UNCONTROLLED IF PRINTED TERHAD

PU 2103

TECHNICAL AIRWORTHINESS MANAGEMENT MANUAL

SECTION 1 LEAFLET 3

OVERVIEW OF THE STATE TECHNICAL AIRWORTHINESS REGULATORY FRAMEWORK FOR MAINTENANCE

INTRODUCTION 1. The design-related regulations define the approach to state aircraft engineering, whereas the state aircraft maintenance regulations in Section 2 specify state maintenance policy and practices within the technical airworthiness regulatory framework. The state aircraft maintenance regulations have been developed to harmonise with equivalent worldwide civil airworthiness regulations. PURPOSE 2. The purpose of this leaflet is to provide an overview of the state aircraft maintenance regulatory framework defined by the regulations. In particular, this leaflet identifies the major classes of organisations mentioned in the regulations and describes the relationship between them. DEFINITIONS 3. Definitions relevant to Section 1 are found in the glossary and to be considered as regulatory in nature. ORGANISATIONS AND PERSONNEL IN THE REGULATORY FRAMEWORK
Maintenance Organisations

4. The actual maintenance work conducted on state aircraft and aeronautical product is performed by organisations separate from the Technical Airworthiness Regulator (TAR). Prior to these organisations conducting the maintenance, two formal steps are required: a. The maintenance organisation must be authorised to undertake the work by duly empowered personnel of the Maintenance Authorising Office (MAO) at respective SAO HQ; and b. The organisation must be certified by DGTA as being an acceptable organisation in accordance with the regulations to conduct maintenance within a specified scope and level. 5. Subject to certain exceptions (see Authorisation of Non-AMOs to Perform Maintenance), only organisation holding a current certificate together with Letter of Maintenance Authority (LMA) from DGTA and an authorisation from the MAO will be permitted www.dgta.gov.my 1.3 - 1 of 5 TERHAD Rev 1 July 2013

UNCONTROLLED IF PRINTED TERHAD

PU 2103

to maintain state aircraft or aeronautical product. With the authorisation and certification, that organisation may be referred to as an Approved Maintenance Organisation (AMO). 6. The MAO is the Head of SAO Aviation Engineering Organisation that has a responsibility for controlling the resources that enable the maintenance organisation to conduct maintenance. For instance; Malaysian Army, the MAO is Chief Engineer of Army Air Wing; RMN, the MAO is the Chief Engineer (Aviation) of RMN; RMAF, the MAO is the Chief Engineer of RMAF; MMEA, the MAO is the Chief Engineer (Aviation) of MMEA; Pasukan Bomba dan Penyelamat Malaysia, the MAO is the Chief Engineer of UUBPM. Figure 31 is a representation of this arrangement.

MAINTENANCE AUTHORISING OFFICE Submission Authorisation Certification

Audit MAINTENANCE

DGTA

ORGANISATION Figure 31 Authorisation and Certification of AMO 7. AMOs conduct a variety of maintenance tasks. Some AMOs, particularly the flying squadrons/units with an organic maintenance capability, will be responsible for the whole aircraft as well as aeronautical product maintenance to the authorised level and scope. Other AMOs may only be responsible for maintenance of a very limited range of aeronautical product. DGTA makes no distinction between these organisations and simply refer to them as AMOs. 8. For contractors, the MAO will also usually be the Chief Engineer (Aviation) of Services. Where any other state organisation places a contract, or otherwise purchases maintenance services for aircraft or aeronautical product, that organisation will be the MAO.

ROLE OF THE MAINTENANCE AUTHORISING OFFICE 9. The basic functions of the MAO are as follows: a. Ensure appropriate AMO requirements are reflected in the contract to be awarded to commercial organisations; b. Order the prospective AMO to develop and submit an AMO application within an appropriate time scale; c. Act as intermediary between the AMO and DGTA; 1.3 - 2 of 5 TERHAD Rev 1 July 2013 www.dgta.gov.my

UNCONTROLLED IF PRINTED TERHAD

PU 2103

d.

On receipt of an AMO application, review it for: (1) Consistency with the MAOs understanding of the scope and level of the AMOs activity; (2) Applicable contractual requirements; and (3) Any significant concerns or issues that need to be addressed before the application is forwarded to DGTA (the MAO does not need to assess the application for compliance with the regulations nor undertake any audits for AMO certification purposes);

e. Forward the AMO application to DGTA with a covering letter indicating that the application is supported or otherwise; f. If desired, participate as an observer in any AMO audits conducted by DGTA (where the MAO staff includes appropriately trained and experienced auditors, fuller participation in the DGTA audit may be possible); g. Where applicable and appropriate, manage the contractual implications of any non-compliances; and h. Provide feedback to DGTA when the MAO becomes aware of any regulatory non-compliances or performance issues that could affect AMO certification. i. Besides authorising service AMOs, MAO may promulgate guidance to assist the AMOs to comply with the TAMM within the operational environment. Guidance should be in the form of standing instructions authorised by the MAO, or delegate.

10. DGTA will proceed with the AMO certification process and deals directly with the AMO. The MAO will be provided with correspondence/report on the activities during the certification process.
CERTIFICATION How a Commercial Organisation May Enter the Environment

11. The first thing to note about the state aircraft maintenance regulatory environment is that, like the design engineering environment, entry is not discretionary. Only those organisations that are participating in the contract negotiation process for aircraft or aeronautical product maintenance, and/or with authorisation from MAO, will be permitted to seek AMO certification. Such organisations are required to submit Maintenance Management Plan (MMP) and applicable procedures in accordance with authorised scope and level. This process does not preclude assessment of an organisation for compliance with the state aircraft maintenance regulations during tender evaluations. Assessments at that stage will normally be to a system level. However, successful tenderers will be required to submit a complete package for assessment by DGTA as soon as possible after formal instrument has been established. The submission package normally consists of an MMP and copies of any referenced plans, procedures or instructions. www.dgta.gov.my 1.3 - 3 of 5 TERHAD Rev 1 July 2013

UNCONTROLLED IF PRINTED TERHAD

PU 2103

Once DGTA has completed a systems audit of the applicants submission, a compliance audit will be required before an applicant organisation is certified. The composition of the audit team would depend on the applicants scope and level of maintenance work and any particular conditions set by the MAO. DGTA staffs are responsible for coordination with the maintenance organisations for certification.
How a Service Organisation May Enter the Environment

13. Service organisations are to submit their AMO application to DGTA as soon as the documentation has been prepared. The submission will be treated in much the same way as in the preceding paragraphs that deal with commercial organisations. That is, they will be subject to a systems audit followed by a compliance audit. When a new state aircraft or aeronautical product maintenance unit is formed, or a previously disbanded unit is reformed, that unit is to forward its AMO submission through its MAO as soon as possible. New or reformed units should expect the permissible timeframe to become an AMO will be set when the unit is initially formed. Ideally the new unit should aim to be an AMO before maintenance operations begin.
EXEMPTIONS Requests for Exemption

14. TAMM Regulation 4.3 (Exemptions) requires that AMOs must submit a formal exemption request to DGTA if they wish to depart from any applicable regulation. The AMO must document in the exemption request the reasons for non-compliance and the alternative action to be taken to ensure that airworthiness is not compromised by the non-compliance. Exemption requests will be managed by DGTA. The disposition of all exemption requests will be advised to the applicant along with any terms or conditions relevant to the Exemption. 15. Not all regulations may be applicable to an individual AMO. For example, an AMO conducting only off aircraft maintenance of avionics equipment would find Regulation 4.5.8, dealing with authorisation of aircrew to perform maintenance, not applicable. Exemptions are not required for non-applicable regulations. However, AMOs are to clearly identify in their MMPs any non-applicable regulations, together with a brief justification.
Leased Aircraft

16. Policy for the maintenance support of leased aircraft is outlined in Regulation 2.7 of the TAMM. Organisations maintaining leased state-registered aircraft will be required to become AMOs and are subjected to the state regulatory requirements.
AUTHORISATION How a MAO Authorises a Maintenance Organisation

17. Commercial AMOs shall be authorised by the MAO through the approval of formal instrument or sponsorships. Service AMOs are authorised to conduct maintenance by the relevant MAO via a suitable instrument. The authorisation instrument may include operational considerations, but must include (or reference) the need for AMO certification by DGTA. The authorisation instrument formally authorises the organisation to conduct maintenance on behalf www.dgta.gov.my 1.3 - 4 of 5 TERHAD Rev 1 July 2013

UNCONTROLLED IF PRINTED TERHAD

PU 2103

of the state. Withdrawal of either the authorisation instrument or AMO certification may preclude the maintenance organisation from providing maintenance services to the state.
AUTHORISATION OF NON-AMOs TO PERFORM MAINTENANCE Sub-contractors

18. Only an organisation directly contracted by the SAO organisation may become a commercial AMO. Subcontractor may also subject to be certified as AMOs but normally be part of a commercial AMOs Maintenance Support Network (MSN). The prime contractor AMO shall retain overall responsibility for the maintenance performed by a subcontractor.
Temporary Maintenance Authorisation (TMA) Requirements

19. There may be occasions when maintenance activity is required on a short term or temporary basis, for example to meet a short term surge, or to perform one-off or ad hoc modifications over a short period of time. In such cases it may not be cost-effective to require the maintenance organisation to undertake the AMO certification process. Typically, the maintenance activity would be completed before the certification process is complete. Regulation 4.1.1 allows for DGTA or SAO to provide specific temporary authorisation for a nonAMO to undertake a maintenance task.
Transition between Contract Signature and AMO Certification

20. AMO certification will normally be a contractual requirement for a commercial organisation. However, submission of the AMO application may occur after contract signature and the full compliance assurance process leading to AMO certification may take a considerable period of time. Meanwhile, maintenance activity may probably need to commence shortly after contract signature and transition may occur over a significant period as facilities and workforces are established, particularly if maintenance activities are being transferred incrementally from the state or other contractors. In these cases, the DGTA may issue interim authority to perform maintenance prior to full AMO certification in accordance with Regulation 4.1.1.
Limitations of Scope of the Aircraft Maintenance Regulations

21. The scope of application of the State Technical Airworthiness Regulations to industry must inevitably be limited by resource availability and risk considerations. There will be overseas repair item maintenance contracts, including US Foreign Military Sales (FMS) support contracts, which are underwritten by US DoD and OEM quality systems. For such contracts, the full implementation of State Technical Airworthiness Regulations would require resource allocations out of proportion to the risk being addressed. DGTA may exclude such contracts from the requirement for AMO certification.
Consultation

22. In all cases involving authorisation of non-AMOs to perform maintenance, the applicable MAO should consult DGTA for advice.

www.dgta.gov.my

1.3 - 5 of 5 TERHAD

Rev 1 July 2013