EASA Comment-Response Document to ToR RMT.0252 (MDM.056) Instructions for continuing airworthiness Issue 4 after RAG/TAG and SSCC consultation

Size: px

Start display at page:

Download "EASA Comment-Response Document to ToR RMT.0252 (MDM.056) Instructions for continuing airworthiness Issue 4 after RAG/TAG and SSCC consultation"

Alexander Booker
9 years ago
Views:

1 01 Ms J. Barry on behalf of UK P&M TAG Member 02 Mr F. Meier SVFB/SAMA/ASEA Member of the Board of ECOGAS acting SSCC member Thank you for the opportunity to comment on the draft TOR Issue 4 for the above rulemaking task and nominate specialists. The UK CAA do not have any comments on the TOR. On behalf of ECOGAS I send you the comments to the said RMT MDM.056 ICA's. ECOGAS, European Council of General & Business- Aviation Support RMT.0252 'Instructions for continuing airworthiness' Draft ICA's may help to avoid accidents, as mentioned in mdm.056 issue 3. (attached) ECOGAS comments in reference to ToR RMT.0252 issue 4: Quote: "The consequence is that parts of this data may not be sufficiently controlled by design approval holders and that maintenance organisations may not have all the necessary data to perform the maintenance in the correct way, which can lead to using unapproved methods, unapproved or wrong parts, or standard practices where not appropriate" Endquote. We have principal objections for this RMT: it should only be promoted with the following The Agency evaluated during the Pre-RIA (issued in 2009) the need of a rulemaking task. The accident mentioned in the ToR was taken into account as it was addressed to the Agency. The Agency does not agree with your comment that one accident is not enough for taking action. Not only the conclusion at the time of the Pre- RIA, but also the high participation from various stakeholders, Member States and competent authorities confirms the common understanding of a need to clarify the rule and responsibilities, and to allow higher harmonisation with other regulatory systems when possible. Regarding the economic impact, this is one of the aspects that will be taken into consideration when the NPA is issued. Consequently, the Agency does not agree that this rulemaking task must be abandoned. Page 1 of 5

The UK CAA do not have any comments on the TOR. On behalf of ECOGAS I send you the comments to the said RMT.0252 - MDM.056 ICA's. ECOGAS, European Council of General & Business- Aviation Support RMT.

2 limitations respectively: in order for rule(s)making to become performance driven and risk based, any rulemaking must be data driven. However, in the draft ToR for RMT.0252 there is only one accident cited on page 3 of 7. "1 Refer to Air Accidents Investigation Branch (AAIB) accident investigation report EW/C2007/04/02 published in AAIB Bulletin 6/2008 on 12 June 2008 accident to Piper PA- 28R-201T G-JMTT on 09 April 2007" Here is the link: _2008/piper_pa_28r_201t_turbo_cherokee_arrow_ iii g_jmtt.cfm 1) The idea to organise the maintenance data in such a manner by the TC holder, that the owner, the operator, the MRO have all data easy and understandably at their disposition, is fully supported. Concerning eventual changes in Part 145 and Part M we request: 2) Any rule making must be data driven. 2.1) there is not enough evidence shown, to add new rules in this case. Page 2 of 5

"1 Refer to Air Accidents Investigation Branch (AAIB) accident investigation report EW/C2007/04/02 published in AAIB Bulletin 6/2008 on 12 June 2008 accident to Piper PA- 28R-201T G-JMTT on 09 April

3 3) The economical impact of the rulemaking must be fully transparent and the consequences understood. 3.1) they must be accepted by the stakeholders 3.2) in cases where the risk assessment shows that there is no impact on the relative risk, through probability or outcome, then the rulemaking should not be amended and in fact should be actively discouraged, as it will only incur additional economic costs to both EASA and industry. 3.3) In the example shown where the accident was highly regrettable, there were already existing regulations which should have been applied. Adding further processes would not improve such examples (ref to roadmap of GA)..> 3.4) unless the new rule will have a demonstrated positive effect by 3.4a) making present affected rulemaking better, that means more user friendly AND 3.4b) reduces volume of legal code Therefore, ECOGAS proposes to abandon this tasks unless it is limited to CAT AND aircraft >5.7 T in the first step. Only If the resulting, improved rules will have a demonstrated positive economical effect as well and apart from the expected safety effect, it may be extended for other categories. ECOGAS fm Page 3 of 5

discouraged, as it will only incur additional economic costs to both EASA and industry. 3.

4 03 Mr M. Chatterton Rolls-Royce plc (SSCC Member) Dear Sir/Madam, please find: 2) Comments on the subject amended draft ToR (below): a) As indicated in the ToR, a number of issues raised within the original rulemaking group have been put to one side, to be addressed at a later date while the issues were not common concerns between EASA and the FAA/TCCA, several points important to industry were included, and particularly the question of the approval of maintenance information (whether ICA or not) and the use of DOA privilege. These items are linked to the ICA question and were identified by EU members of the original MDM 056 group as causing significant confusion, concern, and lack of consistency from EASA and NAAs. It is proposed that these issues should be retained in MDM 056, with a separate subtask, which is not required to be harmonised. b) It is important to recognise that the subtasks are linked, and as such should not be pursued separately from each other. As the composition/expertise of each subtask group is listed in the ToR, it is not clear whether the subtasks are intended to be populated with different people. To retain the links between the subtasks, it is proposed that, if they are able, group members are allowed to participate in more than one subtask group. c) While the link between ICA and MRB activity is clearly relevant, the items 3, 4 and 5 under subtask 3 related to the recognition of engines and propellers, and the introduction of changes/ The Agency acknowledges the need to address the rest of the issues previously discussed within the former working group, although they are not relevant from a harmonisation point of view. Unfortunately, not all the identified concerns can be addressed at the same time due to workload reasons. The Agency agrees on the link between different subtasks although each subtask will address the objective to use more specific expertise to be more effective and provide a quicker deliverable. It does not preclude a group member from being invited to more than one subtask. The efficiency and completeness of the MRB process while referring to ICAs are considered relevant to the task. Page 4 of 5

rulemaking group have been put to one side, to be addressed at a later date while the issues were not common concerns between EASA and the FAA/TCCA, several points important to industry were

5 modifications during the MRB process do not appear relevant to the relationship between ICA and MRB, but seem to relate to the efficiency and completeness of the MRB process itself. I propose these three items are removed. d) It is also not clear why in the Process Map, subtask 3 is not a Group task. The Agency will make use of the work done by the first MDM.056 working group. e) In the Status Report for MDM.056 (Document No12D54544) a definition of ICA was given, with the message that this would not be reviewed any further, yet subtask 1 covers the definition of ICA. Is this a contradiction? The definition of ICA will be discussed again, but the starting point is the one already mentioned in the Status Report. 04 Mr 0 F. Graser Austria (RAG member) 05 Mr 0 M. Nemecek Slovak CAA (RAG member) 06 Ms C. Gathier (SSCC Member) Dear All, please be informed that Austria supports the subject RMT Slovak CAA has no comments to amended ToR RMT.0252 (MDM.056) We have no comment to formulate regarding the ToR. Note: The final ToR and Group Composition are available on the EASA website under: Page 5 of 5

e) In the Status Report for MDM.056 (Document No12D54544) a definition of ICA was given, with the message that this would not be reviewed any further, yet subtask 1 covers the definition of ICA.

GC M.029 (RMT.0217) and RMT.0546. Issue 1

ToR M.029 (RMT.0217) and RMT.0546 Issue 1 Description: Language: Group Composition: ToR M.029 (RMT.0217) and RMT.0546 Issue 1 English GC M.029 (RMT.0217) and RMT.0546 Issue 1 ToR number: 029/0546 ToR Series: