
Release to Service - What is a “release to service”?
Reading through Commission Regulation (EC) No. 2042/2003, a clear definition of the term “release to service” is not given. This term is also not defined in EASA Certification Specification “Definitions & Abbreviations” (CS-DEF). Going through the homepages of various Civil Aviation Authorities I did find the following wording: Ref.: CAA New Zealand, Advisory Circular AC00-5: A primary purpose of the authorised release certificate is to declare the airworthiness of maintenance work undertaken on an item (other than an aircraft), and to certify that the maintenance work has been performed in accordance with the prescribed regulatory requirements. Whereby this statement is intended for component maintenance, we can transform it to aircraft maintenance as well in the following way: A primary purpose of the release certificate is to declare the airworthiness of maintenance work undertaken on an aircraft, and to certify that the maintenance work has been performed in accordance with the prescribed regulatory requirements. - What are the legal requirements for a “release to service”?
In Regulation (EC) No. 2042/2003 we find two places where the subject “release to service” is defined. The first reference is in Part-M (M.A. Subpart H) and the second reference is in Part-145 (145.A.50). - Part-M (M.A. Subpart H):
M.A.801(a) defines: Except for aircraft released to service by a maintenance organisation approved in accordance with Annex II (Part-145), the certificate of release to service shall be issued according to this Subpart; M.A.801(b) defines: No aircraft can be released to service unless a certificate of release to service is issued at the completion of any maintenance, when satisfied that all maintenance required has been properly carried out, by: - appropriate certifying staff on behalf of the maintenance organisation approved in accordance with Section A, Subpart F of this Annex (Part M); or
- certifying staff in compliance with the requirements laid down in Annex III (Part-66), except for complex maintenance tasks listed in Appendix VII to this Annex for which point 1 applies; or
- by the Pilot-owner in compliance with point M.A.803;
- Part-145 (145.A.50):
145.A.50(a) defines: A certificate of release to service shall be issued by appropriately authorised certifying staff on behalf of the organisation when it has been verified that all maintenance ordered has been properly carried out by the organisation in accordance with the procedures specified in point 145.A.70, taking into account the availability and use of the maintenance data specified in point 145.A.45 and that there are no non-compliances which are known to endanger flight safety. 145.A.50(b) defines: A certificate of release to service shall be issued before flight at the completion of any maintenance. With these requirements it is made clear that a release to service is required after any maintenance. But, what is “maintenance”? - What is “maintenance”?
Regulation (EC) No. 2042/2003 Article 2 (h) defines “maintenance” in the following way: ‘maintenance’ means any one or combination of overhaul, repair, inspection, replacement, modification or defect rectification of an aircraft or component, with the exception of pre-flight inspection. And, what is “pre-flight inspection”? Regulation (EC) No. 2042/2003 Article 2 (j) defines “pre-flight inspection” in the following way: ‘pre-flight inspection’ means the inspection carried out before flight to ensure that the aircraft is fit for the intended flight. This shows us that for “pre-flight inspection” a “release to service” is not required. - What should be the minimum content of a “release to service”?
Again, we find information in Part-M. With respect to that, Part-145, i.e. 145.A.50, is not that specific. The Acceptable Means of Compliance (AMC) to those two Parts, i.e. AMC M.A.801(f) and 145.A.50(b), give additional and more detailed guidance. - Part-M (M.A. Subpart H):
M.A.801(f) defines: A certificate of release to service shall contain as a minimum: - basic details of the maintenance carried out; and
- the date such maintenance was completed; and
- the identity of the organisation and/or person issuing the release to service, including:
- the approval reference of the maintenance organisation approved in accordance with Section A, Subpart F of this Annex (Part M) and the certifying staff issuing such a certificate; or
- in the case of point M.A.801(b)2 or M.A.801(c) certificate of release to service, the identity and if applicable licence number of the certifying staff issuing such a certificate;
- the limitations to airworthiness or operations, if any.
- AMC to Part-M and AMC to Part-145:
Both AMC require a specific “statement” AMC M.A.801(f) defines two possible statements: - The aircraft certificate of release to service should contain the following statement:
- 'Certifies that the work specified except as otherwise specified was carried out in accordance with Part-M and in respect to that work the aircraft is considered ready for release to service'.
- For a Pilot-owner a certificate of release to service should contain the following statement:
‘Certifies that the limited pilot-owner maintenance specified except as otherwise specified was carried out in accordance with Part M and in respect to that work the aircraft is considered ready for release to service’. 145.A.50(b) requires the following statement: - The certificate of release to service should contain the following statement:
‘Certifies that the work specified except as otherwise specified was carried out in accordance with Part-145 and in respect to that work the aircraft/aircraft component is considered ready for release to service’. - What to do if not all maintenance could be performed?
Also here we have the possibility to issue a “release to service”. What we must ensure in such a case is the following: M.A.801(g) By derogation from paragraph (b) and notwithstanding the provisions of paragraph (h), when the maintenance prescribed cannot be completed, a certificate of release to service may be issued within the approved aircraft limitations. Such fact together with any applicable limitations of the airworthiness or the operations shall be entered in the aircraft certificate of release to service before its issue as part of the information required in paragraph (f)4; 145.A.50(c) New defects or incomplete maintenance work orders identified during the above maintenance shall be brought to the attention of the aircraft operator for the specific purpose of obtaining agreement to rectify such defects or completing the missing elements of the maintenance work order. In the case where the aircraft operator declines to have such maintenance carried out under this paragraph, paragraph (e) is applicable. - Short Summary
As a short summary we can state the following: - A “release to service” does not certify the airworthiness of the complete aircraft. The “release to service” only certifies that the work was performed according to the regulations and with respect to that work we consider the aircraft as ready for release to service.
- A “release to service” is necessary after any maintenance on aircraft or component.
- The “release to service” can be issued by:
- appropriately authorised certifying staff on behalf of the maintenance organisation (Part-145 or Part-M Subpart F), or
- independent certifying staff, except for complex maintenance tasks, or
- the pilot-owner, if
- this person holds a valid pilot licence, and
- own the aircraft, either as sole or joint owner, and
- for any privately operated non-complex motor-powered aircraft of 2 730 kg MTOM and below, sailplane, powered sailplane or balloon, and
- the scope of the limited Pilot-owner maintenance shall be specified in the aircraft maintenance programme
- The “release to service” must contain
- the appropriate “release to service” statement, and
- basic details of the maintenance carried out, and
- the date such maintenance was completed, and
- the identity of the organisation and/or person issuing the release to service, and
- the limitations to airworthiness or operations, if any.
ATTENTION: In any case, a “release to service can not be issued if there is any non-compliance which is known to endanger flight safety. In such a case it is also not allowed to issue a “limited release to service”.
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Notices of Proposed Amendments (NPAs)TITLE
| DATE PUBLISHED | END OF COMMENT
| | Avionics | 2009-12-03 | 2010-03-03 | Systematic review and transposition of existing FAA TSO standards for parts and appliances into EASA ETSO | 2009-10-20 | 2010-01-20 | Cabin Air Quality onboard Large Aeroplanes
| 2009-09-28 | 2010-09-01
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Upcoming EASA Event19 January 2010 in Cologne, Germany ICA Workshop (Instructions for Continued Airworthiness - MDM.056)) Objective: Presentation of the ToR of the new rulemaking task MDM.056
Participation: Open to all stakeholders affected by possible new rules.
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Boeing 787 “Dreamliner” Completes First Flight
On December 18th Boeing was finally able to test their newest aircraft. The virgin flight went off without a hitch and hopefully the Dreamliner can be delivered to the clients by the last quarter of 2010. Ryanair, among a few others, has cancelled its order of 200 Boeing 737-800. Europe's largest low-fare airline has decided to reduce its expansion during the next couple of years in order to maximise cash balances.
More information can be found on the Boeing website.
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All scheduled courses from January to March are listed below. All other information regarding Q.C.M.’s courses and services as well as an overview of 2009 course-dates are published on our website www.qcm.ch. Please feel free to call us if any questions arise. You will find our contact details at the end of this newsletter .
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Aircraft Maintenance Manager Air-Glaciers SA, an Air Operator with its own EASA Part-145/ EASA Part-M/G Organisation,
operating, beside different helicopters,
three (Hawker Beechcraft) Beech 200 Series (PWC PT6), two Pilatus PC-6 (PWC PT6), one Cessna 206 Series (Continental) and one PA 18
requires a
Aircraft Maintenance Manager Aeroplane Departmentreporting directly to the Accountable Manager, responsible for the maintenance of the fleet, for the compliance with the defined standards, rules and regulations, the training of the personnel etc. and last but not least, together with the CAM, for the airworthiness of the fleet.
Qualification/Experience expected: - Have a background in business aircraft maintenance activities.
- Have excellent technical knowledge.
- Knowledge and understanding of European Regulations EASA (EASA Part-145/Part-M).
- Possess a good knowledge of the English and the French languages (of the German language is an asset).
- Have a high sense of responsibility.
- Have a Part 66 B1 license, min. 5 years experience.
- Possess a type rating for the following aircraft/engines: Beech 200, Pilatus PC6 and PT6-Engines.
- Be flexible and motivated, able to work under pressure.
- Be computer literate.
- Leadership experience.
We offer you an attractive position, work within a small team of mechanics with a wide experience on Beech and PC6, remuneration in accordance with your experience and your competence. For consideration, forward your complete resume and references to: Air Glaciers SA, PO Box 27, CH-1951 Sion, Switzerland.
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We hope that you have found this month’s newsletter interesting and informative.
Do not hesitate to contact us for further information.
Q.C.M. quality control management AG
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Tel: 0041 31 960 40 60
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