Maintenance Control Manual Template
OTAR Part 39 Subpart E Option 2 and Subpart F
Form AW-282 V.4 Jan 2021
INTRODUCTION
The purpose of this Maintenance Control Manual (MCM) Guidance Document is to assist applicants with a view to ensuring that MCM's submitted to
Bermuda CAA for approval have been developed in a standardised fashion, have visibility of compliance to OTARs and include the elements required
to ensure that the subject aircraft can be effectively maintained in an airworthy condition.
It is intended that this document establishes a standardised format for an MCM, however in developing a MCM you will inevitably have to take account
of the nature of included material, cater for operator related material and be dependent on other documentation with a consequence that this may alter
the formatting from this document. Where the applicant has deviated from this guidance format, completing and maintaining this document will assist in
establishing continued visibility of compliance to OTARs.
It is not intended that this document should constrain or prevent the applicant from including required information. In all cases where the applicant has
included additional data or other means of compliance, the applicant should submit with the MCM an explanatory document detailing any such changes.
The columns titled MCM MP (maintenance programme); references should be entered where appropriate. Where it is determined that the subject is not
applicable, is covered by a process in another document, or is dealt with in an alternative way, details of the variance including any cross references
should be recorded in the `Compliance Notes' column.
The column titled Section Interpretation is designed to assist the applicant to develop the text for a particular section/paragraph.
The column titled compliance text is intended for the applicant to record the narrative to be utilised in the MCM. If the applicant has already identified
this narrative, this document should be only used to identify the cross references to the compliance text in the accompanying MCM.
For small organisations and in the interests of simplicity, compliance sectional text should be combined where appropriate. In such cases cross
referencing should be maintained in this guidance document.
Form AW-282 V.4 Jan 2021
Application Details
OPERATOR
TECHNICAL CO-ORDINATOR / AOC POST HOLDER
AOC NUMBER * where applicable
CONTRACTED PART 39 ORGANISATION
MCM REFERENCE / CAME REFERENCE
MP REFERENCES
APPLICATION POINT OF CONTACT/TECHNICAL AUTHOR
Form AW-282 V.4 Jan 2021
SECTION ONE
Introduction, Document Control, Facilities, Resources and Organisation
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AN(OT)O
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SUBJECT Section Interpretation
1 39.59(a) Contents Page A list of the contents by title of; sections/parts and key paragraphs.
These should also refer to the page number where they can be
found in the MCM
BCAA Inspector Review
2 39.59(d) List of
Effective
Pages
A tabulated list of pages providing details of amendment status,
Example:
List of Effective Pages
Page
Number
Revision Dated Page
Number
Revision Dated
1
2
3
BCAA
Inspector Review
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
3 39.59(j) Amendment
Record
A method of identifying the control of amendments, an example:
Amendment Record
Amendment
Number:
Date Amendment
Details
Amended
By
Date of
Inclusion
BCAA Inspector Review
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
4 39.59(d) Distribution
List
The document should include a distribution list to ensure
recorded distribution of the exposition that demonstrates to
BCAA that all personnel involved in continuing
airworthiness have access to the relevant information. This does
not mean that all personnel have to be in receipt of the MCM but
that a reasonable amount of MCMs are distributed within the
organisation(s) so that the appropriate personnel have quick and
easy access to this MCM.
Accordingly, the MCM should be distributed to:
-
the operator’s or the organisation’s management
personnel and any person at a technical level as
necessary; and
-
The OTAR Part 145 contracted maintenance
organisation(s); and
-
BCAA
BCAA Inspector Review
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SUBJECT Section Interpretation
5 39.59(p) List of
Acronyms
There should be a list of all acronyms utilised in the MCM, special
attention should be given to those acronyms that have more than
one definition. The following list is for guidance only:
AD Airworthiness Directive
ADD Acceptable Deferred Defect
AOC Air Operator's Certificate
AOG Aircraft on Ground
ASSI Air Safety Support International
CAA Civil Aviation Authority
CAME Continuing Airworthiness Management Exposition
C OF A Certificate of Airworthiness
CDL Configuration Deviation List
CRS Certificate of Release to Service
ETOPS Extended Range Twin Operations
EASA European Aviation Safety Agency
FAA Federal Aviation Authority
MCM Maintenance Control Manual
MEL Minimum Equipment List
MNPS Minimum Navigation Performance Service
MO Maintenance Organisation
MOE Maintenance Organisation Exposition
MPD Maintenance Planning Document
MP Maintenance Programme
BCAA
OTAC Overseas Territories Aviation Circular
OTAR Overseas Territories Aviation Requirement
OT Overseas Territories
SB Service Bulletin
SIL Service Instruction Leaflet
SMI Scheduled Maintenance Inspection
SMP Standard Maintenance Practice
SRP Sector Record Page
TCCA Transport Canada Civil Aviation
Bermuda Civil Aviation Authority
BCAA Inspector Review
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SUBJECT Section Interpretation
6 39.59(c) Corporate
Commitment
Policy for
Continued
Airworthiness
Accountable
Management
The following is a suggested corporate statement for the accountable
manager, any alterations to this statement must not affect the intent of
this guidance:
This Exposition defines the organisation and procedures upon which
this OTAR Part 39 Subpart E approval is based.
These procedures are approved by the undersigned and must be
complied with, as applicable, in order to ensure that all the continuing
airworthiness activities including maintenance for aircraft managed is
carried out on time and to an approved standard.
It is accepted that these procedures do not override the necessity of
complying with any new or amended OTAR or AN(OT)O requirements
where these new or amended requirements are in conflict with these
procedures.
It is understood that the Director of BCAA will approve this organisation
whilst he is satisfied that the procedures are being followed. It is further
understood that the Director reserves the right to suspend, vary or
revoke the OTAR Part 39 Subpart E approval for continuing
airworthiness management of this organisation, as applicable, if he has
evidence that procedures are not followed and the standards not upheld.
It is further understood that for commercial air transport operations the
suspension or revocation of the OTAR Part 39 Subpart E approval
would invalidate any associated BCAA AOC or International Lease
Agreement.
Signed: ....................................................................... Date:
Name: ....................................................................... Title: Accountable
Manager ..................................................................
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
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SUBJECT
7 39.59(o) MCM BCAA
Approval
Reference
A section for the inclusion of the BCAA approval letter and or its
reference.
BCAA
Inspector Review
8 39.59(a) Description of
Organisation
This paragraph should clearly identify the general nature of the
organisations structure, any other NAA approvals for which the
OTAR approval is based on, general history of the organisation
and types of operations and aircraft that it has historically
supported.
BCAA
Inspector Review
9 39.53(a)(b)(c) List of
Managed
Aircraft
List of United Kingdom Overseas Territories Operators, OT AOC
holders and/or non-commercial, their contact details including
applicable technical coordinators and post holders for which the
organisation has principal contractual arrangements with.
BCAA
Inspector Review
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SUBJECT Section Interpretation
10
39.59(m)
39.59(o)
39.59(n)
Approval Scope of approval, list of aircraft types and any other ratings the
OTAR approval is based on.
If the organisation is seeking to be approved to conduct aircraft
design review required by OTAR Part 21.175(c), details of the
specific capability should be recorded including personnel
authorised to make such reviews.
Personnel who are authorised to complete and sign the BCAA C of
A survey report should be identified
BCAA
Inspector Review
11
39.59(k)
Management
Personnel
Management positions should be identified with details of key
responsibilities. All personnel including technical who have a
responsibility of maintaining compliance in part or total to the
requirements of OTAR Part 39 should be referred to.
Cross-referencing to the organisational chart is advisable.
BCAA
Inspector Review
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
12
39.59(k)
Organisational
Chart
The organisational chart should replicate the description of the
management personnel in line 11, show reporting lines of
accountability and any coordinated functionality.
BCAA
Inspector Review
13
39.59(e)
39.59(l)
Manpower
Resources
Resources can be made from a combination of permanent and
contracted personnel. This section should identify measures that
are utilised to control an effective resources/workload balance
ensuring that the organisation can demonstrate adequate
resources to meet the demands of workload. Where contracted
personnel are utilised this section should identify the organisations
policy and control of contracted personnel.
Inspector Review
BCAA
14
39.59(k)
Technical
Team
The organisations primary management team may undertake
depending on the size of the organisation the technical functionality
of continued airworthiness management. This section should
clearly identify the personnel involved in the technical processes of
continued airworthiness management.
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
15
39.59(g)
Quality and
safety policy
The organisation shall establish policy and procedures for a quality
and safety system taking account of the size of the organisation and
any contractual arrangement.
BCAA Inspector Review
16
39.59(e)
Personnel
Training Policy
Competency of personnel is key to ensuring that the corporate
responsibilities can be discharged. This section should identify the
organisations training policy and any competency verification.
Developing areas of technology, human factors and safety
management systems should feature in the training policy and
programme.
Inspector Review
BCAA
17
39.59(j)
Organisation
Changes
Changes to Organisation notification procedures
BCAA Inspector Review
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SUBJECT Section Interpretation
18
39.59(i)
MCM Review To maintain the effectiveness of the policies and procedures
contained in the MCM, to develop a process of continued
improvement and to address any adverse indicators, a regular and
formal review of the MCM should take place. It is expected that
such a review would not exceed a period of twelve months. This
section should identify the organisations policy for such a review
and who has the responsibility for managing the process.
Inspector Review
BCAA
19
39.59(k)(3)
39.55(n)
Computer
Systems
It is likely that computer systems are utilised in the process of
continued airworthiness management. This paragraph should
describe the system/s utilised, measures of protection, security,
data backup, manual redundancy and technical support.
Procedures should also be in place for the management control
and security of aircraft software.
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
20
39.59(k)(1)
Facilities The prime facility also known as the principal place of business
should be described identifying the resources made available to the
technical and managerial personnel.
Where the organisation utilises other sites and or subcontracted
organisations/individuals for the purpose of maintaining the
capability and scope of the approval, these facilities should also be
described and form the complete picture of available facilities.
Inspector Review
BCAA
21
39.59(k)(4)
Technical
Library
The scope and capability of the approved organisation is
dependant of maintaining an adequate technical library. This
section should identify the library, the control and distribution of
technical data.
Where data is acquired from contracted operators, the process of
validating this data should be described.
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
22
39.59(k)(4)
Data
Subscription
Services
Data subscription services are considered part of the technical
library, access to this data by the technical personnel should be
controlled and managed to ensure ready access at all times, the
data is accurate and representative and of the correct revision.
This paragraph should identify the process of controls.
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
SECTION TWO
Continuing Airworthiness Management Procedures
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SUBJECT Section Interpretation
23
39.55
C of A This paragraph should detail the processes and the allocation of
responsibility for ensuring the Certificate of Airworthiness remains
valid.
Procedures should also be made to establish scheduling of the
required presentation of documentation and that of the aircraft to
the
BCAA
for subsequent C of A reissues.
Procedures should provide for the removal from service any aircraft
that does not have a valid and an in force certificate of
airworthiness.
When an aircraft is removed from service permanently or for an
extended period, procedures should be in place to notify the
applicable BCAA
Inspector Review
BCAA
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SUBJECT Section Interpretation
24
39.79
Aircraft
Technical Log
This paragraph should detail the functions of technical log
management. Theses functions should include:
data acquisition; and
data recording; and
data analysis; and
control of defects; and
despatch deviations; and
unscheduled maintenance instructions; and
status of scheduled maintenance.
Details of procedural arrangements for communicating technical log
data and engineering decisions between the Operator and the
Continued Airworthiness Management Organisation should be
identified in this paragraph.
The utilisation instruction of technical logs utilised should be
described, where possible technical log commonality should be
encouraged.
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
25
39.73
Aircraft Log
books
The operators log books should be maintained in a manner
acceptable to BCAA. These may be in hard copy or electronic
or combination of. Appropriate procedures should be developed to
control these records.
Inspector Review
BCAA
26
39.55(e)
MEL / CDL
Procedure
If the operator operates to an approved MEL, the organisation
should be familiar with the document sufficiently to provide advice
for its utilisation and amendment. Modifications service reliability
and mandatory requirements can affect this document. This section
should detail appropriate procedures addressing these and any
other related issues.
Inspector Review
BCAA
27
39.55
Aircraft
Acceptance by
the Pilot
These are procedures principally aimed at the operator of the
aircraft. Where the organisation is contracted by the operator, any
specific operator requirements should be catered for.
Inspector Review
BCAA
Form AW-282 V.4 Jan 2021
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SUBJECT Section Interpretation
28
39.55(e)
MEL / CDL
Rectification
Expiry
The operators MEL will specify rectification requirements.
Maintenance planning and operational control of the aircraft should
be considered in establishing a rectification environment agreed
with the operator that will ensure an MEL related defect is rectified
in a timely manner.
Inspector Review
BCAA
29
39.55(e)(3)
Repetitive
Defects
Procedures should be established to identify, track and develop
where needed in cooperation with the maintenance provider
solutions. Where necessary operation constraints should be
applied in agreement with the operator.
Inspector Review
BCAA
30
39.55(e)
Deferred
Defect policy
Deferred defects should be monitored on a continued basis to
provide for effective control of individual defects and rectification
and the wider issue of effective maintenance. Any trends resulting
from maintenance actions, procurement of spares and functional
reliability should be addressed to ensure that the prime
responsibility of the Part 39 organisation remains effective.
Inspector Review
BCAA
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SUBJECT Section Interpretation
31
39.55(e)
Non
Deferrable
Defects Away
from Base
Procedures should be established to organise working parties or
other suitable maintenance resources. In some cases it may be
necessary to contact
BCAA
for extensions to approval ratings.
BCAA
Inspector Review
32
OTAR Part 21
Subpart P
Permit to Fly When an aircraft is to be operated under a Permit to Fly, it will be
incumbent on the applicant for such a certificate to provide robust
technical justification to BCAA. Procedures should be
established to generate the required technical justification.
BCAA
Inspector Review
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39.55(b)
39.61
Aircraft
Maintenance
Programmes
There should be a list of Maintenance Programmes for which the
organisation is directly responsible for the ongoing technical
development. In a case where this function is undertaken by
another organisation, details should be provided of the other
organisation and responsibilities for the management of
maintenance scheduling.
BCAA
Inspector Review
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SUBJECT Section Interpretation
34
39.61
Maintenance
Programme
Author
List of Maintenance Programmes holders and technical authors
should be identified.
BCAA Inspector Review
35
39.55(j)
Maintenance
Programme
Review
Analysis of the Effectiveness of the Maintenance Programme is a
prime task for the OTAR 39 organisation. The OTAR 39 approved
maintenance programme should contain detailed requirements for
a regular review. The organisations procedures should ensure
these requirements are catered for.
BCAA
Inspector Review
36
36.61(g)
Maintenance
Programme
Amendment
This section should identify the process for securing an approval for
an amendment to the Maintenance Programme in particular the
development of the technical justification for any proposed
alteration to existing inspection requirements.
BCAA
Inspector Review
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SUBJECT Section Interpretation
37
39.61(h)(5)(6)
Maintenance
Programme
Variations
An applicant for a variation to an approved maintenance
programme will be required to provide sufficient technical
justification. For maintenance programmes that have been
approved with a limited capability these should feature in the
organisations procedures. For applications to BCAA , technical
justification may need to cater for a larger variance. Additional
technical support from agencies the type certificate holder or other
organisations may be required.
BCAA
Inspector Review
38
39.61
Pre-Flight
Inspections
Pre-Flight inspections should be a feature of the maintenance
programme for the purpose of ensuring that the inspections remain
effective. The methods and procedures employed during the
inspection including training of personnel should be monitored.
These inspections are not developed to require certification by
maintenance personnel therefore any trend of findings resulting
from these inspections will require investigating and possible
alteration to the Pre-Flight check.
The organisation should develop appropriate review procedures.
BCAA Inspector Review
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SUBJECT Section Interpretation
39
39.55(d)
Pilot
Authorisation
Pilots can form part of a maintenance resource. In such
circumstances arrangements should be established to ensure that
appropriate authorisations are granted supported by appropriated
technical training. The scope of any authorisation should be readily
identifiable.
Inspector Review
BCAA
40
39.61(h)(8)
39.55(g)
Reliability
Programmes
Reliability programmes can be complex, this section should detail
any other documents utilised and or any subcontracted resource
utilised. The maintenance programme should detail any required
programme and details of the systems employed.
The organisation should ensure where such programmes are
catered for that every opportunity is made in integrating other
related functions into the reliability analysis.
BCAA Inspector Review
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SUBJECT Section Interpretation
41
39.61(h)(8)
39.55(g)
Engine Health
Monitoring
This monitoring can be derived from in-flight data logs completed
manually or electronically. Other mechanisms such as oil and chip
detector analysis are also employed. This section should detail the
required methods of sampling and the process of data reduction.
Inspector Review
BCAA
42
39.61(f)
39.59(f)
Structural
Inspections
The maintenance programme should identify the applicable
structural inspection programmes. Where there are reporting
functions the procedures should be made available to the
contracted maintenance providers and subsequently monitored by
the Part 39 organisation. Procedures should be developed to take
account of findings raised in the development of the maintenance
programme and that of the applicable structural programme.
Inspector Review
BCAA
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SUBJECT Section Interpretation
43
39.61(c)
Inspection
Standards
Inspection standards should be a feature of the maintenance
programme. Work order contracts with maintenance providers
should clearly identify these standards. Procedures should be
established to ensure these standards are utilised and remain
effective.
BCAA Inspector Review
44
39.73
Maintenance
Records
These records should be reviewed for completeness and any
indicators of abnormal findings. The records should be retained in
compliance with OTARs.
BCAA
Inspector Review
45
39.59(f)
Monitoring
Maintenance
A component part of the organisations activities in ensuring the
aircraft remain airworthy is to establish a process of review of the
effectiveness of scheduled maintenance
BCAA
Inspector Review
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SUBJECT Section Interpretation
46
39.73
Access to
Continuing
Airworthiness
Records
The Part 39 organisation should establish ready access to all
continued airworthiness records known to the operator. Appropriate
transfer of these records during the service provision should be
established and be reflected in the contract with the operator.
BCAA
Inspector Review
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39.77
Records
Transfer
Procedures should be established for the transfer of Continuing
Airworthiness Records in the Event of a Sale or other Disposal of
the Aircraft
BCAA
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39.55(q)
Aircraft
Leasing
The Part 39 organisation should have clear contractual instructions
where an aircraft is subject of lease and any subsequent alterations
of.
BCAA
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49
39.55(f)
Mandatory Life
Limitations
The maintenance programme should readily identify life limitations
and any associated conditions. The organisation should have
associated systems procedures and document controls to ensure
life limitations are not exceeded.
BCAA
Inspector Review
50
39.59(f)
39.55(f)
Airworthiness
Directives
Arrangement should be established for access to applicable
airworthiness directives taking account of the build standard of the
aircraft. Procedures should be established for the administration
and compliance monitoring of these requirements.
BCAA
Inspector Review
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39.73
39.69
Maintaining
Mandatory
Records of
Compliance
Recording of airworthiness directive compliance is an important
feature of the organisations responsibilities. Details of the systems
and procedures employed should be identified.
BCAA
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39.55(g)(3)
Service
Bulletins
Embodiment
Policy
Non-Mandatory Change (Modification) Embodiment Policy should
be established in agreement with the operator. Appropriate
procedures encompassing operator involvement should be
established
BCAA
Inspector Review
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39.55(i)
OTAR Part 21
Subpart C
Design
Changes
Major Change (Modification) Standards, Minor Changes, Recording
of Changes (Modifications), Repairs. Procedures should be
established to ensure appropriate approvals are granted, that the
interoperability and compatibility of design changes has been
established and any continued airworthiness instructions have
been captured.
BCAA
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SUBJECT Section Interpretation
54
39.55(h)
Repair Control Repairs should be monitored to ensure the structural integrity and
any requirement for damage tolerance is not adversely effected.
Aging aircraft requirements applicable to the aircraft should be
considered particularly where repairs require design approval.
Procedures should be developed in line with the nature of the
applicable structural and fatigue requirements.
BCAA
Inspector Review
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39.61(h)(9)
39.55(m)
Special
operational
approvals
Where an operator has or is seeking to obtain a special operational
approval, the organisation should ensure that the airworthiness
related issues of such an approval are addressed by the OTAR
Part 39 CAMO and where applicable the OTAR Part 145 AMO.
BCAA
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56
39.57
Maintenance
Arrangements
Detailed List of Maintenance organisations utilised and the
Maintenance Contractor Selection Procedure
BCAA
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SUBJECT Section Interpretation
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OTAR Part 43
Subpart C
Maintenance
Certification
Procedures should be established for the review of maintenance
work order instructions to ensure that certifications are made in
compliance with OTARs.
BCAA
Inspector Review
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39.55
Ground
Handling
Sub-contracted Ground Handling functions are an operator’s
responsibility. Where these arrangements affect the airworthiness
of the aircraft, arrangements should be made with the operator to
ensure that any need to alter the ground handling agreements are
addressed.
BCAA
Inspector Review
59
39.55(j)
Liaison
Meetings
Arrangements should be established for Maintenance Programme
Review, Development and Amendment Maintenance Programme
Meetings, Reliability and any other required meetings both internal
and external. These meetings should be formalised, recorded and
where possible the frequency should be established.
BCAA
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SUBJECT Section Interpretation
60
39.55
Liaison with
Manufactures
and
Regulatory
Authorities
Arrangements should be made for appropriate liaison with
organisations that support the continued airworthiness of the
aircraft. Contact details should be readily available and
communications established in order that given any situation
requiring addition technical support the Part 39 organisation can
elicit such support.
BCAA Inspector Review
61
39.55(p)
Mandatory
Occurrence
Reporting
Occurrence reporting should be a feature of the organisation and
that of the control of occurrence reports and the subsequent
investigations and rectification actions.
BCAA
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62
39.59(f)
Fuelling Policy Control of Aircraft Refuelling, Quantity/Quality, Contamination
Checks, safety procedures should be established and secured with
the operator
BCAA
Inspector Review
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SUBJECT Section Interpretation
63
OTAR Part 36
39.55
Environmental
Protection
Control of Snow, Ice, Dust and Sand Contamination and any noise
certificate should be reflected in the organisations procedures
BCAA
Inspector Review
64
39.81
Aircraft
Loading
Security of Cargo and Baggage loading should be reviewed to
ensure the operator’s procedures do not affect the airworthiness of
the aircraft.
BCAA
Inspector Review
65
OTAR Part 43
Subpart C
Aircraft
Weighing
The operators mass and balance manual should be readily
available and procedures established for the production of
schedules as required by OTARs.
BCAA
Inspector Review
66
OTAR Part 21
Subpart E
Check Flight
Procedures
The need to undertake a check flight should be established with
appropriate justification. Any required data recording identifying
approved data should be furnished to the operator.
BCAA Inspector Review
Form AW-282 V.4 Jan 2021