Review of ORS9 Decision 24 ‘Part ML MRO Parts’

Overview

The UK Civil Aviation Authority (CAA) proposes to continue its existing policy to recognise certain EASA Form One documents as equivalent to CAA Form One documents 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.

The objective of the proposal is to clarify that applicable parts issued with EASA Form One documents pursuant to the effect of the ORS9 Decision referred to above may continue to lawfully be fitted as standard to aircraft within the scope of Part ML from 1 January 2025 onwards. The market conditions have not changed within the UK substantially since the original decision was taken in December 2022 and after consideration of any available alternative options, this extension is being proposed.

To achieve the policy objective the CAA is proposing to amend the current end date within Acceptable Means of Compliance (AMC) to UK Regulation (EU) No. 1321/2014, specifically in Part-145, and Part-ML. 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.

In doing so the UK CAA intends to issue a renewed ORS9 decision extending the current date for 5 years until till 31 December 2029.

These amendments are required because the current ORS9 decision that was issued by the CAA will expire on the 31 December 2024. The AMC needs to reflect the new expiry date and continued recognition of the EASA Form 1s in these limited circumstances to prevent disruption of access to maintained parts. Guidance Material would also be updated to reflect the new expiry date.

During the period of any extension, the CAA will consider what the further longer-term requirements of the general aviation community may be in this area.

This consultation:

The AMC consultation document relates to the articles within UK Regulation (EU) 1321/2014, on the continuing airworthiness of aircraft and aeronautical products, parts and appliances.

The material being consulted on contains amendments to the AMC to Part-145 (145.A.42), and Part-ML (ML.A.501) Continuing Airworthiness – UK Acceptable Means of Compliance for UK Regulation (EU) No. 1321/2014 as assimilated in UK law.

How to respond:

Responses to this consultation can be submitted by no later than 12 November 2024. If you wish to provide feedback please use the online survey.

Why your views matter

It is important to the CAA that industry 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 due to the legal status of these documents.  Consequently, this consultation is an opportunity to provide your views and comments on this proposed AMC amendment.