SUMMARY

1 SUBJECT

2 REVOCATION.

3 LEGAL BASIS

4 DEFINITIONS

5 SUBJECT DEVELOPMENT

5.1 Applicability. 4

5.2 Foreign maintenance organization certification.

5.3 Acceptance of maintenance tasks performed by foreign AMO without Anac certification (except for complete aircraft, aircraft engine, and propeller services)

5.4 Certification process. 

5.5 Certification renewal process

5.6 Certification amendment process.

5.7 Brazilian supplement revisions (or revisions of other manuals that required acceptance / approval by Anac)

6 APPENDIX.. 

7 FINAL CONSIDERATIONS. 

A.1 ACRONYMS. 

SUBJECT

This Supplementary Instruction (IS) provides guidance and detailed procedures for foreign approved maintenance organizations (AMO) to obtain and maintain an Anac certification under the Brazilian RBAC No. 145.

REVOCATION

This IS revokes IS No. 145-002, Revision B.

LEGAL BASIS

The Anac Resolution No. 30, of May 21^st, 2008, establishes in its article 14 the supplementary instruction – IS, a guidance material issued by the head of the competent department, aiming to clarify and detail the application of a requirement provided in RBAC.

​​​​​​​​​​​​​​The applicant/certificate holder who intends, for any purpose, to demonstrate compliance with a requirement set out in RBAC may:

a) adopt the procedures specified in the IS; or

b) present a duly justified alternative means of compliance, requiring, in this case, the analysis and express authorization of the Anac’s competent department.

​​​​​​​The alternative means of compliance mentioned in paragraph 3.2(b) of this IS must ensure the same or greater level of safety than that established by the applicable requirement or achieve the objectives standardized in IS.

The IS cannot create new requirements or contradict requirements established in RBAC or another normative act.

​​​​​​​ In accordance with article 70 of law No. 7.565, of December 19^th, 1986 (“Código Brasileiro de Aeronáutica” - CBAer), and paragraph 145.5(a) of RBAC No. 145, no person may operate as a certified maintenance organization without, or in violation of, a maintenance organization certificate and operations specifications issued by Anac, unless expressly authorized.

​​​​​​​ In accordance with article 8^th, XVII, of law No. 11.182, of September 27^th, 2005, Anac is the competent authority to carry out homologation and issue certificates, approvals and authorizations, related to activities under the jurisdiction of the Brazilian civil aviation flight safety system.

​​​​​​​ DEFINITIONS

This IS uses definitions and concepts further established in the following Brazilian regulations: RBAC No. 01, RBAC No. 43 e RBAC No. 145.

​​​​​​​SUBJECT DEVELOPMENT

5.1 Applicability

The procedures described in this IS apply ONLY to AMO that meet the following criteria:

a) be located outside of Brazilian territory; and

b) be previously certified by its local civil aviation authority (foreign primary authority), with valid certificate; and

c) AMO’s country of origin or its primary aviation authority CANNOT have a bilateral civil aviation agreement with Brazil on maintenance, limiting the certification of maintenance organizations only to the method established in that agreement.

Note 1: general information regarding the applicability, scope of work and associated fees for Anac approved AMO located outside Brazil and not covered by a maintenance agreement are available at Ref. 01 of the table IS No. 145-002C - LINKS AND REFERENCES, found at the topic “Useful links” at following Anac website: https://www.gov.br/anac/en/topics/approved-maintenance-organization/useful-links.

Note 2: for authorities and/or countries that HAVE a bilateral agreement in place with Brazil, the AMO must consult the specific procedures established in each agreement. The current bilateral agreement (BASA), maintenance annex guidance (MAG), memorandum of understanding (MoU), and technical arrangement (TA) can be found at Ref. 02 of the table IS No. 145-002C - LINKS AND REFERENCES, found at the topic “Useful links” at following Anac website: https://www.gov.br/anac/en/topics/approved-maintenance-organization/useful-links.

5.2 Foreign maintenance organization certification

5.2.1 Whereas foreign and domestic Anac AMO certification processes are the same in nature, foreign Anac AMO certification processes have some special characteristics which should be considered:

a) geographic distance from Brazil which results in logistical issues for audits performed by Anac; and

b) the existence of a local civil aviation authority (CAA) that acts as the primary certification authority. This CAA has conditions to provide continuous surveillance over the foreign AMO more effectively than Anac's surveillance by any means.

5.2.2 Considering these characteristics, special treatment is given to these AMO to make advantage of the available information and ongoing surveillance structures already in place, provided by the relationship with the primary CAA.

5.2.3 This IS presents the procedures for a foreign AMO to obtain an Anac AMO certificate, covering the following:

a) initial certification (in accordance with RBAC No. 145, section 145.51);

b) certification renewal (in accordance with RBAC No. 145, section 145.55); and

c) certification amendment (in accordance with RBAC No. 145, section 145.57).

5.2.4 To receive and analyze the process, Anac uses the SEI electronic protocol system (SEI!). Through this system representatives of foreign maintenance organizations can obtain access to the Anac services portfolio. The use of the Anac SEI! is made upon prior registration. Guidance for foreign maintenance organizations representatives to register in the Anac SEI! is available at Ref. 03 of the table IS No. 145-002C - LINKS AND REFERENCES, found at the topic “Useful links” at following Anac website: https://www.gov.br/anac/en/topics/approved-maintenance-organization/useful-links.

Note: from now on, any references listed in Table IS No. 145-002C – Links and References, located under the “Useful Links” section on the following ANAC webpage: https://www.gov.br/anac/en/topics/approved-maintenance-organization/useful-links will be cited simply as “Ref X”.

5.2.5 Communication. For questions related to the processes covered by this IS, the AMO can contact Anac via email at foreign145@anac.gov.br.

Note 1: the foreign145@Anac.gov.br is not the appropriate mean to receive documents related to these processes but remains the main contact for questions.

Note 2: in any communication with Anac, the AMO must identify itself by providing its name and its Anac COM (Certificado de Organização de Manutenção) number, in case the AMO already has one.

5.3 Acceptance of maintenance tasks performed by foreign AMO without Anac certification (except for complete aircraft, aircraft engine, and propeller services)

5.3.1 In accordance with RBAC No. 43, paragraph 43.17(b)-I, a foreign AMO that is not certified by Anac may perform maintenance, preventive maintenance, rebuild and alteration and approve the article to return to service, not including complete aircraft, aircraft engine and propeller, if, among other requirements detailed on the referred paragraph:

a) the regulatory system regarding aeronautical products maintenance activities should be considered similar between Brazil and the local CAA; and

b) the AMO should hold a valid certificate issued by the local CAA with adequate capability regarding services to be performed.

5.3.2 The AMO complying with the conditions of paragraph 5.3.1 above are not required to be certified according to the instructions described on this IS.

5.3.3 It is important to emphasize that regulatory similarity must be formally declared by Anac. This declaration is made by Anac through Ordinances (Portarias - published only in Portuguese).

Note: the CAA whose regulatory systems have been considered similar by Anac as well as respective Ordinances can be found at Ref. 04 (check note at 5.2.4). Additional questions can be directed to: foreign145@anac.gov.br.

5.4 Certification process

5.4.1 A foreign AMO certification process includes the following activities:

a) submission of the certification application and documents;

b) certification application and documents analysis;

c) audit scheduling;

d) audit scheduling confirmation;

e) audit;

f) audit finding report;

g) corrective action plan for the findings raised; and

h) issuance of the certificate and complementary documents.

5.4.2 Submission of the certification application and documents:

a) after registering your representative in the Anac electronic protocol system (SEI!), the AMO must start a new process to submit the certification application, using the guidelines available at Ref. 03 (check note at 5.2.4);

b) the certification application form - Anac Form F-143-30 must be submitted by the AMO representative;

Note: the Anac Form F-143-30 is available as principal document for initial, renewal and amendment process. It must be filled out and signed inside the Anac electronic protocol system (SEI!).

c) together with the certification application form - Anac Form F-143-30, foreign AMOs must also submit all the documents listed below, for analysis of Anac's technical team from the Department of Flight Standards (Superintendência de Padrões Operacionais - SPO):

I- AMO certificate proposal ("Certificado de Organização de Manutenção - COM" proposal) - Anac Form F-900-71 - available at Ref. 05 (check note at 5.2.4), including the ratings the AMO intend to perform maintenance, preventive maintenance, rebuild and alteration, under Anac certification, according to definitions given in section 145.59 of RBAC No. 145;

Note 1: the COM proposed to Anac cannot include ratings other than those already certified by its local CAA, except the specialized services rating from section 145.59 of the RBAC No. 145. Specialized service rating, as described on RBAC No. 145, will be evaluated to be equivalent to the respective AMO limited rating certification obtained with its local CAA.

Note 2: for Anac certification purposes, an auxiliary power unit (APU), when used to supply power (electrical, hydraulic or pneumatic), is considered an accessory and is therefore classified in the Accessories Category, Class 1 (mechanical accessories), according to section 145.59 of RBAC No. 145.

II- Operations specifications proposal ("especificações operativas - EO" proposal) - Anac form F-900-72, available at Ref. 05 (check note at 5.2.4), listing the aircraft models, engines, propellers, rotors, equipment and/or specialized services, and their limitations, on which the AMO intends to perform maintenance, preventive maintenance, rebuilding and alteration, according to definitions given in section 145.59 of RBAC No. 145;

Note: an EO submitted to Anac must not contain aircraft, engine, propeller, equipment, and/or specialized services other than those already under the capability certified by its local CAA.

III- Capability list proposal ("lista de capacidade - LC" proposal), listing all the components, parts, accessories, radios, instruments, except aircraft, engine, and propellers (APUs being considered as accessories) the AMO intends to add to its Anac certification;

Note 1: the Anac only grants limited certification to AMOs (equivalent to FAA´s "limited rating"). Therefore, when requesting Anac certification, even foreign AMOs that have a certification that allows a wide work scope within a category (equivalent to FAA´s "class rating") granted by their local CAA, must prepare and submit a capability list, containing all the articles to which the AMO intends to perform maintenance under the Anac certification.

Note 2: if the AMO already has a capability list accepted or approved by its local CAA, then the section related to parts, components, instruments, and accessories may be deemed approved by Anac, limited to the classes and ratings contained in the Anac certificate. In this case, the AMO does not need to submit a proposal for a new capability list, it must only submit the capability list already accepted/approved by its authority, and proof of formal acceptance/approval by the local authority of this document.

Note 3: if the AMO does not have a capability list accepted or approved by its local CAA, in addition to the capability list proposal, the AMO will need to develop an article self-inclusion procedure to be included in the Anac supplement (see IS No. 145-001 revision H, item 5.6.3, or equivalent item in future revisions). In this case, whenever the AMO makes modifications to its capability list, the new revision must be forwarded to Anac by a means described in the supplement and accepted by Anac. The example of supplement, available at Ref. 10 (check note at 5.2.4), presents an acceptable means of compliance for the submission of the capability. If AMO does not have an LC in an already defined format, Anac recommends the use of the format defined in IS No. 145-001, revision H item 5.6.3, or equivalent item in future revisions.

IV- list of technical personnel (roster), including each license number, when applicable;

Note 1: in accordance with paragraph 145.151(e)-I of RBAC No. 145, a foreign AMO must have personnel qualified who demonstrate to be able to read and understand Portuguese language whenever it is necessary to accomplish tasks that must comply with the Brazilian regulations. This requirement is also important with respect to the documentation and maintenance records written in Portuguese language.

Note 2: it should be noted that a professional with proficiency in the Portuguese language is necessary, not only during the initial certification process, but also throughout the entire time that the AMO exercises the prerogatives of an Anac certification, in situations such as those in which it is necessary to serve Brazilian customers or understand Anac documents.

V- designation of the employee who will technically represent the organization for interactions with Anac, as required by RBAC No. 145, paragraph 145.151(a)-IV;

Note 1: paragraph 145.151(a)-IV of RBAC No. 145 requires foreign AMO to present an employee who will technically represent it before Anac, similarly as required by paragraph 145.151(a)-II to Brazilian based AMO.

Note 2: the person required in RBAC No. 145.151(a)-IV is the one to be indicated as "focal point" for communications with Anac for technical matters associated with certification of the AMO. Therefore, he / she must be a person whose functions are linked to the performance of the AMO's maintenance prerogatives. Ex: technical director, quality assurance manager, or chief inspector, etc.

Note 3: this person must be the same person indicated as "equivalent to accountable technician (RT)" on the initial certification request form - Form F-143-30.

VI- statement indicating that it has all the tools, equipment, test equipment, bench tests, etc. and technical documentation necessary for the safe performance of work. This declaration must be accompanied by:

A- a list of all tools, equipment, test equipment, bench tests necessary for the safe performance of work; and

B- a list of the technical documents necessary for the safe performance of work;

Note: items 5.5.2.1 e) and f) of IS No. 145-009, revision E, or equivalent items in future revisions, provide an acceptable way to demonstrate compliance with tools and technical documentation requirements.

VII- copy of Foreign AMO certificate and operations specifications (Ops. Specs.) or equivalents, issued by primary local CAA;

VIII- demonstration of need, stating the intent of a client to use the applicant AMO services, in accordance with paragraph 145.51(c)(1) of RBAC No. 145, issued by:

A- a Brazilian registered aircraft operator;

B- a Brazilian registered aircraft owner;

C- an AMO certified by Anac;

D- a foreign AMO approved by Anac by means of an agreement; or

E- other person who may need the AMO services under the Anac certification, as long as it is duly justified;

IX- compliance checklist regarding the requirements of RBAC No. 43 and RBAC No. 145 with the cross-reference to the AMO manuals and to the Brazilian supplement;

Note: the compliance checklist is a fundamental tool to Anac assess the AMO eligibility to receive a Brazilian COM, as it provides means for the AMO to show how it will comply with the applicable Brazilian requirements to its operation with its manuals, accepted or approved by its own local CAA, and Brazilian supplement. IS No. 145-001 provides guidance for its elaboration. Also Form F-143-40, available at Ref. 05 (check note at 5.2.4), is a guide for it.

X- copy of all manuals required in a certification process by the local CAA. The AMO must submit a copy of the current revision of all manuals that, in its local initial certification process, received the formal acceptance or approval from its local CAA (ex.: handbook or manuals of maintenance organization; manuals of quality control; training programs; safety management system manuals);

Note 1: the manuals that received formal acceptance or approval from its local CAA may be considered acceptable by Anac.

Note 2: if the AMO does not have a safety management system (SMS) manual accepted or approved by its local CAA, it must prepare and submit to Anac an SMS manual in accordance with the characteristics specified in Supplementary Instruction IS No. 145.214-001 (Portuguese only). A template for this manual (Portuguese only) can be found at Ref. 06 (check note at 5.2.4).

Note 3: similarly, if the AMO does not have a training program accepted or approved by its local CAA, it must prepare and submit to Anac a manual in accordance with the characteristics specified in Supplementary Instruction IS No. 145-010 (Portuguese only).

XI- a Brazilian supplement to the existing manual (or manuals) required by the local CAA covering all regulatory requirements applicable to maintain a Brazilian aeronautical product not covered by the original manual (or manuals). The Ref. 10 (check 5.2.4 at 5.2.4) could be used as a guidance for the development of the Brazilian supplement to the manual (or manuals) of AMO;

Note 1: the Brazilian supplement may be provided in English, Spanish or Portuguese as well, as long as the chosen language is fully understood by the personnel required to use the supplement.

Note 2: the existing manual (or manuals), accepted or approved by the local CAA, to be used by the AMO in addition to the Brazilian supplement to demonstrate compliance with all regulatory requirements applicable to the Brazilian certification should be published in English, Spanish or Portuguese; otherwise the AMO must submit an English, Spanish or Portuguese version of the applicable manuals to Anac.

Note 3: the set of manuals to be submitted to Anac for analysis must show elements that reflect compliance to each requirement listed on the compliance checklist. Therefore, they should not include only general policies and directives but sufficiently detailed procedures to show requirements compliance. The IS No. 145-009 (Portuguese only) provides guidance for compliance with requirements related to manual.

Note 4: Anac must be notified whenever there are revisions to the supplement, whether for analysis and formal acceptance or just for knowledge and updating of the database. The procedures applied to this notification are the same as those described in IS No. 145-009, revision E, item 5.3.5.1, or equivalent item in future revisions.

XII- list of subcontracted maintenance functions, as applicable: if the AMO intends to subcontract maintenance functions from other maintenance organizations (certified by its local CAA or even from those that do not hold a certification), it must submit a list in the format indicated in F-143-42, available at Ref. 05 (check note at 5.2.4);

Note 1: if the AMO already has a list of subcontracted maintenance functions approved by its local CAA, then this list may be considered acceptable by Anac. In this case, the AMO does not need to submit a proposal for a new list of subcontracted maintenance functions list, it must only submit the one already approved by its authority, and proof of formal approval by the local authority of this document.

Note 2: for the purpose of accepting a list of subcontracted maintenance functions from a foreign maintenance organization, as per RBAC No. 145, section 145.217, Anac considers as a "certified" person ONLY those that hold an Anac authorization/certification as per RBAC No. 43, OR those that, as per item 43.17(b)-I of RBAC No. 43, even without an Anac certification, may perform maintenance on aeronautical parts to be installed on Brazilian registered aircraft. Except from these two cases, foreign maintenance organizations, even if certified by their local CAA, or by third CAAs (as FAA, EASA, TCCA, for example), are considered as "non certified" by Anac.

XIII- accepted procedure for using the electronic maintenance documents and records system - SDRMe, if the AMO uses one; and

Note 1: for foreign AMOs that have their SDRMe accepted or approved by any CAA which has an aviation regulation system recognized by Anac as similar, as described in item 5.3, above, Anac will consider it as an acceptable means of compliance, as an alternative to the method, defined in Anac Resolution No. 458, dated December 20th, 2017.

Note 2: if the AMO does not have its SDRMe accepted/approved, as per note 1 above, it must be submitted for Anac acceptance, in accordance with IS No. 43.9-004.

XIV- the Anac civil aviation inspection fee (TFAC) proof of payment, in case it was paid in advance.

Note 1: the TFAC fee was established by Law No. 11.182/2005, article 29 and its annex III lists the situations that require its payment. The matter is dealt in Resolution No. 653, dated December 20^th, 2021, regulated by Ordinance No. 8.676, dated July 25^th, 2022, or other rules that may come to replace them.

Note 2: the procedures and information regarding TFAC fee value is found at Ref. 07 (check note at 5.2.4).

Note 3: payment of the TFAC is not compulsory prior to the initial application process. Once the applicable process (example: initial, renewal or amendment) has been created by the applicant, on first contact, Anac will provide detailed information on the corresponding fee and how to make the payment, by issuing an Invoice Order Letter.

5.4.3 Certification application and documents analysis

5.4.3.1 Upon receipt of the certification application and documents, the technical personnel of the Anac's Department of Flight Standards (Superintendência de Padrões Operacionais - SPO) will analyze the application documents. If all the required documents are not included in the package or nonconformities have been found, the Anac will issue a document (ofício) stating the pending items and with information about the corresponding fee and how to make the payment. Missing documents may lead Anac to conclude that the application was not initiated.

Note: each pending item and nonconformities requires corrective action by the applicant.

5.4.3.2 The applicant who receives a notification of nonconformities must submit the necessary corrective actions, in accordance with the guidelines contained in the notification, within the deadline established by Anac of up to 30 (thirty) calendar days.

Note: the deadline referred to in this item may be extended upon express request by the applicant, limited to 90 (ninety) calendar days from the date of notification of the nonconformity. After this deadline, unless otherwise determined by Anac, such fact shall be considered sufficient reason for cancellation and archiving of the process.

5.4.3.3 This activity will be closed when, in the final phase, Anac issues a document (ofício) stating that all application documents are ready to be accepted or approved (as the case) by Anac. In addition, Anac will ask the applicant to provide proposed dates for the Anac audit.

5.4.4 Audit scheduling

This phase initiates with the foreign AMO audit dates proposal received by Anac. The AMO must propose a convenient schedule to Anac audit in a written document, to be attached to the certification process. The document must include the proposed dates for a working week.

Note: although AMO proposes a date for the audit, Anac will assess its internal availability and confirm a specific date later.

5.4.5 Audit scheduling confirmation

A document (ofício) will be sent to the AMO, informing the Anac audit team members, the date of the audit, including the audit sequence. A document (ofício) will also be sent to the national CAA of the country where the AMO is located, informing the Anac audit schedule.

5.4.6 Audit

5.4.6.1 With the audit schedule, the AMO must be prepared to receive the Anac audit.

5.4.6.2 Any changes to the proposed schedule must be addressed in the initial meeting between the Anac audit team and the AMOs staff.

5.4.6.3 At the end of the audit, the Anac audit team will have an internal meeting. The AMO must provide an appropriate room for the meeting.

5.4.6.4 Soon after, a final meeting with the AMO accountable manager will finish the audit process with the release of a nonconformity preliminary report (resumo das não conformidades - RNC). At this meeting, the Anac audit team leader will deliver to the AMO all nonconformity then identified (if detected) and necessary observations. Any discussions raised during the meeting must be registered by the Anac audit team and presented to Anac’s office manager.

Note: the nonconformity preliminary report will inform that a final report, containing all nonconformities, will be issued later via official communication from Anac (ofício).

5.4.7 Audit report

After the Anac audit team return to Brazil, all internal pertinent documents will be filled out. The audit report will be analyzed, and a document (ofício) will be issued by the Anac’s Department of Flight Standards (Superintendência de Padrões Operacionais - SPO). Any nonconformity item found will need a formal answer from the AMO including the necessary corrective action plan (plano de ações corretivas - PAC) before issuing the certification document. If nonconformity items are not raised, the certification documents will be issued.

5.4.8 Corrective action plan

If any nonconformity item is presented in the document (ofício) with the audit results, the AMO must address all the nonconformity items with a corrective action plan. This plan must present the correction to the nonconformity raised, identify the (likely) root causes of each item, and a proposal of corrective actions for the root causes.

5.4.9 Certificate documents issuance

5.4.9.1 After all nonconformity items are corrected or addressed by an acceptable method, the Anac’s Department of Flight Standards (Superintendência de Padrões Operacionais - SPO) will issue the following documents:

a) maintenance organization certificate (COM), stating the ratings according to Form F-900-71;

b) operations specifications (EO), stating the aircraft, engine and/or propeller types and models and the limitations to the certification, according to Form F-900-72;

c) approval of the capability list (LC), declaring in the EO that Anac will consider approved all revisions of the LC that are accepted/approved by the local CAA or that the AMO has a self-inclusion procedure described in its Brazilian supplement;

d) acceptance of the Brazilian supplement to AMO manual (or manuals, if applicable);

e) training program approval, if such a document was not previously accepted/ approved by the local CAA;

f) acceptance of safety management system manual, if such a document was not previously accepted/approved by the local CAA; and

g) official communication from Anac to the foreign AMO primary CAA to inform the certification.

5.4.9.2 The certification expiration date will be stated in the COM, which shall remain in force until the last day of the twenty-fourth month, counting from the date of the initial certification issuance, unless it is sooner suspended, revoked or canceled. The COM will also state the address of the main base audited during the certification process. Other addresses, such as secondary bases or additional fixed locations, will be identified on the EO, provided that they are certified under the same certificate issued by the local CAA and provided that they have been included in the initial petition to Anac.

5.4.10 Expedited Certification

5.4.10.1 As defined in RBAC No. 43, paragraph 43.1(e)-I, Anac may, upon request, carry out expedited certification, issuing authorization on a case-by-case basis for persons holding certificates or licenses issued by other countries to perform specific, individually identified maintenance, preventive maintenance, rebuilt or alteration services of articles, within or outside the national territory, if there is no organization certified and qualified according to RBAC No. 145 to perform the intended services.

5.4.10.2 The performance of a service based on expedited certification will only be possible upon demonstration of the unavailability of an AMO certified in accordance with RBAC No. 145 and with the capacity to perform the service.

5.4.10.3 The procedures for requesting expedited certification are described in IS No. 43.1-001A.

5.4.11 Authorization for exceptional service

An AMO with a valid Anac RBAC No. 145, wishing to carry out services on articles for which it is not certified by Anac, may request the performance of an exceptional service. To do so, the AMO must technically demonstrate compliance with the RBAC No. 43 requirements necessary for maintenance (technical personnel, tools, technical publications, adequate facilities, etc.), in addition to meeting at least one of the following situations:

a) already have an open process for inclusion of the article(s) in question in the AMO's Anac operations specifications (EO) or capability list (LC), as applicable; or

b) already have an article similar to the one for which authorization for exceptional service is being requested in the AMO's operations specifications (EO) or capability list (LC), as applicable. (Ex.: the applicant has a Cessna 172M aircraft in its EO and requests authorization for service on a Cessna 172N aircraft).

Note 1: the authorization is exceptional and will not be granted for the same applicant to perform a service on a particular model of article again. If the AMO wishes to perform further maintenance services on the model in question, it must ask for the inclusion of this article in the AMO's Anac operations specifications (EO) or capability list (LC), as applicable.

Note 2: further information on this topic can be found at Ref. 08 (check note at 5.2.4).

5.5 Certification renewal process

5.5.1 The AMO certification renewal process of a foreign AMO has the following activities:

a) submission of the certification renewal application and documents;

b) certification application renewal and documents analysis; and

c) certificate documents issuance.

Note: the renewal of Anac certification is not necessarily subject to prior audits, which may still occur later, as the need is identified.

5.5.2 Submission of the certification renewal application and documents

5.5.2.1 A foreign AMO certified by the Anac which intends to have its certification renewed must submit, at least 60 (sixty) days prior to the certification expiration, the renewal certificate application and corresponding documents, in the same way as for the certification application defined in section 5.4.2 of this IS. Those 60 days are necessary for Anac internal procedures to process the application, preventing the COM expiration.

Note: if the AMO does not submit its renewal application before the COM expiration date, it will be considered revoked. To recover the certification, the AMO should apply for a new certificate, in accordance with section 5.4.2 of this IS.

5.5.2.2 The application for certificate renewal must include the following documents:

a) the certification renewal application form - Anac Form F-143-30 must be submitted by the AMO representative;

Note: the Anac Form F-143-30 is available as principal document for initial, renewal and amendment process. It must be filled out and signed inside the Anac electronic protocol system (SEI!).

b) the current version of the maintenance organization certificate, operations specifications and capability list, or equivalent documents, accepted/approved by the local CAA;

Note: if there have been changes to these documents that could impact Brazilian certification, the AMO must clearly inform what these impacts were.

c) letter indicating whether or not the AMO intends to make any changes to its Brazilian certification, during the renewal process. If the intention is to make such changes (Examples: deletion/addition of an aeronautical product model in the operations specifications; change of AMO address; change of AMO name; changes of class or ratings; etc.), and these changes impact the Brazilian maintenance organization certificate, operations specifications or capability list approval, all pertinent documents listed in section 5.4.2 of this IS must be updated and presented;

d) a letter identifying all maintenance services related to Brazilian products/articles performed since the AMO initial certification, or last certification renewal, or, if the case, stating that no maintenance service was performed in this period;

e) an updated list, identifying all AMO technical personnel and personnel designated to perform maintenance services in Brazilian products/articles. This list must include the employee who will technically represent the organization for interactions with Anac, mentioned in item 5.4.2 c) V of this IS;

f) current revision of repair station´s manuals accepted or approved by the local CAA, which are required for its local certification, ex.: handbook or manuals of repair station (maintenance organization), quality control, training program and safety management system manual;

Note: this set of manuals must also include the SMS manual, accepted or approved by the local CAA in its last revision. If the AMO does not have an SMS manual accepted/approved by the local authority, it must prepare and submit to Anac an updated SMS manual in accordance with the characteristics specified in Supplementary Instruction IS No. 145.214-001 (Portuguese only). A template for this manual (Portuguese only) can be found at Ref. 06 (check note at 5.2.4);

g) current revision of the Brazilian supplement to the existing manual (or manuals); and

h) the Anac fee (TFAC) payment receipt, in case it has already been paid.

Note 1: the TFAC fee was established by Law No. 11.182/2005, article 29 and its annex III lists the situations that require its payment. The matter is dealt in Resolution No. 653, dated December 20^th, 2021, regulated by Ordinance No. 8.676, dated July 25^th, 2022, or other rules that may come to replace them.

Note 2: the procedures and information regarding TFAC fee value is found at Ref. 07 (check note at 5.2.4).

Note 3: payment of the TFAC is not compulsory prior to the initial application process. Once the process has been created by the applicant, on first contact, Anac will provide detailed information on the corresponding fee and how to make the payment, by issuing an Invoice Order Letter.

5.5.3 Renewal application and documents analysis

5.5.3.1 After receiving the renewal certificate application, the Anac will perform a technical analysis of the renewal application and documents. All pertinent details of the technical analysis will be stated in a document (ofício), issued by the Anac’s Department of Flight Standards (Superintendência de Padrões Operacionais - SPO).

5.5.3.2 The purpose of the document (ofício) is to inform the AMO about any pending item in the renewal certification process.

5.5.3.3 This phase will be closed when the Anac issues a document (ofício) stating that all renewal certificate application and documents have been considered acceptable.

5.5.4 Documents issued for certification renewal

5.5.4.1 After all pending items are corrected, the Anac’s Department of Flight Standards (Superintendência de Padrões Operacionais - SPO) will issue, as applicable, the following documents:

a) maintenance organization certificate (COM), stating the classes and ratings according to Form F-900-71;

b) operations specifications (EO), stating the aircraft, engine and/or propeller types and models and the limitations of the certification, according to Form F-900-72;

c) approval of capability list (LC), declaring in the EO that Anac will consider approved all revisions of the LC that are accepted/approved by the local CAA or that the AMO has a self-inclusion procedure described in its Brazilian supplement;

d) acceptance of Brazilian supplement to AMO manual (or manuals, if applicable);

e) training program approval, if such a document was not previously accepted/ approved by the local CAA; and

f) acceptance of safety management system manual, if such a document was not previously accepted / approved by the local CAA.

5.5.4.2 The Certification expiration date will be stated in the COM, which shall remain in force until the last day of the twenty-fourth month, counting from the expiration date of the last COM issued, unless it is suspended, revoked or canceled. The COM and EO will state the address(es) of the facilities considered during the initial certification process.

Note: the issuance of the certificate may occur without a prior audit. This is usually done to avoid lack of support to Brazilian operators while the renewal process is taking place. However, as part of the renewal process or even as surveillance action, the AMO must be available for Anac audit whenever requested, which may occur before or even after the issuance of the certificate. In this case, the procedures mentioned in 5.4.4 to 5.4.8 will be applied. If the AMO does not make itself available to receive the audit or in case of non-compliance with any other requirements of the current Brazilian regulations, according to RBAC No. 145 section 145.55, the certificate may be suspended or revoked by the Anac, at any time.

5.6 Certification amendment process

5.6.1 The application must be made via Anac SEI! system, through a specific process, see Ref. 03 (check note at 5.2.4).

5.6.2 Information, as type of process, fees, etc. related to certificate amendment is available on Ref. 01 (check note at 5.2.4).

5.6.3 For AMOs certified by Anac, it is mandatory to submit a certificate amendment request, using the Anac form F-143-30, whenever the situations listed below occur, observing the minimum notice periods defined in RBAC No. 145, section 145.57 (Portuguese only), as appropriate:

Note: the Anac Form F-143-30 is available as principal document for initial, renewal and amendment process. It must be filled out and signed inside the Anac electronic protocol system (SEI!).

a) Ownership transfer:

I- the property alteration must be submitted to Anac 30 (thirty) days before the intended effective day;

II- together with Anac Form F-143-30, the application must include a letter detailing the amendment;

III- the AMO must identify the new accountable manager, if there has been a change; and

IV- a copy of the certificate amended by its local civil aviation authority has to be sent together with the certificate proposal to be amended by Anac. The new proprietary / owner has to be the same listed at the certificate emitted by its local CAA.

b) Certificate amendments - in the following cases:

I- change and addition of new locations:

A- the change of address must be submitted to Anac 30 (thirty) days before the intended effective day;

B- the application must be accompanied by AMO's local CAA certificate and operations specifications, containing information about the new address;

C- if AMO's local manuals have been revised, those revisions must also be sent along with the application; and

D- additional steps and conditions are shown below, for each of the specified cases:

i. change of address indicated on the Anac certificate:

The application must be accompanied by a proposal for the new Anac certificate (Anac Form F-900-71), indicating the new address, as described in section 5.4.2 c) I- of this Supplementary Instruction.

Note 1: the change of address of the main base in the Anac Certificate may involve an audit to verify AMO's new facilities, in accordance with section 5.4.4 of this IS.

Note 2: other addresses, such as secondary bases or additional fixed locations, will be identified in Anac operations specifications, provided they are under the same certificate issued by the local CAA for the main base.

ii. inclusion of additional fixed locations in existing Anac operations specifications: depending on the geographical location (usually at the same aerodrome, in the same municipality, or in regions close to the base to which they are linked), the AMO may have additional fixed facilities included in an existing Anac operations specifications, without the need to certify each facility individually as an independent workshop or secondary base. For this to occur, the following conditions must be met:

1. the application must be accompanied by a proposal for the new Anac operations specifications (EO) (Anac Form F-900-72), indicating the new address, as described in section 5.4.2 c) II- of this Supplementary Instruction;

2. the AMO must present evidence that the additional fixed facilities remain under the full control of the base to which they are linked; and

3. the AMO manual must clearly describe the services performed at each additional fixed facility and detail how the control and transport of materials, technical data, personnel, and tools between these facilities will be managed.

Note 1: Anac will evaluate the location (distance between facilities), the level of maintenance performed, and whether inspection of additional fixed facilities can be performed during the base audit. If the conditions outlined above are met, the authorization for the use of additional fixed facilities will be included in the AMO's Anac operations specifications (EO).

Note 2: if the new facilities do not qualify as an "additional fixed location", operations specifications (EO) will be issued, categorizing them as a secondary base.

iii. adding a secondary base with issuance of an additional Anac operations specifications (EO):

1. the application must be accompanied by a proposal for the new Anac operations specifications (EO) (Form F-900-72), indicating the new address, as described in section 5.4.2 c) I- of this Supplementary Instruction;

2. the AMO must present evidence that the secondary base facilities remain under the full control of the main base to which they are linked; and

3. the secondary base must use and be included in the same manuals and procedures as of the main base.

II- adding or amending classes or ratings - may occur in the following cases:

capability decrease: in accordance with section 145.57 of RBAC No. 145, an AMO capability decrease must be informed to Anac in 5 (five) business days and Anac may establish additional limitations or even a suspension if it’s found that the AMO has no condition to sustain its certification;

capability increase: in accordance with section 145.57 of RBAC No. 145, the application for adding capabilities must be made by an application to amend the AMO's Anac operations specifications (EO) and / or Anac maintenance organization certificate (COM).

A- Anac operations specifications (EO) amendments:

i. each application for EO amendments has to be made 30 (thirty) days before its intended EO effective date;

ii. the application must be accompanied by the following documentation:

1. AMO's local CAA certificate and operations specifications, containing information about the intended capacity;

2. a letter describing, in detail, all intended changes (See note 2, below);

3. a description of all requirements for the AMO to be considered capable of exercising the new capacity: installations, special tools, technical data access, personnel qualification, manual revision, as required; and

4. the applicable fee (TFAC) payment receipt.

Note 1: this process follows the same activities of section 5.4.2 of this IS.

Note 2: to describe the intended changes, as required above, it is recommended that AMO use, as a reference, the current version of its Anac operations specifications (EO), and include highlights on the items modified / added / removed. Also remember: if the new EO proposal omits a rating previously included, this will be considered as a request to remove the item, therefore, pay close attention to the details informed in your application.

B- Capability list (LC) amendments:

In this case the application for amendment is not applicable, since Anac defines only two cases in which a foreign AMO may change its LC:

i. when the AMO already has a capability list accepted or approved by its local civil aviation authority, and the section referring to parts, components, instruments and accessories is deemed approved by Anac, limited to class and rating contained in the AMO RBAC No. 145 certificate. In this case, the AMO does not need to submit the revision of the capability list; or

ii. when the AMO does not have a capability list accepted or approved by its local CAA, but has incorporated an article self-inclusion procedure in its Anac Brazilian supplement. In this case, whenever the AMO makes modifications to its capability list, the new revision must be forwarded to Anac, for simple information, according to the self-inclusion communication procedures accepted in the AMO Brazilian supplement manual.

Note: in case of amendments in the capability list that imply in Anac certification class or ratings changes, the AMO must apply for amending those class or ratings, as per 5.6 b) II -, sending the documentation listed in that item, except for that referring to installations, special tools, technical data access, etc.

5.7 Brazilian supplement revisions (or revisions of other manuals that required acceptance / approval by Anac)

5.7.1 Manuals must be submitted for acceptance/approval by Anac only in the following cases:

a) inclusion or alteration of procedures which implies an alternative method for compliance with Brazilian regulations or supplementary instructions (IS);

b) complete reissuance of the manual;

c) insertion of procedures to adhere to requirements established in international maintenance agreements; and

d) other situations as determined by Anac in a specific process.

5.7.2 Manuals should be submitted for simple information (and not for acceptance/approval), to update the Anac database in the following cases:

a) adaptation of the procedures described to the reality of the AMO and to simple changes in legislation; and

b) when the change to the manual does not include the situations listed above.

Note 1: payment of fees is only applicable for revisions of Anac supplement (as described in item 5.7.1), and other manuals, such as SMS Manual and training program, that required acceptance/approval by Anac, because they were not accepted/approved by the local authority. In these cases, a TFAC will be charged. Information regarding TFAC fee value is found at Ref. 07 (check note at 5.2.4). There are no fees for the cases defined in 5.7.2.

Note 2: whenever manuals are revised, they must be submitted to Anac. Instructions on how to proceed can be found at Ref. 09 (check note at 5.2.4).

APPENDIX

APPENDIX A - ACRONYMS LIST

APPENDIX B - CHANGE CONTROL

FINAL CONSIDERATIONS

7.1 The changes markups were intentionally hidden, due to the extension of the changes implemented in this revision.

7.2 The AMO must work with a term of 90 (ninety) days to present evidence of required actions during all the process phases as well as the answers for each communication of nonconformity, following as much as possible, the chronology of events as agreed in the certification schedule. Any process with pending items, left without communication from the AMO for more than 90 (ninety) days will be cancelled. If the answer to a same nonconformity is rejected for the third time, the certification process will be terminated, regardless of the previous term.

7.3 Revision C of IS 145-002, does not require that foreign AMO already Anac certified revise its documents (example: manuals, forms, etc.) before a renewal certificate process.

7.4 Infraction to provisions of the Brazilian Aeronautical Code - CBAer: Infractions to provisions of CBAer, including the obligation to comply with regulations issued by Anac, can motivate the application of administrative penalties. In that case, Anac will issue an “auto de infração - AI".

7.5 The cases not addressed by this IS shall be resolved by Anac.

APPENDIX A - ACRONYMS LIST

A.1 ACRONYMS

APPENDIX B – CHANGE CONTROL

Not included, due to the extension of the changes implemented in the revision C.