A Regulation for Maintenance Organisations
By RC (Bob) Williams
JAR-145 is a regulation first published in 1991 which addresses the requirements to be met by a maintenance organisation that wishes to maintain aircraft, components or equipment used in commercial air transportation.
Under the JAA regulations, only organisations that are certificated under JAR-145 may carry out maintenance of such aircraft, components and equipment. This is unlike FAR in that a JAA airline or air taxi organisation may only maintain its aircraft if it holds a JAR-145 approval. This philosophy is based on the concept that there should only be one standard for maintenance of aircraft used in commercial air transportation.
It also follows that the JAA airline or air taxi organisation need not be JAR-145 approved if it prefers to use another JAR-145 approved organisation on a contract basis. Irrespective of who will maintain the aircraft, the JAA member Authority must approve any maintenance arrangement, once compliance has been established, with the relevant regulations.
JAR-145 has been subjected to six amendments since 1991 and the current version known as the change 2 version reflects the need to ensure if not improve safety standards for the travelling public. It also reflects the changing technology and methodology of the aviation industry. It is worth noting that two further amendments are in process at this time.
Turning to the issue of the impact of JAR-145 on USA-based FAR-145 repair stations — it is worth remembering that 145 was, and still is, developed in co-operation with the FAA and based where ever possible upon FAR-145. In reality JAR-145 is an updated version of FAR-145 and it only remains for the proposed FAR 145 NPRM to get off of the political agenda to re-align the two regulations.
On the assumption that the reader understands FAR-145, the remainder of this article will concentrate on the differences between FAR and JAR-145 as seen from a JAA point of view, starting with the most significant.
JAR-145 required a working quality system rather than the inspection system specified in FAR-145. It's worth noting that FAR-121 Subpart L requires a quality system for air carriers. This difference is not intended to suggest that there is anything wrong with inspection systems. In fact, a repair station can combine the quality with the inspection system.
The advantage of a quality system is the ability , or the intended ability, of such a system to make a complete overview of a repair station in an endeavour to minimise problems from arising — thereby improving efficiency and safety.
The quality system required by JAR-145 is not a total quality system but more of a quality audit and follow-up system. This system operates independently of the routine maintenance and inspection system.
The quality audit element is required to be a pre-programmed audit carried out by designated quality personnel of all aspects of maintenance, including the inspection function, and are generally required every 12 months. The independence of the audit must be assured by using designated quality personnel not responsible for the particular aspect of maintenance being audited. The quality audit process will generate findings/discrepancies from time to time and it is the function of the follow up system to ensure correction of such findings/discrepancies in a timely manner. This means that safety issues must be corrected immediately, significant issues corrected within weeks and less significant issues corrected within months. The performance of the quality system as a whole and the responsiveness of the repair station to findings/discrepancies must be reviewed with the accountable manager at least once per year.
JAR-145 requires the repair station Chief Executive Officer, known in JAR-145 as the Accountable Manager, to take responsibility for the repair station and sign a statement of commitment to compliance with FAR-145. The CEO must also agree to a number of additional conditions which ensure equivalence to JAR-145.
The reason for placing responsibility for compliance with the CEO recognises the fact that the CEO ultimately determines both the extent of business of the repair station and the extent of compliance with FAR/JAR-145 and makes it easier to remove the JAR-145 acceptance certificate in the case of non compliance. JAA experience has shown that when ever the CEO takes an active interest in the FAR/JAR-145 certificate, the standards improve.
JAR-145 requires compliance with European airworthiness directives and European approved design engineering data, such as modification and repair data. As a consequence compliance with the customer work order, is vital because the USA based repair station may only be aware of FAA approved data.
Further complicating the issue is the fact whilst much FAA approved data may also be European approved, this is not true of all data. Therefore a critical element for the repair station is the need to follow the customer work order and the need to place the responsibility for ensuring appropriate approvals on the customer.
Components that have been obtained from other sources for fitment during maintenance must be accompanied by a JAA Form 1 or a FAA Form 8130-3 or a Canadian Form 24-0078 depending upon the source. For new components traceability to the Original Equipment Manufacturer specified in the Type Certificate Holders Parts Catalogue must be assured. Used components may only be fitted where the last maintenance was carried out by a JAA JAR-145 approved maintenance organisation or a JAA JAR-145 accepted repair station. Note that in the USA only 1000 of the 4500 FAR-145 repair stations are JAA accepted and therefore great care is needed to ensure that only components from the 1000 JAA JAR-145 accepted repair stations are used.
Finally for those repair stations with an airframe rating or a limited airframe rating, there is the need to be aware that almost all aircraft operating in Europe have expiring certificates of airworthiness which means that unlike FAA normal category certificates of airworthiness, they are date limited. Therefore whilst it is primarily the responsibility of the aircraft operator to ensure the certificate is still valid before flight, the repair station should check the date validity of the certificate during maintenance to minimise the potential embarrassment of illegal flight.