OTAC 39-3 - Air Safety Support International

United Kingdom Overseas Territories Aviation CircularOTAC 39-3Continued Airworthiness Management under anArticle 83bis Agreement - OTAR Part 39.61Issue 124 April 2009Effective: on issueGENERALOverseas Territories Aviation Circulars are issued to provide advice, guidance and informationon standards, practices and procedures necessary to support Overseas Territory AviationRequirements. They are not in themselves law but may amplify a provision of the AirNavigation (Overseas Territories) Order or provide practical guidance on meeting arequirement contained in the Overseas Territories Aviation Requirements.PURPOSEThis Overseas Territories Aviation Circular provides information and guidance on developing aMaintenance Programme required for an aircraft registered in a Territory and granted aCertificate of Airworthiness.RELATED REQUIREMENTSThis Circular relates to OTAR Part 39 Subpart F.CHANGE INFORMATIONFirst issue.ENQUIRIESEnquiries regarding the content of this Circular should be addressed to Manager PQS, AirSafety Support International, to the appropriate Director or Director-General of Civil Aviation orto any office of ASSI.OTAC s/n 045

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-31 Introduction1.1 This document is designed to assist organisations seeking OTAR Part 39Subpart F approval. It provides preliminary guidance material on interpretingthe requirements of EASA Part M where it forms the basis for compliancewith OTARs and, pecifically, approval under the requirements of OTAR Part39 Subpart F.1.2 It applies principally to an organisation seeking an OTAR Part 39 Subpart Fapproval where that organisation does not meet the eligibility requirementsof EASA for holding a Part M approval. OTAR Part 39.105(c) refers.1.3 For organisations that hold an appropriate EASA Part M approval, thisguidance document should assist in identifying those requirements to be metin order to comply with an OTAR Part 39 Subpart F approval.1.4 The references in the Compliance Table are based on the draft version ofOTAR Part 39 which was put to consultation in December 2009 (seeparagraph 2). Part 39 will be subject to further amendment following theconsultation and therefore the guidance in this OTAC is temporary and willbe updated following that amendment. In the meantime the consulation draftof Part 39 will remain available on the ASSI website.2 Document referencesOTAR Part 13 Issue 3OTAR Part 21 Issue 3.5 (consultation version) January 2009OTAR Part 39 Issue 5.4 (consultation version) December 2008OTAR Part 43 Issue 3.1 (consultation version) January 2009OTAR Part 145 Issue 3.1 (consultation version) January 2009EASA Part M M1 May 2006EASA Part M M2 March 2007EASA Part M M3 October 20083 Compliance tableThe following table identifies the applicable EASA requirements and their status inrelation to meeting the applicable requirements of OTARs.OTAC s/n 045 Issue 1 Page 2 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReference1 OTAR Part39 SubpartsB & C2 OTAR Part13OTAC 13-13 OTAR Parts21 SubpartC21 SubpartM39.55(b)(e)(j)39.6739.69EASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReferenceM.A.201 Responsibilities (a) 1,2,3(a) 4M.A.202M.A.301OccurrenceReportingContinuingAirworthinessTasks(b) 1,2(c)(d)(e) (i)(e) (ii)(f)(g)(h) 1,2,3(i)(j)Applicable.Applicable as varied for compliance withan OTAA approved MaintenanceProgramme; OTAR Part 39.61 refers.Applicable.Applicable as varied by OTAR Part 39.57.Applicable.Applicable.Not applicable OTAR Part 39.59(h)refers.Applicable as varied by OTAR Part39.51 (c).Not applicable, OTAR Part 39.57 applies.Not applicable, OTAR Part 39.51(c)applies.Not ApplicableApplicable as varied by requirement forOTAA access.Applicable as varied by compliance withOTAR Part 131.2.3.4.5 (i)(ii)5 (iii)(iv)Applicable.Applicable as varied by compliance withOTAR Part 21 Subpart M.Not applicable OTAR Part 39.55(b)applies.Applicable as varied by compliance withOTAR Part 39.55(j).Applicable as varied by compliance withOTAR Part 39.67, 39.69Not applicable - compliance with OTARPart 39.67(a)(1) and 21.19AMCM.A.201AMCM.A.202N/AVariation and ComplianceNotesNot applicable; requirementsof OTAR Part 39.55 (j) refers.(e)(ii) OTAR Part 39.59(h)refers to listing anycontractual supportarrangements – this will beincluded in issue 6 of Part 39.(f) reference to Appendix 1-this is considered applicableas varied by appropriatereference to the OTAA in lieuof competent authority.Applicable as varied bycompliance with OTAC 13-1.NoneOTAC s/n 045 Issue 1 Page 3 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReferenceEASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReferenceVariation and ComplianceNotes6.7.8.Applicable as varied by compliance withOTAR Part 21.73 and 39.55(i).Applicable.Applicable4 OTAR Parts39.55(b)39.55(j)39.615 OTAR Part39 SubpartC6 OTAR Part21 SubpartsC & MM.A.302M.A.303M.A.304MaintenanceProgrammeAirworthinessDirectivesData forModification andRepairs(a)(b)(c)(d) (i)(d) (ii)(d) (iii)(e)(f)(g)ApplicableApplicable as varied by OTAR Part39.61(b).Not Applicable – OTAR Part 39.61 applies.Not applicable – OTAR Part 39.61(g)applies.Applicable as varied by OTAR Part 39.61.Not applicable – OTAR Part 39.61 and39.63 applies.Applicable.Applicable.Applicable as varied by OTAR Part 39.61.AMCM.A.302Not applicable OTAR Part 39.67 & 39.69 applies N/A NoneNot applicable OTAR Part 21 Subparts C & MappliesN/ANot applicable: OTAC 39-6applies.None7 OTAR Part39 SubpartDM.A.305AircraftContinuingAirworthinessRecord System(a)(b) 1, 2(c)(d)(e)Applicable as varied by OTAR Part 43.105.Applicable as varied by OTAR Part 39Subpart D.ApplicableApplicableApplicableN/ANoneOTAC s/n 045 Issue 1 Page 4 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReferenceEASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReferenceVariation and ComplianceNotes8 OTAR Part39.79M.A.306OperatorsTechnical Log(f)(g)(h)1,2,3,4,5,6Applicable as varied by reporting to theapplicable OTAA.ApplicableApplicableApplicable as varied by OTAR Part 39Subpart DApplicable as varied by OTAR Part 39.79 andapproval by the applicable OTAA.N/ANone9 OTAR Part39 SubpartD10 OTAR Part39.5711 OTAR Part39.5712 OTAR Part39.55(e)13 OTAR Part21 SubpartsK & Q14 OTAR Part39.5715 OTAR Part39.5516 OTAR Part39.59OTAR PartM.A.307 Transfer ofAircraftContinuingAirworthinessRecordsApplicable as varied by OTAR Part 39.77 N/A NoneM.A.401 Maintenance Applicable as varied by OTAR Part 145AMC Applicable Option 1 & 2DataM.A.401M.A.402 Performance of Applicable as varied by OTAR Part 39.57AMC Not applicableMaintenanceM.A.401M.A.403 Aircraft defects Applicable as varied by OTAR Part 39.55(e) N/A NoneM.A.501 Installation Applicable as varied by OTAR Part 21 Subparts K &QM.A.502M.A.503M.A.504ComponentMaintenanceService LifeLimitedComponentsControl ofUnserviceableComponentsAMCM.A.501Not applicableNot applicableAMC Not applicableM.A.502Applicable. N/A NoneApplicable as varied by OTAR Parts 145.59 and Part21 Subparts K & Q.AMCM.A.504Not applicable under OTARPart 39OTAC s/n 045 Issue 1 Page 5 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReference21 SubpartsK & Q17 OTAR Part39.107(a)(4);39.107(b)(3)18 OTAR Part39.103OTAC 39-2;OTAC 39-319 OTAR Part39.10920 OTAR Part39.59EASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReferenceM.A.701 Scope Applicable and with additional compliance withapplicable OTARsM.A.702 Application Not applicable OTAR Part 39.103 and OTAC 39-3refersM.A.703M.A.704Extent ofApprovalContinuingAirworthinessManagementExposition(a)(b)(c)(a)(a) 1(a) 2(a) 3(a) 4(a) 5(a) 6(a) 7(a) 8Not applicable OTAR Part 39.109 refers.Not applicable OTAR Part 39.109 refers.ApplicableNote: The OTAR approval will be in the formof a certificate that will specify the capabilityand scope of the approval includingreferences to key documents.Applicable; this is known as the MaintenanceControl Manual under OTARs.Applicable as varied by compliance withapplicable OTARs.Applicable.Applicable as 2 varied by OTAR Part 39.59.Applicable as varied by OTAR Part 39.59.Not applicable; a list of nominated personnelto certify an OTAA Airworthiness StatusReport for C of A OTAR Part 21.175(e).Applicable.Applicable as varied by compliance withapplicable OTAR Parts.Applicable and with compliance to OTAR Part39.59(b)N/AAMCM.A.702N/AAMCM.A.704Variation and ComplianceNotesNoneNot applicableNoneApplicable as varied by OTARPart 39.59OTAC s/n 045 Issue 1 Page 6 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReferenceEASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReference(a) 9Applicable as varied by OTAR Part 39.61Variation and ComplianceNotes21 OTAR Part39.59(f)22 OTAR Part39.10523 OTAR Part39.59 and39.107(b) Not applicable - the Maintenance ControlManual is to be approved by the applicableOTAA; OTAR Part 39.59(b) refers.(c) ApplicableM.A.705 Facilities Applicable N/A NoneM.A.706M.A.707PersonnelRequirementsAirworthinessReview Staff(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)(a)(1)(a)(2)Applicable as varied by additionalcompliance with OTARs.Not applicable.Applicable as varied by additionalcompliance with OTARs.Not applicable.Not applicable.Applicable.Applicable excluding reference to (d).Applicable.Not applicable.Applicable as varied by this document.Is applicable however the approval ofEASA Part M Subpart I approval is not aspecific feature of OTARs. Arrangementsshould be made for appropriate qualifiedand experienced staff (that being equivalentto the Airworthiness Review Staff) to benominated for the completion of an OTAA Cof A Airworthiness Status Report andRecommendation Form commensurate withthe scope of approval OTAR Part 21.175(e)refers.Not applicable.AMCM.A.706AMCM.A.707Not applicableApplicable as varied by OTARParts 21.175 and OTAR Part39 Subpart C.OTAC s/n 045 Issue 1 Page 7 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReferenceEASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReference(b)(c)(d)(e)Applicable as varied by applicable OTAAoversight and approval.ApplicableApplicableApplicableVariation and ComplianceNotes24 OTAR Part39 SubpartsB, C, D andFM.A.708ContinuingAirworthinessManagement(a)(b) 1(b) 2(b) 3(b) 4(b) 5(b) 6(b) 7(b) 8(b) 9(b) 10(c)(c) 1(c) 2Applicable as varied by this document.Applicable.Not applicable – OTAR Part 39.63 applies.Applicable as varied by OTAR Part39.55(h) and (i).Applicable as varied by OTAR Part 145 and39Applicable as varied by OTAR Part 39.67.Applicable as varied by OTAR Part 39.57.Applicable as varied by OTAR Part 39.57.ApplicableApplicable.Applicable as varied by OTAR Part 39.81Not applicable: OTAR Part 39.57 refers.Not applicable: OTAR Part 39.57 refersNot applicable: OTAR Part 39.57 refersN/ANoneOTAC s/n 045 Issue 1 Page 8 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReferenceEASAPart MSubpart GReferenceTitle Variation and Compliance Notes EASA AMCPart-MReference25 M.A.709 Documentation Applicable as varied by OTAR Part 39.57 AMCM.A.70926 OTAR Part M.A.710 Airworthiness (a) 1, 2,AMC21 SubpartsReview3, 4, 7,M.A.710B, C and M8, 9(b)(c)OTAR Part39.67(a) 527 OTAR Part39.107 and39.10928 OTAR Part39.105M.A.711Privileges of theOrganisation(a) 6(a) 10(b)(c)(d)(e)(f)(g)(h)(a) 1, 2,3(b) 1, 2M.A.712 Quality System (a)(b) 1, 2,3(c)(d)Applicable as it relates to the process ofcompletion of the OTAA. AirworthinessSurvey Report Form for C of A OTARPart 21.175 (e) refers.Applicable as varied by compliance. withOTAR Part 39.67.Applicable as varied by compliance. withOTAR Part 21 Subparts C and M.Applicable as varied by compliance. withOTAR Part 21 Subpart B.Applicable.Applicable as varied by line 12.Not applicable; OTAR Part 21.181 refers.Not applicable; OTAR Part 21.175 (e)refers.Not applicable.Applicable as varied by OTAR Part21.175(e).Not applicable as varied by OTAR Part21.175(e)Applicable as varied by OTAR Part39.109.Not Applicable.Applicable.Applicable as varied by compliance withapplicable OTAR Parts.Applicable.Applicable to EASA approvedorganisations only.AMCM.A.710(d)AMC.M.A.711(b)AMC.712Variation and ComplianceNotesApplicable As varied by OTARPart 39 Subpart CApplicable As varied by OTARPart 21.175(e)Not applicable, refer to OTARPart 21.181Generally applicable;alternative arrangementsmust be agreed by theapplicable OTAA.Generally applicable;alternative arrangementsmust be agreed by theapplicable OTAA.OTAC s/n 045 Issue 1 Page 9 of 10

Continued Airworthiness Management under an Article 83bis Agreement - OTAR Part 39 Subpart F OTAC 39-3LineRefOTAR&OTACReference29 OTAR Part39.59(a)(b)30 OTAR Part39 SubpartD31 OTAR Part39.107,39.111,39.11332 OTAR Part39.113EASAPart MSubpart GReferenceM.A.713Title Variation and Compliance Notes EASA AMCPart-MReferenceChanges to theApprovalContinuingAirworthinessOrganisationM.A.714 Record Keeping (a)M.A.715ContinuedValidity ofApproval(e) Not Applicable in case of contractualarrangements for OTAR Part 39 approval(f) Not ApplicableApplicable as varied by notification to applicableOTAA.(b)(c)(d)(e)(f)(g)(a)(a) 1(a) 2(a) 3M.A.716 Findings (a)(b)(c)Applicable as varied by OTAR Part 39Subpart D.Applicable as varied by OTAR Part21.175(e) refers.Applicable.Applicable.Applicable.Applicable.Applicable.Not applicable, OTAR Part 39.111 refers.Applicable as varied by OTAR Part39.107.Applicable.Applicable.Applicable as varied by applicablecompliance with OTARs.Applicable as varied by applicablecompliance with OTARs.Applicable as varied by applicablecompliance with OTARs and notificationto applicable OTAA.N/AAMCM.A714N/AN/AVariation and ComplianceNotesNoneApplicable as varied by OTARPart 39.57NoneNoneOTAC s/n 045 Issue 1 Page 10 of 10