AMC1 ML.A.801 Aircraft certificate of release to service
CAA ORS9 Decision No. 1
AIRCRAFT CERTIFICATE OF RELEASE TO SERVICE (CRS) AFTER EMBODIMENT OF A STANDARD CHANGE OR A STANDARD REPAIR (SC/SR)
1. Release to service and eligible persons
Only natural or legal persons entitled to release to service an aircraft after maintenance (see ML.A.801(b)) are considered as an eligible installer responsible for the embodiment of a SC/SR when in compliance with applicable requirements.
Since the design of the SC/SR does not require specific approval, the natural or legal person releasing the embodiment of the change or repair takes the responsibility that the applicable certification specifications within CS-STAN are fulfilled while being in compliance with Part-ML/ Part-M Subpart F/Part-CAO and/or Part-145 and not in conflict with the TC holder’s data. This includes responsibility in respect of an adequate design, the selection/manufacturing of suitable parts and their identification, documenting the change or repair, generation or amendment of aircraft manuals and instructions as needed, embodiment of the change/repair, releasing the aircraft to service and record-keeping.
Depending on its nature, for certain SCs/SRs, CS-STAN might restrict the eligibility for the issuance of the release to service to certain persons (e.g. standard change/repair not suitable for release to service by the pilot-owner).
NOTE: Until 1 October 2020 (ref. entry into force of Commission Regulation (EU) 2018/1142), it is possible to have aircraft maintenance released to service by the holder of an appropriate certifying staff qualification valid in the UK (national qualification). In this case, the following conditions apply:
— If the holder signs the release to service on behalf of a maintenance organisation, this release is valid regardless of the Member State where the aircraft is registered.
— If the holder signs the release to service as an independent certifying staff, this release is only valid in the Member State responsible for such certifying staff qualification and where the aircraft is registered.
2. Parts and appliances to be installed as part of a SC/SR
The design of the parts and appliances to be used in a SC/SR is considered a part of the change/repair, and, therefore, there is no need of a specific design approval. However, it is possible that for a particular SC, these certification specifications specifically require the use of parts and appliances that meet a technical standard. In this case, when the parts and appliances are required to be authorised as an ETSO article, other articles recognised as equivalent by means of an international safety agreement or grandfathered in accordance with Regulation (EU) No 748/2012 are equally acceptable.
Normally, a SC/SR shall not contain specifically designed parts that should be produced by a production organisation approved in accordance with Part 21 (POA). However, in the case that the change or repair would contain such a part, it should be produced by an approved production organisation (POA holder), and delivered with a CAA Form 1. An arrangement in accordance with 21.A.122(b) is not applicable.
Eligibility for installation of parts and appliances belonging to a SC/SR is subject to compliance with the Part 21 and Part-ML and maintenance-organisation-related provisions, and the situation varies depending on the aircraft in/on which the SC/SR is to be embodied, and who the installer is. The need for a CAA Form 1 is addressed in Part 21 and Part-ML, while less restrictive rules may, for instance, apply for ELA1 and ELA2 aircraft parts (e.g. 21.A.307) and sailplane parts (e.g. AMC 21.A.303 of the ‘AMC and GM to Part 21’). Furthermore, Part-M Subpart F, Part-CAO and Part-145 contain provisions (i.e. M.A.603(c), CAO.A.020(c) and 145.A.42(c)) that allow maintenance organisations to fabricate certain parts to be installed in/on the aircraft as part of their maintenance activities.
3. Parts’ and appliances’ identification
The parts modified or installed during the embodiment of the SC/SR need to be permanently marked in accordance with Part 21 Subpart Q.
4. Documenting the SC/SR and declaring compliance with the certification specifications
In accordance with Part-ML, Part-M Subpart F, Part-CAO or Part-145 (e.g. ML.A.801(e), M.A.612, CAO.A.065 and 145.A.50(b)), the legal or natural person responsible for the embodiment of a change or a repair should compile details of the work accomplished. In the case of SCs/SRs, this includes, as necessary, based on the complexity, an engineering file containing drawings, a list of the parts and appliances used for the change or repair, supporting analysis and the results of tests performed or any other evidence suitable to show that the design fulfils the applicable certification specifications within CS-STAN together with a statement of compliance and amendments to aircraft manuals, to instructions for continuing airworthiness and to other documents such as aircraft parts list, wiring diagrams, etc. as deemed necessary. The CAA Form 123 is prepared for the purpose of documenting the preparation and embodiment of the SC/SR. The aircraft logbook should contain an entry referring to CAA Form 123; both CAA Form 123 and the release to service required after the embodiment of the SC/SR should be signed by the same person.
CAA Form 123 and all the records listed on it should follow elementary principles of controlled documentation, e.g. contain reference number of documents, issue dates, revision numbers, name of persons preparing/releasing the document, etc.
5. Record-keeping
The legal or natural person responsible (see paragraph 1. above) for the embodiment of the change/repair should keep the records generated with the SC/SR as required by Part-ML, Part- M Subpart F, Part-CAO or Part-145 and CS-STAN.
In addition, ML.A.305 requires that the aircraft owner (or CAMO or CAO, if a contract in accordance with ML.A.201 exists) keeps the status of the changes/repairs embodied in/on the aircraft in order to control the aircraft configuration and manage its continuing airworthiness.
With regard to SCs/SRs, the information provided to the owner, CAMO or CAO may be listed in CAA Form 123 and should include, as required, a copy of any modified aircraft manual and/or instructions for continuing airworthiness. All this information should normally be consulted when the aircraft undergoes an AR, and, therefore, a clear system to record the embodiment of SCs/SRs, which is also easily traceable, would be of help during subsequent aircraft inspections.
6. Instructions for continuing airworthiness (ICA)
As stipulated in ML.A.302, the aircraft owner, CAMO or CAO needs to assess if the changes in the ICA of the aircraft require the amendment of the AMP.
7. Embodiment of more than one SC
The embodiment of two or more related SCs described in Subpart B of CS-STAN is permitted as a single change (the use of one CAA Form 123 only) as long as adequate references to and records of all SCs embodied are captured. Restrictions and limitations of the two (or more) SCs would apply. It is permitted to issue a single release to service containing adequate traceability of all the SCs embodied.
8. Acceptable form to be used to record the embodiment of SCs/SRs
See CAA Form 123.
CAA Form 123 — Standard Change/Standard Repair (SC/SR) embodiment record
Notes:
Original remains with the legal or natural person responsible for the embodiment of the SC/SR. The aircraft owner should retain a copy of this form.
The aircraft owner should be provided with copies of the documents referenced in boxes 5 and 7 and those in box 6 marked with an asterisk ‘*’.
The ‘relevant paragraphs’ in boxes 9a and 9b refer to the applicable paragraphs of ‘Subpart A – General’ of CS-STAN and those of the SC/SR quoted in box 2.
For box 12, when the aircraft owner has signed a contract in accordance with ML.A.201, it is possible that the CAMO or CAO representative signs box 12 and provides all relevant information to the owner before next flight.
Completion instructions:
Use English or the official language of the State of registry to fill in the form.
1. Identify the SC/SR with a unique number and reference this number in the aircraft logbook.
2. Specify the applicable CAA CS-STAN chapter including revision (e.g. CS-SCxxxy or CS-SRxxxy) & title. Provide also a short description.
3. Identify the aircraft (a/c) registration, serial number and type.
4. List the parts' numbers and description for the parts installed. Refer to an auxiliary document if necessary.
5. Identify affected aircraft manuals.
6. Refer to the documentation developed to support the SC/SR and its embodiment, including design data required by CS-STAN: design definition, documents recording the showing of compliance with the certification specifications or any test result, etc. The documents' references should quote their revision/issue.
7. Identify instructions for continuing airworthiness that need to be considered for the aircraft maintenance programme review.
8. To be used as deemed necessary by the installer. 9a., 9b., 10. and 12. Self-explanatory.
11. Give full name details and certificate reference (of the natural or legal person) used for issuing the aircraft release to service.