Maintenance Annex Guidance - Anac
Maintenance Annex GuidanceBetween theEuropean Aviation Safety Agency (EASA) for theEuropean UnionandAgência Nacional de Aviação Civil (ANAC) forBrazil0
THE MAINTENANCE ANNEX GUIDANCE (MAG) APPROVAL:THIS IS TO CERTIFY APPROVAL BY:Original signed by Dino IshikuraOriginal signed by Wilfried SchulzeAirworthiness SuperintendentAgência Nacional de Aviação CivilDate: 11 /06/2015Flight Standards Director (acting)European Aviation Safety AgencyDate: 11 /06/2015Page 1
Revision HistoryMaintenance Annex GuidanceRevisions to this guidance shall be approved by the Joint Sectorial Committeeon Maintenance. Revisions become effective upon signature of the reviseddocument.Revision#OriginalDateRevision DescriptionSigned onOriginal Edition of the MaintenanceAnnex GuidancePage 2
Table of ContentsIntroduction . 5Section A: Authority Interaction . 6I General . 71. Purpose . 72. Communications . 73. Technical Consultations and Interpretations and Resolution of issues between ANAC and EASA . 74. Joint Sectorial Committee on Maintenance (JSCM) . 85. Revisions . 8II Cooperation in Quality Assurance and Standardisation Activities . 9General . 91. Implementation of the EU-EASA Standardisation in EU Member States. . 92. EASA and Sampling Inspection System in Brazil (SIS) . 113. Surveillance Activities within ANAC . 134. ANAC and Sampling Inspection System in EU (SIS) . 14III Definitions . 18IV Specific Regulatory Requirements . 23General . 23V Special Conditions . 19VI Appendices . 19Appendix 1: EASA and ANAC contacts . 29Appendix 2: Technical contacts of Aviation Authorities: . 30Appendix 3: EASA Visit Report ANAC Regional Office (RO) (SIS Form 10 CAN) . 30Appendix 4: EASA Visit Report AMO (SIS Form 8 CAN) . 36Appendix 5: ANAC Visit Report Member State NAA (SIS Form 10 EU) . 39Appendix 6: ANAC Visit Report AMO (SIS Form 8 EU) . 43Section B: Approval process for Brazilian Based Approved Maintenance Organisations. 46Introduction . 47I. Initial Approval Process . 471. ANAC actions . 472. Applicant actions . 473. ANAC/EASA actions . 47II. Continuation Process . 4871. ANAC Action.4872. Applicant actions .4873. ANAC/EASA actions .487Page 3
4. EASA actions .4985. Surrender of approval .498III Amendment process . 4981. Applicant actions .4982. ANAC actions .4983. EASA Actions .509IV Suspension or Revocation . 501. Suspension . 502. Revocation . 503. EASA Actions . 504. Communication . 50V Appendices . 51Appendix 1: EASA Supplement Contents . 52Appendix 2: Example EASA Supplement.532Appendix 3: Application form (EASA Form 17) . 73Section C: Approval process for EU Based Maintenance Organizations . 7777Introduction . 77I Initial Approval Process . 771. Introduction . 772. NAA Action . 773. Applicant Action. 784. NAA/ANAC Actions . 78IIContinuation Process . 791. Introduction . 792. NAA Actions . 793. Applicant Actions . 794. NAA/ANAC actions . 805. ANAC actions . 806. Late Applications . 807. Surrender of approval . 80III Amendment process . 811. Applicant actions . 812. NAA actions . 813. ANAC Actions . 81IV Suspension or Revocation . 821. Suspension . 822. Revocation . 823. ANAC Actions . 824. Communication . 82V Appendices . 83Appendix 1: ANAC Supplement Contents . 83Appendix 2: Example ANAC Supplement . 84Page 4
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Introduction1.The Brazilian requirements for maintenance are contained in Brazilian CivilAviation Regulations (RBAC) 43 (Maintenance) and 145 (ApprovedMaintenance Organisations).2.The European Union requirements for maintenance are contained in theregulation (EC) No 216/2008 of the European Parliament and of theCouncil-, Commission Regulation (EC) No 2042/2003, Annex II Part 145,as amended (hereafter referred to as EASA Part 145) and the respectiveEASA Acceptable Means of Compliance (AMC) and Guidance Material.3.ANAC and EASA have established the differences between EASA Part-145and RBAC 43 and 145. These differences led to the establishment ofSpecial Conditions listed in Appendix B1 to Annex B to the Agreement. Anymaintenance organisation of one Party that has been certified by aCompetent Authority of that Party to perform maintenance functions shallbe required to have a supplement to its maintenance manual in order tocomply with the Specific Regulatory Requirements as per § 8 of Annex B.When it is satisfied that the supplement meets the Specific RegulatoryRequirements and the Special Conditions set out in Appendix B1, therespective Competent Authority shall issue an approval attestingcompliance with the applicable requirements of the other Party subject toscope of ratings and limitations not exceeding that contained in its owncertificate.4.This guidance, Maintenance Annex Guidance (hereinafter referred to asMAG), which is sub-divided into Sections A, B and C, details ANAC, EASA,Competent Authorities and applicant actions required to be taken in orderfor an ANAC Certificated RBAC 145 approved maintenance organisation(AMO) located in Brazil to maintain civil aeronautical products under thejurisdiction of a European Union Member State and for a EASA Part-145approved maintenance organisation located in the EU to maintain civilaeronautical products under the jurisdiction of ANAC, in accordance withthe Agreement on Civil Aviation Safety Between the European Union andBrazil and published in the Official Journal of the European Union.5.Under the leadership of the Joint Sectorial Committee on Maintenance(JSCM), EASA and ANAC have agreed to organize, as appropriate,reciprocal participation in each other’s internal standardization or qualitycontrol system.Page 6
Section A:Authority Interaction(Not applicable to the Industry)Page 7
I General1. PurposeThe purpose of this Section of the Maintenance Annex Guidance (MAG) isto detail the interface procedures and activities between Agência Nacionalde Aviação Civil (ANAC), the European Aviation Safety Agency (EASA) andNational Aviation Authorities (hereafter “NAA”) of the EU member statesrequired to implement the Annex B to the Agreement.NOTE: National Aviation Authority is the designation used in the EUsystem for the Competent Authority as defined in the Agreement.2. Communications2.1 Proposed significant revisions to the relevant laws, regulations,standards, acceptable means of compliance and guidance material whichmay affect the basis and the scope of this guidance, should be notified ina manner consistent with Article 8 of the Agreement. Accordingly, uponnotice of such changes ANAC or EASA may request a meeting to reviewthe need for amendment to this MAG.2.2 The list of contact points for the various technical aspects of the MAG,including communication of urgent issues is included in Appendix 1.3. Technical Consultations and Interpretations and Resolution of issuesbetween ANAC and EASA3.1 Technical ConsultationsANAC and EASA agree to consult as necessary to provide input whenrequested on interpretations and technical issues. The frequency of theseexchanges will depend upon the number and significance of the issues tobe discussed.3.2 Interpretations and Resolution of issues between ANAC and EASA3.2.1 ANAC and EASA agree to address interpretations and resolve issuesthrough consultation or any other mutually agreed-upon means. Everyeffort shall be made to resolve the issues at the lowest possible level.3.2.2 Issues that cannot be satisfactorily resolved between the ANACAirworthiness Superintendent and EASA Flight Standards Director on anad hoc basis shall be added to the agenda for the next formal JointPage 8
Sectorial orfurther3.2.3 Issues that cannot be resolved by the JSCM must be forwarded tothe Joint Committee for resolution (the Joint Committee is a jointexecutive level group responsible for effective functioning of theAgreement).4. Joint Sectorial Committee on Maintenance (JSCM)4.1 The JSCM, under the leadership of the ANAC’s AirworthinessSuperintendent and EASA’s Flight Standards Director shall meet at leastannually to ensure the effective functioning and implementation of AnnexB to the Agreement by reviewing the progress on implementation issuesand propose changes to this MAG when required. Meeting attendeesshould include the officials responsible for the technical coordination ofthis guidance and additional officials of ANAC, EASA, and the NAAs asneeded to address the meeting agenda items. At the discretion of thejoint leadership, staff and representatives of other appropriateorganisations may be invited to participate.4.2 The host is responsible for the meeting minutes and action items thatare centrally tracked.4.3 Significant audit findings, reports and recommendations resultingfrom standardisation and Sampling Inspection System (SIS) activities willbe submitted to the JSCM. During the JSCM, each party shall present itsintention for the next 12 month period.4.4 The JSCM shall report to the Joint Committee the issues resultingfrom differences the JS CM failed to resolve and shall ensure theimplementation of any decisions reached by the Joint Committee.4.5 The JSCM may setup a Joint Sectorial Maintenance Group (JSMG)comprised of representatives from both ANAC and EASA in charge of thereview of the implementation of the Agreement and propose revision ofthis MAG to the JSCM.4.6 The JSCM may sponsor subgroups to address specific technical issuesand make recommendations for amendment to the Agreement orrevisions to this guidance.5. RevisionsThe JSCM shall review this guidance as necessary. These revisionsbecome effective upon approval by the JSCM and shall be implemented,as applicable, within 90 days after the change has been published, unlessotherwise specified.Page 9
II Cooperation in Quality Assurance and StandardisationActivitiesGeneral1. In order to ensure the effective functioning and implementation ofAnnex B to the Agreement, continued understanding and compatibility ofeach other’s maintenance systems should be promoted by ANAC andEASA.2. To this end, ANAC and EASA shall consult and share information onquality assurance and standardisation activities and promote theparticipation in each other’s inspections and audits.3. These activities may include sampling inspections at each other’sapproved maintenance organisations to ensure the Competent Authorityis applying the procedures set forth in this MAG. ANAC and EASA maydecide to conduct these visits on a scheduled or unscheduled basis.1. Implementation of the EU-EASA Standardisation in EU MemberStates.1.1 Access to ReportsThe EASA Approvals and Standardisation Directorate shall, upon requestof ANAC, provide reports to the ANAC to record the fact that theStandardisation Inspection Team visits are being conducted and show thestatus of achieved maintenance standards of the NAAs.1.2 ANAC Involvement as ObserversANAC Technical Agents have the right to participate as an observer in theStandardisation Inspection Team visit schedule. The annual schedule isgoing to be raised as required by Regulation (EC) No. 628/2013. Ad hocinspections may also be called at short notice. The ANAC role is passiveand as part of the Inspection Team the ANAC observer shall follow theappropriate working procedures.1.3 Conduct of Inspections1.3.1 The ANAC contact point will be provided with the EASAStandardisation Inspection Visit schedule of visits raised annually and asamended. EASA Flight Standards Directorate publish the guidance forteam member qualification and the inspection procedures applicable to ateam carrying out a standardisation inspection of an NAA.Page 10
1.3.2 In order to assist EASA in planning and managing thestandardisation inspection visit schedule and teams, ANAC shall notify theEASA contact in writing two months in advance indicating which visitsANAC representatives wish to attend as observers.1.4 EASAVerification of AnnexBRequirements and ANAC Special ConditionsSpecificRegulatory1.4.1 EASA monitors the NAAs of the Member States to ensurecompliance with the terms of the Agreement namely the SpecificRegulatory Requirements and ANAC Special Conditions contained inAppendix B1 to Annex B. The audit schedule may not be synchronizedwith the EASA standardisation inspection schedule and will take intoaccount the ANAC SIS schedule in EU. Expected Visit frequency isnormally once every 2 years.1.4.2 During EASA verification of Annex B Specific RegulatoryRequirements and ANAC Special Conditions of Member State NAAs theform / report contained in Appendix 5 shall be used by EASA.1.4.3 The number of files to be sampled at the visited NAA should beproportional and statistically representative in relation to the number ofAMOs holding a RBAC 145 supplement approval in the EU Member State.2. EASA and Sampling Inspection System in Brazil (SIS)The EASA Flight Standards directorate responsible for standardisationshould establish a sampling visit schedule to check that the Agreement isbeing implemented in Brazil in accordance with its terms.2.1 Objectives2.1.1 To monitor ANAC's application of Annex B to the Agreement,ensuring that the Annex is applied in a consistent manner such that anyorganisation approved by ANAC in accordance with the provisions of theAgreement meets a standard equivalent to that required of an EASA Part145 organisation.2.1.2 To assist ANAC and the RBAC 145 Approved MaintenanceOrganizations (AMO) holding an EASA Part 145 Approval in understandingtheir obligations under the terms of the Agreement on Aviation Safetybetween the European Union and Brazil.2.2 Mode of Operation2.2.1 EASA SIS Teams need to visit selected ANAC Regional Offices andapplicable Brazilian AMOs on a regular basis to satisfy the Section A PartII paragraph 2.1 objectives.Page 11
2.2.2 When the EASA SIS Team perceives compliance problems with theAgreement, this guidance or the application of maintenance standards,such problems are to be reported on the applicable EASA Visit Report tobe presented to ANAC at the conclusion of the visit.2.2.3 During the course of the visit, the SIS Team may have cause toraise findings in accordance with the following:a) Non-compliance findings with regards to Specific RegulatoryRequirements and EASA Special Conditions contained in AppendixB1 to Annex BIn this case the EASA Flight Standards Directorate should reviewthe EASA Visit Reports and request ANAC to take the appropriateremedial actions in a timely manner. Findings can be raised at boththe ANAC Regional Office and / or visited AMO.b) ObservationsIn this case they must be communicated to the ANAC AirworthinessDepartment - Continued Airworthiness Branch (SAR – GGAC) duringthe visit. SAR - GGAC must ensure the necessary follow up actionsare taken by the applicable ANAC Regional Office and / or AMO.2.3 EASA SIS Team Composition2.3.1 Each SIS Team should consist of two experienced maintenancesurveyors, and can be selected from EASA staff with additional staff fromNAAs when there is a shortage of experienced maintenance surveyorsfrom EASA. Each team may include a third maintenance surveyorundergoing team familiarisation.2.3.2 The personnel assigned by ANAC Airworthiness Department Continued Airworthiness Branch (SAR – GGAC) shall accompany the SISTeam during the visit to ensure that no misunderstandings arise inrespect of perceived standards and interpretation of maintenanceregulations. The ANAC airworthinessinspector as focal point andresponsible for the particular organisation visited should join the team forthat visit in order to facilitate the on-site visit and provide backgroundinformation about the organization, as required.2.4 EASA SIS Team Visit ProgramEASA SIS Teams will visit ANAC Regional Offices and Brazilian AMOsholding an EASA Part 145 Approval at a frequency to ensure thatstandards are being achieved and therefore the frequency may vary inlight of experience. EASA Flight Standards directorate should determine avisit schedule and provide it to ANAC. The final dates of a specific visitshould be provided to ANAC Airworthiness Department - ContinuedAirworthiness Branch (SAR – GGAC) at least 2 months in advance. ANACis expected to make every effort to both receive and cooperate with theteam.Page 12
2.5 The Selection of ANAC Regional Offices (RO) to be visited2.5.1 EASA Flight Standards directorate will determine the SIS visitschedule using objective criteria and risk analysis. The following list is notexhaustive but may illustrate the main criteria used to select a region /Regional Office to visit.a) ROs that have large concentration of ANAC approvedmaintenance organisations may be used as an indication ofbusiness carried out in that area and a selection of approvalsused to give a sample of that RO.b) Where EASA has received a number of reports of non-compliancein relation to organisations from a RO, this could indicate aproblem and need for a visit.c) Previous EASA sampling inspections reports that indicate aparticular RO may be of concern to EASA.d) The scope of individual approvals may be used to carry out a riskanalysis and indicate where safety could be most at risk.2.5.2 In addition a review of occurrences reported to EASA may be usedas an indicator of potential problem areas. Occurrence reports may bedrawn from the following areas and used to make a selection:a) EU Member States NAAs.b) Operators within the EU.c) Approved and unapproved organisations within the EU.d) Approved organisations within Brazil2.6 EASA SIS Procedures2.6.1 SIS Teams normally visit Brazil for one week. The EASA FlightStandards coordinator responsible for International Standardisation mustliaise with ANAC national and regional coordinators to organize the visitschedule. ANAC will make every effort to cooperate with the SIS team.2.6.2 At the start and end of each visit, ANAC shall be briefed regardingthe visit.2.6.3 The SIS Team should complete an EASA Visit Report RO (Section Aof this MAG, Appendix 3) in respect of each Regional Office visited and anEASA Visit Report AMO (Section A of this MAG, Appendix 4) in respect ofeach organisation visited. ANAC National or Regional Coordinator, asapplicable, should also sign the EASA Visit Report RO to indicate that thereport has been seen, adding any comment he/she wishes against eachfinding, and if necessary, disagreement with the non-compliancefinding(s) and / or observations. Signature by ANAC National or RegionalCoordinator only means that the findings have been seen.Page 13
2.6.4 The SIS Team may have cause with some organisations to raisenon-compliance Level 1 findings as defined by EASA Part-145 Section B.In this case, use the EASA Visit Report AMO to record the finding(s). TheANAC Regional Office must carry out the necessary follow up actions.2.6.5 After each visit, the International Standardisation Coordinator mustdebrief the EASA Manager responsible for Maintenance.2.7 Resolution of SIS Team Findings2.7.1 The EASA Flight Standards Directorate should review the EASA VisitReport RO and request ANAC to take the appropriate remedial actions in atimely manner.2.7.2 The visited ANAC Regional Office must take action on all the EASAVisit Report AMO non-compliance findings raised following the visit. Actionshould be taken directly with the affected organisation. This may involveremoving the organisation from the EASA list. EASA Flight StandardsDirectorate must be kept informed of the actions taken by ANAC.2.7.3 Review general observations contained in EASA Visit Report withANAC to consider possible corrective measures to ensure standardscompatible with EASA Part-145. Follow-up will be accomplished by ANACand reported to EASA for closure.3. Surveillance Activities within ANAC3.1 Access to Reports.The ANAC Airworthiness Department - Continued Airworthiness Branch(SAR – GGAC) shall, upon request of EASA, provide repo
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