PART-145 EASA and FAA: understanding aviation maintenance approvals

Aircraft maintenance is not an isolated technical act. It is a documentary, human and material chain governed by an international framework whose cornerstones bear the name PART-145. Behind this code lies the rule book that defines how a workshop may legally release an aircraft, an engine or a component back into service. For AéroNéo, which is structuring its MRO activity on the Tiaret aeronautical base, understanding then integrating this framework is not optional, it is the very condition of commercial existence.

1. Why a regulatory framework for aircraft maintenance

Before examining the texts, we must recall what they protect. A civil aircraft must, on every flight, be in a state of airworthiness. This airworthiness is not a spontaneous state: it results from scheduled maintenance operations, inspections, repairs and modifications, all of which must be traced, signed and retained throughout the life of the airframe. Without such a framework, no authority could certify that an aircraft is fit to fly, no insurer could underwrite the operator, no technician could shoulder personal responsibility.

The regulatory framework pursues three inseparable objectives:

• Safety: prevent technical failure by imposing standards of competence, tooling, procedures and quality review.
• Traceability: require that every part, every task, every flight hour be documented and retrievable, from the component supplier through to the final operator.
• Continuing airworthiness: ensure that the aircraft remains compliant with its type certificate (TC) throughout its operational life, including after modifications, major repairs or operational feedback.

PART-145 addresses these three requirements by imposing not a product quality, but an organisational quality. We do not certify an aircraft leaving the workshop: we certify the workshop itself, its personnel, its procedures, its capability list, its documentation. The release of an aircraft thus becomes the legitimate consequence of an organised system.

2. ANAC Algeria: national competent authority

In Algeria, the competent authority for airworthiness and maintenance matters is the ANAC (Autorité Nationale de l'Aviation Civile). Any organisation established on Algerian territory wishing to obtain a maintenance approval for 7T- registered aircraft falls primarily under ANAC. It is ANAC that audits, approves, supervises and, where applicable, suspends or withdraws the approval.

The Algerian framework rests on Law 98-06 on civil aviation, its implementing texts, and a progressive alignment on ICAO standards (Annexes 6, 8, 19) and on the EASA and FAA frameworks, themselves integrated into many national regulations worldwide. ANAC capitalises on this dual movement: bringing the Algerian MRO fabric up to international standards while retaining sovereignty of supervision.

For a workshop such as AéroNéo, the sequence is clear: ANAC approval first, then extension to EASA Part-145 and FAA Part-145 in a second stage, the latter two via bilateral agreements (BASA, MAG, MIP) or via a direct approach with mandated external auditors. Algerian logic first, international openness second, is the only realistic path to structuring a credible MRO player.

3. EASA Part-145: origin and architecture

EASA Part-145 originates from the work of the JAA (Joint Aviation Authorities) from the early 1990s. JAR-145, published in 1991, was the first unified European framework for maintenance organisations. In 2003, EASA (European Union Aviation Safety Agency) took over this work and incorporated it into Community law.

The current reference text is Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products. Its Annex II (Part-145) sets out the requirements applicable to maintenance organisations. It is supplemented by the Acceptable Means of Compliance (AMC) and the Guidance Material (GM) issued by EASA, which detail acceptable methods of application.

EASA Part-145 covers the maintenance of public transport aircraft, large aircraft, engines, components and equipment. It defines the responsibilities of the Postholder Accountable Manager, the Maintenance Manager, the Quality Manager and the Safety Manager. It imposes a quality system independent from production, an internal audit programme and a follow-up of findings.

4. FAA Part-145: 14 CFR Part 145

In the United States, the equivalent framework is codified under 14 CFR Part 145, entitled Repair Stations. The Federal Aviation Administration approves organisations (whether located in the United States or abroad) that wish to perform maintenance on N- registered aircraft or on components intended to fit such aircraft.

The principles of the American Part 145 are close to those of the European Part-145 — requirements on tooling, personnel, premises, documentation, quality system — but with specificities. The concept of repair station is broader and includes a notion of line maintenance and shop work. The Repair Station Manual (RSM) plays a role equivalent to the European MOE, supplemented by the Quality Control Manual (QCM).

For a workshop based outside the United States and wishing to obtain an FAA approval, two routes coexist. Either a direct FAA approval (foreign repair station), or the benefit of a Bilateral Aviation Safety Agreement (BASA) between the United States and the country of establishment, supplemented by a Maintenance Implementation Procedure (MIP). These agreements allow local authorities to approve the organisation on behalf of the FAA, under joint surveillance.

5. Ratings and scopes: structure of approvals

A PART-145 approval is never generic. It is scope-driven: the organisation is approved for a precise list of aircraft and equipment categories. This structure is codified through ratings, whose EASA nomenclature has become the international reference.

Rating	Technical scope	Examples
A1	Aeroplanes above 5,700 kg	A320, A330, 737, 777
A2	Aeroplanes 5,700 kg or below	Cessna 208, PA-31, Beech King Air
A3	Helicopters	EC135, AS350, Bell 412
A4	Aircraft other than A1/A2/A3	Gliders, balloons, airships
B1	Turbine engines	CFM56, V2500, PW1100, RR Trent
B2	Piston engines	Lycoming O-360, Continental TSIO-550
B3	APU (Auxiliary Power Units)	APS 3200, GTCP 131
C	Components other than complete engines	Landing gear, computers, hydraulics, avionics, structures
D	Specialised services	Non-destructive testing (NDT), specific tests

The C rating is itself subdivided into sub-ratings (C1 air conditioning, C2 auto flight, C3 communications, etc.) covering about twenty equipment families. This granularity allows each organisation to target its scope precisely without committing to skills it does not master.

6. The MOE: Maintenance Organisation Exposition

The central document of Part-145 is the MOE — Maintenance Organisation Exposition. This manual, sometimes several hundred pages long, describes the organisation in its entirety. It is approved by the competent authority during the initial audit, then any substantial modification must be subject to a fresh approval.

The MOE is traditionally structured in five main parts:

1. Part 1 — Management: commitment of the Accountable Manager, organisation chart, named postholders, scope of approval, capability list.
2. Part 2 — Maintenance procedures: reception of aircraft and components, planning, task execution, quality control, release via CRS and Form 1.
3. Part 3 — Quality system: internal audits, finding follow-up, indicators, management review, lessons-learned management.
4. Part 4 — Specific procedures: line maintenance, exceptional works, sub-contractor contracts, calibrated tooling management.
5. Part 5 — Annexes: form examples, document templates, lists of applicable publications.

The MOE is not a theoretical document. During each audit, the auditor verifies that actual practice corresponds strictly to what is described. Any deviation is recorded as a finding, classified as level 1 (immediate) or level 2 (to be addressed within a defined deadline).

7. The capability list: cornerstone of the scope

The capability list is the detailed inventory of tasks that the organisation is authorised to perform. It refines the general scope into a precise list of aircraft (by MSN or by family), engines, components (by P/N or by family), and associated tasks. An A1-rated organisation is not authorised to work on every aircraft above 5,700 kg: only the types listed in its capability list are covered.

Establishing a rigorous capability list implies for each entry:

• Availability of up-to-date manufacturer documentation (AMM, IPC, SRM, CMM as applicable).
• Specific calibrated tooling, as well as any GSE (Ground Support Equipment).
• Trained and qualified personnel on the relevant type, with proof of initial training and recurrent training.
• Traceable spare parts with EASA Form 1 or FAA 8130-3.
• Local procedures drafted and approved in the MOE or in MOE Procedures (MOEP).

The capability list evolves over time: additions as new skills are acquired, deletions in case of loss of competence or discontinuation of the relevant activity. Each modification is submitted to the Quality Manager and, depending on its magnitude, to the competent authority.

8. Personnel: technicians, support staff, certifying staff

A PART-145 approval relies on people more than on hangars. Several personnel categories are defined, each with specific prerogatives and requirements.

Licenced Aircraft Maintenance Engineer (LAME / Part-66)

Part-66 defines the individual licences of aircraft maintenance engineers. The B1 (mechanical, structural, engine, electrical) and B2 (avionics) licences are the most widespread on public transport aircraft. A Part-66 licence is issued after theoretical examinations, practical experience (typically 5 years), and type-specific training on the relevant aircraft.

Certifying Staff

The Certifying Staff is the individual authorised to sign the CRS (Certificate of Release to Service) on behalf of the organisation. They engage the legal liability of the workshop and their own. Their nomination relies on a Part-66 licence or equivalent, a specific authorisation issued by the organisation (badge or stamp number), and demonstrated experience on the relevant aircraft type.

Support Staff

The Support Staff assists Certifying Staff during base maintenance inspections (C-check, D-check). These technicians do not sign the CRS but prepare, execute and document the tasks under the responsibility of the Certifying Staff.

Postholders

Named postholders are the organisational pillars: Accountable Manager (overall and financial responsibility), Maintenance Manager, Quality Manager (independent from production), Safety Manager. Each is named in the MOE and accepted by the competent authority.

9. EASA Form 1 and FAA 8130-3: component release

When a component leaves a workshop after maintenance, it must be accompanied by a document attesting to its conformity and fitness for reinstallation. This document is called an Authorized Release Certificate.

• On the EASA side, it is called EASA Form 1. It attests that the component has been maintained in accordance with Part-145 requirements.
• On the FAA side, its equivalent is the FAA Form 8130-3, in its Authorized Release version.

Under bilateral agreements (US-EU BASA), a workshop may issue a dual release: the same Form 1 / 8130-3 is valid simultaneously on the EASA side and on the FAA side, provided that the organisation holds both approvals and that the corresponding box (« dual release ») is ticked and signed.

Dual release is a major commercial asset: it spares the operator a duplicate release fee, opens access to a worldwide market, and signals a level of organisation that is perfectly bilingual from a regulatory point of view. This is the horizon towards which an ambitious workshop structures its MOE from day one.

10. The CRS: Certificate of Release to Service

The CRS (Certificate of Release to Service) is the fundamental legal act of maintenance. Affixed by the Certifying Staff at the end of the intervention, it declares that the task has been carried out in accordance with the applicable maintenance data and that the aircraft or component is fit to return to service.

The CRS is recorded in the aircraft technical log for line operations, or in the work pack for base operations. As a minimum, it includes:

• Precise description of the task performed.
• References to the maintenance data used (AMM, SB, AD, EO).
• Date, time, place of execution.
• Identification of the Certifying Staff (name, signature, authorisation number).
• Approval number of the organisation.

The CRS engages both the organisation and the individual: in the event of a subsequent incident linked to a poorly executed intervention, it is binding evidence in the investigation. This is why Part-145 requires the retention of records for a minimum of three years after the intervention, a duration regularly extended by operators through contract.

11. Initial audit and ongoing surveillance

Obtaining a Part-145 approval begins with lengthy documentary work: drafting of the MOE, formalisation of procedures, qualification of personnel, structuring of the capability list. Once this foundation is ready, the organisation lodges a formal application with the competent authority, accompanied by the proposed MOE.

The initial audit proceeds in two phases:

1. A documentary review: the authority examines the MOE, procedures, postholder CVs, sub-contracting agreements, personnel competences.
2. An on-site audit: the auditors visit the premises, check the tooling, observe the actual execution of tasks, interview technicians, control the traceability of recent work packs (even pre-approval).

Findings are classified as level 1 (major non-compliance, to be corrected immediately before issue) or level 2 (minor non-compliance, to be corrected within a defined timeframe). The approval is issued once all level 1 findings are cleared.

Once approved, the organisation enters a cycle of continuous surveillance: annual (or bi-annual depending on risk profile) audits, unannounced audits, inspection of major work packs. Any substantial change (new postholder, new site, scope extension, capability list modification) must be notified and, where applicable, approved.

12. AéroNéo and PART-145: an engaged path

AéroNéo has chosen, from the design phase, to set its MRO workshop on the trajectory of a Part-145 approval. The process is engaged, not yet achieved: we are currently in the phase of structuring the MOE, mapping the target capability list, and recruiting qualified postholders. The objective is an Algerian ANAC approval as a first step, followed by an EASA Part-145 extension as a second step, then FAA Part-145 via the applicable bilateral agreements.

The target capability list reflects our industrial positioning: A320 and 737 narrow-bodies, A330 and 777 wide-bodies, CFM56 and V2500 engines, APUs and an extended component scope (C sub-ratings). To this is added a P2F conversion stream and a recycling stream which, while not directly under Part-145 for the dismantling part, rely on the same principles of traceability and quality.

The path is long, demanding and costly. It is in no way optional for a serious player. Every page of the MOE, every line of the capability list, every Part-66 training course funded represents a step towards the ultimate outcome: an Algerian workshop capable of affixing a CRS recognised worldwide, accompanied by a Form 1 and an 8130-3 in dual release, releasing aircraft and components to the most demanding standards of commercial air transport.

PART-145 is not a paper on the director's office wall. It is the backbone of an MRO workshop. Everything that comes in, everything that goes out, everything that takes place finds its justification in this framework. For aeronautical Algeria, it is the mandatory horizon.