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Thread: Part 145.A.48(a) Tool control declaration

  1. #1
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    Default Part 145.A.48(a) Tool control declaration

    Our QM has just communicated with us a new EASA regulation which has just come into force. Part 145.A.48(a)

    It seems that EASA haven't updated their website yet, as their latest revision is dated July 2016. https://www.easa.europa.eu/system/fi...2016-011-R.pdf

    the (a) states “after completion of maintenance a general verification is carried out to ensure that the aircraft or component is clear of all tools, equipment and any extraneous parts or material, and that all access panels removed have been refitted“

    We have been informed that Airbus have modified their AMMs accordingly, so if you sign off a task IAW the AMM, you don't need to make a separate declaration. However Boeing haven't incorporated it into their manuals yet.

    Some operators are adapting their tech-logs to include a tool declaration CRS box.

    Our QM has agreed that a following example of a tech-log write up is acceptable, “No 3 main wheel assembly replaced IAW AMM 32-45-01 Rev Jan17.Tool check performed IAW Part 145.A.48(a).”

    For work packages that do not have this declaration incorporated into them, our company have designed a form to accompany the work pack with a separate CRS with the tool declaration.
    God created aircraft mechanics so that pilots can have heroes too.

  2. #2
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    Default Re: Part 145.A.48(a) Tool control declaration

    We've been using that statement for A checks and above for some time now, but not for individual tasks certified in the tech log.

    The CRS block in our tech log has a statement that work has been carried out iaw Part 145. Albeit a bit of a blanket statement, this seems sufficient to cover the requirement of Part 145.A.48(a)

    There is no applicable AMC for 145.A.48(a), so a bit of interpretation is required...

    As a side note, the latest publications should be viewed/downloaded from the new EASA erules site :

    https://www.easa.europa.eu/document-...gulation-eu-no

    Our resident regulations expert, 400hz will be along shortly to put his spin on it.
    Last edited by Dunny; April 12th, 2017 at 18:52.
    Eat more pies....2E0AUG


  3. #3
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    Default Re: Part 145.A.48(a) Tool control declaration

    Ooh, AMCs....You know how he feels about those....
    Dip me in chocolate and throw me to the lesbians....



  4. #4
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    Default Re: Part 145.A.48(a) Tool control declaration

    Yes Billy, exactly.

    There's quite a lot to this and making sure that the tools are back in the tool box is a good start. Error capturing, elimination of multiple errors, grouping of tasks for safety, critical maint tasks and maintaining critical design features (separation) of fuel tank wiring systems. They even identify the European trick of 'reinspection' method for the same person to do the independant inspection. Some of this has been in place after EC2042 disappeared although technically I guess it appeared in the regulations at the M2 amendment EU2015/1536.

    I think someone in Safety & Compliance (they've even changed the name of the Quality Manager) will be busy, but he might slope his shoulders and point to the Part-145 postholder and his team.

    Let's quickly go on holiday while it gets sorted out.

  5. #5
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    Default Re: Part 145.A.48(a) Tool control declaration

    you'd be good as a politician. A load of waffle but no answers...
    Eat more pies....2E0AUG


  6. #6
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    Default Re: Part 145.A.48(a) Tool control declaration

    Quote Originally Posted by Dunny View Post
    you'd be good as a politician. A load of waffle but no answers...
    or a QM.
    Dip me in chocolate and throw me to the lesbians....



  7. #7
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    Default Re: Part 145.A.48(a) Tool control declaration

    We've had all this in helicopters for yonks, you plank guys might need to catch up.


  8. #8
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    Default Re: Part 145.A.48(a) Tool control declaration

    I could understand the need for this with helicopters but not with real aircraft...
    Dip me in chocolate and throw me to the lesbians....



  9. #9
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    Default Re: Part 145.A.48(a) Tool control declaration

    I await our safety and compliance manager making a mountain out a mole hill out of this. Saying that the AMM for one of my types does state replacement of panels removed and removal of all external objects including tools in each task write up.
    Alonso Hater

  10. #10
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    Default Re: Part 145.A.48(a) Tool control declaration

    Don't even start looking at the CAA definition of Line and Base Maintenance....then some people will get a shock! That's another mess of an AMC to contend with.

    There will be more tears at bedtime.


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