Safety Management Systems (SMS) requirements in Part-M Continuing Airworthiness and Part-145 Maintenance Organizations could be two of the driving factors.
In the past few years ICAO (International Civil Aviation Organization) has inserted SMS and standards and recommended practices (SARPs) into several different annexes, and it is developing a new one (Annex 19 SMS) to unify all of ICAO's SMS provisions into a single document. That annex will probably come out by the end of 2013. Once SARPs are embedded within the ICAO annexes, it becomes an obligation of the signatory states of the Chicago Convention, including EU member states, to comply with ICAO SARPs. The embodiment of SMS requirements in Part-M and Part-145 will be an interesting test to see how SMS programs will be mandated in a large aviation market.
The continuing airworthiness section of EASA's product safety department has announced a notice of proposed amendment (NPA) to EU Regulation 2042/2003 on continuing airworthiness (with focus on Part-M and Part-145 and related acceptable means of compliance and guidance materials). It was scheduled to be published in late December. The overall objective of the NPA is to adopt streamlined organization management system requirements, considering ICAO standards and recommended practices on SMS. It also attemps to review the procedures to align them with authority requirements in Part-ARA/Part-ARO, as well as to support the implementation of state safety programs in the framework of the European Aviation Safety Program.
EASA regulation also should affect flight tests. In September 2012, EASA published a comment response document (CRD) to NPA 2008-20 on flight testing for Part-21 initial airworthiness. This flight-testing regulation has been welcomed by the EU engineering and maintenance community because many personnel involved in flight tests have often had uncomfortable experiences.
It is important to note that the applicability of the original regulation focused only on flight testing and excluded maintenance-check flights and ferry flights. “However, the agency has recognized the importance to address other types of flights,” so maintenance-check flights and other flight types related to design and production activity will now be included.
It also will define categories of flight tests (CAT 1/2/3/4), the definition and qualifications for lead flight-test engineer for all categories of flight tests (for aircraft above 2,000 kg or 4,400 lb.), the qualifications for pilots for flight tests (for aircraft above 2,000 kg) and the flight-test operational manual.
“While it is acknowledged that further work may be required to rationalize some subjects (e.g., the requirements to include a lead flight-test engineer license), a delay in the publication of this material will be of increasing concern. An advance-NPA will discuss the creation of a licensing scheme for a lead flight-test engineer (lead FTE),” reported EASA.
The changes proposed by the CRD to NPA 2008-20 aim to increase safety when conducting flight tests and minimize additional burdens on the organizations involved. The CRD was released shortly after NPA 2012-08 on maintenance-check flights, addressing the need for a specific manual, dedicated pilot requirements (including training), and the definition of crew and persons on board. This NPA proposes a set of proportionate rules, depending on the complexity of the aircraft used and foreseen flight procedures. In addition, EASA proposed acceptable means of compliance and guidance.
In accordance with the text proposed in NPA 2012-08, “maintenance organizations may be able to release the inconclusive maintenance to allow for a maintenance-check flight when this is required by the aircraft maintenance manual. A permit to fly may be required if there is a need to perform a maintenance-check flight but, in accordance with the maintenance organization requirements, the aircraft cannot be released,” reports EASA. With regard to maintenance-check flights, it should be clarified that for most large aircraft there is currently no requirement, according to aircraft maintenance programs, for the performance of maintenance-check flights. It is up to the aircraft operator to require a maintenance-check flight with the responsible approved maintenance organization to make sure that the released aircraft is fully serviceable. It is common practice and highly advisable to conduct maintenance-check flights when maintenance checks imply the replacement of more than 50% of the engines or the replacement of, for example, the flight controls, the control cables and the landing gear.