4.2 Management, Personnel, Certifying Staff & Support Staff Requirements

Management Structure and Leadership Accountability (145.A.30)

An approved maintenance organisation cannot function as a loose collective of certified technicians. EASA Part-145 establishes a rigid statutory hierarchy under 145.A.30, defining clear lines of administrative, technical, and legal responsibility. The management framework ensures that commercial and financial pressures never compromise airworthiness standards, and that safety oversight remains structurally independent of production demands.

The Accountable Manager (145.A.30(a))

The cornerstone of the Part-145 management structure is the Accountable Manager (AM). The regulation mandates that the organisation must appoint a single corporate leader—typically the Chief Executive Officer (CEO), Managing Director, or Chairman of the Board of Directors—who possesses:

• Corporate Authority: The formal executive power to direct company operations, establish policy, and enforce compliance with Part-145 and the approved MOE.
• Financial Responsibility: Direct control over corporate financial resources, ensuring that all maintenance required by the customer can be fully financed and executed to the statutory standards of Part-145.

The Corporate Commitment Statement (MOE 1.1)

The Accountable Manager must personally sign the Corporate Commitment Statement in Part 1.1 of the MOE. This document constitutes a legally binding covenant made directly to the Competent Authority. By signing, the AM certifies that the MOE and associated procedures define the organisation's compliance with Part-145 and will be adhered to at all times. If the Accountable Manager is replaced, the incoming executive must re-sign the statement within a defined period accepted by the Competent Authority, reaffirming corporate commitment.

Nominated Persons (145.A.30(b))

The Accountable Manager delegates operational management to a cadre of Nominated Persons (often referred to as postholders). These individuals are responsible for the daily execution of maintenance and safety functions, reporting directly or functionally to the Accountable Manager:

1. Base Maintenance Manager: Responsible for the planning, execution, hangar infrastructure, and technical integrity of all base maintenance operations.
2. Line Maintenance Manager: Responsible for all outstation and flight-line facilities, ensuring defects are rectified and transit flights released without compromising airworthiness.
3. Workshop Manager: Responsible for component, engine, and specialised service shops, overseeing bench overhaul and the issuance of EASA Form 1 certificates.
4. Compliance Monitoring Manager (formerly Quality Manager):
   • Exercises complete structural independence from the production hierarchy.
   • Holds direct access to the Accountable Manager to report non-compliances, audit findings, and regulatory deficiencies without fear of operational reprisal.
   • Oversees the independent audit plan and monitors corrective action implementation.
5. Safety Manager (introduced under Regulation (EU) 2021/1963):
   • Coordinates the Safety Management System (SMS) across the organisation.
   • Facilitates hazard identification, safety risk management, and the internal safety reporting scheme under 145.A.202.

The EASA Form 4 Approval Process

Nominated persons are not merely selected by company human resources; they must be formally evaluated and found acceptable by the Competent Authority. This vetting procedure involves submitting an EASA Form 4 (or equivalent national form), documenting the nominee's academic qualifications, aviation technical credentials, managerial background, and comprehensive working knowledge of Part-145, Part-M, and safety management principles.

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Manpower Resources and Production Planning (145.A.30(d))

Under 145.A.30(d), the organisation must establish and control the competence of personnel involved in any maintenance, management, or safety audits. Crucially, it must implement a formal Manpower Planning System:

• Workload Forecasting: The organisation must demonstrate that it has sufficient qualified staff to plan, perform, supervise, inspect, and compliance-monitor all maintenance activities.
• Production Man-Hour Plan: A structured, mathematically calculated plan showing that planned maintenance commitments do not exceed available technician working hours. The plan must account for non-productive hours, including scheduled leave, sick leave, mandatory recurrent training, and administrative duties.
• Reassessment: If actual maintenance man-hours exceed planned hours by more than a defined threshold (typically 25% for a given work package), the organisation must formally reassess the plan to prevent technician overload.

Fatigue Risk Management and Work-Hour Limits

Human fatigue is recognized as a primary causal factor in maintenance errors. In accordance with AMC 145.A.30(d) and international human factors guidance, Part-145 organisations must enforce strict work-hour limitations within their approved procedures:

• Maximum continuous duty shifts (typically not exceeding 12 hours including handover);
• Mandatory minimum rest periods between consecutive shifts (at least 11 continuous hours in any 24-hour period);
• Strict limits on consecutive night shifts (typically capped at 3 or 4 consecutive nights) followed by mandatory restorative rest days.

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Base Maintenance Architecture: Certifying Staff vs Support Staff

One of the most essential concepts in EASA Part-145—and a foundational topic in Module 10 examinations—is the division of legal responsibility between Category C Certifying Staff and Category B1 / B2 Support Staff in the base maintenance of complex motor-powered aircraft (CMPA) under 145.A.30(h) and 145.A.35.

The Mechanics of the Base Maintenance CRS Gate

In base maintenance, the release of the aircraft is a coordinated, multi-stage legal process:

1. Task Execution: Technicians and mechanics perform physical inspections, component removals, structural modifications, and reassemblies under approved maintenance data.
2. Support Staff Verification & Sign-Off: The Category B1 and Category B2 support staff ensure that all technical tasks, inspections, and independent inspections within their respective disciplines have been executed correctly. They physically sign off each individual task card or work order stage.
3. The Category C Release Gate: The Category C certifying staff member reviews the complete maintenance work package. The Cat C engineer verifies that:
   • Every job card is signed off by appropriately qualified B1 or B2 support staff;
   • All required independent inspections for critical tasks have been conducted and documented;
   • All Airworthiness Directives (ADs) and customer work orders are accounted for;
   • No known defects or physical discrepancies exist that jeopardize flight safety.
4. Issuance of Aircraft CRS: The Category C certifying staff member signs the single Certificate of Release to Service on behalf of the Part-145 organisation, returning the entire aircraft to service.

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Competence Assessment, Training, and Company Authorisations (145.A.35)

Holding an EASA Part-66 licence is a prerequisite, but it does not grant an individual the automatic legal privilege to certify maintenance on behalf of an approved organisation. Certification privileges flow exclusively through an internal company document known as the Company Certification Authorisation (CCA) issued under 145.A.35.

Competence Assessment (145.A.30(e) & 145.A.35)

Before issuing a CCA to certifying staff or support staff, the organisation must conduct a formal, documented Competence Assessment. This evaluation assesses:

• Technical knowledge and practical expertise on the specific aircraft types, systems, and maintenance tooling;
• Working knowledge of the MOE, company procedures, and customer technical logbook completion;
• Human factors awareness, safety reporting attitude, and communication skills;
• Language proficiency in the language used for technical maintenance documentation (normally English).

Mandatory Initial and Recurrent Training Regimes

To obtain and maintain a Company Certification Authorisation, technical personnel must complete continuous recurrent training. Under Part-145 AMCs, recurrent training must occur at least once every 24 months (2 years) and cover four core disciplines:

1. Human Factors (HF):
   • In accordance with AMC 145.A.30(e), training covers human performance limitations, circadian rhythms, fatigue, shift work, communication barriers, complacency, situational awareness, and the "Dirty Dozen" error precursors.
2. Electrical Wiring Interconnect System (EWIS):
   • Mandated by AMC 20-22, structured into Target Groups 1 through 8. Certifying and support staff belong to Target Groups 1 and 2, requiring in-depth training on wiring inspection, zonal cleaning, wire bundle degradation, clamp installation, and separation of wiring from hydraulic/oxygen lines.
3. Fuel Tank Safety (FTS / CDCCL):
   • Mandated by AMC 20-19, encompassing Phase 1 (awareness) and Phase 2 (detailed technical instructions). Focuses on ignition prevention, nitrogen inerting systems, and Critical Design Configuration Control Limitations (CDCCL)—design features (such as fuel pump bonding leads and conduit clearances) whose integrity must be preserved to prevent explosion hazards.
4. Safety Management System (SMS):
   • Mandated by Regulation (EU) 2021/1963, instructing staff on hazard identification, safety risk assessment, voluntary occurrence reporting, and the organisation's Just Culture principles.

Recency of Maintenance Experience

Under 145.A.35(c), certifying staff and support staff must maintain operational currency. The regulation establishes a strict recency threshold: personnel must have accumulated at least 6 months of relevant aircraft or component maintenance experience in any consecutive 2-year (24-month) period.

• Relevant experience means the staff member has worked in an aircraft or component maintenance environment, exercised the privileges of their authorisation, or performed technical management, planning, or quality auditing directly relevant to the authorisation scope.
• If a staff member fails to meet the 6-month recency threshold, their CCA is automatically suspended until they undergo supervised refresher training under the oversight of an active certifying staff member.

Authorisation Records Retention

Since Regulation (EU) 2021/1963 the personnel record rules sit in 145.A.55(d), not in 145.A.35. Under 145.A.55(d)(3) the records of all certifying staff and support staff must include the details of any Part-66 licence held (or equivalent), the scope of the certification authorisations issued, and the particulars of anyone holding limited or one-off authorisations under 145.A.30(j). Under 145.A.55(d)(4) personnel records are kept for as long as the person works for the organisation and retained for at least 3 years after the person has left, or after an authorisation issued to that person has been withdrawn. Under 145.A.55(d)(5) staff must be given access to their records on request and a copy on leaving.

Do not confuse this with the other Part-145 retention periods: maintenance records 3 years (145.A.55(a)(3)), airworthiness review records 3 years (145.A.55(b)(2)), and management system and contracting/subcontracting records 5 years (145.A.55(c)). Separately, 145.A.35(j) simply requires the organisation to give certifying staff a copy of their certification authorisation, and 145.A.35(k) requires them to produce it to any authorised person within 24 hours.

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Practical Maintenance Scenario & Module 10 Exam Tips

Maintenance Practical Scenario: During an Airbus A330 base maintenance C-check, a Category B1 support staff member oversees the replacement of the main landing gear brake assemblies and functional leakage tests, signing off the corresponding job cards in the work package. Concurrently, a Category B2 support staff member oversees the functional testing of the dual flight management guidance computers (FMGC), signing off the avionics task cards. Neither the B1 nor the B2 support staff can issue an aircraft Certificate of Release to Service. The Category C certifying engineer performs a final review of all completed task cards, confirms that all independent inspections and deferred defects are resolved, and signs the single aircraft CRS.

Module 10 Exam Tips:

• The Accountable Manager is defined by corporate authority and financial responsibility to ensure maintenance can be funded to Part-145 standards.
• Nominated postholders are approved by the Competent Authority via EASA Form 4.
• In base maintenance of CMPA: Category C issues the aircraft CRS; Category B1 and B2 support staff sign off tasks at work package level but never issue the aircraft CRS.
• Recency requirement under 145.A.35: at least 6 months of relevant experience in the preceding 2 years.
• Recurrent training (Human Factors, EWIS, Fuel Tank Safety/CDCCL, and SMS) must be refreshed at least every 24 months.
• Personnel records must be kept for at least 3 years after the person leaves the organisation — the rule is 145.A.55(d)(4), not 145.A.35(j). Management system and contracting records are kept 5 years (145.A.55(c)).