ML.A.801 Aircraft certificate of release to service

Regulation (EU) 2019/1383

1. A CRS shall be issued after the required maintenance has been carried out properly on an aircraft.
2. The CRS shall be issued, alternatively by:
   1. appropriate certifying staff on behalf of the approved maintenance organisation;
   2. independent certifying staff;
   3. the pilot-owner in compliance with point ML.A.803.
3. By derogation from point (b), in the case of unforeseen circumstances, when an aircraft is grounded at a location where no appropriately approved maintenance organisation and no appropriate certifying staff are available, the owner may authorise any person, with no less than 3 years of appropriate maintenance experience and holding the proper qualifications, to maintain the aircraft according to the standards set out in Subpart D of this Annex and release the aircraft. The owner shall in that case:
   1. obtain and keep in the aircraft records, details of all the work carried out and of the qualifications held by the person issuing the certification;
   2. ensure that any such maintenance is rechecked and released in accordance with point (b) of point ML.A.801 at the earliest opportunity and within a period not exceeding 7 days or, in the case of aircraft operated under Annex VII to Regulation (EU) No 965/2012 (Part-NCO) or, in the case of balloons, not operated under Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/395 or, in the case of sailplanes not following Subpart DEC of Annex II (Part-SAO) to Regulation (EU) 2018/1976, within a period not exceeding 30 days;
   3. notify the contracted CAMO or CAO, or the competent authority in the absence of such a contract, within 7 days of the issuance of such authorisation.
4. In the case of a release to service in accordance with points (b)(1) or (b)(2), the certifying staff may be assisted in performing the maintenance tasks by one or more persons subject to his direct and continuous control;
5. A CRS shall contain at least:
   1. basic details of the maintenance carried out;
   2. the date on which the maintenance was completed;
   3. the identity of the organisation or person issuing the release to service, including, alternatively:
      1. the approval reference of the maintenance organisation and certifying staff issuing the CRS;
      2. in the case of point (b)(2), the identity and, if applicable, the licence number of the independent certifying staff issuing the CRS;
   4. the limitations to airworthiness or operations, if any.
6. By derogation from point (a) and notwithstanding point (g), when the required maintenance cannot be completed, a CRS may be issued within the approved aircraft limitations. In that case, the CRS shall indicate that the maintenance could not be completed, as well as indicate any applicable airworthiness or operations limitations, as part of the information required in point (e)(4).
7. A CRS shall not be issued in the case of any known non-compliance with the requirements of this Annex which endangers flight safety.

ED Decision 2020/002/R

AIRCRAFT CERTIFICATE OF RELEASE TO SERVICE (CRS) AFTER EMBODIMENT OF A STANDARD CHANGE OR A STANDARD REPAIR (SC/SR)

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 a Member State (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.

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 an EASA 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 an EASA 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.

The parts modified or installed during the embodiment of the SC/SR need to be permanently marked in accordance with Part 21 Subpart Q.

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 EASA 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 EASA Form 123; both EASA Form 123 and the release to service required after the embodiment of the SC/SR should be signed by the same person.

EASA 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.

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 EASA 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.

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.

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 EASA 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.

See EASA Form 123.

Formular einfügen

EASA Form 123 — Standard Change/Standard Repair (SC/SR) embodiment record

Form 123 Issue 00

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 EASA 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.

ED Decision 2020/002/R

1. The aircraft CRS should contain one of the following statements:
   1. ‘certifies that the work specified, except as otherwise specified, was carried out in accordance with Part-ML, and in respect to that work, the aircraft is considered ready for release to service.’; or
   2. for a pilot-owner:
      
      ‘certifies that the limited pilot-owner maintenance specified, except as otherwise specified, was carried out in accordance with Part-ML, and in respect to that work, the aircraft is considered ready for release to service.’.
2. The CRS should relate to the task specified in the DAH’s or operator’s instruction or the AMP which itself may cross-refer to a DAH’s/operator’s instruction in a maintenance manual, service bulletin, etc. This should indicate the revision status of the maintenance instruction used.
3. The CRS should include the date when the maintenance took place relative to any life or overhaul limitation in terms of date/flying hours/cycles/ landings etc. as appropriate.
4. When extensive maintenance has been carried out, it is acceptable for the CRS to summarise the maintenance as long as there is a unique cross reference to the work pack containing full details of the maintenance carried out. Dimensional information should be retained in the work pack record.
5. The person issuing the CRS should use his or her normal signature except in the case where a computer release-to-service system is used. In this latter case, the competent authority needs to be satisfied that only this particular person may electronically issue the CRS. One such method of compliance is the use of a magnetic or optical personal card in conjunction with a personal identification number (PIN) known only to the individual, which is keyed into the computer. A certification stamp is optional.
6. At the completion of all maintenance, owners, certifying staff, operators and maintenance organisations should ensure they have a clear, concise and legible record of the work performed.
7. In the case of an ML.A.801(b)(2) CRS, the independent certifying staff should retain all records necessary to prove that all requirements have been met for the issuance of a CRS.

ED Decision 2020/002/R

Certain maintenance data issued by the DAH (e.g. AMM) requires that a maintenance task be performed in flight as a necessary condition to complete the maintenance ordered. Within the aircraft limitations, the person authorised to certify the maintenance per ML.A.801 should release the incomplete maintenance before this flight. GM1 ML.A.301(f) describes the relations with the aircraft operator, which retains the responsibility for the MCF. After performing the flight and any additional maintenance necessary to complete the maintenance ordered, a CRS should be issued in accordance with ML.A.801.

→ ML.A.802