If you wish to start an EASA MRO (EASA Part 145), you have first to figure out where your application should be send and this is already the first decision step which requires you to identify your “principal place of business”, that is the primary location where your taxpayer’s business is performed and generally also where the head of the firm (or at least the upper management) is located.
In fact, should your principal place of business being located in the EU, in the USA, in Canada or in Brazil, you should then refer to the local authority (rispectively the specific EU NAA, the FAA, the TCCA or the ANAC).
Reason is that in the EU, each country has its National Aviation Authority (NAA) who deals with the local Part 145 approvals, while outside the EU, the US, Canada and Brazil signed a bilateral aviation safety agreement (BASA) with the EU in order to facilitate their Industry by letting it directly deal with the local authority (for example the FAA in USA) in order to get an EASA approval as well.
If you are instead located in any country of the world, other than those above mentioned, you are part of the “foreign” group (for the EASA point of view of course) and this post is actually meant for you.
So if you fulfil the above highlighted condition, you need now to cope with the following bullet points.
- Download and fill in the official EASA application Form (EASA Form 2)
Don’t worry, the form I have linked comes from the EASA webpage related to foreign 145 approvals (here).
There you can also find a document providing instructions on how to fill the application form (here).
Once the EASA Form 2 is filled in and ready..
- you should simply send it via email to this address: email@example.com and wait for acknowledgment.
I recommend to use the email, despite the use of other mediums, such like the surface email, the EASA website or a fax, is possible. In such a case you should look for the details in the EASA website (fir example by contacting them through the “contact form” you can find in the footer of their website (here a direct link , click on “Aviation” and then “Applications”).
At this point, things will start to happen and you will be asked to accept and pay the calculated fee (cots are detailed later on). You will be assigned with your preliminary approval number (EASA.145.XYZW, where XYZW is a number) and an Inspector (PMI in the American “aviation slang”) will be assigned to you in order to follow up your application.
Be now ready since your assigned inspector will go to ask you for the following:
- produce and send to your inspector the MRO company manual called Maintenance Organisation Exposition (MOE), where the organisation is described, along with those maintenance and quality procedures required by the EASA Part 145 regulation.
A guidance how to write this manual can be found here. The guide explains what to describe in each and every chapter of the MOE, however not all the contents and chapters may be applicable to you (for example if you only apply for a line station, you do not need to explain how the base (heavy) maintenance is done etc.).
- produce and send to your inspector a List of Certifying Staff if it is not already inserted in the MOE.
This document should list the personnel authorised by your company to release to service the product maintained at your organisation (an aircraft, an engine and/or other components). You should also be ready to send along the list all the evidences your inspector will need in order to assess the competency and experience of the personnel you proposed as Certifying Staff (for example, Aircraft Type Training Certificates, Human Factor training, Aviation Legislation training, training on your MOE, etc.)
- produce and send to your inspector the Organisation Capability List, if not already inserted in your MOE.
This is the list of Part Numbers that identify the components you are capable to make maintenance on (in terms of know-how, tools, manuals, personnel and facilities).
Note that when it comes to aircraft and engines, the related models that you are capable for, are normally listed in the MOE, however if you want to have a Class C approval as well (Class C stands for Components), the list will show the P/N you are capable for and the manuals used for the maintenance, along with further information that you will also find in the EASA MOE user guide as well.
Now, you need to identify the main persons who will run your Maintenance Organisation.
An important thing to be aware of is that EASA wants at least three main figures in a maintenance organisation:
- An Accountable Manager, whose main responsibility is ensuring that the maintenance can be financed and carried out according to the EASA rules,
- a Quality Manager, you should monitor the continued compliance of the Organisation to the EASA rules (mainly through audit activity)
- at least one Maintenance Manager, who should manage the maintenance activity according to the EASA rules.
Both the Quality manager and the Maintenance Manager need to be approved by the EASA and this is done through an assessment for satisfactory experience, knowledge and background. The possible acceptance is then formalised in a document called EASA Form 4. Therefore, you should now…
- produce and send an EASA Form 4(s) for each of the above listed managers, where name, position experience and qualifications of the proposed post-holders are described. While you should send an EASA Form 4 for each individual in Quality Manager and Maintenance Manager position, a Form 4 for the Accountable Manager is optional.
The EASA Form 4 can be found here.
The related instructions on how to fill in the EASA Form 4 can be instead found here.
Your inspector will now check all the above documents and a discussion might start in order to align those things that need to be aligned with the EASA requirements.
Once done, the “big part” is also done and you should now just be required to…
- carry out an internal audit to your not yet approved Organisation in order to verify its compliance with the EASA requirements.
- Send the related audit report and a final statement of compliance to your inspector.
Your inspector will now be ready to propose you an on-site visit (audit) date, which may be of a variable length, in dependance of the complexity of the Organisation supposed to be approved.
The EASA on-site audit is another challenging phase of your approval process as you will likely face findings that need to be resolved in order to finally receive the approval certificate. However, once your corrective actions have been done and accepted by the inspector, you only need to seat down and wait to finally receive your well deserved EASA Approval Certificate.
The average time to carry out all of the above steps is (as explained by EASA in its website) about 8 months. However it is of course dependant from many factors, such as the ability you have in producing the required above described documents (MOE, lists and Form 4) and the capacity of rectifying the non-conformities that have been found by the inspector during the above described process.
The costs (in Euro) can be worked out from the following table, which takes in account the fee related to the number of the staff within the Organisation and the cost related to the class ratings you want to apply for (for example A1 is large aircraft).
This is a table extracted from the current Fees and Charges Regulation, which can be found here.
Still about the costs, you should also take in account those costs related to the first EASA on-site visit. These will include the flight for the inspector(s), if the inspector(s) has to fly to reach you, the inspector(s) accommodation (Hotel) and his/her/their per-diem. The details are also all in the Fees and Charges Regulation.
Let me conclude by highlighting that this article is just a summary of a quite complex process, therefore I would like to reassure you that beside my direct experience, to write this post I have of course used all the reliable available sources of the EASA and the EU. However I would encourage you to check the following links in order to further detail the topic, should you feel it necessary. Thank you. and good luck!