Summary of the EASA Aircraft Paint and Certification Process

Sofema Aviation Services (SAS)?www.sassofia.com considers the regulatory & aircraft paint and certification process.

Introduction?

The process of painting and refinishing aircraft involves strict procedures and controls to ensure airworthiness and compliance with safety regulations.

• A change to the external livery (e.g. painting or adhesive films) of an aircraft is considered a change to the Type Design and DOA holders having the scope “External schemes, placards and markings” within their Terms of Approval are entitled to perform this activity.

o???EASA Part-21 Subpart D?covers changes to type certificates and supplemental type certificates, which include modifications to an aircraft’s painting scheme. Applicants must demonstrate that the design change complies with applicable airworthiness and environmental protection requirements

• Demonstration of compliance for several technical disciplines might be required. For example:

o???In the field of structures, the change of external livery could introduce a corrosion initiator on a metallic aircraft, alter the conductivity behaviour during a lightning strike on composite aircraft, and adversely affect (i.e. increase) the surface temperature when dark colours or different paint types are used, adversely affect UV protection capability of composite structure, influence the mass balance of the control surfaces.

o In the field of cabin safety, marking requirements, colour contrast and emergency markings need to be considered.

o???In the case of the use of adhesive films or foils, it must be ensured that they cannot rip off in flight, especially not in large pieces.

o In the field of flight performance, static port measurements and information used for operation in RVSM (“Reduced Vertical Separation Minimum”) could be affected.

o???Finally, regarding effects on ICA, existing approved maintenance requirements may necessitate that the adhesive film is either removed, so inspections such as GVI (General Visual Inspection), DET (Detailed inspections), Dye Penetrant or UT (Ultrasonic Testing) can be performed, or alternatively a change in inspection might be appropriate.

?Key Points

Maintenance Quality Control:

1. All painting and associated processes (stripping, refinishing, refurbishing) on aircraft with a Certificate of Airworthiness or Flight Permit must adhere to stringent quality control standards.

Assessment of Airworthiness:

1. Aircraft owners/operators and approved maintenance organizations must assess the proposed painting tasks for airworthiness implications based on the aircraft manufacturer’s guidelines and other specified precautions.

Certificate of Release to Service (CRS):

1. If deemed necessary, a CRS must be issued upon completion of the painting process. The signatory to the CRS takes full responsibility for the entire process, ensuring proper supervision, documentation, and adherence to specifications. The process includes ensuring no hazards are introduced, defining tasks through documented specifications, providing necessary guidance materials, and addressing potential issues like additional paint weight or corrosion.

Specialist Painting Organizations:

1. No specific approval is granted to painting organizations for airworthiness certification. Only organizations with maintenance approval or licensed aircraft engineers with relevant type ratings can issue a CRS.

Potential Hazards and Damages:

1. The guidelines outline various potential damages and hazards that must be avoided, including:Damage to structural integrity from improper preparation.Damage to transparencies, composites, and sealants from improper use of chemicals.Inadvertent deletion of critical markings and placards.Blockage of vents and openings and incorrect mass balance on flight control surfaces.Variations in surface profile and weight due to excessive paint thickness.

Finishing Work Requiring CRS:

1. Examples of work requiring a CRS include:Complete repainting or overcoating existing finishes.Reversion to bare metal.Repainting or refinishing critical surfaces such as control surfaces or lifting surfaces.Finishing of radomes, antennas, and composite materials.Any alterations to the helicopter main rotor and tail rotor blades or other critical parts.

Additional Notes:

• Minor surface repairs with minimal airworthiness implications do not usually require a CRS.

CS Stan (Not for CMPA Aircraft) – CS-SCO85a Aircraft Painting – applicable Non-CMPA & EL2

Exchange of an aircraft livery paint and decorative sticker scheme.

Purpose

This SC is for a full or partial exchange of the design of the external livery of an aircraft.

• Applicability/Eligibility – This SC applies to aeroplanes and to rotorcraft that are not complex motor-powered aircraft, and to any ELA2 aircraft.
• Furthermore, painting may be covered in the maintenance manual for the type in question.

Acceptable methods, techniques, and practices

• Paint/sticker materials to be used: by default, only materials (e.g. primer, filler, top coat, gel coat, decorative adhesive sticker, etc.) that have been approved to be used on a given aircraft through the existing applicable maintenance data (e.g. the AMM, supplemental maintenance manual, or any other ICAs that are applicable to the aircraft) shall be used.
• If some or all of the materials listed in the existing ICAs are either no longer available (obsolete) or not compliant with the applicable environmental protection requirements, then the following two options apply:

o???the use of alternate materials shall be approved in accordance with Part 21 or

o???materials may be used if they have been declared by the materials’ manufacturer(s) to be equivalent to the materials listed in the existing ICAs.

• Application processes for paint/sticker materials: any application processes/techniques that were approved by the TC/STC holder through the applicable maintenance data (e.g. the AMM, the SMM, or the equivalent ICAs) shall be followed.
• In any case, the aircraft pre-painting preparation tasks and the final checks (bounding, balance, etc.), if any, that were defined by the TC/STC holder shall be followed.

Note: Particular attention must be paid to not covering static ports, fuel vents, drainage and similar openings.

• Design of the external livery: when defining the design of the external livery, the following must be considered:
• Markings: each emergency exit and external door (if any) in the passenger compartment must be externally marked and readily identifiable from outside the aeroplane by:

o? ?A conspicuous visual identification scheme; and

o? ?A permanent decal or placard on or adjacent to the emergency exit that shows the means of opening the emergency exit, including any special instructions, if applicable.

o???Each placard and operating control for each emergency exit must be red in colour.

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