ED Decision 2020/002/R
M.A.615(b) refers to work carried out by another organisation which is not appropriately approved under M.A. Subpart F, Part-145 or Part-CAO to carry out such tasks.
The intent is to permit the acceptance of specialised maintenance services, such as, but not limited to, non-destructive testing, surface treatment, heat-treatment, welding, fabrication of specified parts for minor repairs and modifications, etc., without the need of Subpart F approval for those tasks.
The requirement that the organisation performing the specialised services must be ‘appropriately qualified’ means that it should meet an officially recognised standard or, otherwise, it should be acceptable to the competent authority (through the approval of the Maintenance Organisation Manual).
‘Under the control of the Subpart F organisation’ means that the Subpart F organisation should investigate the capability of the subcontracted organisation (including qualifications, facilities, equipment and materials) and ensure that such organisation:
- Receives appropriate maintenance instructions and maintenance data for the task to be performed.
- Properly records the maintenance performed in the Subpart F airworthiness records.
- Notifies the Subpart F organisation for any deviation or non-conformity, which has arisen during such maintenance.
The CRS may be issued either at the subcontractors or at the organisation facility by authorised certifying staff, and always under the M.A. Subpart F organisation reference. Such staff would normally come from the M.A. Subpart F organisation but may otherwise be a person from the subcontractor who meets the M.A. Subpart F organisation certifying staff standard which itself is approved by the competent authority via the Maintenance Organisation Manual.
Subcontracted specialised services organisations should be listed in the Maintenance Organisation Manual of the Subpart F organisation together with their qualifications, and the associated control procedures.
AMC M.A.615(b) explains how Subpart F organisations may accept specialised maintenance services from non-approved subcontractors, requiring capability checks, control, and listing in the Maintenance Organisation Manual.
* Summary by Aviation.Bot - Always consult the original document for the most accurate information.
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