Friday, September 7, 2012

Critical and Flight Safety Sensitive Task - Responsibilities

          "Who is responsible to identify tasks requiring independent inspection and to ensure that such independent inspections are carried out? Is it the person or organisation carrying out maintenance or is it the person or organisation who accomplishes the tasks associated with continuing airworthiness?"
From the regulatory point of view there is no clear explanation which defines the responsibility.
145.A.65(b)3 requires a procedure regarding critical tasks. But a critical task according to that explanation does not require an independent inspection.
M.A.402(a) requires that an independent inspection shall be carried out after any flight safety sensitive maintenance task.
                But, who is responsible to classify a task as "critical" or as "flight safety sensitive"?
Is that really only the person or organisation that carries out maintenance?The responsibility must be shared. Shared between the person or organisation carrying out the maintenance and the person or organisation accomplishing the tasks associated with continuing airworthiness.
Why shared? Simply because both parties are involved in the planning of maintenance activities.
             It starts with the person or organisation who accomplishes the tasks associated with continuing airworthiness. This person or organisation is responsible to establish the maintenance programme. The maintenance programme includes the maintenance schedule which defines which scheduled activity should be carried out when. And each scheduled maintenance activity must be listed. So, preparing this schedule, an initial assessment of the activity should be performed regarding criticality. And each maintenance activity which directly has an impact on flight safety according M.A.402(a) should be classified as such and should require an independent inspection. Furthermore each activity which is regarded to be critical in terms of 145.A.65(b)3 should be classified as critical and processed accordingly. And this should be clearly identified in the work order handed over to the maintenance.
          Once the person or organisation carrying out the maintenance receives the work order they must evaluate the received work order and assess each task for criticality again. Furthermore, every unscheduled task resulting from scheduled maintenance must be assessed for criticality as well and, in case of being classified as such, must be subject to an independent inspection.
         Consequently, before the release to service is issued, the certifying staff must be satisfied that all requirements of CAR-145 and CAR-M are met.In the end, the person or organisation who accomplishes the tasks associated with continuing airworthiness must ensure that all records are complete and all maintenance is carried out according CAR-M, and if required CAR-145.  Both parties are required to ensure that all maintenance is carried out appropriately.
             When we talk about the release to service besides others we have to consider one strict requirement. The requirement that a release to service shall not be issued in the case of any known non-compliance which endangers flight safety. And we have to be aware that an airworthiness directive overdue for compliance is also considered a hazard to flight safety.
           But, who is responsible to ensure that all airworthiness directives are complied with. Is it the person or organisation carrying out maintenance or is it the person or organisation who accomplishes the tasks associated with continuing airworthiness?

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