Regulatory perspective on paperless support in

Continuing Airworthiness Compliance

Rosa Tajes Regulations OfficerAtlanta, 16-18 November 2015

TE.GEN.00409-001

IATA 2nd RFID & Paperless Technical Operations Conference

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Contents

EASA regulatory framework

Requirements for continuing airworthiness and maintenance records

Summary

EASA regulatory

framework

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Facts and figures

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Scope of competences

5

ATM/ANSAerodromes3rd CountryOperations

Operations & FCL

Airworthiness

EASA Safety Regulator

Safety significantly affects all aviation domains:

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Partnership with EU Member States

6

Member states

Implementing EU Legislation

Oversight of national organisationsProduction

Maintenance

OPs/Licencing

Training

ATM

Aerodromes

Drafting implementing rules

Oversight of Member States

Aircraft and products certification

Safety of non-EU operations

Approval of non-EU organisationsProduction

Maintenance

Training

ATM

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Continuing airworthiness regulations

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Regulation (EU) 1321/2014, continuing airworthiness of aircraft

on the approval of organisations and personnel involved in these tasks

Part- M: Continuing airworthiness requirements

Part-145: Maintenance organisations approvals

Part-66: Certifying staff

Part-147: Maintenance training

organisations

Aircraft continuing airworthiness records

Aircraft maintenance records

Requirements for

continuing airworthiness

and maintenance records

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Why?

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Source of information on accident/ incident investigation

Global requirement (ICAO Annex 6 standard)

Necessary to support the airworthiness status of the aircraft

Continuing airworthiness and maintenance records requirements

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M.A.305 applies to operators and provides the elements of the continuing airworthiness records system

M.A.614 and 145.A.55 apply to maintenance organisations and establishes the requirements of the maintenance records system

Paper and electronic systems are possible, although guidance for electronic systems is limited

Information and records

required

Time that the records need

to be kept

Storage and protection conditions

Transfer to the next operator or customer

RMT.0276 : Technical records

Affects M.A.305

NPA 2014-04 under consultation until June 2014

Review of the comments

Opinion to be issued mid-2016

Proposes guidance on the use of information technologies and/or digitised records to establish the continuing airworthiness records system.

Includes the following minimum requirements for the system:

To ensure the integrity and accuracy of the record

To have safeguards against alteration of the data.

To be maintained against technological obsolescence.

To provide assurance that the data has not been modified after creation.

To be capable of retrieval of records within a reasonable time period.

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AMC to Appendix II to Part-M

AMC to Appendix II to Part-M: EASA form 1, contains extensive guidance:

Electronic system generating the EASA form 1

Electronic signature

Electronic exchange of the EASA form 1.

This guidance could also be used as reference for any other electronic records system

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AMC to Appendix II to Part-M

guarantee secure access for each certifying staff

ensure integrity and accuracy of the data

be active only at the location where the part is being released with an EASA Form 1

not permit to sign a blank form

Include safeguards against alteration

provide for a ‘personal’ electronic signature, identifying the signatory

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Electronic system generating the EASA form 1 should:

AMC to Appendix II to Part-M

Electronic signature

it is uniquely linked to

the signatory

it is capable of identifying the signatory

it is created using means under signatory’s sole

control

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data in electronic formwhich serves as a method ofauthentication

National or Europeanrequirements may apply

Directive 1999/93/EC,

Regulation (EU) 910/2014

AMC to Appendix II to Part-M

The exchange system shall:

voluntary basis and be agreed by both parties

provide high level of digital security

provide traceability of data back to its source

ELECTRONIC EXCHANGE SYSTEM

Electronic exchange shall include:

all data contained in the EASA form 1

data required for authentication of the

certificate

data necessary for the electronic format

additional customer data

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Summary

EU regulation requires operators and maintenance organisations to keep records to show continuing airworthiness

Paper and electronic record systems are acceptable

Guidance for electronic systems may be found in AMC to Appendix II to part-M

RMT.0276 still under development will include additional guidance for electronic systems

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Many thanks