Can AMO Part 145 perform CMM level work ??

I have noticed many people failed to understand it properly ! Yes and No! Check the below post to find out what is the regulatory requirement and the right process.

To ensure compliance with regulatory and manufacturer requirements, the following process must be adhered to for a Part 145 Maintenance, Repair, and Overhaul (MRO) organization performing Component Maintenance Manual (CMM) level work:

1.Authorization from the Original Equipment Manufacturer (OEM):

? A Part 145 MRO must first obtain explicit permission from the OEM to perform CMM-level work. This authorization ensures that the MRO has demonstrated adequate skills, specialized tooling, and proper training to carry out the tasks in accordance with the standards outlined by the OEM.

? This step is essential to comply with EASA Part 145.A.45(b) and FAA 14 CFR 145.201(c), which require organizations to be equipped and competent for the maintenance they undertake.

2.Compliance with Design and Airworthiness Requirements:

? The maintenance performed must align with the applicable regulatory frameworks, such as EASA Part 21 Subpart M and FAA 14 CFR Part 21, ensuring that repairs or modifications do not deviate from the approved design specifications.

3. Repair and Design Approval Form (RDAF) from Airbus:

? After receiving the OEM’s approval, the MRO must secure an RDAF from Airbus to demonstrate compliance with airframe release requirements. This document, previously known as the Repair Design Approval Sheet (RDAS), is a formal approval from Airbus confirming that the proposed maintenance or repair meets the necessary design and safety standards.

? The RDAF is issued in compliance with EASA Part 21.A.435 and FAA AC 120-77, which govern repairs or modifications on certified airframes.

4.Verification and Documentation:

? The MRO must maintain complete records of OEM authorization, RDAF, and any additional regulatory approvals, as stipulated under EASA Part 145.A.55 and FAA 14 CFR 145.219.

? These records ensure traceability and demonstrate compliance during audits by aviation authorities.

Summary:

To perform CMM-level work on Airbus aircraft, a Part 145 MRO must:

1.Obtain explicit authorization from the OEM to ensure compliance with regulatory requirements (e.g., EASA Part 145, FAA 14 CFR 145).

2. Secure an RDAF from Airbus to confirm compliance with airframe design and safety standards.

3.Adhere to documentation and traceability requirements under global regulatory frameworks to maintain airworthiness and accountability.

By following these steps, the MRO ensures that all activities meet both regulatory standards and the manufacturer’s specifications, safeguarding the aircraft’s airworthiness and operational integrity.