Subcontracting Engine Overhaul to a Non-Approved Facility
An AMO approved by CAAM under Part 145 for ATR 72 airframe line and base maintenance has no engine shop approval. An operator's ATR 72-600 needs a PW127M engine hot-section inspection. The AMO removes the engine and sends it to a local specialist shop that holds an FAA repair station certificate but no CAAM Part 145 approval. The shop returns the engine with an FAA Form 8130-3 and a work report. The AMO's quality manager says: 'The 8130-3 is an airworthiness approval, so we can fit it and issue the CRS.' The AMO's MOE requires subcontractors to be approved by CAAM or acceptable to CAAM under a bilateral arrangement; the local shop is neither. The aircraft is grounded and the operator wants it back in service tomorrow. The AMO's capability list does not include engine hot-section work, and its certifying staff have not been trained on the PW127M.
1. Can the AMO accept the engine and issue a CRS? Explain what the FAA Form 8130-3 does and does not prove.
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Not on the facts given. The 8130-3 is an authorised release/airworthiness approval tag, but it is not a CAAM maintenance release and it does not by itself show that the engine work was performed by an organisation acceptable to CAAM. The local shop holds an FAA repair station certificate, not CAAM Part 145 approval, and the AMO's MOE requires subcontractors to be CAAM-approved or acceptable under a bilateral arrangement. The AMO's own capability list does not cover engine hot-section work, and its certifying staff are not trained on the PW127M. Issuing a CRS would certify that the engine and its installation were maintained under the AMO's approved system, which is not true. The 8130-3 may be useful evidence of the shop's FAA status, but it does not fill the CAAM approval gap. Without CAAM acceptance, the engine should be treated as not released for Malaysian service.
2. What regulatory route could make the installation acceptable, and who must approve it?
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There are three possible routes, and the approval authority is CAAM. First, send the engine to a CAAM Part 145 approved engine shop, or to an organisation acceptable to CAAM under a bilateral agreement, and obtain a release from that organisation. Second, ask CAAM to accept the local shop for this one-off work; this would require evidence of the shop's capability, procedures, and FAA oversight, and CAAM may impose conditions or refuse. Third, if a bilateral arrangement between Malaysia and the United States covers repair station work of this type, obtain written confirmation from CAAM that the shop's rating and scope are accepted. The AMO cannot self-approve the subcontractor, and the quality manager cannot convert an 8130-3 into a CAAM approval. The operator's continuing airworthiness manager should be involved because the engine affects the aircraft's airworthiness status.
3. What should the certifying staff do now?
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Do not issue the CRS. Quarantine or clearly identify the engine as not released for service, and record the reason. Inform the quality manager and accountable manager in writing that the shop lacks CAAM approval and that the AMO's MOE does not permit acceptance. Check whether the engine has already been installed; if it has, the aircraft is not eligible for a CRS and the installation should be reviewed. The certifying staff should not rely on the operations pressure or on the 8130-3 alone. The AMO should also review its subcontracting procedure and vendor approval process, because the failure occurred before the engine was sent out. If a non-compliant release has already occurred, the AMO should consider occurrence reporting and a corrective action plan.