NANDTB meeting with CASA Regulatory Change group

On 30th November the Chairman and Secretary met with CASA to address some anomalies and offer the Board’s views on the draft Part 145 MOS and AMC documents, as they affect NDT and the NANDTB. CASA was represented by Nick Ward, David Skeoch, Ifte Ahmed and Michael English.

The new CASA regulations follow the EASA model very closely. Part 145 defines the requirements for an Approved Maintenance Organisation (AMO) and will replace the existing CAR 30 requirements. The new rules are in three tiers, these are;

• The Part 145 Regulation itself
• The Manual of Standards, which is descriptive text in outcome based language describing what is required of the AMO
• The Acceptable Means of Compliance (AMC) and Guidance Material (GM), which describe one way, but not the only way, to comply with the regulation and explains and amplifies the policy intention.

In November CASA published Part 145 and other draft regulations on its web site (http://www.casa.gov.au) and is aiming to finalise the new maintenance suite of regulations by mid 2010, with the applicability and effect of the rules to be phased in from 1 November 2010. Regular public transport operators and the maintenance organisations servicing them will be the first to move to the new regulations.

These organisations will have two years to transition to part 42; which covers the maintenance responsibilities of operators, and part 145; which covers the requirements for maintenance organisations. When this first phase of transition is complete, Parts 42 and 145 will begin to apply to all other classes of aircraft operations, with a further two year transition period.

The applicability to the other classes of aircraft operations is reliant on the introduction of the new operational suite of the Civil Aviation Safety Regulations. CASA will consult further with the general aviation sector at this stage of transition to the new rules.

NDT is not specifically mentioned in the MOS as it describes higher level requirements and NDT is regarded as just one of a series of specialist services. In a Part 145 organisation, these services are known as “D” ratings. D1 being NDT, D2 being welding and D3 being other specialist services. The MOS states that personnel performing specialist services work shall be competent, qualified and capable. In the case of NDT, the competence, qualification and capability are found in the Part 145 AMC and refer directly to the AS 3669. The draft AMC material reflects closely the existing CAAP for NDT and so needs some modification to align with the new Part 145 requirements.

It is in the AMC that CASA states its recognition of the NANDTB as the industry representative body for the purposes of AS 3669. One of the changes will be the addition of EN4179 and NAS 410 to AS 3669 as acceptable standards. Other standards of qualification may be used if acceptable to CASA. This is consistent with the Board’s decision in May 2009 to use EN 4179 and NAS 410 in lieu of AS 3669, because it is expected that in a few years, AS 3669 will cease to be an active Australian standard.

CASA reaffirmed it policy to liaise with the NANDTB as the new regulations guidance material is developed and implemented, and the Board responded with some suggestions of how it may be of assistance to CASA. From the timeframes noted above, NDT Airworthiness Authorities will remain in force until transition is complete. Beyond that however, it will be the responsibility of the Part 145 organisation to assess and authorise its NDT staff, and have a process to accept/authorise contracted NDT staff.