Acceptable Means of Compliance & Guidance Material to UK Regulation (EU) 1321/2014: Maintenance data and component installation

Overview

Acceptable Means of Compliance & Guidance Material to Regulation (EU) 1321/2014 as retained (and amended in UK domestic law) regarding maintenance data and the installation of certain aircraft components during maintenance.

The CAA is amending UK Regulation (EU) No. 1321/2014, including revision and correction of Part-M, Part-145, Part-T, Part-ML, Part-CAMO and Part-CAO as regards maintenance data and the installation of certain aircraft components during maintenance.

This document presents the proposed changes to the AMC and GM material associated with the rule changes described above together with background and explanatory information regarding this consultation.

These amendments are required as a consequence of amendments to UK Regulation (EU) No. 748/2012 which will be revised to:

• Remove the requirement to certify the conformity of new components with their design data when non-conformity of these components will have a negligible effect on the safety of the operation of the aircraft, and to permit their installation in type-certified products without the issuance of a CAA Form 1 or equivalent.
• Clarify the obligations of the type-certificate holders to produce a standardised set of instructions for continued airworthiness on how to maintain their product or part to ensure it remains airworthy for the entirety of its life. 

In order to achieve the same objective of proportionality and efficiency as detailed above, and to ensure consistency in terminology, UK Regulation (EU) No. 1321/2014 will also be amended to:

• Permit the installation of certain parts during maintenance (for which their effect on the safety of the operation of the aircraft is negligible in case of non-conformity with their design data) and to maintain and certify these parts without the requirement for the issuance of a CAA Form 1.
• Define 'maintenance data' to ensure consistency across UK Regulation (EU) No.748/2012 and UK Regulation (EU) No. 1321/2014.

The CAA expects the results of such an amendment to reduce the regulatory burden on maintenance organisations that use these parts during their maintenance work without decreasing the level of safety.

It also expects, through establishing the ICA as part of the TC, increased safety benefits due to clarity and availability of all required maintenance data. 

Our independent conclusion is that the legal changes to UK Regulation (EU) No. 1321/2014 and UK Regulation (EU) No. 748/2012 should closely follow what has been published by EASA and will be published, together with the accompanying AMC & GM, in the first quarter of 2023.

AMC and GM

AMC are means by which the requirements in the Implementing Rule and the Essential Requirements of the Basic Regulation to which it relates can be met. However, entities may show compliance by other means. 

An entity may choose to offer an alternative means of compliance (AltMOC) which must be reviewed and accepted by the CAA. However, it is important to note they will lose the presumption of compliance provided by the CAA AMC so it is essential for the operator to demonstrate that the AltMOC meets the intent of the Implementing Rule and the Essential Requirements of the Basic Regulation. 

GM is non-binding and provides explanatory and interpretation material on how to achieve the requirements in the law and the AMC. It contains information, including examples, to assist the applicant with the interpretation of the legislative provisions.

This consultation

As a consequence of the above rule changes, and in support of them, the CAA is also amending the accompanying Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Part-M, Part-145, Part-T, Part-ML, Part-CAMO and Part-CAO of UK Regulation (EU) No 1321/2014.  

This AMC & GM consultation document relates only to Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Part-M, Part-145, Part-T, Part-ML, Part-CAMO and Part-CAO of UK Regulation (EU) No 1321/2014.

The AMC and GM material being consulted on contains amendments relating to the classification, installation, and release of components; the definition of maintenance data; the use of Information, Communication and Technology (ICT) for remote audits; and editorial corrections.

• AMC/GM to Part M
• AMC/GM to Part 145
• AMC/GM to Part CAMO
• AMC/GM to Part CAO
• AMC/GM to Part ML
• AMC/GM to Part T

Related consultations  

Alongside this consultation, is a separate AMC and GM consultation proposing changes to the AMC and GM to Annex I (Part-21) of UK Regulation (EU) No 748/2012 regarding instructions for continued airworthiness, the production of parts to be used during maintenance and the consideration of ageing aircraft aspects during certification.  

• Acceptable Means of Compliance & Guidance Material to Regulation (EU) 748/2012 as retained (and amended in UK domestic law) regarding instructions for continued airworthiness, the production of parts to be used during maintenance and the consideration of ageing aircraft aspects during certification

Why your views matter

It is important to the CAA that everyone has an opportunity to voice their opinion on matters that could affect them. There is also a legal requirement to consult when creating or amending AMC and GM, due to the legal status of these documents.

We welcome comments from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry, whether as an aviator, aviation consumer and/or provider of related products and services.

How to respond

This consultation will close on 11 February 2023. We cannot take into account comments received after this date. We will assume that all responses can be published once the consultation has closed. There is an option to request for your name to remain private, but in any event your email address will never be published.

Please submit your comments using the survey link below. 

What happens next

At the end of the response period, we will review and publish each comment and submission received.

Your feedback will be used to refine the AMC and GM and guide the development of the regulatory changes.