AMC 25-19 Certification Maintenance Requirements
ED
Decision 2018/005/R
1 PURPOSE
This
Acceptable Means of Compliance (AMC) provides guidance on the selection,
documentation and control of Certification Maintenance Requirements (CMRs).
This AMC also provides a rational basis for coordinating the CMR selection
process and the Maintenance Review Board (MRB) process if the latter is used.
The applicant should ensure that the maintenance tasks and intervals
identified in the system safety analyses to support compliance with CS 25.1309
and other system safety requirements (such as CS 25.671, CS 25.783, CS 25.901,
and CS 25.933) are protected in service. For those
aeroplanes whose initial maintenance programme is developed under a different
process than the MRB process, the coordination and document aspects have to be
adapted to the particular case. This AMC describes an acceptable means, but
not the only means, for selecting, documenting and managing CMRs. Terms such
as ‘shall’ and ‘must’ are used only in the sense of ensuring applicability of
this acceptable means of compliance.
2 RELATED CERTIFICATION
SPECIFICATIONS
a. CS 25.671 Control Systems — General
b. CS 25.783 Fuselage Doors
c. CS 25.901 Powerplant — Installation
d. CS 25.933 Reversing systems
e. CS 25.1309 Equipment, systems and installations
f. CS 25.1529 Instructions for Continued Airworthiness
3 RELATED DOCUMENTS
a. Airlines for America (A4A), MSG–3,
Operator/Manufacturer Scheduled Maintenance Development Document.
b. International Maintenance Review
Board/Maintenance Type Board Process Standard (IMPS)
4 NOT USED
5 CERTIFICATION MAINTENANCE REQUIREMENTS (CMR) DEFINITION
A CMR is a
required scheduled maintenance task, established during the design
certification of the aeroplane systems as an airworthiness limitation of the
type certificate (TC) or supplemental type certificate (STC). The CMRs are a
subset of the Instructions for Continued Airworthiness (ICA) identified during
the certification process. A CMR usually result from a formal, numerical
analysis conducted to show compliance with the requirements applicable to
catastrophic and hazardous failure conditions as defined in paragraph 6e,
below. A CMR may also result from a qualitative, engineering judgment-based
analysis.
a. The CMRs are required tasks, and
associated intervals, developed to achieve compliance with CS 25.1309
and other requirements requiring safety analyses (such as CS 25.671, 25.783, 25.901, and
25.933). A
CMR is usually intended to detect latent failures that would, in combination
with one or more other specific failures or events, result in a Hazardous or
Catastrophic Failure Condition. A CMR can also be used to establish a required
task to detect an impending wear out of an item whose failure is associated
with a hazardous or catastrophic failure condition. A CMR may also be used to
detect a latent failure that would, in combination with one specific failure
or event, result in a major failure condition, where the SSA identifies the
need for a scheduled maintenance task.
b. CMRs are derived from a fundamentally
different analysis process than the maintenance tasks and intervals that
result from MSG–3 analysis associated with MRB activities (if the MRB process
is used). Although both types of analysis may produce equivalent maintenance
tasks and intervals, it is not always appropriate to address a Candidate
Certification Maintenance Requirement (CCMR) with a Maintenance Review Board
Report (MRBR) task.
c. CMRs verify that a certain failure has
or has not occurred, indicate that corrective maintenance or repair is
necessary if the item has failed, or identify the need to inspect for
impending failures (e.g. wear out or leakage). Because the exposure time to a
latent failure is a key element in the calculations used in a safety analysis,
limiting the exposure time will have a significant effect on the resultant
overall failure probability of the system. The intervals for CMR tasks
interval should be designated in terms of flight hours, cycles, or calendar
time, as appropriate.
d. The type certification process assumes
that the aeroplane will be maintained in a condition or airworthiness equal to
its certified condition. The process described in this AMC is not intended to
establish routine maintenance tasks (e.g. greasing, fluid-level checks, etc.)
that should be defined through the MSG–3 analysis process. Also, this process
is not intended to establish CMRs for the purpose of providing supplemental
margins of safety for concerns arising late in the type design approval
process. Such concerns should be resolved by appropriate means, which are unlikely
to include CMRs not established via normal safety analyses.
e. CMRs should not be confused with
required structural inspection programmes, that are developed by the TC applicant
to meet the inspection requirements for damage tolerance, as required by CS 25.571 or CS 25.1529, and Appendix H25.4
(Airworthiness Limitations Section). CMRs are to be developed and managed
separately from any structural inspection programs.
6 OTHER DEFINITIONS
The
following terms apply to the system design and analysis requirements of CS
25.1309(b) and (c), and to the guidance material provided in this AMC. (for a
complete definition of these terms, refer to the applicable specifications and
acceptable means of compliance, (e.g. CS and AMC 25.1309)).
a. Catastrophic. Refer to AMC 25.1309.
b. Compatible MRBR task. An MRBR task whose
intent addresses the CCMR task intent and whose interval is equal to or lower
than the interval that would otherwise be required by a CMR.
c. Crew. The cabin crew, or flight crew, as
applicable.
d. Failure. Refer to AMC 25.1309.
e. Failure Condition. Refer to AMC 25.1309.
f. Failure Effect Category 5 task (FEC5).
Refer to MSG-3, Operator/Manufacturer Scheduled Maintenance Development.
g. Failure Effect Category 8 task (FEC8).
Refer to MSG-3, Operator/Manufacturer Scheduled Maintenance Development.
h. Hazardous. Refer to AMC 25.1309.
i. Latent Failure. Refer to AMC 25.1309.
j. Major. Refer to AMC 25.1309.
k. Qualitative. Refer to AMC 25.1309.
l. Quantitative. Refer to AMC 25.1309.
m. Significant Latent Failure. A latent
failure that would, in combination with one or more other specific failures or
events, result in a hazardous or catastrophic failure condition.
n. Task. Short description (e.g. descriptive
title) of what is to be accomplished by a procedure. Example: ‘Operational
check of the static inverter’.
o. Wear out. A condition where a component
is worn beyond a predetermined limit.
7 SYSTEM SAFETY
ASSESSMENTS (SSA)
a. CS 25.1309(b) specifies required safety levels
in qualitative terms, and a safety assessment must be conducted to show
compliance. Various assessment techniques have been developed to help
applicants and EASA in determining that a logical and acceptable inverse relationship
exists between the probability and the severity of each Failure Condition.
These techniques include the use of service experience data of similar,
previously approved systems, and thorough qualitative and quantitative
analyses.
b. In addition, difficulties have been
experienced in assessing the acceptability of some designs, especially those
of systems, or parts of systems, that are complex, that have a high degree of
integration, that use new technology, or that perform safety-critical
functions. These difficulties led to the selective use of rational analyses to
estimate quantitative probabilities, and the development of related criteria
based on historical data of accidents and hazardous incidents caused or
contributed to by failures. These criteria, expressed as numerical probability
ranges associated with the terms used in CS 25.1309(b), became commonly
accepted for evaluating the quantitative analyses that are often used in such
cases to support experienced engineering and operational judgement and to
supplement qualitative analyses and tests.
NOTE: See
AMC 25.1309 for a complete description of the inverse relationship between the
probability and severity of Failure Conditions, and the various methods of
showing compliance with CS 25.1309.
8 DESIGN CONSIDERATIONS
RELATED TO SIGNIFICANT LATENT FAILURES
a. The applicant should implement practical
and reliable failure monitoring and flight crew indication systems to detect
failures that would otherwise be significant latent failures. A reliable
failure monitoring and flight crew indication system should utilise current
state-of-the-art technology to minimise the probability of falsely detecting
and indicating non-existent failures. Experience and judgement should be
applied when determining whether or not a failure monitoring and flight crew
indication system would be practical and reliable. Comparison with similar,
previously approved systems is sometimes helpful.
b. Supplemental design considerations are
provided in Appendix 1 to this AMC.
9 OVERVIEW OF THE CERTIFICATION
MAINTENANCE REQUIREMENTS DEVELOPMENT PROCESS
a. Figure 1 shows the development process
of CMRs. The details of the process to be followed in defining, documenting,
and handling CMRs are given in paragraphs 10 through 13.
Figure 1 — CMR development process
10 IDENTIFICATION OF CANDIDATE CMRs (CCMRs)
a. The SSA should address all significant
latent failures.
b. Credit may be taken for correct flight
crew performance of the periodic checks required to demonstrate compliance
with CS 25.1309(b). Unless these flight crew actions are
accepted as normal airmanship, they should be included in the approved
Aeroplane Flight Manual procedures. Similarly, credit may be taken from
self-initiated checks (e.g. power-up built-in tests). In both cases, these
significant latent failures do not need a CCMR.
c. Tasks that are candidates for selection
as CMRs come from safety analyses (e.g. SSAs), which establish whether there
is a need for tasks to be carried out periodically to comply with
CS 25.1309, and other requirements (such as CS 25.671, CS 25.783, CS 25.901,
and CS 25.933) requiring this type of analysis. The SSA
should identify as CCMRs the maintenance tasks intended to detect significant
latent failures. Tasks may also be selected from those intended to inspect for
impending failures due to wear out.
d. As the safety analysis may be qualitative
or quantitative, some task intervals may be derived in a qualitative manner
(e.g. engineering judgment and service experience). As per AMC 25.1309,
numerical analysis supplements, but does not replace, qualitative engineering
and operational judgment. Therefore, other tasks that are not derived from
numerical analysis of significant latent failures, but are based on properly
justified engineering judgment, can also be candidates for CMRs. The
justification should include the logic leading to identification of CCMRs, and
the data and experience base supporting the logic.
e. In some situations, a Catastrophic or
Hazardous Failure Condition might meet the quantitative probability objective,
yet it might contain one or more components that, as per the quantitative
analysis, do not require a periodic maintenance task to meet that
objective (i.e. could be failed latent for the life of the aeroplane). In such
cases, the SSA should include a qualitative assessment to determine whether a
periodic maintenance task is needed.
Unless otherwise substantiated, a CCMR
should be identified to:
—
reduce
exposure to a single failure or event that would cause the failure condition,
—
ensure
the availability of backup or emergency systems, and
—
ensure
the availability of equipment/systems required to be installed as per CS-25.
f. For failure conditions involving
multiple significant latent failures, the SSA should identify a CCMR for each
significant latent failure unless otherwise justified (e.g. one CCMR may cover
multiple significant latent failures, or the significant latent failure could
exist for the life of the aeroplane without compromising compliance with the
safety objectives and paragraph 10.e considerations).
g. For each identified CCMR, the applicant
should indicate:
—
the
failure mode to be detected,
—
the
failure condition of concern,
—
the
intended maintenance task, and
—
the
task interval (the allowable value coming from the SSA or other relevant
analysis).
11 SELECTION OF CMRs
a. Each CCMR should be reviewed and a
determination made as to whether or not it should be a CMR.
Criteria and guidance are
provided below for CMR selection or non-selection. The applicant may seek
additional input from an advisory committee, as described in Appendix 2,
before proposing CMRs to EASA for final review and approval.
b. The applicant should provide sufficient
information to enable an understanding of the Failure Conditions and the
failure or event combinations that result in the CCMRs. CCMRs are evaluated in
the context of the Failure Conditions in which they are involved, e.g. whether
the significant latent failure is part of a dual failure, a triple failure, or
more.
c. The CMR designation should be applied in
the case of catastrophic dual failures where one failure is latent. The CMR
designation should also be applied to tasks that address wear out of a
component involved in a Catastrophic Failure Condition that results from two
failures.
d. In all other cases, the CMR designation
may not be necessary if there is a compatible MRBR task to accommodate the
CCMR, provided that the applicant has the means in place to ensure that the
CCMRs are protected in service. Appendix 3 provides examples of acceptable
means of protection. Any means should be presented to EASA for acceptance.
These means
of protection should address future evolutions of the compatible MRBR task
proposed by the applicant or by the operator. In this respect, these means
should ensure that in service:
—
the
compatible MRBR task would not be changed to the extent that the CCMR task
intent is adversely affected, and
—
the
compatible MRBR task would not be escalated beyond the interval that would
otherwise be required by a CMR.
The TC
applicant should adequately describe the selected means of protection in the
associated technical publication in order for the operator to be aware of the
process to be followed if there are modifications to any compatible MRBR tasks
that are included in the operator’s aeroplane maintenance program (AMP).
e. The rationale for the disposition of each
CCMR should be presented to EASA for acceptance.
f. Since the MSG-3 logic may not consider a
Failure Condition containing three or more failures, it is possible that a
CCMR might not have any identified MRBR tasks. In this case, a CMR will be
required.
g. Where the SSA identifies the need for a
scheduled maintenance task, the CMR designation may also be used to detect a
latent failure that would, in combination with one specified failure or event,
lead to a Major Failure Condition. This CMR designation may be necessary if no
adequate scheduled maintenance task has been identified in any other
Instructions for Continued Airworthiness.
h. If the SSA does not specify an interval
shorter than the life of the aeroplane, an interval may be established by
considering the factors that influence the outcome of the Failure Condition,
such as the nature of the fault, the system(s) affected, field experience, or
task characteristics.
12 DOCUMENTATION AND
HANDLING OF CMRs
a. CMRs are considered functionally equal to
airworthiness limitations, therefore they should be included in the
Airworthiness Limitations Section of the Instructions for Continued
Airworthiness.
b. The CMR data location should be
referenced in the type certificate data sheet (TCDS). The latest version of
the applicant’s CMR documentation should be controlled by a log of pages
approved by EASA. In this way, changes to CMRs following certification will
not require an amendment to the TCDS.
c. Since CMRs are based on statistical
averages and reliability rates, an ‘exceptional short-term extension’ for CMR
intervals may be made on one aeroplane for a specific period of time without
jeopardising safety. Any exceptional short-term extensions to CMR intervals
must be defined and fully explained in the applicant’s CMR documentation. The
competent authority must concur with any exceptional short-term extension
allowed by the applicant’s CMR documentation before it takes place, using
procedures established with the competent authority in the operators’ manuals.
The exceptional short-term extension process is applicable to CMR intervals.
It should not be confused with the operator’s ‘short-term escalation’ program
for normal maintenance tasks described in the operators’ manuals.
(1) The term ‘exceptional short-term
extension’ is defined as an increase in a CMR interval that may be needed to
cover an uncontrollable or unexpected situation. Any allowable increase must
be defined either as a percent of the normal interval, or a stated number of
flight hours, flight cycles, or calendar days. If no exceptional short-term
extension is to be allowed for a given CMR, this restriction should be stated
in the applicant’s CMR documentation.
(2) Repeated use of exceptional short-term
extensions, either on the same aeroplane or on similar aeroplanes in an
operator’s fleet, should not be used as a substitute for good management
practices. Exceptional short-term extensions must not be used for the systematic
escalation of CMR intervals.
(3) The applicant’s CMR documentation should
state that the competent authority must approve, prior to its use, any desired
exceptional short-term extension not explicitly listed in the CMR document.
13 POST-CERTIFICATION
CHANGES TO CMRs (New, revised or deleted)
a. The introduction of a new CMR or any
change to an existing CMR should be reviewed by the same entities that were
involved in the process of CCMR/CMR determination (refer to paragraphs 10 and
11 of this AMC) at the time of initial certification. To allow operators to
manage their own maintenance programs, it is important that they be afforded
the same opportunity for participation that they were afforded during the
initial certification of the aeroplane.
b. Any post-certification changes to CMRs
must be approved by EASA which approved the type design.
c. Since the purpose of a CMR is to limit
the time of exposure to a given significant latent failure, or a given wear
out, as part of an engineering analysis of the overall system safety,
instances of a CMR task repeatedly finding that no failure has occurred may
not be sufficient justification for deleting the task or increasing the time
between repetitive performances of the CMR task. In general, a CMR task change
or interval escalation should only be made if experience with the aeroplane
fleet in service worldwide indicates that certain assumptions regarding
component failure rates made early during the engineering analysis were too
conservative, and a re-calculation of the system’s reliability with revised
failure rates of certain components reveals that the task or interval may be
changed.
d. If later data provides a sufficient
basis for the relaxation of a CMR (less restrictive actions to be performed),
the change may be documented by a revision to the applicant’s CMR
documentation and approved by EASA.
e. To address an unsafe condition, EASA may
determine that the requirements of an existing CMR must be modified (more
restrictive actions to be required) or a new CMR must be created. These
modified requirements will be mandated by an Airworthiness Directive (AD) and
the applicant’s CMR documentation will be revised to include the change.
f. New CMRs that are unrelated to
in-service occurrences may be created and they should be documented and
approved by EASA. New CMRs can arise in situations such as:
(1) the certification of design changes, or
(2) updates of the applicant’s certification
compliance documentation. These may result from regulatory changes, actions
required by an AD on similar systems or aeroplanes, awareness of additional
Hazardous or Catastrophic Failure Conditions, revised failure rates,
consideration of extended service goals, etc.
APPENDIX 1 SUPPLEMENTAL GUIDANCE FOR THE USE OF CMRs
1. The TC/STC applicant should choose a
system design that minimises the number of significant latent failures, with
the ultimate goal that no such failures should exist, if this is practical. A
practical and reliable failure monitoring and flight crew indication system
should be considered as the first means to detect a significant latent
failure. If the cost of adding practical and reliable failure monitoring and
flight crew indication system is high, and the added maintenance cost of a CMR
is low, the addition of a CMR may be the solution of choice for both the type
certificate applicant and the operator, provided all applicable regulations
are met. Substituting a CMR with an MRBR task does not necessarily reduce
maintenance costs.
2. The decision to create a CMR may include
a trade-off of the cost, weight, or complexity of providing mechanism or
device that will expose the latent failure, versus the requirement for the
operator to conduct a maintenance or inspection task at fixed intervals.
3. The following points should be
considered in any decision to create a CMR in lieu of a design change.
a. What is the magnitude of the changes to
the system and/or aeroplane needed to add a reliable failure monitoring and
flight crew indication system that would expose the latent failure? What is
the cost in added system complexity?
b. Is it possible to introduce a self-test
on power-up?
c. Is the monitoring and flight crew
indication system reliable? False warnings must be considered, as well as a
lack of warnings.
d. Does the failure monitoring or flight
crew indication system itself need a CMR due to its latent failure potential?
e. Is the CMR task reasonable, considering
all aspects of the failure condition that the task is intended to address?
f. How long (or short) is the CMR task
interval?
g. Is the proposed CMR task labour
intensive or time consuming? Can it be done without having to ‘gain access’
and/or without workstands? Without test equipment? Can the CMR task be done
without removing equipment from the aeroplane? Without having to re-adjust
equipment? Without leak checks and/or engine runs?
h. Can a simple visual inspection be used
instead of a complex one? Can a simple operational check suffice in lieu of a
formal functional check against measured requirements?
i. Is there ‘added value’ to the proposed
task (i.e. will the proposed task do more harm than good if the aeroplane must
be continually inspected)?
j. Have all alternatives been evaluated?
APPENDIX 2 ROLE OF THE CERTIFICATION MAINTENANCE COORDINATION COMMITTEE
(CMCC)
1. The CMCC functions as an advisory
committee for the applicant and proposes the disposition of each presented
CCMR. EASA is the authority that ultimately approves CMRs as airworthiness
limitations of the type certificate as per Part-21.
2. In order to grant aeroplane operators
the opportunity to participate in the selection of CMRs, and to assess the
CCMRs and the proposed MRBR tasks and intervals in an integrated process, the
applicant should convene a CMCC as early as possible in the design phase of
the aeroplane program, and at intervals as necessary. This CMCC should
comprise TC/STC holder representatives (typically maintenance, design, and
safety engineering personnel), operator representatives designated by the
Industry Steering Committee (ISC) chairperson, EASA certification
specialist(s), and the MRB chairperson(s). EASA certification specialist
participation in the CMCC is necessary to provide regulatory guidance on the
disposition of CCMRs.
3. The CMCC should review CCMRs and their
purposes, the Failure Conditions and their classifications, the intended tasks
and their intervals, and other relevant factors. In addition, where multiple
tasks result from a quantitative analysis, it may be possible to extend a
given interval at the expense of one or more other intervals, in order to
optimise the required maintenance activity. However, once a decision is made
to create a CMR, then the CMR interval should be based solely on the results
of the SSA or other relevant analysis. If the SSA does not specify an interval
shorter than the life of the aeroplane, then the CMR interval may be proposed
by the CMCC considering factors that influence the outcome of the failure
condition, such as the failure mode(s) to be detected, the system(s) affected,
field experience, or task characteristics.
4. The CMCC should address all CCMRs.
Alternatively, the applicant may coordinate with EASA to define a subset of
CCMRs to be presented to the CMCC.
5. The CMCC discusses compatible tasks (if
any) that the MRB generates. The CMCC may select an MRBR task in lieu of a CMR
in accordance with paragraph 11 of this AMC.
6. The CMCC may request the ISC to review
selected CMCC results (e.g. proposed revised MRBR tasks and/or intervals).
Upon ISC review, the proposed revised MRBR tasks and/or intervals accepted by
the ISC are reflected in the MRBR proposal, and the proposed revised MRBR
tasks and/or intervals rejected by the ISC result in CMRs. Following
consideration by the ISC, the applicant submits the CMRs to EASA for final
review and approval.
APPENDIX 3 MEANS OF PROTECTION PROPOSED BY THE DESIGN APPROVAL HOLDER
(DAH) AGAINST FUTURE EVOLUTIONS OF THE COMPATIBLE MRBR TASKS AND DERIVED TASKS
OF THE OPERATOR’S AEROPLANE MAINTENANCE PROGRAM — EXAMPLES
1. With reference to paragraph 11.c of this
AMC, this Appendix provides examples to facilitate the implementation of the
means to ensure that the CCMRs are protected in service.
2. These examples describe acceptable means,
but not the only means. Any means should be presented to EASA for acceptance.
EXAMPLE 1 — Traceability of CCMRs and MRBR tasks in the Airworthiness
Limitations Section
a. The CMR designation may not be necessary
if there is a compatible MRBR task to accommodate the CCMR, provided that the
design approval holder (DAH) shows direct traceability between the MRBR task
and the accommodated CCMR in the airworthiness limitations section (ALS).
b. The compatible MRBR task and its interval
are not airworthiness limitations. The status of the compatible MRBR task with
regard to the MRB process remains unchanged.
c. Traceability between the CCMR and the
compatible MRBR task should be provided in the ALS of the instructions for
continued airworthiness to ensure that the CCMR is respected during in-service
operation of the aeroplane and any future evolution of the maintenance
program.
Table 1
illustrates one possible means for traceability.
CCMR task reference |
CCMR interval |
Compatible MRBR task reference |
CCMR task #NN |
60 months |
MRBR task #XX |
CCMR task #MM |
10 000 flight hours |
MRBR task #YY |
… |
… |
… |
Appendix 3 — Table 1
d. If
the DAH changes the compatible MRBR task to the extent that the intent of the
corresponding CCMR task is adversely affected, this corresponding CCMR task is
no longer accommodated. Therefore, the DAH could either propose a new
compatible MRBR task, if one exists, or create a new CMR in line with the
intent of the previously referenced CCMR limitation. These changes to the ALS
require EASA approval.
e. If the DAH escalates the interval of the
compatible MRBR task beyond the corresponding CCMR limitation, this
corresponding CCMR is no longer accommodated and the DAH needs to create a CMR
in order to satisfy the corresponding CCMR limitation. Alternatively, the DAH
could assess the feasibility of escalating the interval of the corresponding
CCMR by re‑evaluating the system safety assumptions that lead to the CCMR at
the time of initial certification. These changes to the ALS require EASA
approval.
f. Furthermore, the DAH shall describe in
the ALS what the operator needs to observe when changing the operator’s
aeroplane maintenance program (AMP). For tasks included in an AMP, which are
based on compatible MRBR tasks, the following applies:
i. Should the operator propose to change
the intent of a task, the operator should ask for the DAH’s confirmation that
this change does not adversely affect the intent of the corresponding CCMR
task. If the corresponding CCMR task is no longer accommodated, the operator
needs to propose to include a mandatory task in the AMP in order to satisfy
the intent of the referenced CCMR limitation. These changes to the AMP require
the approval of the competent authority responsible for the oversight of the
operator.
ii. If the operator proposes to escalate the
interval of a task, the corresponding CCMR limitation must not be exceeded.
EXAMPLE 2 — Uniquely identifying the compatible MRBR tasks
a. The CMR designation may not be necessary
if there is a compatible MRBR task to accommodate the CCMR, provided that the
DAH uniquely identified each compatible MRBR task in the existing MRBR task
listing. Table 2 illustrates one possible means for marking.
MRBR task
reference |
MRBR task
description |
Failure effect category
(FEC) |
Interval |
Tracking |
MRBR task #XX |
Functional check of […] |
FEC 8 |
60 months |
|
MRBR task #YY |
Detailed inspection of […] |
- |
72 months |
EWIS |
MRBR task #ZZ |
Operational check of […] |
FEC 8 |
10 000 flight hours |
CCMR |
… |
… |
… |
… |
… |
Appendix 3 — Table 2
b. The purpose of the marking and the
policies to be observed for appropriate change control of the marked MRBR
tasks should be stated in the MRB report.
c. The status of the compatible MRBR task
with regard to the MRB process remains unchanged.
d. If the DAH changes the marked MRBR task
to the extent that the intent of the corresponding CCMR task is adversely
affected, the DAH needs to create a CMR to satisfy the intent of the initial
CCMR task. This change to the ALS requires EASA approval.
e. For future escalations of MRBR tasks, the
DAH should have procedures in place to ensure that these escalations do not
increase the interval of the marked MRBR task beyond the corresponding CCMR
interval.
f. However, should the DAH escalate the
marked MRBR task beyond the CCMR interval, the DAH needs to create a CMR in
order to satisfy the corresponding CCMR. This change to the ALS requires EASA
approval. Alternatively, the DAH could assess the feasibility of escalation of
the interval of the corresponding CCMR by re-evaluating the system safety
assumptions that lead to the CCMR at the time of initial certification. This
change to the CCMR interval requires EASA involvement in accordance with the
process described in paragraph 11 of this AMC.
g. Furthermore, the DAH shall describe in
the MRBR what the operator needs to observe when changing the operator’s
aeroplane maintenance program (AMP). For tasks included in the AMP, which are
based on marked MRBR tasks, the following applies:
i. If the operator proposes to change the
intent of a task, the operator should ask for the DAH’s confirmation that this
change does not adversely affect the intent of the corresponding CCMR task.
ii. If the operator proposes to escalate the
interval of a task, the operator should ask for the DAH’s confirmation that
this escalation does not increase the interval beyond the corresponding CCMR
interval. These changes to the AMP require the approval of the competent
authority responsible for the oversight of the operator.
[Amdt
25/20]
[Amdt
25/21]