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Easy Access Rules for Continuing Airworthiness Annex I (Part-M)

(Regulation (EU) No 1321/2014)


SECTION A — TECHNICAL
REQUIREMENTS

AMC M.A.402(g) Performance of maintenance


ED Decision 2016/011/R

(a) To minimise the risk of multiple errors and to prevent omissions, the person or organisation
performing maintenance should ensure that:
(1) every maintenance task is signed off only after completion;
(2) the grouping of tasks for the purpose of sign-off allows critical steps to be clearly
identified; and
(3) any work performed by personnel under supervision (i.e. temporary staff, trainees) is
checked and signed off by an authorised person.
(b) To minimise the possibility of an error being repeated in identical tasks that involve
removal/installation or assembly/disassembly of several components of the same type fitted to
more than one system, whose failure could have an impact on safety, the person or organisation
performing maintenance should plan different persons to perform identical tasks in different
systems. However, when only one person is available, then this person should perform
reinspection of the tasks as described in AMC2 M.A.402(h).

AMC1 M.A.402(h) Performance of maintenance


ED Decision 2016/011/R

CRITICAL MAINTENANCE TASKS


The following maintenance tasks should primarily be reviewed to assess their impact on safety:
(a) tasks that may affect the control of the aircraft, flight path and attitude, such as installation,
rigging and adjustments of flight controls;
(b) aircraft stability control systems (autopilot, fuel transfer);
(c) tasks that may affect the propulsive force of the aircraft, including installation of aircraft
engines, propellers and rotors; and
(d) overhaul, calibration or rigging of engines, propellers, transmissions and gearboxes.

AMC2 M.A.402(h) Performance of maintenance


ED Decision 2016/011/R

INDEPENDENT INSPECTION
(a) What is an independent inspection
Independent inspection is one possible error-capturing method. It consists of an inspection
performed by an ‘independent qualified person’ of a task carried out by an ‘authorised person’,
taking into account that:
(1) the ‘authorised person’ is the person who performs the task or supervises the task and
assumes the full responsibility for the completion of the task in accordance with the
applicable maintenance data;
(2) the ‘independent qualified person’ is the person who performs the independent
inspection and attests the satisfactory completion of the task and that no deficiencies
have been found. The ‘independent qualified person’ does not issue a certificate of
release to service, therefore he/she is not required to hold certification privileges;

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Easy Access Rules for Continuing Airworthiness Annex I (Part-M)
(Regulation (EU) No 1321/2014)
SECTION A — TECHNICAL
REQUIREMENTS

(3) the certificate of release to service is issued by the ‘authorised person’ after the
independent inspection has been carried out satisfactorily;
(4) the work card system should record the identification of each person, the date and the
details of the independent inspection, as necessary, before the certificate of release to
service is issued.
(b) Qualifications of personnel performing independent inspections
(1) When the work is performed by a Part-M Subpart F organisation, then the organisation
should have procedures to demonstrate that the ‘independent qualified person’ has been
trained and has gained experience in the specific control systems to be inspected. This
training and experience could be demonstrated, for example, by:
(i) holding a Part-66 licence in the same subcategory as the licence subcategory or
equivalent necessary to release or sign off the critical maintenance task;
(ii) holding a Part-66 licence in the same category and specific training in the task to
be inspected; or
(iii) having received appropriate training and having gained relevant experience in the
specific task to be inspected.
(2) When the work is performed outside a Part-M Subpart F organisation:
(i) the ‘independent qualified person’ should hold:
(A) a Part-66 licence in any category or an equivalent national qualification
when national regulations apply; or
(B) a valid pilot licence for the aircraft type issued in accordance with European
Union regulations or an equivalent national qualification when national
regulations apply;
(ii) additionally, the ‘authorised person’ should assess the qualifications and
experience of the ‘independent qualified person’ taking into account that the
‘independent qualified person’ should have received training and have experience
in the particular task. It should not be acceptable that the ‘authorised person’
shows to the ‘independent qualified person’ how to perform the inspection once
work has been already finalised.
(c) How should independent inspection be performed
Independent inspection should ensure for example correct assembly, locking and sense of
operation. When inspecting control systems that have undergone maintenance, the
‘independent qualified person’ should consider the following points independently:
(1) all those parts of the system that have actually been disconnected or disturbed should be
inspected for correct assembly and locking;
(2) the system as a whole should be inspected for full and free movement over the complete
range;
(3) cables should be tensioned correctly with adequate clearance at secondary stops;
(4) the operation of the control system as a whole should be observed to ensure that the
controls are operating in the correct sense;
(5) if different control systems are interconnected so that they affect each other, all the
interactions should be checked through the full range of the applicable controls; and

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