accordance with procedures detailed in the MOE and through the correct use of maintenance data as specified in DASR 145.A.45.
8.3.3.20 This statement does not necessarily mean that authorised Certifying Staff have to personally perform or supervise77 the whole process of every task, rather it is expected that Certifying Staff will (non-exhaustive list):
make sure that personnel assigned to perform the maintenance are authorised to sign-off the work for the appropriate scope of their authorisation;
coordinate the different tasks associated with the maintenance being performed; and
be available to support personnel in case of any mistakes or unexpected difficulties.
8.3.3.21 Authorised Certifying Staff are responsible to determine the amount of involvement they require in order to be satisfied that the maintenance can be issued a CRS. Subsequently, the DASR 145 MO cannot limit Certifying Staff in terms of what level of supervision they put in place for the maintenance task. The DASR 145 MO may however set a minimum requirement.
How do Certifying Staff, “make an assessment that there are no non-compliances which are known to endanger flight safety”?
8.3.3.22 This is achieved by a cognitive process that assesses whether an endangerment to flight safety exists as defined within AMC1 DASR 145.A.50(a) against the physical outcomes of maintenance ordered by the CAMO. It does not require the DASR 145 MO to find or become responsible for hidden defects which are not expected to be discovered during the ordered maintenance. Defect assessments, including those endangering flight safety, must be clearly identified in the CA records system along with any corresponding limitations (if any) for further CAMO consideration.
Considerations for when the aircraft is left in a non-airworthy condition
8.3.3.23 In circumstances where after performing the maintenance ordered by the CAMO, the aircraft is left in a non-airworthy configuration, a CRS can still be issued for the maintenance that has been completed. The CRS can be issued as long as the incomplete maintenance or known defects are properly identified in the CA records system and communicated to the CAMO. For example, where the DASR 145 MO removes an engine for preservation (without installing a new one), or where the organisation performs an NDT inspection and identifies a crack outside limits.
8.3.3.24 The circumstances mentioned above (including defects affecting flight safety discovered during maintenance), can be properly addressed by using the provisions contained in DASR 145.A.50(c) and (e).
8.3.3.25 It is important to appreciate that a CRS does not mean that the aircraft is airworthy and ready for flight. A CRS is issued by the DASA 145 MO for the maintenance performed; the CAMO is accountable for ensuring that all CA requirements are met for the aircraft to undertake its assigned mission before releasing to the Operator.
When is a CRS issued?
8.3.3.26 IAW DASR 145.A.50(b) “A certificate of release to service shall be issued before flight at the completion of any maintenance”. Subsequently, “any maintenance” can be interpreted in multiple ways, such as:
any maintenance task.
any combination of maintenance tasks.
any maintenance event.
8.3.3.27 Utilising the flexibility afforded by the “any maintenance” interpretation an organisation may choose one or more of the following systems of release to service:
Several CRS are issued, each one of them covering a different single maintenance task.
Several CRS are issued, each one of them covering a different group of maintenance tasks.
A single CRS is issued covering all the maintenance included in a maintenance event.
8.3.3.28 The organisation must ensure that the CRS issued to the CAMO clearly identifies what maintenance is complete. If there is any incomplete maintenance, the CRS must clearly identify it in the CA records system and the corresponding limitations (if any). In each of the above cases, it is important to note that there is no change in the accountabilities of the individual authorised Certifying Staff in signing the CRS.
Who can issue a CRS in Line Maintenance?
8.3.3.29 Only appropriately authorised category A, B1 and/or B2 MAML holders can issue a CRS in Line Maintenance. The scope and responsibility of each license category is provided below.
Limited Certification Authorisation
8.3.3.30 By way of exception to paragraph 8.3.3.29, and in accordance with 145.A.30(j) 4, in unforeseen cases where the aircraft is grounded or operating away from a Main Operating Base, and where no appropriate certifying staff are available, the maintenance organisation may issue a limited certification authorisation to the aircraft commander on the basis of the flight crew licence subject to being satisfied the aircraft commander can accomplish the specified task to the required standard. These provisions shall be detailed in a MOE procedure.
One off Certification Authorisation
8.3.3.31 In unforeseen cases, where an aircraft is grounded at a location other than the main base where no appropriate certifying staff are available, the maintenance organisation may issue a one-off certification authorisation in accordance with 145.A.30(j)5.
Category A licence
8.3.3.32 The category A licence permits the authorised MAML holder, in a Line Maintenance environment only, to issue CRS for work that the licence holder has personally performed (‘sign off’) and within the scope of their certification authorisation.
8.3.3.33 A category A licence does not permit the authorised MAML holder to issue a CRS for the work of others, only for their own maintenance. While other personnel may be present and directed by the authorised A MAML holder in providing assistance during the performance of the maintenance task, the category A MAML holder may not undertake a supervisory role.
Category B licence
8.3.3.34 The category B1/B2 licence permits the authorised MAML holder to issue CRS, within the scope of their license and certification authorisation on maintenance that has been ‘signed off’ by themselves or other authorised personnel, within the scope of their license and certification authorisation.
Category C licence
8.3.3.35 The category C licence permits the authorised MAML holder to issue a CRS following Base Maintenance on aircraft carried out by a DASR 145 AMO. By definition, the DASR permits an authorised category C MAML holder to issue a single CRS for all maintenance activities pertaining to the aircraft during a single Base Maintenance visit.
8.3.3.36 Noting the complexity and the volume of the maintenance being carried out during a Base Maintenance activity, it is difficult for the authorised category C MAML holder to be across all tasks, to the extent required, to issue a CRS. For this reason, the authorised category C MAML holder may use Support Staff to enable the CRS to be issued.
8.3.3.37 The authorised category C MAML holder is accountable to ensure that all required maintenance that has been ordered, has been carried out properly, that there are no non-compliances which are known to endanger flight safety and any outstanding or incomplete maintenance has been identified and the CAMO notified before issuance of the CRS.
Support Staff
8.3.3.38 Support Staff are authorised B1 and B2 MAML holders. The role of Support Staff during Base Maintenance is to conduct, within the scope of their MAML and authorisation, activities such that it can be communicated to the authorised category C MAML holder that:
the maintenance has been performed properly;
that any defects found during the course of maintenance are recorded in the CA records; and
that any outstanding or incomplete maintenance is identified and recorded in the CA records.
8.3.3.39 In essence, Support Staff are oversighting and managing allocated maintenance tasks within Base Maintenance in support of the authorised category C MAML holder. Subsequently, the DASR 145 MO must have a mechanism in place and articulated in the MOE WRT how Support Staff communicate to the category C MAML holder when the CRS can be issued.
8.3.3.40 An authorised category C MAML holder may not require Support Staff if they also hold the required B1/B2 license scope and subsequent authorisation with regard to the Base Maintenance being performed. The authorised category C MAML holder in this instance can issue the CRS without the use of additional Support Staff. The procedures with respect to an authorised category C MAML holder acting as their own support staff must be articulated in the MOE.
Summary of Maintenance Authorisations
8.3.3.41 The following figure summarises the different types of authorisations an organisation will require and the scope of work against which they may authorise their staff. It is the DASR 145 that performs and certifies maintenance requested by the DASR M.
Figure 1 Summary of Maintenance Authorisations
Introduction
8.3.4.1 This chapter provides additional guidance on what constitutes a DASR Form 1 or recognised equivalent and outlines how DASR 145 Approved Maintenance Organisations (AMOs) should assess the suitability of component documentation to ensure such components are eligible to be fitted to Defence registered, type-certified products.
8.3.4.2 The Defence Aviation Safety Regulations (DASR) require Approved Maintenance Organisations (AMOs) to ensure the airworthiness88 of components and materials prior to fitment to Defence registered, type-certified products. To fulfil this requirement, the AMO must ensure that components are accompanied by appropriate documentation attesting to the legitimacy of the component’s maintenance or production history. This is underpinned by the regulatory requirement for the AMO to obtain a DASR Form 1 or equivalent documentation prior to fitment of such components.
8.3.4.3 This chapter relates to the acceptance of new and used aircraft components, which are listed by the appropriate design organisation as eligible for installation in/on a product and included in the design data approved by the Authority99. The term components broadly covers any product (other than complete aircraft), part or appliance that is, or is intended by its manufacturer to be, a part of or used in operating an aircraft in flight, or is installed in or attached to a product. This may include any self-contained part, combination of parts, assembly, subassemblies or units, which perform a distinctive function necessary to the operation of the airframe, engine, or propeller, or may include any other instrument, mechanism, equipment, apparatus, software or accessory, including communications equipment.
8.3.4.4 Although alternate artefacts can be consumed by a DASR 145 Approved Maintenance Organisation (AMO), DASA requires the relevant CAMO to seek approval for, and manage, the ongoing validity of alternate artefacts for their respective platforms. Further detail on alternate artefacts can be found in Chapter 8.2.3 – Alternate Artefacts.
Products, parts and appliances
8.3.4.5 To align with the European Military Airworthiness Requirements (EMAR), the DASR has replaced the term Aeronautical Product with separate definitions for products, parts and appliances. The term ‘components’ in this document will be used interchangeably with products (other than complete aircraft), parts and appliances for simplicity.
Acceptance of components
8.3.4.5 The AMO is responsible for ensuring the ‘eligibility for fitment’ of components to type-certified products prior to installation1010.
Eligibility for fitment
8.3.4.6 A component is eligible to be fitted to a type-certified product, or another part or appliance if:
the fitting of the component is permitted by the approved design1111 for the product, part or appliance of the higher assembly;
the component is in a serviceable condition for safe operation; and
the component has been appropriately released or returned to service1212.
8.3.4.7 The AMO should have procedures for the acceptance of components and material, to ensure that the supplied components and material are in satisfactory condition and eligible for fitment. Furthermore, the AMO is responsible for ascertaining the traceability of components and material to their original or authorised source, including the maintenance or production and supplier source, where applicable. Therefore, it is the responsibility of the installer to request the appropriate documentation which establishes the airworthiness status and traceability of components and materials.
8.3.4.8 In determining whether a component is eligible for fitment, the AMO should conduct the following:
a physical inspection of components and/or material (including a check for any obvious physical damage and verification that part numbers, serial numbers, lot and/or batch numbers, etc. match the accompanying documentation; and
a review of accompanying documentation and data, which should be acceptable IAW DASR 145.A.42.
8.3.4.9 Particular caution should be exercised when the origin of components and materials cannot be established or when the origin is in doubt.
8.3.4.10 The flowcharts provided at Appendix 1 and Appendix 2 illustrate the process for determining the eligibility for fitment of new and used aircraft components, respectively, to type-certified products, or other parts and appliances.
Acceptance of Aircraft Components
What is an Authorised Release Certificate?
8.3.4.11 An Authorised Release Certificate (ARC) is a document issued by an entity that has the applicable privilege and attests that a new or used component has been produced or maintained IAW the approved design data/standard, modification standard or applicable maintenance data1313.
8.3.4.12 An acceptable ARC is either:
DASR Form 1, or equivalent (refer DASA recognition website); or
an ‘alternate artefact’ accepted by DASA.
8.3.4.13 An acceptable ARC must show traceability back to a recognised CAA/MAA. In general, an Authorised Release Certificate must provide evidence of (where applicable):
the name and address of the issuing organisation;
the name of the recognised CAA/MAA;
evidence that the issuing organisation is working within the recognised authority’s system (e.g. organisation approval reference);
details of the component(s): description, part number, serial number(s) and/or batch number, as applicable;
for used service-life-limited components, complete traceability to the component’s service history;
a clear indication of the current airworthiness status (serviceability) of the component at the date of issue;
a release statement made by a suitably authorised person within the production or maintenance organisation;
the name, signature (or electronic equivalent) and approval number (where applicable) of the person making the release statement;
for components released from maintenance, a statement that the maintenance was carried out in accordance with the recognised authority’s regulation/policy; and
for components released from production, a statement that the component(s) was manufactured in conformity with approved data.
8.3.4.14 The ARC does not constitute authority to install the item on a particular product or component, but provides evidence that assists the AMO in determining the item’s eligibility for fitment. Furthermore, an ARC cannot be used for the release of complete aircraft.
8.3.4.15 The ARC serves as the official certificate for components from the manufacturer/AMO to users. It should therefore be used for the transfer of components between different airworthiness systems or AMOs. A delivery or shipping note does not constitute an ARC.
8.3.4.16 It should also be noted that a mixture of new and used items is not permitted on the same ARC. Likewise, a mixture of items certified in conformity with ‘approved data’ and to ‘non-approved data’ is not permitted on the same certificate.
When is an Authorised Release Certificate required?
8.3.4.17 An ARC is necessary for the release to service of either new or used components. The certification of new components is performed IAW DASR 21.A.307, whereas the certification of maintenance on used components is performed IAW DASR 145.A.50.
8.3.4.18 A component is eligible for fitment to a type-certified product when the component is in a condition for safe operation (i.e. serviceable) and accompanied by an ARC. An ARC helps the AMO to determine the airworthiness approval status for components and therefore eligibility for fitment.
8.3.4.19 Release of new components following production1414. The component manufacturer is responsible for producing the ARC following the production of a new component. The purpose of the Authorised Released Certificate for new components is to certify that the item has been manufactured in conformity to approved design data and marked in accordance with DASR 21, Subpart Q. An ARC is required for components produced under:
type-certificate or supplemental type-certificate and changes thereof;
Production Organisational Approval;
Parts Manufacturing Approval (PMA) / European Part Approval (EPA)1515; or
AUSMTSO authorisation.
8.3.4.20 Such components will normally be listed within the OEM furnished Illustrated Parts Catalogue (IPC) or Illustrated Parts Breakdown (IPB).
8.3.4.21 Release of used components following maintenance1616. The purpose of the ARC for used components is to release components to service after off-aircraft maintenance. The ARC is issued by the AMO and must be within their scope of approval
8.3.4.22 Issuing an ARC following maintenance is an attestation that all maintenance is complete (except for deferred defects agreed to by the CAMO), and there are no non-compliances which are known to endanger flight safety. Any incomplete maintenance ordered/tasked should be clearly stated in the ARC when such non-compliances (i.e. deferred maintenance) are within the approved aircraft limitations.
8.3.4.23 Only personnel authorised by the DASR 145 may issue a DASR Form 1 Authorised Release Certificate following off-aircraft maintenance. Where component maintenance is subcontracted to another maintenance organisation1717, the ARC may be issued either at the:
non-DASR 145 contractor/tasked maintenance organisation1818; or
AMO facility by staff holding a certification authorisation, as appropriate1919 .
8.3.4.24 Further, for used components that are service life-limited the ARC shall contain, or be accompanied by, an updated maintenance status with reference to this status in Block 12 of the certificate. In addition to configuration data (modifications, repairs, ADs and SBs), the status should contain information on the utilisation, particularly accumulated service life in relation to component life-limits.
When is an Authorised Release Certificate not required?
8.3.4.25 An ARC is not always required after component production or maintenance. However, documented evidence of conformity to approved design or certified material specification must be obtained prior to fitment to a type-certified product. Such evidence must be traceable back to the organisation that manufactured or maintained the component.
New Components.
8.3.4.26 Specific equipment. Components which have been incorporated into the type design as specific equipment2020 and therefore have been shown not to adversely affect the airworthiness of the aircraft and not subject to recognised airworthiness standards2121 do not require an ARC. The CAMO should provide installation instructions that authorise the component’s return to service requirements. Examples of specific equipment may include commercial-off-the-shelf (COTS) ‘industry supply’ equipment. This may include Commercial Parts such as cabin reading light bulbs, curtain rings, sink valves, etc.
8.3.4.27 Standard Parts. Standard Parts must be supplied with a CoC referring to the specified standard, the manufacturer and supplier source, the batch/lot number and, if applicable, the shelf life (including expiration date) and storage conditions. Standard Parts are specified within the manufacturer’s IPC/IPB or maintenance data. Examples of Standard Parts include, but are not limited to, those conforming to National Aerospace Standard (NAS), Air Force/Navy (AN) Aeronautical Standard, Society of Automotive Engineers (SAE), Aerospace Standard (AS), Military Standard (MS), etc.
8.3.4.28 A part is no longer considered a Standard Part if it is used in a critical application that imposes qualification or quality control requirements beyond the published standard specification. In such a case, the OEM should allocate its own part number reference, and these parts would require an ARC.
8.3.4.29 Materials. Both raw and consumable materials, used in the fabrication, maintenance, servicing or operation of an aircraft or component, may be accepted without an ARC2222. Such materials are required to meet the specification detailed in the approved design, and have appropriate traceability.
Used Components.
8.3.4.30 Restricted Parts manufactured by the AMO. Where a maintenance organisation has been granted approval by the Authority to fabricate a restricted range of parts to be used by that maintenance organisation in the course of overhaul, maintenance, modifications or repair within its own facility, such parts do not qualify for certification via an ARC2323.
8.3.4.31 Unserviceable Parts. An ARC should not be issued for any unserviceable components, except where such items are undergoing a series of maintenance processes at multiple AMOs. In this case, the receiving AMO requires an ARC to accept the component prior to subsequent maintenance.
8.3.4.32 In-house release. An ARC may not be required in the case where an AMO maintains a component for its own use and there is an approved alternative in-house release document as described in the AMO’s MOE.
8.3.4.33 Aircraft on Ground – other than at Main Operating Base (MOB). When an aircraft is grounded at a location other than the MOB due to the non-availability of a component with an appropriate release certificate, it is permissible to temporarily fit a component with an alternative release certificate, subject to CAMO approval. The component must be removed at a time specified by the CAMO, unless the appropriate release certificate has been subsequently obtained, prior to removal of the component.
What do I do with a completed Authorised Release Certificate?
8.3.4.34 The completed ARC becomes part of the technical record for the component to which it relates, and eventually will become part of the technical record of the higher assembly or product on which that component is installed. The certificate is therefore subject to all applicable regulatory requirements related to maintenance and technical records .
When are components not eligible for fitment?
8.3.4.35 A component is not eligible for fitment on a type-certified product where it is known or suspected to have any of the following:
Discrepancy between the component’s identifying markings (as required by DASR 21 subpart Q) and its accompanying documentation;
Non-conformances between the component’s physical characteristics and its approved design data/specification or applicable maintenance data (i.e. unacceptable or questionable quality);
Damage (due to packaging, etc.) or unserviceability;
Absence of or incomplete or inappropriate release documentation to determine the airworthiness status or eligibility for fitment; or
Unknown, suspect or unverified origin of the component (i.e. has not or may not have been manufactured or maintained by an approved source).
Introduction
8.3.5.1 This chapter provides guidance on the application of DASR GR.80 Flexibility provisions within the specific context of maintenance organisations. To meet an operational need, there may be circumstances where the authorisation of non-MAML staff in certifying or support staff roles is necessary. These circumstances also extend to where it is not practical for foreign-trained personnel to obtain a MAML in the time available (e.g. short-term secondment).
8.3.5.2 Currently, the scope of guidance provided is related to the authorisation of non-MAML staff as certifying and support staff for on-aircraft maintenance.
DASR GR.80 Flexibility provisions
8.3.5.3 Provisions. DASR GR.80 Flexibility provisions includes two different avenues to enable regulated entities to deviate from the requirements of applicable DASR. These provisions are available subject to an operational need, where compliance with applicable DASR would impact the ability to meet operational objectives. The two avenues are:
Achieve an equivalent level of protection under GR.80(b). DASA may approve the deviation using the applicable DASR as the safety standard against which the deviation is assessed and approved.
Equivalent level of protection not demonstrated, but supported by the application of sound risk management, under GR.80(c). DASA may allow the deviation but cannot approve it due to the absence of any established safety standard against which to approve.
8.3.5.4 Second-order effects. The use of DASR GR.80 provisions, including GR.80(b) which requires an equivalent level of protection, has the potential to create unintended second-order safety impacts due to the interlinked nature of the DASR (a system of systems). In each instance, the regulated entity seeking to apply these flexibility provisions should identify and address any such impacts.
8.3.5.5 Increased safety risk. The application of GR.80 flexibility provisions by service providers, such as maintenance organisations, may result in increased Aviation Safety risk for the relevant Military Air Operator (MAO). Affected MAOs must apply additional due diligence to activities utilising the flexibility provision for the period in which that flexibility provision is in effect, commensurate with the residual risk level. Additionally, GR.80 application does not absolve the organisation of its obligation to continue to comply with all other applicable DASR. Where GR.80 flexibility provisions have been appropriately applied, DASA will not issue a finding for non-compliance against specific DASR clauses covered by the provision.
8.3.5.6 Remediation. Any flexibility provision should only be continue to be in place while:
the operational need continues to exist; and
compliance with relevant DASR would continue to impact operational objectives.
8.3.5.7 Application to DASA. DASA expects that proposed implementation of flexibility provisions to be detailed within, or referenced by, draft amendments to the MO exposition submitted under a DASR Form 2 Application for DASR 145 and DASR M Subpart G Approval.
8.3.5.8 Application by Defence Industry. Defence Industry organisations may only enact DASR GR.80 provisions through their relevant Military Air Operator (MAO) as the Risk Management Authority. In the event that a MAO’s operational need requires a Defence Industry MO to exercise flexibility provisions, Defence Industry would support the MAO through provision of technical considerations and controls.
Use of flexibility provisions to authorise certifying and support Staff
8.3.5.9 Background. As discussed in chapter 8.3.3, the DASR requires2424 that certifying staff and support staff for on-aircraft maintenance hold an appropriate MAML. DASA MAMLs are issued when an applicant provides to DASA the relevant evidence, from a DASR 147 Maintenance Training Organisation (MTO) or recognised equivalent, that basic knowledge, basic experience and applicable type training requirements have been met. Gaps in basic knowledge result in MAML exclusions – mostly aircraft system based (e.g. propulsion systems, electrical systems) – and preclude a MAML holder from issuing a CRS or acting as support staff on the excluded aircraft systems.
8.3.5.10 Granting of MAMLs to foreign-trained personnel. Provisions within the DASR 147 enable foreign-trained maintenance personnel to obtain a MAML by undergoing an equivalency assessment where time permits. This assessment is conducted by an approved or recognised 147 MTO and will consider knowledge and experience as well as relevant type training.
8.3.5.11 DASA assurance of procedures and outcomes. DASA will conduct independent safety assurance differently for DASR GR.80(b) and GR.80(c), commensurate with the level of risk exposure. However, DASA assurance for both DASR GR.80(b and GR.80(c) involves the prior assessment of the procedure used to authorise non-MAML staff in certifying or support staff roles. Where uncertainty exists as to the procedure’s applicability or suitability in a particular instance, the DASR 145 MO (through the CAMO, on behalf of the MAO), should seek advice from DASA.
8.3.5.12 Common guidance. The maintenance organisation may choose to utilise a single procedure to address both GR.80(b) and GR.80(c) scenarios. However, the organisation must make it clear how it will meet the different aviation safety performance outcomes. In both scenarios, where practicable, the procedure should require DASA 145 MOs to seek assistance from the ADF DASR 147 MTO to assess training deficiencies and inform decisions.
DASR GR.80(b) equivalent level of protection
8.3.5.13 An application to use the GR.80(b) equivalent level of protection provision must articulate how the procedure to authorise non-MAML staff in certifying or support staff roles will provide an equivalent level of protection to that which would otherwise be attained through compliance with the relevant DASR. If DASA agrees that an equivalent level of protection is achieved through the procedural outcome, DASA will approve the exception from the DASR. DASA will apply assurance to the ongoing application of the procedure(s) through routine oversight unless the DASR 145 MO, through the CAMO (on behalf of the MAO), requests DASA independent assurance prior to the issue of an individual authorisation.
8.3.5.14 An application to DASA for approval of the GR.80(b) equivalent level of protection flexibility provision should describe a method for implementing risk controls equivalent to those inherent in a DASA MAML (e.g. categorisation, exclusions and type ratings). The procedure should require assessment of individual competency, through knowledge and experience considerations, via:
an approved foreign nation/service comparison process; or
suitable evidence against each relevant module of DASR 66 Appendix I I and relevant chapters of DASR 66 Appendix III, to the appropriate training level, for the scope of the authorisation to be given.
8.3.5.15 Utilisation of DASR GR.80(b) is likely to be complex and time-consuming, requiring detailed analysis that may not be suitable to support agile operations.
DASR GR.80(c) risk management
8.3.5.16 For DASR GR.80(c), the procedure to authorise non-MAML staff in certifying or support staff roles must demonstrate that a credible and defensible level of military aviation safety performance will be maintained through sound management of aviation safety risks arising through the deviation from applicable DASR. DASA will not approve a GR.80(c) procedure but will allow its use subject to the requirement that all instances of the organisation applying the procedure are reported to DASA at the first practical opportunity. The DASA assurance role provides an independent assessment of the credibility and defensibility of the risk-based decision that is made by the organisation.
8.3.5.17 Any application to DASA to implement a GR.80(c) risk management approach should address the following:
The seven-step risk management guidance provided in Annex A and the format and means in which it will be submitted to DASA.
The necessary interfaces to the MAO such that any Decisions to Proceed are appropriately documented.
Where operational needs allow for prior assurance by DASA, the relevant DASA desk officer should be provided with the output of the procedure, to review prior to enactment.
Where operational needs do not allow for prior assurance by DASA, the procedure for authorising non-MAML certifying or support staff may still be enacted by the DASR 145 AMO (through the MAO). Retrospective DASA assurance will be applied where an ongoing operational need supports continued application of the flexibility provision.
Annex:
Contextualised guidance for seven-step risk management
Introduction
8.4.1.1 This chapter provides additional guidance on the Military Aircraft Maintenance Licence (MAML), and for those individuals applying for a “personnel authorisation2525” under DASR 66, how to comply with DASR 66 requirements.
8.4.1.2 DASR 66 establishes the regulations required to be met by Aircraft Maintenance Training Organisations (AMTO), responsible for either Basic or Type Training, to be eligible for a DASR Military Aircraft Maintenance Licence (MAML).
8.4.1.3 For the purpose of this chapter additional guidance does not include information already presented at Volume 2, but represents additional guidance material. Referenced content relevant to, but not directly related to, continuing airworthiness will be found in other areas of the Defence Aviation Safety Program including in other chapters of DASP Manual Volume 3. Further information regarding DASR 147 is located within Volume 3, chapter 8.5.
Background
8.4.1.4 During the DASR 66/147 transition, DASA provided a number of interim arrangements which allowed the current workforce to apply for DASR 66 MAMLs, including acceptance of existing Military Aircraft Type Rating training until the DASR were fully implemented.
8.4.1.5 The DASR 66.A.70 conversion provisions were based on the Australian National Competency Training and Assessment framework. These provisions were applied to staff who held valid certifying qualifications prior to the date of these regulations being introduced.
8.4.1.6 All DASA MAMLs are based on objective evidence of an individual’s Qualification, Training and Experience (QTE), against the criteria in Appendix I to DASR 66 Basic Knowledge Requirements. DASA has mapped the EMAR syllabus (Appendix I to DASR 66) to associated Australian nationally adopted Competency Based Training and Assessment Units of Competency (UoC), qualifications and non-vocational education and training (VET) service specific training. This mapping resulted in providing a DASA Category A1, A3, B1.1, B1.3 or B2 MAML, with or without exclusions and inclusions.
8.4.1.7 The Defence Airworthiness Safety Regulations (DASR) 66 - Military Aircraft Maintenance Licencing provides Defence personnel who hold a MAML the privilege to issue Certificate of Release to Service (CRS). This regulation is based on the European Military Airworthiness Requirements Part 66 (EMAR Pt 66), but adapted to suit the Australian military maintenance environment.
8.4.1.8 DASR 66 identifies the skills and knowledge requirements for each licence category (refer MAML Categories below) by syllabi. DASA have mapped initial trade training and technical, promotion-related courses (eg Aviation Technician Supervisor Course, LSATT, CPL SUBJ 4 etc) against these syllabi.
8.4.1.9 The MAML is an attestation the holder has met the DASR 66 knowledge and experience requirements, but does not entitle the holder to issue an aircraft CRS until they are authorised within a DASR 145 Maintenance Organisation (MO) to exercise these privileges.
DASR 66.A.3 - MAML Categories
8.4.2.1 There are four basic licence categories:
The Category A licence is a non-type rated licence for minor scheduled and unscheduled maintenance permitted within Line Maintenance (relevant tasks will be detailed in the relevant DASR 145 MOE). The privileges of a Category A licence are not applicable to Base Maintenance.
Category B1 - permits certification privileges for scheduled and unscheduled airframe, engine, structures, mechanical systems and electrical maintenance for more complex Line Maintenance activity. The B1 MAML also permits minor avionics maintenance (eg 'black box' changes, where no specialised support equipment is required). The B1 MAML allows for authorisations as support staff within Base Maintenance.
Category B2 - permits certification privileges for scheduled and unscheduled complex avionics and electrical Line Maintenance activities and allows the holder to act as B2 support staff within Base Maintenance.
Note: The Category B1 and B2 licences are aircraft type-rated licences and permit the holder to certify the release to service only of aircraft types that are endorsed as ratings on their licence.
Category C - is required for personnel who issue the CRS following Base Maintenance.
Note: The Category C licence is an aircraft type-rated licence and permits the holder to issue the CRS of an aircraft following Base Maintenance only. GM to DASR 66.A.20(a) para 3 provides more detail.
DASR 66.A.50 – Limitations and DASR 66.A.52 – Extensions
8.4.2.2 All MAMLs are managed in accordance with the DASA 66 MAML Exclusion Inclusion & Endorsement Manual, available on the DASA Website.
8.4.2.3 The DASA 66 MAML Exclusion, Inclusion & Endorsements Manual outlines the required competency details and provides general guidance that reflects DASR 66.A.20 privileges against the S1000D system of standard numbering to specify particular Systems and Sub-systems.
8.4.2.4 Exclusions (Limitations) introduced on a MAML are omissions from an individual’s certification privileges, indicating that the licence holder shall not issue a CRS in
8.4.2.5 Line Maintenance or act as B1 or B2 support staff in Base Maintenance if maintenance related to that exclusion has occurred.
8.4.2.6 Inclusions (Extensions) introduced on a MAML are additional privileges to an individual’s certification privileges, indicating that the licence holder may issue a CRS or act as B1 or B2 support staff if maintenance related to that Inclusion. Noting that additional military specific systems Inclusions can be achieved through completion of all required competencies & a type course (where appropriate) which incorporates S1000D Air-vehicle system basic knowledge requirements into the type syllabus.
8.4.2.7 The S1000D is a numerical technical classification of all the systems and sub systems on an aircraft, which is largely used in aircraft engineering and maintenance, and helps to standardise data across aircraft manufacturers and programs to facilitate improved maintenance and logistics.
DASR 66.A. 10 - Application
8.4.3.1 Refer to DASPMAN Volume 3, Chapter 5.3 – Annex W – MAML for details.
Foreign Licence Applications
8.4.3.2 Military Aviation Authority/National Aviation Authority’s (MAA/NAA) have differing training requirements for aircraft maintenance personnel based upon their sovereign regulatory maintenance framework. Therefore, there may be considerable differences in each country’s licence privileges, regulations, assessment methods/framework and specific guidelines; resulting in gaps and difficulties to enable direct conversion of a foreign MAA/NAA issued licence to a DASA MAML.
8.4.3.3 Australia has nationally adopted competency-based training and assessment in lieu of EASA/EMAR basic knowledge syllabus and examinations, which results in attainment of Units of Competency (UoC), which in turn lead to Aeroskills qualifications.
8.4.3.4 DASA has mapped these Aeroskills Mechanical and Avionics UoC against DASR 66 syllabi requirements to provide either a Category A, B1.1, B1.3 or B2 MAML, with/without exclusions and inclusions.
8.4.3.5 To enable Non-Australian competencies/qualifications to be used to apply for a MAML, a 147 Maintenance Training Organisation (MTO) RPL assessment must be performed using objective evidence to provide an individual with an RPL report clearly outlining the required theory and practical training requirements that have been met.
Aging Qualifications
8.4.3.6 All MAML applications will need to meet the following requirements:
Any grandfathering formally recognised and utilised for a MAML assessment during the transitional period will be honoured and no further action is required by the individual;
IAW DASR 66.A.25 any training courses and examinations shall be passed within 10 years prior to the application for:
a MAML; or
an addition of a category or subcategory to a MAML; or
the removal/addition of a DASA exclusion/inclusion to a MAML.
Qualifications 10 years or older now come into question, as not meeting the requirements of 66.A.25(b). Any of these qualifications provided as evidence for a MAML application (initial or update), will generally not be accepted unless they have been assessed and converted against DASR 66.A.25 Basic knowledge requirements by a DASA/CASA approved 147 Organisation;
DASA acknowledges that there may be individual unique circumstances where aging qualifications could be considered in more detail – specifically where the time and effort required for conversion to contemporary standards, by a DASA/CASA approved 147 Organisation, may not be reasonable. To support this, where aging qualifications (>10yr) are used as evidence for a MAML application (initial or update), the applicant must provide detailed justification (with supporting evidence) on why the aging qualification should be considered. This should include relevant work history for the applicant (including objective evidence of previous maintenance authorisations) and detail any factors that support the acceptance of aging qualifications without conversion. MAML applications, with aging qualifications, will be rejected if no supporting justification is provided.
Where there is any doubt or ambiguity regarding the requirements for a MAML, contact DASA at dasa.dcadasr66@defence.gov.au, and provide detailed evidence for DASA’s consideration
DASR 66.A.25 – Basic Knowledge Requirements
8.4.4.1 A MAML applicant must have a demonstrated level of knowledge relevant to the MAML privileges to be granted, and in order to obtain a Category A (Line Maintenance only), B (Line & Base Maintenance) or C (Base Maintenance only) MAML. An applicant requires “Basic Knowledge” in the appropriate subject modules IAW Appendix I toDASR 66.
DASR 66.A.30 – Basic Experience Requirement
8.4.4.2 In addition to Basic Knowledge requirements (DASR 66.A.25), a MAML applicant must also have a demonstrated level of Basic Experience of the requested licence category (DASR 66.A.30). An applicant requires:
The practical experience must be gained in the real environment of military aircraft maintenance;
Initial employment training (IET) delivered to trainees of all three ADF Services provides the minimum practical training detailed in Appendix I to DASR 66. Therefore, maintenance personnel who have completed their IET are eligible for a category A licence after six months of practical training, following completion of specific aircraft task training in accordance with DASR AMC 66.A.20(b), and having achieved syllabus Module 10 requirements.
8.4.4.3 Experience shall be acquired within 10 years preceding the initial category or subcategory.
DASR 66.A.40 - Continued validity of the MAML
8.4.4.4 All MAMLs are perpetual and will remain valid unless suspended, surrendered or revoked.
8.4.4.5 DASA has a process that allows it to assess breaches or suspected breaches of the conditions that a MAML was issued and take appropriate action. Contact DASA at DASA.DCA DASR66 for more information.
DASR 66.A.45 - Military Aircraft Type Rating
8.4.5.1 In order to enact the privileges of a DASR 66 Category B (Line and Base Maintenance) MAML, MAML holders must have a specific Military Aircraft Type Rating (MATR) endorsement and be authorised by the DASA 145 nominated person (generally the Quality Manager) to operate within their approved quality system. In order to obtain a type rating, an applicant requires:
Type Training (Theory & Practical) (DASR 66.A.45): and
On the Job Training (OJT) for first Type Rating (AMC 66.A.45)
Military Aircraft Type Ratings Guidance
8.4.5.2 Refer to Chapter 8.5.8 – Military Aircraft Type Ratings for further details.
Expectations
8.4.5.3 All MATR applications must confirm that any OJT requirements are completed IAW Appendix III to DASR 66.
8.4.5.4 All MATR type training courses must be started and completed within the 3 years preceding application for the MATR.
8.4.5.5 The “Basic Training Course” requirements stated in 66.A.30 and 147.A.200 must be met before individuals are eligible for the relevant category MAML.
8.4.5.6 OJT requirements stated in Appendix III to DASR 66 must be met for first MATR in licence subcategory. Evidence of completion must be provided with the MAML endorsement application.
8.4.5.7 DASA may accept practical and/or OJT experience gained on civil variants of state aircraft e.g. Boeing 737 – Northrop Grumman for applications for P-8A Poseidon or E-7A Wedgetail.
8.4.6.1 On receipt of notification of fraudulent or unsafe behaviour by a MAML holder, DASA will assess the information to determine what action, if any, is required.
Notice to Show Cause
8.4.6.2 Should DASA determine that a suspension or revocation of a MAML be warranted, then a Notice to Show Cause (NTSC) will be issued to the MAML holder. For procedural fairness, the affected MAML holder will be provided the reasons and evidence supporting the decision to issue a NTSC. The NTSC provides the MAML holder the opportunity to respond to the proposed suspension or revocation of their MAML.
8.4.6.3 The response to the NTSC will be assessed by DASA to determine if:
No action required; or
MAML will be suspended; or
MAML will be revoked.
MAML Suspension or Revocation
8.4.6.4 DASA will notify the MAML holder, and the organisation for which the MAML holder held the authorisation, of the suspension or revocation of the MAML. DASA also publishes a list of suspended MAML on the Military Aircraft Maintenance Licencing page on the DASA website.
Review of Suspension or Revocation
8.4.6.5 The organisation for which the MAML holder held the authorisation, can request DASA to review the decision. The request for review should include the results of any internal investigation and any other relevant information to support the request for a review.
Introduction
8.5.1.1 This chapter provides additional guidance on the Defence Airworthiness Safety Regulations DASR 147 – Aircraft Maintenance Training Organisations (AMTO), to assist those organisations applying for a DASR 147 approval on how to comply with DASR 147 requirements.
8.5.1.2 DASR 147 establishes the regulations required by an AMTO responsible for either Basic or Type Training of DASR 66 Engineers and Aircraft Maintenance Technicians to be eligible for a Military Aircraft Maintenance Licence (MAML).
8.5.1.3 For the purpose of this chapter additional guidance does not include information already presented at Volume 2, but represents additional guidance material. Referenced content relevant to, but not directly related to, continuing airworthiness will be found in other areas of the Defence Aviation Safety Program including in other chapters of DASP Manual Volume 3
Requirements for Aircraft Maintenance Training Organisation
8.5.1.4 The Defence Aviation Safety Regulations (DASR) requires individual DASR 147 Maintenance Training Organisations (MTOs) to define their maintenance training activities in their Maintenance Training Organisation Exposition (MTOE). The scope of maintenance training of basic knowledge and/or Military Aircraft Type Rating (MATR) training should be in accordance with the MTO’s policy and procedures defined in the MTOE.
Background
8.5.1.5 The Defence Aviation Safety Authority (DASA) and Headquarters Air Force Training Group (HQAFTG) have agreed that the primary framework to meet the DASR 147 requirements for the training of ADF personnel is through the creation of a single Air Domain MTO.
8.5.1.6 The single Air Domain MTO will:
leverage existing Joint and Single Service Individual Education and Training governance arrangements to provide an efficient and standardised governance approach for Australian Defence Organisation (ADO) aviation maintenance training.
align with the Defence Registered Training Organisation (DRTO) framework to enable standardisation against benchmarked Australian Skills Quality Authority (ASQA) standards.
provide a single point of accountability for aviation maintenance training, which will provide better holistic oversight that safety outcomes are being achieved.
provide the simplest path to the provision of recognition of Defence Maintenance Training by civil regulators and foreign militaries.
8.5.1.7 Commercial organisations that deliver aircraft maintenance training, either initial technical training (basic training) or Military Aircraft Type Training to meet DASR 66 requirements will be recognised by DASA if they:
already have a Part 147 Approval issued by a DASA- recognised Civil Aviation Authority (CAA)/ Military Aviation Authority (MAA); or
are included within the Air Domain MTO; or
are issued a discrete DASR 147 Approval, where they provide aviation maintenance training to DASR 145 organisation(s), but do not train ADF personnel.
8.5.1.8 The Air Domain MTO includes military aircraft type training courses delivered by Army Aviation Training Centre (AAvnTC), the Navy Training Authority – Aviation (TA-AVN) and the Air Force – Force Element Groups (FEGs). Basic aviation knowledge training delivered by RAAF School of Technical Training (STT) is also included under the Air Domain MTO.
Application to become an MTO
8.5.1.9 Refer to DASPMAN Volume 3, Chapter 5.3 – Annex I – MTO for detailed guidance on the application process.
8.5.2.1 This regulatory provision outlines the facility requirements for a DASR 147 Aircraft Maintenance Training Organisation (AMTO) and contains several sub-sections, which detail the requirements that AMTOs must meet in terms of facilities, equipment and resources.
Facility Standards
8.5.2.2 AMTOs are to provide adequate facilities, equipment and tools to conduct training. AMTOs must ensure that their facilities meet the appropriate standards for classroom space, simulator training areas and other areas necessary for conducive aviation maintenance training. Additionally, AMTOs must have facilities for storage of maintenance tools, equipment and parts.
Workshop Standards
8.5.2.3 Workshops must be equipped with tools, equipment and materials necessary to perform the practical tasks required by the relevant training courses. AMTOs must have appropriate facilities for the storage, testing and calibration of equipment used in the maintenance of the aircraft.
Training Equipment
8.5.2.4 Training equipment must be maintained and calibrated to ensure that it is safe and effective for use in training. AMTOs must ensure that they have the appropriate equipment for training in various aspects of aircraft maintenance including aircraft systems, avionics, structures and powerplant maintenance.
Library Facilities
8.5.2.5 AMTOs are to provide access to relevant aviation related reference materials, manuals and other resources necessary for aviation maintenance training. AMTOs must ensure that their libraries are up to date and have a wide range of materials that are relevant to the training courses they offer.
Computer Facilities
8.5.2.6 AMTOs are to have computer facilities that provide access to relevant aviation related software, databases and other tools necessary for effective aviation maintenance training. AMTOs must ensure that their computer facilities have up to date software and hardware as well as high-speed internet connections.
Personnel Requirements
8.5.3.1 This section specifies the personnel requirements for management personnel employed by DASR 147 AMTOs. The organisation must have sufficient management personnel to ensure the effective management of its operations. The management personnel must be qualified, experienced and possess the necessary skills to oversee the organisation's activities and ensure compliance with all relevant regulations and standards. This includes an Accountable Manager who has overall accountability for the organisation's compliance with DASR regulations and will appoint other necessary resources to accomplish training commitments. The regulation includes requirements for different types of personnel, including management personnel, technical personnel, quality personnel, training personnel, and support personnel.
Records of Instructors, Examiners, Assessors and Invigilators
8.5.3.2 DASR 147.A.110 requires approved maintenance training organisations (AMTOs) in Australia to maintain records of instructors, examiners, and assessors. The records must contain specific details about the personnel including:
Personal Details: Personal details of the instructor, examiner, or assessor, including their full name, date of birth, and contact information.
Qualifications: Details of the instructors, examiners, or assessor’s qualifications, including the type of qualification, the date it was obtained, and the organisation that issued it.
Experience: Details of the instructors, examiners, or assessor’s experience, including the type of experience, the duration of experience, and the organisation where the experience was gained.
Training: Details of the training received by the instructor, examiner, or assessor, including the type of training, the duration of training, and the organisation that provided the training.
Authorisations: Details of any authorisations held by the instructor, examiner, or assessor, including the type of authorisation and scope, the date it was issued, and the organisation that issued it.
Currency: Details of the instructors, examiners, or assessors currency, including the type of currency, the date it was last achieved, and the date it is due to expire.
Performance: Details of the instructor’s, examiner’s or assessor’s performance, including any relevant feedback or reviews and professional development plan.
Relevant Training Material: Details of any relevant training material that the instructor, examiner, or assessor has access to or uses in the performance of their duties.
Verification of Competence: Details of any verification of competence conducted on the instructor, examiner, or assessor, including the type of verification, the date it was conducted, and the organisation that conducted it.
Compliance: Details of the instructor's, examiners, or assessor's compliance with all relevant regulations and standards.
8.5.3.3 AMTOs can ensure that their personnel are qualified, competent, and authorised to perform their duties, and comply with all relevant regulations and standards.
Key Personnel Requirements
8.5.3.4 The qualification and experience of the instructors, knowledge examiners, practical assessors and invigilators are fundamental to ensuring the quality of a training course – only appropriately qualified personnel should be appointed to carry out training and examinations. In addition to the published Acceptable Means of Compliance (AMC) and Guidance Material (GM) to DASR 147.A.105(f), the following information provides additional guidance on the knowledge and skills that are expected of authorising instructors, knowledge examiners, practical assessors and invigilators employed by a DASR 147 Maintenance Training Organisation (MTO).
Instructors
8.5.3.5 A nominated person who will deliver a DASR 66 module or unit of competency (DASR 66 appendix I), a DASR 66 element (DASR 66 appendix III), or part thereof either of these. The instructor is not necessarily the person involved in drafting of the course material (content, duration, etc.), however they should be involved in the continued development of the lessons themselves (creation of the instructor notes, slides, sequencing, etc.).
8.5.3.6 Instructors should be:
Conversant with the DASR 66, 145 and 147 regulations, AMC, GM and specific procedures (MTOE, instructions, etc.) that are assigned to their scope of approval within a DASR 147 MTO.
Pedagogic – should know how to organise a lesson and how to efficiently deliver a course that clearly highlights the fundamental points. They should also be able to adapt when communicating to a particular audience including with pre-existing knowledge/experience.
Able to promote the appropriate attitude towards regulation and procedures; in particular the strict adherence to approved maintenance practices and quality standards through the lens of their own experience in a regulated aviation environment.
Familiar and proficient with the tools and training techniques used by the training organisation to deliver lessons.
Appropriately experienced in the aircraft maintenance environment.
Able to demonstrate good knowledge, complimented with communication skills in the English language.
Able to demonstrate a good understanding of the workplace environment, human performance and safety culture.
Able to demonstrate good knowledge of technical publications (Aircraft Maintenance Manual, Component Maintenance Manual, Airworthiness Directives, Service Bulletin, Maintenance Programme, etc.).
In receipt of continuous training in the company’s procedures and DASRs.
Knowledge Examiners
8.5.3.7 A nominated person who will determine the level of theoretical knowledge of the trainees on a particular module, unit of competency, element, or part thereof. The function may include the drafting and/or the selection of questions (Multi-Choice Questions and Essays), the evaluation of the correctness of answers (except when correct answers are pre-determined) and the final judgement regarding the level of knowledge demonstrated by the trainee.
8.5.3.8 Persons solely supervising an exam session are not considered as examiners but are considered as support staff invigilators and, in this context, are not subject to knowledge and experience requirements, but need to be trained to the examination procedure described in the MTOE.
8.5.3.9 Knowledge examiners should be:
Conversant with the DASR 66, 145 and 147 regulations, AMC, GM and specific procedures (MTOE, instructions, etc.) that are assigned to their scope of approval within a DASR 147 MTO, including the examination standards required by DASR 66.
Able to demonstrate a responsible attitude to the conduct of examinations, so that the highest integrity is ensured.
Trained in contemporary examination techniques and able to conduct an examination in such a way that the true abilities of the candidate are demonstrated.
Able to remain neutral at all times and behave in a manner that will not influence or prejudice the final result of the examination, for example by providing undue assistance or clarification to a candidate.
Familiar and proficient with the tools or the examination techniques used by the training organisation to perform the exams.
Appropriately experienced in the aircraft maintenance environment.
Able to demonstrate good knowledge, complimented with communication skills in the English language.
Able to demonstrate a good understanding of the workplace environment, human performance and safety culture.
Able to demonstrate good knowledge of technical publications (Aircraft Maintenance Manual, Component Maintenance Manual, Airworthiness Directive, Service Bulletin, Maintenance Programme, etc.).
In receipt of continuous training in company’s procedures and DASRs.
Practical Assessors
8.5.3.10 A nominated person who will determine the level of practical knowledge/practical skills of the trainees on a particular module, element, or part thereof. The function may include the drafting and/or the selection of practical tasks, the performance oversight and assessment of the practical activities. Practical assessors should be:
Conversant with the DASR 66, 145 and 147 regulations, AMC, GM and specific procedures (MTOE, instructions, etc.) that are assigned to their scope of approval within a DASR 147 MTO.
Experienced and show solid judgement regarding the abilities of the assessed trainees – the assessor should have the required knowledge and experience of the task/s to be assessed. They should also be able to determine if the trainee accomplishes the tasks in compliance with current regulation, approved procedures, maintenance practices, etc.
Trained to contemporary assessment techniques. The assessor should be fully aware of the aim of the assessment and conduct a practical assessment in such a way that the true abilities of the candidate are demonstrated.
Familiar and proficient with the tools or the techniques used by the training organisation to assess the practical abilities of trainees (maintenance simulators, mock up, etc.).
Appropriately experienced in the aircraft maintenance environment.
Able to demonstrate good knowledge, complimented with communication skills in the English language.
Able to demonstrate a good understanding of the workplace environment, human performance and safety culture.
Able to demonstrate a good knowledge of technical publications (Aircraft Maintenance Manual, Component Maintenance Manual, Airworthiness Directive, Service Bulletin, Maintenance Programme, etc.).
In receipt of continuous training in company’s procedures and DASRs.
Able to act safely, apply safety precautions and prevent dangerous situations.
Able to demonstrate knowledge and understanding of areas requiring special emphasis or novelty (areas peculiar to the aircraft type, domains not covered by DASR-66 Appendix, practical training elements that cannot be imparted through simulation devices, etc.).
Able to demonstrate an understanding of the aircraft systems interaction.
Able to navigate, execute and obey the prescribed maintenance procedures.
Invigilators
8.5.3.11 A nominated person who will ensure the correct conduct of an examination in accordance with the examination procedures of the DASR 147 organisation. The invigilator is responsible for ensuring that examinations are conducted in accordance with the MTOE and Training Procedures and operates under the direction, responsibility and delegation of the Training Manager. The organisation can nominate permanent exam invigilators who should then be listed in MTOE Part 1 and qualified in accordance with Training Procedures.
8.5.3.12 Training organisations often delegate the invigilation of an examination to staff not listed as an examiner for the particular subject. These “invigilators” do not need to be qualified to the same extent as an examiner, and in particular, they do not need to demonstrate specialty knowledge, as long as their duty is strictly limited to the conduct of the examination itself.
8.5.3.13 Invigilators should however be trained to the organisation’s examination procedures with a specific emphasis on the exam’s integrity aspects and on the handling of cheating or misconduct cases. Such staff should be listed by the organisation with records of their training kept in the individual’s personnel file.
Assessment and acceptance of staff
8.5.3.14 Assessment and acceptance of instructors, examiners and assessors should be performed, and documented by the approved training organisation in accordance with dedicated procedure described in the MTOE. Appropriate staff in the maintenance training organisation should physically interview proposed candidates in order to ensure their competency. Once completed, detailed result of this assessment, including any supporting documents (diplomas, DASR 66 licence, etc.) should be filed in accordance with MTOE procedure. The staff should be listed in MTOE with intended scope of instruction, examination or assessment.
Continued qualification
8.5.3.15 The qualification criteria and experience requirements only address the initial acceptance of instructor, examiners and assessors. The training organisation should develop and document a program in MTOE to ensure the continued competence of these staff.
8.5.4.1 DASR 147.A.115 requires approved maintenance training organisations (AMTOs) to ensure that they have appropriate instructional equipment available to support their training activities. Here are some important points that must be considered when meeting this regulation:
Type of Equipment: The equipment must be appropriate for the type of training being delivered. This includes a wide range of equipment such as applicable aircraft, training aids, simulators, and computer-based training tools.
Condition: The equipment must be in good working order, and any faults or defects must be promptly rectified.
Calibration: The equipment must be calibrated as required, and records of calibration must be maintained.
Availability: The equipment must be readily available for use when required, and there must be sufficient equipment available to support the number of students being trained.
Security: The equipment must be stored securely when not in use, and access to the equipment must be controlled to prevent damage or misuse.
Maintenance: The equipment must be regularly maintained, and records of maintenance activities must be maintained.
Training Material: The equipment must be used in conjunction with appropriate training material to support effective learning.
Compliance: The equipment must comply with all relevant regulations and standards.
Training for Equipment Use: Instructors and trainers must be trained in the correct use of the equipment and any associated software or training materials.
Upgrades and Replacements: Equipment should be upgraded or replaced as necessary to ensure that it remains effective and meets current training requirements.
Aircraft Maintenance Training Aids
8.5.4.2 These are physical devices used to simulate or replicate various components or systems of an aircraft. For example, a training aid may be used to teach students how to inspect and troubleshoot an engine. Important points to consider for training aids:
The training aid must accurately represent the aircraft component or system being taught.
The training aid should be durable and long-lasting.
The training aid should be kept clean and well-maintained.
8.5.4.3 Computer-Based Training Tools: These are software applications or programs that are used to deliver training material to students. For example, a computer-based training tool may be used to teach students how to use a maintenance management system. Important points to consider for computer-based training tools:
The software should be up-to-date and compatible with the AMTO's computer hardware.
The software should be easy to use and navigate.
The AMTO should have a system for monitoring and tracking student progress.
8.5.4.4 Simulator Devices: These are devices that replicate real-world situations or scenarios to provide hands-on training to students. For example, a simulator may be used to teach students how to perform a maintenance task on an aircraft. Important points to consider for simulator devices:
The simulator should accurately represent the real-world situation or scenario being taught.
The simulator should be well-maintained and regularly calibrated.
The AMTO should have a system for monitoring and tracking student progress.
8.5.4.5 Training Videos and Audio Recordings: These are pre-recorded videos or audio recordings that are used to deliver training material to students. For example, a training video may be used to teach students about safety procedures.
8.5.4.6 Important points to consider for training videos and audio recordings:
The video or audio recording should be up-to-date and relevant to the training being provided.
The AMTO should have a system for monitoring and tracking student progress.
The AMTO should ensure that the video or audio recording is of high quality and easy to understand.
8.5.5.1 DASR 147.A.120 requires approved maintenance training organisations (AMTOs) to develop and use maintenance training material that is appropriate for the type and level of training being delivered. DASR 66 specifies requirements for both basic and type course training material. Here are some important points to consider for each Basic course training material:
The training material used for basic courses must cover a broad range of topics and must be suitable for entry-level students. The following are some important points to consider when developing or using training material for basic courses:
The training material must cover the theoretical and practical aspects of the aircraft, system, or component being taught.
The training material must be easy to understand and follow.
The training material must include practical exercises that reinforce theoretical knowledge.
The training material must be regularly reviewed and updated to ensure that it remains relevant and accurate.
The training material must be appropriate for the level of experience and education of the students being trained.
Type Course Training Material
8.5.5.2 The training material used for type courses must cover the specific make and model of the aircraft, system, or component being taught. The following are some important points to consider when developing or using training material for type courses:
The training material must cover all relevant aspects of the aircraft, system, or component, including maintenance, inspection, troubleshooting, and repair.
The training material must be regularly reviewed and updated to ensure that it remains relevant and accurate.
The training material must be appropriate for the level of experience and education of the students being trained.
8.5.5.3 Some additional important points to consider when developing or using maintenance training material include:
The training material must be structured in a logical and organized manner.
The training material must be consistent with the relevant regulations and standards.
The training material must be presented in a manner that is engaging and interesting for students.
The AMTO must have a system for tracking and monitoring the use of training material, including the progress and performance of students.
8.5.5.4 By meeting the requirements of DASR 147.A.120, AMTOs can ensure that they are providing high-quality maintenance training material that is appropriate for the level and type of training being delivered. This can help to ensure that students receive the knowledge and skills they need to perform maintenance tasks safely and effectively.
8.5.6.1 DASR 147.A.135 specifies the requirements for conducting examinations for aircraft maintenance training organisations (AMTOs) to ensure that their students have the necessary knowledge and skills to perform their maintenance duties effectively and safely. Here are some key points regarding the examination requirements:
Examination Development
8.5.6.2 The AMTO should develop examination questions that are aligned with the training objectives and outcomes. The questions should be designed to test the knowledge and skills that the student has acquired during the training program. The AMTO should also ensure that the examination questions are reviewed and approved by qualified personnel.
Examination Administration
8.5.6.3 The AMTO should have procedures in place for administering examinations. This includes ensuring that students are aware of the examination format, rules and regulations, and any special instructions that apply. The AMTO should also ensure that the examination environment is conducive to learning and that the examination is conducted in a fair and unbiased manner.
Examination Security
8.5.6.4 The AMTO should have procedures in place for ensuring the security of all the question, examinations and databanks. Particular attention should be made to the storage and transportation of the examination between venues and whilst onsite. Care must be taken to ensure the examination questions are secure at all times. Electronic means of storage may be utilised where available, providing that suitable security arrangements are in place.
Examination Grading
8.5.6.5 The AMTO should have procedures in place for grading and evaluating examination results. The grading procedures should be fair, consistent, and transparent, and should be based on established criteria. The AMTO should also ensure that examination results are communicated to students in a timely manner and that students have access to feedback on their performance.
Examination Records
8.5.6.6 The AMTO should maintain records of examination results, including the student's performance and any relevant feedback. These records should be kept in a secure location and retained for a specified period of time in accordance with regulatory requirements (e.g. Annex A to AMC 147.A.125)
Examination Review
8.5.6.7 The AMTO should have procedures in place for reviewing and evaluating examination results to identify any areas where improvements can be made. This includes analysing trends in examination results, identifying areas where students are struggling, and taking corrective actions to improve the effectiveness of the training program.
8.5.6.8 In summary, the examination requirements outlined in DASR 147.A.135 are designed to ensure that the AMTO's training program is effective and that students have the necessary knowledge and skills to perform their maintenance duties safely and effectively. By following these requirements, the AMTO can maintain a high standard of training and contribute to the overall safety of the aviation industry.
8.5.7.1 DASR 147.A.130 requires Aircraft Maintenance Training Organizations (AMTOs) to establish and maintain effective training procedures and a quality system to ensure that their training programs are of a high standard and meet the requirements of all applicable regulations and standards including DASRs. Some important points to be considered when developing or maintaining training procedures and a quality system are:
Training Procedures
8.5.7.2 The training procedures must include a description of the training program, including the objectives, scope, and content of the training. This should include the methods and materials used for training, the sequencing of the training, and the assessments used to measure the effectiveness of the training.
Courseware
8.5.7.3 The AMTO should have a system in place to develop, review, and update courseware, including lesson plans, training manuals, visual aids, and other materials used for training. The courseware should be reviewed and updated regularly to ensure that it remains relevant and effective.
Instructor Qualifications and Training
8.5.7.4 The AMTO should have procedures in place to ensure that their instructors are qualified and competent to deliver the training. This includes requirements for instructor qualifications and training, such as experience in the industry, knowledge of the subject matter, and teaching skills. The AMTO should also have a system in place to regularly assess the performance of their instructors and provide them with feedback / training as necessary.
Assessment Procedures
8.5.7.5 The AMTO should have a system in place to assess the effectiveness of their training, including the use of assessments and evaluations to measure the knowledge and skills of the students. The assessments should be designed to provide a fair and accurate measure of the student's performance, and be reviewed and updated regularly to ensure that they remain valid and reliable.
Quality System
8.5.7.6 The AMTO should have a quality system in place to ensure that their training program meets the requirements of DASRs and any other applicable regulations and standards. This includes procedures for monitoring and evaluating the effectiveness of the training by identifying, correcting and preventing recurrence of any deficiencies and continuously improving the training program.
8.5.7.7 Some additional important points to consider when developing or maintaining training procedures and a quality system include:
The AMTO should ensure that all training is conducted in a safe and secure environment, and that appropriate safety procedures are followed at all times.
The AMTO should ensure that their training programs are accessible to all students and meet their needs.
The AMTO should ensure that all training is conducted in accordance with relevant laws and regulations including those related to privacy and data protection.
The AMTO should ensure that all training is conducted in a professional and ethical manner, and that all students are treated fairly and with respect.
Quality Policy
8.5.7.8 The AMTO should have a quality policy that outlines the organisation's commitment to quality and its goals for maintaining a high standard of training. The policy should be communicated to all staff and stakeholders, and reviewed and updated regularly.
Quality Objectives
8.5.7.9 The AMTO should establish quality objectives that are measurable and aligned with the goals of the organisation. The objectives should be reviewed and updated regularly, and progress towards meeting the objectives should be monitored.
Document Control
8.5.7.10 The AMTO should have a system in place to manage and control documents related to training procedures and the quality system. This includes procedures for document creation, control, review, approval, distribution and revision.
Record Keeping
8.5.7.11 The AMTO should maintain records related to the training programs and the quality system, including records of student performance, instructor qualifications, audit results, corrective actions taken, and other relevant information.
Records of Students
8.5.7.12 DASR 147.A.125 requires approved maintenance training organisations (AMTOs) to maintain accurate and complete records of their students. These records must include a variety of information to demonstrate that the student has successfully completed the required training and has the necessary knowledge and skills to perform maintenance tasks safely and effectively. Here are some important points to consider when developing or maintaining student records:
Student Identification: The record must include the student's full name, date of birth, contact information, and any relevant identification numbers or codes.
Training History: The record must include a detailed history of the student's training, including the courses they have completed, the date of completion, and the grade they received. This information should also include any remedial training or retesting that was required.
Assessment Records: The record must include documentation of any assessments or examinations the student has completed, including the results and any feedback or comments provided by the examiner.
Attendance and Absences: The record must include information on the student's attendance and any absences from training, including the reason for the absence and any make-up training that was required.
Certification: The record must include information on any certifications the student has received as a result of their training, including the type of certification, the date it was issued, and any restrictions or limitations.
Other Relevant Information: The record should also include any other relevant information about the student, such as their prior education or experience in the field of maintenance, any disciplinary actions taken, or any other notable achievements or accomplishments.
Some additional important points to consider when developing or maintaining student records include:
The record must be maintained in a secure and confidential manner to protect the privacy of the student.
The record must be accurate, complete, and up-to-date at all times.
The record must be available for review by relevant authorities, such as regulatory agencies or potential employers.
The AMTO must have a system in place to ensure that student records are regularly reviewed and updated as necessary.
8.5.7.13 By meeting the requirements of DASR 147.A.125, AMTOs can ensure that they are maintaining accurate and complete records of their students, which can help to demonstrate that the students have received the necessary training and are qualified to perform maintenance tasks safely and effectively.
Corrective and Preventive Actions
8.5.7.14 The AMTO should have a system in place to identify and address non-conformities or areas where the procedures and system can be improved. This includes procedures for taking corrective and preventive actions to avoid recurrence including causal or root cause analysis, tracking and monitoring the effectiveness of the actions taken, and documenting the results.
Management Review
8.5.7.15 The AMTO should conduct regular management reviews of the training procedures and quality system to ensure that they are effective and meeting the goals of the organisation. The management review should include a review of audit results, quality objectives, corrective and preventive actions, and other relevant information.
Audit Procedures
8.5.7.16 Auditing is an important part of ensuring that the training procedures and quality system of the AMTO are effective and meeting the requirements of the applicable regulations. Audits should be conducted by an independent auditor, who can be an internal auditor or an external auditor.
Internal Auditing
8.5.7.17 The AMTO should conduct internal audits of their training procedures and quality system on a regular basis to ensure that all aspects of DASR 147 compliance are checked at least once in every 12 months and may be carried out as one complete single exercise or subdivided over a 12-month period in accordance with a scheduled plan. The purpose of internal audits is to identify any non-conformities or areas where the procedures and system can be improved. The results of the internal audits should be documented and corrective actions should be taken to address any non-conformities.
External Auditing
8.5.7.19 The AMTO should also undergo external audits by an independent auditor, who is not part of the AMTO organisation. The purpose of external audits is to ensure that the training procedures and quality system of the AMTO are in compliance with the requirements of the regulation. The results of the external audits should be documented, and any corrective and preventive actions that need to be taken should be identified and addressed.
8.5.7.20 By meeting the requirements of DASR 147.A.130, AMTOs can ensure that their training programs are of a high standard and meet the requirements of the regulation, which can help to ensure the safety and effectiveness of maintenance operations in the aviation industry.
Introduction
8.5.8.1 Military Aircraft Type Rating Training consists of theory and examination, practical and assessment, plus On-the-Job Training (OJT) – see DASR 66.A.45(c) – for first aircraft in licence category/subcategory. Any subsequent Military Aircraft Type Rating (MATR) within the same category/sub-category require both theory and practical elements but will only require further OJT if stipulated by DASA during the approval of the course.
Note: A minimum of only theory and examination is required for the Category C Military Aircraft Maintenance Licence (MAML) rating (AMC 66.A.45).
Figure 1: Military Aircraft Type Rating (MATR) - Required Elements
Privileges
8.5.8.2 In order to be entitled to exercise certification privileges for B and C categories on a specific aircraft type, the holder of a MAML shall have their MAML endorsed with the relevant Military Aircraft Type Ratings and technologies, these technologies may be sub-divided in airframe and/or power-plant and/or avionics/electrical systems type training courses.
8.5.8.3 Type training for military specific systems (and their interfaces with other aircraft systems) may be included in these sub-divisions as appropriate, or carried out as a separate course and shall have been started and completed within the 3 years preceding the application for a type rating endorsement.
8.5.8.4 Holding a MAML with the relevant MATR does not mean by itself that the holder is qualified to be authorised as certifying staff and/or support staff. The DASA 145 maintenance organisation is responsible to assess the individual for:
scope of privileges within the MAML;
relevant MATR training;
currency of MAML IAW DASR 66.A.20;
any OJT requirements; and
appropriate authorisations.
ADF Course Design and Development
8.5.8.5 To ensure consistency across all ADF courses, the design and development of courses, including the course curriculum, should follow the System Approach to Defence Learning (SADL) – see SADL Website.
MATR Course – Initial Approval / Change Management
8.5.8.6 In order to facilitate formal administrative approval by the authority, the following relevant DASR Forms are to be completed and submitted as appropriate;
DASR Form 12 - Application for DASR 147 Initial-Changes of Approval. The DASR Form 12 is the official DASA form to apply for a DASR 147 Maintenance Training Organisation approval. This form is considered part of an application pack and should be submitted with the appropriate evidence as detailed within the form to support the application.
DASR Form 12A - Military Aircraft Type Rating Initial/Change Course Approval. The DASR Form 12A is to accompany the DASR Form 12 when the application is for an initial course approval. For an update to an existing approved course, only the completed Form 12A and associated evidence documents are required for submission.
8.5.8.7 As a minimum standard, the following documents must be submitted as evidence for MATR courseware approval;
Training Needs Analysis (TNA) or equivalent as accepted by DASA
Completed DASR 66 Appendix III MATR Courseware Assessment Matrix
MATR Theory Element (Learning Management Plan)
MATR Practical Element (Practical Training Logbooks)
On-The-Job-Training (OJT) logbook.
DASA Notification Requirements
8.5.8.8 Changes to MATR Courses shall be defined as either a Major or Minor Change.
8.5.8.9 A Major Change is any amendment, alteration or change to a MATR Course that is not accurately categorised as a Minor Change within the relevant Maintenance Training Organisation (MTO) Exposition procedure. A DASR Form 12A - Military Aircraft Type Rating Initial/Change Course Approval must be submitted and approved prior to any Major Change to a MATR Course.
8.5.8.10 A Minor Change is any amendment, alteration or change to a MATR Course that does not affect the DASR related approval. Minor Changes may be acceptable to DASA without prior approval by the Authority; contingent to endorsement by the relevant MTO QMS that no adverse material effect is posed to safety, quality of training or the knowledge, skills and attitudes of course graduates, course learning outcomes or location.
8.5.8.11 An internally reportable process for approval of Minor Changes to MATR Courseware must be included within the relevant MTO Exposition/Annex; containing either a specific predefined listing of all actions, or defining statement considered by the MTO to fall within the scope of a ‘Minor Change’.
8.5.8.12 Subject to the endorsement of the MTO QMS, listed actions could include (but are not limited to);
Grammatical and typographic changes
Changes that incorporate updates from the relevant platform specific technical publications (e.g. updated maintenance procedures, configuration changes etc.)
Changes of content (provided the learning outcomes are not affected).
Theoretical Element of the Military Aircraft Type Rating Training
8.5.8.13 The theoretical element of the Type Course shall provide the person with detailed theoretical knowledge of the applicable systems, structure, operations, maintenance, repair, and troubleshooting of the aircraft type according to the approved maintenance data, including;
The appropriate use of manuals and approved procedures, including any relevant inspections and limitations;
How to perform system, power-plant and component functional checks as specified in the maintenance manual;
Related information for the purpose of making decisions in respect of fault diagnosis and rectification within the scope of the maintenance manual;
Describing procedures for replacement of components unique to the aircraft.
8.5.8.14 Theory training shall be conducted by an appropriately approved DASA 147 MTO or an organisation recognised by DASA.
8.5.8.15 In the case of a Category C person qualified by holding an academic degree as specified in DASR 66.A.30(a)(5), the first relevant aircraft type theoretical training shall be at the Category B1 or B2 level or at a level recognised by DASA.
8.5.8.16 Theory training shall have been started and completed within the 3 years preceding the application for a MATR endorsement.
8.5.8.17 The minimum pass mark for the theoretical exam is 75%.
8.5.8.18 The theoretical type training shall describe how the type training is delivered (i.e. classrooms, training equipment, instructors qualifications, TNA etc.) meeting the requirements of DASR 66 and 147, as appropriate.
8.5.8.19 The course content and duration shall be demonstrated by:
a detailed curriculum showing the levels for each chapter of the type training, which should be assessed for equivalence to Appendix III to DASR 66 for the relevant certifying staff category; and
verifying that both content and duration are justified through a comprehensive TNA (or equivalent as accepted by DASA).
8.5.8.20 Evidence is required for the following elements:
the teaching methods and instructional equipment;
the material and documentation provided to the student;
the qualification of instructors, examiners;
the documentation and records provided to the student to justify the satisfactory completion of the training course and related assessment.
Note: For further information about these elements, refer to the MTO exposition.
Practical Element of the Military Aircraft Type Rating Training
8.5.8.21 Practical training is a structured training activity that consolidates the knowledge gained during the theoretical phase of type training and as such, may be performed after or integrated within the theory training. Practical training should:
Address the different parts of the aircraft and its associated engines, which are representative of the structure, the systems/components installed and the cabin.
Include the use of technical manuals, maintenance procedures and the operational interfaces with the aircraft (e.g. FMC, electronic flight bag, etc.)
Include common maintenance and ground handling activities.
Cover both type specific and generic safety elements of the aircraft’s maintenance.
Develop the student’s competence in performing safe maintenance, prior to the practical assessment.
8.5.8.22 The purpose of practical training is not to include all the maintenance tasks associated with a particular type, but a representative sample of them that will allow the student to acquire the required knowledge, attitude and skills to safely carry out maintenance on that type.
8.5.8.23 The practical element of the MATR Training can be performed concurrently with the OJT element if both are performed on the same military aircraft type and in a real maintenance environment.
8.5.8.24 Practical training may be performed either following or integrated with the theoretical elements however, it should not be performed before theoretical training.
8.5.8.25 Where objective evidence can be provided; DASA may accept elements of practical and/or OJT experience gained on civil variants of state aircraft e.g. Boeing 737 for a P-8A Poseidon or E-7A Wedgetail MAML endorsement, provided the completed application also includes evidence of any additional ‘differences training’ for the Military type variant.
8.5.8.26 Table 1 summarises the MATR Training requirements contained in DASR 66.A.45, and Appendix III to DASR 66.
Table 1: Military Aircraft Type Rating Training requirements
8.5.8.27 The practical training may include instruction in a classroom or in simulators but part of the practical training should be conducted in a DASA 145 maintenance organisation or manufacturer environment (recognised by DASA).
8.5.8.28 Selected tasks should consist of a group of representative maintenance tasks drawn from the type training and examination curriculum, at the indicated level and shall cover all the relevant chapters described in the table contained in paragraph 3.2 of Appendix III to DASR 66.
8.5.8.29 The task curriculum must:
Be distributed in order to cover all applicable S1000D chapters.
Include all of the task categories (LOC, FOT, SGH, R/I, MEL, TS - Refer table below) and may include others deemed appropriate to the type (e.g. ‘INS’pection, ‘ADJ’ustment).
Include an appropriate number of tasks in each task category for the aircraft type’s training requirements to be met.
Be sufficient to cover at least 50% of the crossed tasks in Appendix III to DASR 66 para 3.2. (Refer to “How should the 50% of tasks required for practical training be selected?” below).
Note: for further information on the S100D Specification refer to the following links on the DASA website. S1000D - International specification for technical publications.
8.5.8.30 The duration of the practical training should ensure that the content of training required by paragraph 3.2 of Appendix III to DASR 66 is completed.
8.5.8.31 A record of the tasks completed should be entered into a logbook which should be designed such that each task or group of tasks may be countersigned by the designated assessor. The logbook format and its use should be clearly defined.
8.5.8.32 The practical element (for power-plant and avionics systems, armaments, escape systems and other relevant military-specific systems) of the MATR Training may be subcontracted by the approved DASA 147 organisation under its quality system according to the provisions of DASR 147.A.145(d)3 and the corresponding Guidance Material.
How should the 50% of tasks required for practical training be selected?
8.5.8.33 When selecting the tasks, the usage of a filtering method based on the criteria similar to that described in AMC to paragraph 3.1(d) of Appendix III to DASR 66, point 5f) is recommended.
8.5.8.34 The selection of 50% of tasks cannot be selected according to the glossary only (e.g. LOC, FOT, SGH, R/I, etc.);
Paragraph 3.2 of Appendix III to DASR 666 states that ‘the tasks selected shall be representative of the aircraft and systems both in complexity and diversity’. In addition, the practical training should particularly address the tasks which cannot be explained by theoretical training only. While relatively simple tasks may be included, other more complex tasks shall also be incorporated and completed as appropriate to the aircraft type.
How each task is selected (LOC, SGH, etc.), should be based upon the potential gains for the students’ competency or its impact on safety. Availability should not be a reason to omit a pertinent task and consideration should be made to mix ‘actual hands on’ and ‘task simulation’ to complete an important or critical learning objective.
All pertinent sub-tasks, associated with the safe completion of each main task, such as Isolating mechanical/electrical systems, opening/closing CBs, locking flight controls, etc., should be included and the applicable aircraft maintenance manuals used.
Regarding the way to read the table in paragraph 3.2, each line aims to cover each of the main systems so that no line relevant to the particular aircraft type should be omitted in the selection. Inside each line applicable to the aircraft type, half or more of the crosses can be selected. From a learning point of view, selecting 2 simple tasks as LOC and SGH would not be “representative”, while selecting LOC and TS, for example, would be much more appropriate of the aircraft and systems both in complexity and diversity.
The intent of the following tables are to provide a compliance report demonstrating that the practical type training meets the standard required by Appendix III to DASR 666. In particular, the tables shall indicate the percentage of tasks effectively performed against the tasks contained in the Appendix III to DASR 66 which are applicable to the aircraft type.
8.5.8.35 The following tables have been developed as an effective format for assessment of MATR practical courseware elements; in order to facilitate formal administrative approval of courseware by the authority, these must be completed by the MTO delivering the MATR practical type training.
8.5.8.36 A template for MATR courseware assessment (including the tables below) can be found at the following link:
DASR 66 Appendix III MATR Courseware Assessment Matrix
Percentage by Task Type
|
Type of task |
Number of tasks applicable to the A/C type |
Total number of tasks selected |
Percentage (%) effectively performed against applicable tasks (should be at least 50% of the applicable tasks) |
|
LOC |
|
|
|
|
FOT |
|
|
|
|
SGH |
|
|
|
|
R/I |
|
|
|
|
MEL |
|
|
|
|
TS |
|
|
|
Table 2 – Practical Task Training Requirements (By Task Type)
Glossary of the table: LOC: Location; FOT: Functional/Operational Test; SGH: Service and Ground Handling; R/I: Removal/Installation; MEL: Minimum Equipment List; TS: Trouble-Shooting.
Percentage by Module
|
Module |
Number of tasks applicable to the A/C type |
Total number of tasks selected |
Percentage (%) effectively performed against applicable Tasks (should be at least 50% of the applicable tasks within each Module) |
|
Introduction Module |
|
|
|
|
Helicopters |
|
|
|
|
Airframe Structures |
|
|
|
|
….. |
|
|
|
|
Military-Specific Systems |
|
|
|
Table 3:Practical Task Training Requirements (By Module)
Practical Training Logbook
8.5.8.37 A Military Aircraft Type specific Practical Training Logbook (PTL) must be developed by a DASA 147 MTO, completed by the student and a certified true copy retained by the MTO delivering the training. It will record the training activities carried out during the practical training course and the subsequent assessment of trainee competence.
8.5.8.38 The PTL shall list all of the applicable S1000D systems, as specified within Appendix III to DASR 66, Section 3.2.
8.5.8.39 After the practical element of the MATR Training has been completed, an assessment must be performed, which must comply with the following:
The assessment shall be performed by designated assessors appropriately qualified (AMC to Appendix III).
The assessment shall evaluate the knowledge and skills of the trainee.
8.5.8.40 The PTL should include:
Trainee attendance sheet.
Course and Instructor’s details.
S1000D system number and title.
Aircraft Maintenance Manual or work-pack reference for each training task.
A list and detailed description of the training tasks.
Each task must have a method of denoting the training technique (Synthetic, Aircraft registration, Classroom, etc.).
Task type (R/I, LOC, SGH etc.).
Date of each individual task completion.
Instructor signatures or stamps.
Spare entries for documenting additional/replacement “ad hoc” training tasks.
Note: Additional/replacement tasks must be of relevance to those they replace, be of benefit to the training objective and only replace planned tasks in exceptional circumstances.
8.5.8.41 EASA provide Practical type training logbook examples for both B1 and B2 PTL that can be used for guidance.
Practical Instructors and Assessors
8.5.8.42 In the majority of cases, the Practical instructor will be the same as that used for the Theory phase of the type training. They are a logical choice, as they possess an in-depth knowledge of the aircraft’s systems and will have developed an understanding of each student’s specific academic requirements.
8.5.8.43 Using the same instructor for both the Theory and Practical phases will often suit the business model of many organisations. In some cases, however, especially where a DASA 147 / DASA 145 affiliation exists, the organisation may choose to utilise experienced MAML holders from their own maintenance workforce to deliver the Practical training.
8.5.8.44 These individuals must be given suitable training on the organisational processes involved, particularly the use of the Practical training record. It is recommended that they attended a train the trainer course, whether delivered by an external or internal source, which should specifically target the training techniques required for Practical training and set the organisation’s bench mark for the conduct of this training. They should be familiar with the tools or the techniques used by the training organisation to assess the competence of the practical abilities of trainees (maintenance simulators, mock up and etc.).
8.5.8.45 They should be experienced and show solid judgement regarding the abilities of the assessed trainees, they must have the required knowledge and experience of the task/s to be assessed. They should also be able to determine if the trainee accomplishes the tasks IAW current regulation, utilising approved procedures, maintenance practices etc. They should be fully aware of the aim of the assessment and conduct a practical assessment in such a way that the true abilities of the candidate are demonstrated to maintain the system.
8.5.8.46 Workforce sourced Instructors will be qualified and managed by the DASA 147 organisation. Refer to DASR 147.A.105 for details.
8.5.8.47 They must be included in the list Instructional staff (point 1.5 of the MTOE) and be subject to the same Instructor records and update training requirements as the directly employed Instructors.
8.5.8.48 Practical assessments may be conducted by either the Practical Instructor or a dedicated assessor, who has undergone a similar training and qualification process to that detailed above.
8.5.8.49 Upon completion of the PTL, it must be reviewed, assessed and approved by the relevant DASA 147 in its entirety.
OJT Element of the Military Aircraft Type Rating
8.5.8.50 OJT is required for the initial type rating being sought in each licence category or sub-category:
8.5.8.51 For example; If a B1.1/B2 MAML is endorsed with the P-8A type in the B1.1 category and the MAML holder wishes to add the P-8A in the B2 category, he/she will have to complete B2 related OJT representative of that aircraft and its systems.
8.5.8.52 If the same B1.1 MAML holder adds the B1.3 category to their MAML, and wishes to add their first helicopter type, he/she must complete OJT representative of that first helicopter type. Any subsequent MATR within the same category/sub-category will only require further OJT if stipulated by DASA during the approval of the course.
8.5.8.53 A DASA 145 maintenance organisation appropriately approved for the maintenance of the particular aircraft type can conduct OJT for that type rating;
The OJT content shall be approved by DASA (Appendix III to DASR 66, sec. 6) and supported by a detailed curriculum showing its content and recorded within detailed worksheets/logbook;
OJT tasks shall be signed off by the student and countersigned by a ‘designated supervisor’;
Final assessment of OJT is mandatory and shall be performed by a ‘designated assessor’;
It can be carried out in an approved DASA 145 maintenance organisation with a Category A rating (maintenance on aircraft) and the procedures for OJT should be included in the exposition (MOE chapter 3.15 “OJT procedure”) approved by DASA.
Where objective evidence can be provided; DASA may accept elements of practical and/or OJT experience gained on civil variants of state aircraft e.g. Boeing 737 for a P-8A Poseidon or E-7A Wedgetail MAML endorsement, provided the completed application also includes evidence of any additional ‘differences training’ for the Military type variant.
8.5.8.54 The OJT should include a sufficient number of tasks that are carried out under ‘one to one’ supervision (i.e. one supervisor dedicated to one trainee) and should involve actual work task performance on aircraft/components, covering line and/or base maintenance tasks.
8.5.8.55 AMC to Appendix II to DASR 66 contains a list of tasks, from which a representative sample appropriate to the type and licence (sub-) category applied for, should be extracted and approved by the MAA. The OJT should cover at least 50% of this approved extracted list.
8.5.8.56 Up to 50% of the required OJT may be undertaken before the aircraft theoretical MATR Training starts, noting that:
the ADF Initial Employment Training (IET) workplace journals are the primary means of meeting the practical requirements for the Defence Registered Training Organisation issuance of selected MEA Unit of Competency;
portions of these workplace journals may also be utilised as a means of meeting the requirements of OJT, as long as they are completed in a DASA 145, and on the platform/components which the individual is completing their Type Rating training (Appendix III to DASR 66, para 6).
8.5.8.57 If these journal tasks are not carried out on the aircraft type (or its components) required for their subcategory, then these tasks cannot be constituted as OJT.
8.5.8.58 As a minimum, the OJT procedure should describe the following elements:
Content of the OJT: the list of tasks that should be performed during the OJT or a list of generic tasks and the process how to develop a list of particular tasks out of this list of generic tasks,
Qualifications of the assessor and supervisors performing the OJT,
OJT logbook/worksheets format and content,
OJT compliance report format and content,
Production planning for the implementation of OJT (how to plan the tasks),
Supervision process and the assessment process, what to do if the assessment is not positive,
Safe release to service of the aircraft after OJT,
OJT Log Book final assessment process and associated forms:
An OJT Logbook assessment is carried out on an OJT Logbook to ensure that all required tasks have been carried out and certified for in accordance with the OJT Logbook assessment procedure.
MTOE procedure and associated documents should contain a procedure for the final assessment of an OJT Logbook and who it is completed as well as any associated forms needed and who is qualified to carry out such assessment.
Note: AMC to Section 6. of Appendix III to DASR-66 should be used when defining the content of the procedure.
Practical Assessment Vs On the Job Training (OJT) for Military Aircraft Type Ratings
8.5.8.59 The objective of OJT is to gain the required competence and experience in performing safe, effective and efficient maintenance. The practical assessment addresses the practical portion of any type training, whereas the OJT assessment addresses the additional hands-on experience necessary in a true maintenance environment as part of the first type rating in a (sub)category, as illustrated by the table below:
Table 4 – Practical Assessment Vs On the Job Training
Practical DASR 147 MILITARY AIRCRAFT TYPE TRAINING LEVELS VS SERVICE LEARNING LEVELS
The following table provides guidance on the correlation between the DASR Military Aircraft Type Training levels (TL), Air Force (MAFET) Learning Levels (LL), Army (ATI 1-3/20), SADL TLs and Navy LLs;
Table 5 - SADL Training Level Descriptions