Review of ORS9 Decision 24 ‘Part ML MRO Parts’

For comments on the proposal that the CAA continues its existing policy to recognise certain EASA Form 1s as equivalent to CAA Form 1s in certain limited circumstances, namely for maintained parts released by the Original Equipment Manufacturer or authorised agent for use on aircraft falling within the scope of Part-ML, where a component cannot be repaired by an organisation holding a UK approval. Currently this is managed by CAA ORS9 Decision No. 24 that was issued in December 2022 with an expiry date of 31 December 2024. We proposed in the consultation to extend this policy until 31^st December 2029.

To achieve the policy objective the CAA proposed to amend the current end date within Acceptable Means of Compliance (AMC) to UK Regulation (EU) No. 1321/2014 (the UK Continuing Airworthiness Regulation), specifically in Part-145, and Part-ML to reflect the 2029 deadline. The amendments clarify that specified EASA Form 1s (only) are ‘equivalent documents’ as permitted by the terms of the regulation to which the AMC applies.

We received 31 responses.

We received strong support of (90%) for the CAA to continue its policy of recognising certain EASA Form 1s as equivalent to CAA Form 1s in certain limited circumstances.

We received significant support (77%) for the proposed wording of AMC1 ML.A.501(a)(ii) Classification and installation.

We received significant support (70%) for the proposed wording of AMC1 145.A.42(a)(i) Components.

We received comments suggesting that the new decision should be issued indefinitely. This is not considered a viable option as the UK would be unilaterally accepting parts from the EU without any sort of reciprocal arrangement. However, the CAA will review annually the need for the new decision and will continue encouragement for foreign organisations to obtain CAA approval. We will also seek to look at a more permanent solution for beyond December 2029.

We received several comments relating to widening the scope of the decision to include Part-CAMO/Part-M aircraft. This was not in the scope of the original decision and given the targeted requirement of the use of Article 4 (1A) within the UK Regulation (EU) No. 1321/2014, we are unable to extend this provision further outside the scope of Part-ML.

We received comments to clarify where the EASA approved organisation must be located. By means of a typographical correction made to the AMC to align with the original decision, we have clarified within the AMC that it must be an EASA approved organisation based within an EASA member state.

We have decided to issue a new decision following the policy set by the original Decision 24 and thereby amend the current end date to 31^st December 2029 within AMC to UK (EU) Regulation 1321/2014. The new decision will apply as follows:

• Provided that the component is not available from a CAA approved organisation, a maintenance organisation in a state with which the UK has a bilateral safety agreement, or an organisation based in a state with whose NAA the CAA has a working arrangement, components of Part-ML aircraft released on an EASA Form 1 by the component’s original equipment (or their approved agent) manufacturer based in an EASA member state may be fitted to a UK registered aircraft.