The Civil Aviation Authority (CAA) plays a crucial role in regulating and overseeing various aspects of aviation safety, maintenance, and operations. In this article, the term CAA refers to the UK CAA and any Civil Aviation Authority within the European Union Aviation Safety Agency (EASA) framework, including the UK CAA itself.
One of the essential elements of aviation regulation involves the implementation of legislative frameworks that set standards for everything, from aircraft maintenance and personnel training to airworthiness and certification of aircraft components.
The CAA legislation is divided into various sections that govern different aspects of aviation. This article will provide an in-depth look at the main sections of the CAA legislation: Part 145, Part 147, Part CAMO, Part 21, and Part 66.
Understanding these parts helps to clarify how aviation organisations must comply with regulations to maintain safety, compliance, and operational integrity.
Part 145: Maintenance organisations
Part 145 outlines the requirements for organisations involved in the maintenance of aircraft. It sets forth the standards that a maintenance organisation must meet to gain approval to perform maintenance tasks on aircraft. This section is critical because it ensures that maintenance is carried out according to the highest standards, thus safeguarding the safety of passengers, crew, and aircraft.
To become a Part 145 organisation, a maintenance facility must meet several criteria, including:
- Facility requirements: The physical infrastructure must meet the specific standards necessary for maintenance activities. This includes having adequate space, equipment, and safety protocols in place.
- Personnel requirements: Staff must be properly qualified and available to perform the required tasks. This includes engineers, technicians, and support staff.
- Certifying and support staff: A sufficient number of qualified certifying staff must be supported by the necessary number of support personnel to handle the workload effectively.
- Airworthiness review staff: The organisation must have staff dedicated to reviewing all maintenance documentation to ensure that it is accurate and up to date.
- Equipment, tools, and materials: Proper equipment and tools must be available for all maintenance tasks, ensuring that nothing is overlooked or completed incorrectly.
- Component acceptance: The organisation must manage and process components correctly, ensuring all parts meet regulatory requirements.
- Maintenance data: Updated maintenance manuals and relevant data must be provided to staff, ensuring they have the correct information to carry out their tasks.
- Production planning: As the organisation grows, effective production planning becomes critical to ensure smooth and timely operations.
- Certification of maintenance: Facilities must follow well-defined procedures outlined in the maintenance organisation (MOE) to certify maintenance tasks and conduct independent inspections.
- Occurrence reporting: A system must be in place for reporting and learning from occurrences that could affect safety or regulatory compliance.
- Safety and quality policy, maintenance procedures, and quality system: A robust safety and quality assurance system must be in place to monitor and enforce the highest standards of practice.
- MOE (Maintenance organisation exposition): The MOE is the key document governing all activities within the organisation, ensuring compliance with regulations and organisational standards.
Without the proper regulations and standards outlined in Part 145, maintenance organisations could cut corners to reduce costs, jeopardising aircraft safety. If a facility fails to maintain these standards, it risks losing its approval to operate. This could potentially affect the safety of flights and the organisation’s reputation.
Part 147: Training organisations
Part 147 focuses on training organisations to ensure that appropriate training is provided to maintenance personnel. While Part 145 organisations are concerned with the actual maintenance of aircraft, Part 147 organisations handle the training of those who carry out the work.
These organisations ensure that training meets the necessary standards and prepare individuals to meet the qualifications required for their roles.
Key characteristics of Part 147 organisations include:
- Qualified instructors: A Part 147 organisation must employ qualified instructors capable of delivering training to a high standard.
- Training facilities: The organisation must have the necessary facilities and equipment to provide training, including classrooms, workshops, and technical equipment.
- Up to date syllabus: The training syllabus must be kept up to date in accordance with the latest standards from bodies like the European Union Aviation Safety Agency (EASA) and the CAA. This includes incorporating any syllabus changes issued by the regulatory authorities.
- Accreditation: Similar to Part 145 organisations, Part 147 organisations are subject to audits to ensure they meet the regulatory requirements. These audits ensure the training is delivered correctly and that exams and assessments are conducted under the correct conditions with proper invigilators.
Examples of Part 147 organisations include training schools and colleges that provide courses for maintenance personnel. For example, ICAT College in Cardiff offers modular exams and issues CAA-approved certificates for Part 66 modular exams.
Part CAMO: Continuing Airworthiness Management Organisation
Part CAMO governs the continuing airworthiness management of aircraft. This section is specifically concerned with ensuring that aircraft are kept in a state of continued airworthiness, meaning they must be maintained in compliance with both regulatory requirements and operational standards.
The key role of a CAMO is to ensure that scheduled maintenance tasks are performed in a timely manner, preventing any lapses in airworthiness. Some of the duties of a CAMO include:
- Scheduled maintenance: CAMO organisations are responsible for ensuring that aircraft undergo scheduled maintenance before it lapses. This can include inspections, repairs, and component replacements.
- Component compliance: CAMO organisations are tasked with ensuring that aircraft are equipped with the correct components that are in line with the specific requirements of the country in which the aircraft is registered. For example, a G-registered aircraft (under CAA) may have different component requirements compared to an n-registered plane (under FAA).
- Authority liaison: CAMO acts as a liaison between the aircraft owner and the relevant aviation authority. For example, if an aircraft becomes unserviceable in a location where maintenance is not feasible, the CAMO will request approval from the authority to allow for a one-off ferry flight to a more suitable maintenance facility.
In essence, CAMO ensures that the airworthiness of an aircraft is always maintained, ensuring compliance with regulatory requirements and preventing any operational interruptions.
Part 21 and C rating: Design and production of aircraft and components as well as overhaul of components.
Part 21 deals with the design, production, and certification of aircraft and aircraft components. This section outlines the standards required to design, manufacture, and develop new aircraft and components, and it includes the process of gaining approval for the parts used on the aircraft.
Part 21 also incorporates something called C ratings. A company with a Part 21 C rating is approved to carry out maintenance on certain components, provided that the components meet the required standards for use on an aircraft.
A company with Part 21 approval can issue certifications (such as Form 1 or FAA Form 8130) for the components it overhauls or repairs, certifying that the parts meet the required standards for use on live aircraft.
Many Part 145 organisations request Part 21 approvals to carry out in-house tasks such as tyre replacements, engine overhauls, or landing gear repairs. Part 21 organisations are audited by the relevant authorities to ensure they meet the standards required to produce, maintain, or certify aircraft components.
Part 66: Licencing of maintenance engineers
Part 66 governs the licencing requirements for aircraft maintenance engineers. It outlines the qualifications and procedures necessary for an individual to become licenced to perform maintenance on aircraft. Part 66 is one of the most well-known sections of the CAA legislation, as it regulates the certification process for maintenance engineers and technicians.
Part 66 licences are issued by the relevant authority and are required for those who carry out maintenance tasks on aircraft. Although a Part 147 organisation can issue training certificates that are used in your licence application, it is usually the authority that approves the final Part 66 licence.
In some countries, like the Netherlands, the Part 66 licence approval process has been outsourced to external vendors, but it is increasingly being brought back in-house by the regulatory authorities.
A real-life scenario: how the different regulations interact
Let’s look at a real-life scenario to better understand how all the regulations work together.
Imagine a Global Express aircraft, registered as 9H-GOLD, developed by Bombardier, has a landing gear fault while on a small runway in the Congo.
The aircraft operator, GoldenJet, contacts a nearby Part 145 maintenance organisation, BizJetMaintenance, based in Germany, for assistance. However, due to the lack of a hangar, jacking the aircraft to replace the landing gear is impossible in it’s current location.
GoldenJet requests a one-off approval from the Maltese CAA (9H is a Maltese registration which means the Maltese CAA is responsible for it), which issues an approval for the aircraft to fly with its landing gear down to the nearest appropriate maintenance facility.
Upon arrival, BizJetMaintenance carries out the replacement of the landing gear. The landing gear, overhauled by SAFRAN Aerospace in the UK, arrived with a CAA and EASA dual Form 1 certificate.
At the end of this input the faulty landing gear is sent back to SAFRAN for overhaul for it to then be issued a new Form 1 and then it will go back into the parts system.
In this scenario, the following parts of the legislation are in action:
- BizJetMaintenance - Part 145 approval to perform maintenance
- GoldenJet - Part CAMO approved organisation
- BizJetMaintenance - engineers hold Part 66 licences
- PCAT - Part 147 training organisation
- SAFRAN Aerospace - 21 C-rated organisation
- Luftfahrt Bundesamt - Part 66 organisation
- Bombardier - Part 21 Type certificate holder
Wrapping up
The various parts of CAA legislation – Part 145, Part 147, Part CAMO, Part 21, and Part 66 – work together to maintain the safety, compliance, and operational integrity of the aviation industry.
Each part governs a different aspect, from maintenance organisations to training and licencing to the design and certification of aircraft components.
By ensuring that these regulations are followed, the CAA helps maintain the high safety standards necessary for safe and efficient flight operations.
Obtaining and maintaining approvals under CAA legislation can be a costly and complex process. For example, renewing an EASA approval can cost tens of thousands of pounds. However, these investments are crucial to ensuring that aviation organisations operate safely and in compliance with regulatory standards.
Through regular audits and stringent oversight, the CAA ensures that all approved organisations continue to meet the required standards, helping to ensure safety throughout the aviation industry.
