ED Decision 2022/021/R
WHEN AN ALTERNATIVE MEANS OF COMPLIANCE IS NEEDED
When there is no EASA AMC to a certain point of a regulation, the means of compliance (MoC) that are proposed by the organisation to that point do not need to go through the AltMoC process. It is the responsibility of the competent authority to verify that compliance with the regulation is achieved. However, in certain cases, the organisation may propose, and the competent authority may agree, to have such MoC go through the AltMoC process.
When there is an EASA AMC, the AltMoC process is needed in the following cases (non-exhaustive list):
— an AltMoC to the regulation is technically different to the AMC that is published by EASA; and
— a Form is significantly different from the one that is included in the EASA AMC.
Note: a Form that is required by a delegated or implementing act cannot be modified.
Examples of issues that are not considered to require the AltMoC process include, but are not limited to:
— editorial changes to an EASA AMC, as long as they do not change the intent of the AMC; and
— incorporating an EASA AMC into the organisational structure, organisational processes, or standard operating procedures of an organisation with different wording and terminology that are customised to the organisation’s environment if it does not change the intent of the AMC and its associated level of safety.
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