Airworthiness review staff issuing airworthiness review certificates or recommendations in accordance with point (e) of point CAMO.A.125 and, if applicable, issuing permits to fly in accordance with point (f) of point CAMO.A.125 shall have:
(1) at least 5 years of experience in continuing airworthiness;
(2) acquired an appropriate licence in compliance with Annex (III) Part-66 or an aeronautical degree or a national equivalent;
(3) received formal aeronautical maintenance training;
(4) held a position within the approved organisation with appropriate responsibilities.
AMC1 CAMO.A.310(a)(3) Formal aeronautical maintenance training
Formal aeronautical maintenance training means training (internal or external) supported by evidence on the following subjects:
— Relevant parts of initial and continuing airworthiness regulations;
— Relevant parts of operational requirements and procedures, if applicable;
— The organisation’s continuing airworthiness management exposition;
— Knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course. These courses should be at least at a level equivalent to Part-66 Appendix III Level 1 General Familiarisation and could be provided by a Part-147 organisation, by the manufacturer, or by any other organisation accepted by the competent authority.
‘Relevant sample’ means that these courses should cover typical aircraft and aircraft systems that are within the scope of work.
— Maintenance methods.
AMC1 CAMO.A.310(a) General
(a) Airworthiness review staff are only required if the CAMO wants to be granted CAMO.A.125(e) airworthiness review and, if applicable, CAMO.A.125(f) permit to fly privileges.
(b) ‘Experience in continuing airworthiness’ means any appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks.
(c) A person qualified according to AMC1 CAMO.A.305(c) subparagraph (e) should be considered as holding the equivalent to an aeronautical degree.
(d) An appropriate licence in compliance with Annex III (Part-66) is any one of the following:
— a category B1 or L licence in the subcategory of the aircraft reviewed, or
— a category B2 or C licence, or
— in the case of piston-engine non-pressurised aeroplanes of 2 000 kg MTOM and below, a category B3 licence.
It is not necessary to satisfy the experience requirements of Part-66 at the time of the review.
(e) To hold a position with appropriate responsibilities means the airworthiness review staff should have a position in the organisation independent from the airworthiness management process or with overall authority on the airworthiness management process of complete aircraft.
Independence from the airworthiness management process may be achieved, among other ways, as follows:
— By being authorised to perform airworthiness reviews only on aircraft for which the person has not participated in their management. For example, performing airworthiness reviews on a specific aircraft type, while being involved in the continuing airworthiness management of a different aircraft type.
— A CAMO holding a maintenance organisation approval may nominate maintenance personnel from their maintenance organisation as airworthiness review staff, as long as they are not involved in the airworthiness management of the aircraft. These personnel should not have been involved in the release to service of that particular aircraft (other than maintenance tasks performed during the physical survey of the aircraft or performed as a result of findings discovered during such physical survey) to avoid possible conflict of interests.
— By nominating as airworthiness review staff personnel from the compliance monitoring department of the CAMO.
Overall authority on the airworthiness management process of complete aircraft may be achieved, among other ways, as follows:
— By nominating as airworthiness review staff the accountable manager or the nominated post holder.
— By being authorised to perform airworthiness reviews only on those particular aircraft for which the person is responsible for the complete continuing airworthiness management process.
— In the case of one-man organisations, this person has always overall authority. This means that this person can be nominated as airworthiness review staff.
Can an Airworthiness Review Staff (ARS) perform an airworthiness review on an aircraft in which he/ she had released some maintenance as Certifying Staff (CS)?
To avoid possible conflict of interests, the ARS (Airworthiness Review Staff) should not be or have been involved in the release of the maintenance for the aircraft on which he or she intends to perform the airworthiness review (AR), except in one of the following cases: Such maintenance has been released as part of the airworthiness review’s physical survey of the aircraft (e.g. release necessary after visual inspections requiring panel opening); Such maintenance has been released as a result of findings discovered during the physical survey of the aircraft (defect rectification) Note: cases 1 and 2 are justified by the fact that such specific maintenance activity is part of the AR and therefore does not require independence between maintenance and the AR. Such maintenance has been released as part of the 100-h/annual inspection contained in the maintenance programme conducted together with the Airworthiness Review of the Part-ML aircraft: 1. by an approved maintenance organisation (145.A.75(f) or CAO.A.095(c)(2)) (see also ML.A.901(b)(3)); or 2. by independent certifying staff holding an ARS authorisation (see ML.A.901(b)(4)) for aircraft operated under Annex VII (Part-NCO) to Regulation (EU) No 965/2012 or, for balloons not operated under Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/3951 or for sailplane, not operated under Subpart DEC of Annex II (Part-SAO) to Regulation (EU) 2018/1976. Remark From regulatory perspective, cases 1 and 2 are explicitly considered by ‘AMC M.A.707(a)’ and ‘AMC1 CAMO.A.310(a)’ [2nd bullet of point (5), respectively point (e)] for an ARS belonging to a CAMO also holding a AMO approval. Although not explicitly mentioned in any AMC, considering the Note above, the Agency understands that this principle is also permitted in other cases where the ARS happens to be also Certifying staff (including independent certifying staff). Remark: Iaw M.A.901(l) or ML.A.903(b), when the ARS is not Certifying Staff, he/she must be assisted by a Certifying Staff to release the maintenance mentioned in cases 1 and 2.
Notwithstanding points (a)(1), (a)(3) and (a)(4), the requirement laid down in point (a)(2) may be replaced with 5 years of experience in continuing airworthiness additional to those already required by point (a)(1).
Airworthiness review staff nominated by the organisation can only be issued an authorisation by that organisation when formally accepted by the competent authority after satisfactory completion of an airworthiness review under the supervision of the competent authority, or under the supervision of the organisation’s authorised airworthiness review staff, in accordance with a procedure approved by the competent authority as part of the CAME.
AMC1 CAMO.A.310(c) Formal acceptance by the competent authority
The approval by the competent authority of the CAME, containing, as specified in point CAMO.A.300(a)(8), the nominative list of CAMO.A.305(e) personnel, constitutes the formal acceptance by the competent authority of the airworthiness review staff.
If the airworthiness review is performed under the supervision of existing airworthiness review staff, evidence should be provided to the competent authority.
The inclusion of an airworthiness review staff in such CAME list also constitutes the formal authorisation by the organisation.
The organisation shall ensure that aircraft airworthiness review staff can demonstrate appropriate, recent continuing airworthiness management experience.
AMC1 CAMO.A.310(d) Recent experience and validity
In order to keep the validity of the airworthiness review staff authorisation, the airworthiness review staff should have either:
— been involved in continuing airworthiness management activities for at least 6 months in every 2-year period, or
— conducted at least one airworthiness review in the last 12-month period.
In order to restore the validity of the authorisation, the airworthiness review staff should conduct at a satisfactory level an airworthiness review under the supervision of the competent authority or, if accepted by the competent authority, under the supervision of another currently authorised airworthiness review staff of the continuing airworthiness management organisation concerned in accordance with an approved procedure.