How to Ensure Continuing Airworthiness Records Compliance with EASA Part ML

Introduction

Part ML is applicable from 24 March 2020 – Here I look at the obligations to ensure compliance with the regulatory obligations.

Note 1: There is no Quality System directly embedded within these regulations so the oversight will come from either a Part CAMO or Part CAO Organisation.

Note 2: There is no Safety Management System (SMS) applicable to Part ML which essentially concerns aircraft operated only for private purposes below the threshold of 2730 kg.

ML.A.305 Aircraft Continuing-Airworthiness Record System

At the completion of any maintenance, the certificate of release to service (CRS) required by point ML.A.801 shall be entered in the aircraft continuing airworthiness record system.

Each entry shall be made as soon as possible but not later than 30 days after the day of the completion of the maintenance task.

What does Part ML Aircraft Continuing Airworthiness Records (CAW) require?

The aircraft continuing airworthiness records shall consist of:

a) An aircraft logbook,

b) Engine logbook(s) or engine module log cards,

c) propeller logbook(s) and

d) log cards, for any service-life-limited component, as appropriate.

Note: The aircraft type and registration mark, the date together with the total flight time and flight cycles and landings, shall be entered in the aircraft logbooks.

The aircraft continuing airworthiness records shall contain:

a) The current status of ADs and measures mandated by the competent authority in immediate reaction to a safety problem;

b) The current status of modifications, repairs and other (Design Approval Holder (DAH)) - Maintenance Recommendations;

c) The current status of compliance with the Aircraft Maintenance Program (AMP);

d) The current status of service-life-limited components;

e) The current mass and balance report;

f) The current list of deferred maintenance.

In addition to the authorised release document, EASA Form 1, as set out in Appendix II of Annex I (Part-M), or equivalent, the following information relevant to any component installed, such as the engine, propeller, engine module or service-life-limited component, shall be entered in the appropriate engine or propeller logbook, engine module or service-life-limited component log card:

a) The identification of the component;

b)The type, serial number and registration, as appropriate, of the aircraft, engine, propeller, engine module or service-life-limited component to which the particular component has been fitted, along with the reference to the installation and removal of the component;

c) The date together with the component’s accumulated total flight time, flight cycles, landings and calendar time, as relevant to the particular component;

d) The current status of service-life-limited.

The person or organisation responsible for the management of continuing airworthiness and tasks pursuant to point ML.A.201, shall control the records as detailed in point ML.A.305 and present the records to the competent authority upon request.

(All entries made in the aircraft continuing airworthiness records shall be clear and accurate. When it is necessary to correct an entry, the correction shall be made in a manner that clearly shows the original entry.)

An owner shall ensure that a system has been established to keep the following records for the periods specified:

a) All detailed maintenance records in respect of the aircraft and any service-life-limited component fitted thereto, until such time as the information contained therein is superseded by new information equivalent in scope and detail but no less than 36 months after the aircraft or component has been released to service;

b) The total time in service, this is to say hours, calendar time, cycles and landings, of the aircraft and all service-life-limited components, for at least 12 months after the aircraft or component has been permanently withdrawn from service;

c) The time in service, this is to say hours, calendar time, cycles and landings, as appropriate, since the last scheduled maintenance of the component subjected to a service life limit, at least until the component scheduled maintenance has been superseded by another scheduled maintenance of equivalent work scope and detail;

d) The current status of compliance with the AMP at least until the scheduled maintenance of the aircraft or component has been superseded by another scheduled maintenance of equivalent work scope and detail;

e) The current status of ADs applicable to the aircraft and components, at least 12 months after the aircraft or component has been permanently withdrawn from service;

f) Details of current modifications and repairs to the aircraft, engine(s), propeller(s) and any other component vital to flight safety, at least 12 months after they have been permanently withdrawn from service.

Additional Notes from AMC

Any other forms different from a logbook/log card of keeping the below information could be acceptable. (For example, that could be in paper form, a spreadsheet or an IT system.)

If the IT system is the only record-keeping system, it should have at least one backup system, which should be regularly updated.

Each terminal should contain programme safeguards against the probability of unauthorised personnel altering the database.

Note: A log card and status for components other than propeller and engines could be combined in a single document.

If the AD is generally applicable to the aircraft or component type but is not applicable to the particular aircraft, engine, propeller or component, then this should be identified as well as the reason why it is not applicable.

There is no need to list those ADs that are superseded or cancelled.

Note: The current status of ADs should be sufficiently detailed to identify the complied AD and/or the due limit.

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