BR-ANAC-IOAR cheat sheet
BR-ANAC-IOAR · Keep the key ideas within reach.
RBAC for Airworthiness and Continuing Airworthiness
RBAC 21 governs type certificates, production certificates, and airworthiness certificates for aeronautical products; RBAC 43 governs maintenance, preventive maintenance, rebuilding, and alteration.
RBAC 45 covers identification and registration marking; RBAC 47 covers aircraft registration with the RAB (Registro Aeronáutico Brasileiro).
ANAC issues the Certificado de Aeronavegabilidade (CA) and the Certificado de Aeronavegabilidade Especial; validity is tied to compliance with the applicable maintenance and inspection program.
Continuing airworthiness obligations rest with the registered owner or operator, who must ensure maintenance is performed by properly certificated persons or approved organizations.
A change to type design requires approval (supplemental type certificate, amended TC, or ANAC-accepted design change) before it may be embodied; unapproved alterations invalidate the airworthiness certificate.
Repairs and alterations must be recorded and, where required, approved by ANAC or a design organization holding the appropriate RBAC 21 privilege.
Maintenance records must be retained and made available to ANAC inspectors; the aircraft cannot be returned to service until required inspections and approvals are completed.
RBAC requirements are harmonized with FAA/EASA frameworks but national differences (e.g., ANAC-specific forms, Portuguese-language records) must be respected.
Airworthiness Certification and Approval Processes
Type certification process: application, definition of certification basis, compliance plan, conformity inspection, test evidence, and issue of the type certificate.
Certification basis typically includes the applicable airworthiness code (e.g., RBAC 23, 25, 27, 29) plus special conditions, equivalent safety findings, and exemptions where justified.
Production approval may be via production certificate, or via approved manufacturing procedures under an accepted quality system.
Airworthiness certificate issuance requires demonstration of conformity to the approved type design and completion of required inspections and tests.
Special airworthiness certificates (e.g., experimental, restricted, provisional) carry operating limitations stated on the certificate and in associated documentation.
Approval of design changes and repairs: major changes require a new or supplemental approval; minor changes may be approved by an authorized designee or approved organization.
Continued airworthiness: TC holder must issue and update maintenance manuals, airworthiness limitations, and service information; ANAC approves airworthiness limitations.
Import/export of aircraft requires validation or acceptance arrangements and a statement of conformity from the exporting authority.
Continuing Airworthiness Management and Maintenance Programs
An approved maintenance program (AMP) is the basis for scheduled maintenance; it derives from the MRB report or manufacturer recommendations plus operator-specific tasks.
Maintenance program content includes tasks, intervals, and escalation rules; changes require ANAC approval or acceptance per the applicable RBAC.
Airworthiness Directives (ADs) are mandatory; compliance must be recorded and tracked, and repetitive ADs must be scheduled in the maintenance program.
Reliability programs may allow interval escalation only where approved and supported by statistical evidence and monitoring.
Maintenance records must link each task to the aircraft, component, or appliance and be retained per the applicable retention schedule.
Component control includes life-limited parts tracking, shelf-life items, and traceability of parts to approved sources.
Continuing airworthiness management organizations (CAMO) perform airworthiness review, maintenance planning, and record-keeping under an approved exposition.
Mass and balance, and weight and CG limits, must be maintained within approved limits after any alteration or repair.
Inspection, Audit, and Surveillance Techniques
Risk-based surveillance: allocate inspection resources according to operator/organization risk profile, occurrence history, and complexity.
Audit types: system audit (organization-wide), product audit (specific aircraft/component), and process audit (specific procedure).
Audit phases: planning, opening meeting, evidence collection (interviews, records, observation), findings classification, closing meeting, corrective action follow-up.
Findings levels: Level 1 (significant non-compliance affecting safety), Level 2 (isolated non-compliance), and observations; each drives a defined response timeline.
Sampling must be representative and documented; conclusions must be traceable to objective evidence.
Checklist design should map to regulatory requirements and to the organization's exposition to ensure coverage.
Surveillance of maintenance organizations includes facility inspection, tooling and calibration checks, personnel licensing verification, and record audits.
Corrective action verification requires evidence of root cause analysis and effectiveness, not just a stated fix.
Air Operator and Maintenance Organization Certification and Oversight
Air operator certification (RBAC 121/135) requires an operations manual, training programs, maintenance program, SMS, and demonstration of compliance through proving runs where applicable.
Maintenance organization approval (RBAC 145) requires an exposition, facility, tooling, trained personnel, quality system, and a designated accountable manager.
The accountable manager has corporate authority for compliance and for funding the maintenance system.
Approval certificates specify ratings (airframe, powerplant, avionics, components) and limitations; work outside ratings requires subcontracting arrangements approved by ANAC.
Oversight includes initial certification, periodic audits, and special inspections triggered by occurrences or changes in scope.
Changes to organization (facilities, key personnel, ratings) require prior notification and, where specified, prior approval.
Training and qualification records for certifying staff, inspectors, and instructors must be maintained and available for audit.
Subcontracting and contract maintenance require evaluation and listing in the organization's procedures, with ANAC acceptance.
Safety Management Systems and Occurrence Reporting
SMS components: safety policy, safety risk management, safety assurance, safety promotion; each must be documented and implemented.
Hazard identification and risk assessment use severity and likelihood matrices; risk must be mitigated to acceptable levels with documented rationale.
Occurrence reporting: mandatory reportable events (accidents, serious incidents, malfunctions) must be reported to ANAC within defined time limits.
Voluntary reporting systems protect reporters and feed safety data; confidentiality rules apply to protect the reporter.
Safety assurance uses audits, surveys, and data analysis (e.g., flight data monitoring, maintenance error trends) to verify mitigations.
Safety performance indicators and targets are established and monitored; deviations trigger corrective action.
Just culture distinguishes inadvertent errors from reckless or intentional violations in determining response.
Investigation of occurrences (e.g., CENIPA for accidents) is separate from SMS internal investigation; both must be coordinated.
Human Factors and Safety Culture in Aviation Maintenance and Inspection
Dirty Dozen: fatigue, complacency, lack of knowledge, distraction, lack of teamwork, lack of resources, pressure, lack of assertiveness, stress, lack of awareness, norms, and lack of communication.
SHEL model: Software, Hardware, Environment, Liveware; interfaces between components are where errors occur.
Error types: slips (attention failure), lapses (memory failure), mistakes (rule or knowledge-based), and violations (intentional deviation).
Maintenance error reduction: task duplication, independent inspection, work cards, shift handover briefings, and clear sign-off procedures.
Fatigue risk management includes duty limits, rest requirements, and recognition of circadian effects on night-shift work.
Safety culture dimensions: reporting culture, just culture, flexible culture, learning culture, and informed culture.
Human factors in inspection: visual inspection reliability decreases with small defect size, poor lighting, and time pressure; aids and re-inspection improve detection.
ICAO Standards, Recommended Practices, and International Harmonization
ICAO Annex 8 (Airworthiness of Aircraft) sets minimum standards for type certification, continuing airworthiness, and airworthiness certificates; states implement via national codes.
Annex 1 (Personnel Licensing) and Annex 6 (Operation of Aircraft) interact with maintenance and continuing airworthiness requirements.
Standards are binding after state adoption; Recommended Practices are desirable but not mandatory.
Article 33 of the Chicago Convention: certificates of airworthiness issued by the state of registry must be recognized by other states if issued per Annex 8 minimum standards.
Article 37 requires each state to collaborate in achieving the highest practicable degree of uniformity in regulations and procedures.
Harmonization vehicles: bilateral airworthiness agreements (BASA), acceptance of FAA/EASA approvals, and mutual recognition of maintenance organizations.
Differences from ICAO standards must be filed with ICAO and published in the state's AIP or equivalent.
Safety oversight audits (USOAP) evaluate state implementation of ICAO SARPs, including airworthiness and personnel licensing.