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Continuing airworthiness management


CAMO.A.315(a) Continuing airworthiness management

The organisation shall ensure that all continuing airworthiness management is carried out in accordance with Section A, Subpart C of Annex I (Part-M), or Section A Subpart C of Annex Vb (Part-ML), as applicable.

CAMO.A.315(b) Organization responsibilities

For every aircraft managed, the organisation shall in particular:

(1) ensure that an aircraft maintenance programme including any applicable reliability programme, as required by point M.A.302 or ML.A.302 as applicable, is developed and controlled;

GM1 CAMO.A.315(b)(1) Aircraft maintenance programme

In accordance with M.A.302 and ML.A.302, the CAMO requirement to ‘control’ the AMP includes in particular:

(i) in the case of aircraft complying with Part-ML, the approval of the AMP and its amendments;

(ii) in the case of aircraft complying with Part-M, the presentation of the AMP and its amendments to the competent authority for approval, unless the approval is covered by an indirect approval procedure in accordance with M.A.302(c).

(2) for aircraft not used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, provide a copy of the aircraft maintenance programme to the owner or operator responsible in accordance with point M.A.201 or ML.A.201 as applicable;

(3) ensure that data used for any modification and repairs complies with points M.A.304 or ML.A.304 as applicable;

AMC1 CAMO.A.315(b)(3) Modifications and repairs

When managing the approval of modifications or repairs, the organisation should ensure that CDCCL are taken into account.

(4) for all complex motor-powered aircraft or aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, establish a procedure to assess non-mandatory modifications and/or inspections and decide on their application, making use of the organisation’s safety risk management process as required by point (a)(3) of point CAMO.A.200;

AMC1 CAMO.A.315(b)(4) Assessment of non-mandatory information

The CAMO managing the continuing airworthiness of the aircraft should establish and work according to a policy, which assesses non-mandatory information (modification or inspections) related to the airworthiness of the aircraft. Non-mandatory information refers to service bulletins, service letters and other information that is produced for the aircraft and its components by an approved design organisation, the manufacturer, the competent authority or the Agency.

Do I have to comply with a ‘mandatory’ Service Bulletin?

The official EASA position regarding ‘required’ application of SB instructions is as follows:

Through the DOA (Design Organisation Approval) oversight process, the Agency promotes that TC/STC holders designate a Service Bulletin (SB) as mandatory only if it is known to them that this SB will also be covered by an AD. In all other cases, the TC/STC holder should use a term like ’highly recommended‘ (or equivalent). However, this is not yet common practice and there are still cases where an SB is termed ’mandatory‘ by the TC/STC holder, although no AD is to be issued. The Agency has no legal tools to prohibit the use of the word ‘mandatory’ by TC/STC holders, but EASA Certification Memorandum CM-21.A-J-001 has been issued to provide advice and guidance on this subject.

The case of an SB for which an AD has been issued, irrespective of whether it is designated by the TC/STC holder as ‘mandatory’, ‘alert’ or ‘highly recommended’, is clear: these are part of the Mandatory Continuing Airworthiness Instructions and must be applied in all cases.

The case of SBs designated as ‘mandatory’, ‘alert’ or ‘highly recommended’ by the TC/STC holder for which no AD has been issued is more complex and the following cases should be considered:

-The TC/STC holder subsequently includes such SB (e.g. repetitive inspection instructions) in the manufacturer maintenance programme (Maintenance Review Board Report (MRBR) or Manufacturer Recommended Programme) for the aircraft concerned. In this case, the SB under consideration will need to be included in the aircraft maintenance programme as defined in Commission Regulation (EU) No 1321/2014, M.A.302(d) and (g) (see also AMC M.A.302(d)) to ensure compliance with instructions for continuing airworthiness issued by the TC/STC holder.

-The TC/STC holder does not include such SB in the manufacturer maintenance programme (MRBR or Manufacturer Recommended Programme) for the aircraft concerned. In this case, the final decision to apply such SB lies with the owner/operator or contracted CAMO, as M.A.302(g) does not apply.

-The TC/STC holder issues an SB defining a modification, the related embodiment instruction and the relevant scheduled maintenance requirements, where these may or may not be subsequently included in the manufacturer maintenance programme (MRBR or Manufacturer Recommended Programme) for the aircraft concerned. In case the SB will not be included in the manufacturer maintenance programme, the final decision to apply it or not lies with the owner/ operator or contracted CAMO. If the final decision is to apply the SB, then the aircraft maintenance programme needs to be updated to include the scheduled maintenance requirements.

Finally, in relation to points 2. and 3. above, for all non-mandatory modifications and/or inspections, including SBs classified by the TC/STC holder as ‘mandatory’, ‘alert’ or ‘highly recommended’ and not covered by a corresponding AD, for all large aircraft, or aircraft used in commercial air transport, an embodiment policy is to be established, as required by M.A.301(7.). That policy should then result in a substantiated (and recorded) operator’s decision for each SB to apply it, or not.

(5) ensure that the aircraft, engine(s), propeller(s) and components thereof are taken to an appropriately approved maintenance organisation referred to in Subpart F of Annex I (Part-M), Annex II (Part-145) or Annex Vd (Part-CAO) whenever necessary;

GM1 CAMO.A.315(b)(5)

This requirement means that the CAMO is responsible for determining what maintenance is required, when it has to be performed, by whom and to what standard in order to ensure the continuing airworthiness of the aircraft.

(6) order maintenance, supervise activities, and coordinate related decisions to ensure that any maintenance is carried out properly and is appropriately released for the determination of aircraft airworthiness.

CAMO.A.315(c) Performance of maintenance

Where the organisation is not appropriately approved in accordance with Subpart F of Annex I (Part-M), Annex II (Part-145) or Annex Vd (Part-CAO) it shall, in consultation with the operator, manage the written maintenance contracts required by points (e)(3), (f)(3), (g)(3) and (h)(3) of M.A.201 or point ML.A.201 to ensure that:

(1) all maintenance is ultimately carried out by an appropriately approved maintenance organisation;

(2) the functions required under points (b), (c), (f) and (g) of point M.A.301 of Annex I (Part-M) or point ML.A.301 of Annex Vb (Part-ML), as applicable, are clearly specified.

AMC1 CAMO.A.315(c) Performance of maintenance/ maintenance contracts

(a) As provided for in M.A.201 or ML.A.201, when the operator is approved as a CAMO, or when the operator/owner contracts a CAMO, this CAMO is in charge of the continuing airworthiness management and this includes the tasks specified:

— for Part-M aircraft, in M.A.301 points (b), (c), (e), (f), (g) and (h);
— for Part-ML aircraft, in ML.A.301 points (b), (c), (d) and (e).

If the CAMO does not hold the appropriate maintenance organisation approval (Part-M Subpart F, Part-CAO or a Part-145 approval), then the CAMO should conclude a contract with the appropriate organisation(s).

(b) The CAMO bears the responsibility for the airworthy condition of the aircraft for which it performs the continuing airworthiness management. Thus, it should be satisfied before the intended flight that all required maintenance has been properly carried out.

(c) The CAMO should agree with the operator on the process to select a maintenance organisation before concluding any contract with a maintenance organisation.

(d) The fact that the CAMO has contracted a maintenance organisation should not prevent it from checking at the maintenance facilities on any aspect of the contracted work to fulfil its responsibility for the airworthiness of the aircraft.

(e) The contract between the CAMO and the maintenance organisation(s) should specify in detail the responsibilities and the work to be performed by each party.

(f) Both the specification of work and the assignment of responsibilities should be clear, unambiguous and sufficiently detailed to ensure that no misunderstanding arises between the parties concerned that could result in a situation where work that has an effect on the airworthiness or serviceability of aircraft is not or will not be properly performed.

(g) Special attention should be paid to procedures and responsibilities to ensure that all maintenance work is performed, service bulletins are analysed and decisions are taken on their accomplishment, airworthiness directives are accomplished on time and that all work, including non-mandatory modifications, is carried out to approved data and to the latest standards.

(h) Appendix IV to AMC1 CAMO.A.315(c) gives further details on the subject.

AMC2 CAMO.A.315(c) Maintenance contract with another CAMO/Operator

(a) The purpose of point CAMO.A.315(c) is to ensure that all maintenance is carried out by an appropriately approved maintenance organisation. It is acceptable to contract another operator/CAMO (secondary operator/CAMO) that does not hold a maintenance organisation approval when it proves that such a contract is in the interest of the CAMO by simplifying the management of its maintenance, and the CAMO keeps an appropriate control of it. In this case, the CAME should include appropriate procedures to ensure that all maintenance is ultimately carried out on time by approved maintenance organisations in accordance with appropriate maintenance data. In particular, the compliance monitoring and safety risk management procedures should place great emphasis on monitoring compliance with the above and ensuring proper hazard identification, and management of risks associated with such contracting. The list of approved maintenance organisations, or a reference to this list, should be included in the CAME.

(b) This contract should not preclude the CAMO from ensuring that all maintenance is performed by appropriately approved organisations which comply with M.A.201 or ML.A.201. Typical arrangements are the following:

— Component maintenance:
The CAMO may find it more appropriate to have a primary contractor (the secondary operator/CAMO) dispatching the components to appropriately approved organisations rather than sending themselves different types of components to various maintenance organisations approved under Part-145. The benefit for the CAMO is that the management of maintenance is simplified by having a single point of contact for component maintenance. The CAMO remains responsible for ensuring that all maintenance is performed by maintenance organisations approved under Part-145 and in accordance with appropriate maintenance data.

— Aircraft, engine and component maintenance:
The CAMO may wish to have a maintenance contract with a secondary operator/CAMO not approved as maintenance organisation for the same type of aircraft. A typical case is that of a dry-leased aircraft between operators where the parties, for consistency or continuity reasons (especially for short-term lease agreements), find it appropriate to keep the aircraft under the current maintenance arrangement. Where this arrangement involves various maintenance organisations, it might be more manageable for the lessee CAMO to have a single maintenance contract with the lessor operator/CAMO. Whatever type of acceptable maintenance contract is concluded, the CAMO is required to exercise the same level of control on contracted maintenance, particularly through the person(s) nominated under point CAMO.A.305(a) and the management system as referred to in CAMO.A.200.

GM1 CAMO.A.315(c) Line maintenance

For line maintenance, the actual layout of the IATA Standard Ground Handling Agreement may be used as a basis, but this does not preclude the CAMO from ensuring that the content of the contract is acceptable and especially that the contract allows the CAMO to properly exercise its continuing airworthiness management responsibility. Those parts of the contract that have no effect on the technical or operational aspects of airworthiness are outside the scope of this paragraph.

EASA policy on Certificates of Release to Service for aircraft maintenance and associated responsibilities of maintenance organisations and CAMOs

Continuing airworthiness responsibilities, including maintenance

The continuing airworthiness responsibilities are described in detail in Part-M(L), point M(L).A.201. This point introduces different provisions depending on the aircraft category (large and other than large aircraft) and type of operations (commercial air transport, other commercial operations and private operations)

However, all these provisions have two aspects in common:
 - the owner/operator (or contracted CAMO, if existing) is responsible for all activities aimed to determine the airworthiness status of the aircraft and to appropriately plan and coordinate maintenance, and
 - the contracted maintenance organisation or, when permitted by the rule, the independent certifying staff, are responsible for adequately performing and certifying the maintenance ordered by the owner/operator/CAMO.

In the particular case of aircraft involved in Commercial Air Transport, according to M.A.201(h), the operator is responsible for the continuing airworthiness of the aircraft it operates and shall be approved as a CAMO.

According to M.A.708(b)/ CAMO.A.315(b), these responsibilities include, among other aspects, ensuring that all maintenance requirements (Airworthiness Directives, maintenance programme requirements, defect rectification, etc) are complied with and released by approved Part-145 maintenance organisations.

This means that the operator (CAMO) is responsible for planning and ordering all required maintenance and for verifying that all the ordered maintenance has been released to service by the approved Part-145 organisation.

However, the operator is not responsible for the actual performance of maintenance, which is the responsibility of the Part-145 organisation issuing the CRS (Certificate of Release to Service). 

Important aspects to be considered are the following:
 - The operator (CAMO) cannot issue Certificates of Release to Service (CRS) following maintenance. The CRS has to be issued always by certifying staff of the Part-145 organisation.
- When maintenance is performed and released by the Part-145 organisation, the operator must have procedures to verify that all the maintenance ordered to that organisation has been released to service by the approved Part-145 organisation. However, in order to perform this verification the operator (CAMO) is not required to use certifying staff.

 - Since the CRS only certifies that the maintenance ordered by the operator (CAMO) has been performed and released in accordance with Part-145, it does not guarantee that all the continuing airworthiness requirements are met (there may be some missing maintenance that has not been ordered by the operator). This is the responsibility of the operator (CAMO).

 - Consequently, the operator (CAMO) must have procedures to ensure that a flight does not take place unless all the continuing airworthiness requirements are met. This could be met, for example, by a procedure where the operator (CAMO) receives a communication from the maintenance organisation and the operator (CAMO) notifies to the commander that there is no other maintenance due. However, other procedures are possible, for example, delegating to the Part-145 the notification to the commander.

 - The CRS issued by the Part-145 organisation has to go always on board the aircraft as part of the Technical Log System, together with all the information related to rectification of defects, deferral of maintenance actions, etc. This information has to be always available to the commander (refer to M.A.306 and AMC M.A.306(a)), who is the ultimate responsible for accepting the aircraft before a flight takes place.

 - The Technical Log System must also contain a maintenance statement issued by the operator (CAMO) providing the status of which scheduled and out of phase maintenance is next due. 

However, this maintenance statement does not need to be on board if the operator (CAMO) has alternate procedures acceptable for the competent authority in order to control the next maintenance due [refer to M.A.306 and AMC M.A.306(a)].

 - This maintenance statement, if placed on board the aircraft, does not supersede the obligation to have the Part-145 CRS on board and available to the commander.

CAMO.A.315(d) Individual work order (maintenance w/o maintenance contract)

Notwithstanding point (c), the contract may be in the form of individual work orders addressed to the maintenance organisation in the case of:

(1) an aircraft requiring unscheduled line maintenance;
(2) component maintenance, including engine and propeller maintenance, as applicable.

GM1 CAMO.A.315 Work Orders

The intent of this paragraph is that maintenance contracts are not necessary when the continuing airworthiness management exposition specifies that the relevant maintenance activity may be ordered through one-time work orders. This includes unscheduled line maintenance and may also include component maintenance up to engines, as long as the maintenance is manageable through work orders, in terms of both volume and complexity. It should be noted that this paragraph implies that even where base maintenance is ordered on a case-by-case basis, there should be a written maintenance contract.

CAMO.A.315(e) Human factor limitations

The organisation shall ensure that human factors and human performance limitations are taken into account during continuing airworthiness management, including all contracted and subcontracted activities.

AMC1 CAMO.A.315 Aircraft configuration

The CAMO should have adequate knowledge of the design information and aircraft configuration (type specification, customer options, airworthiness directives (ADs), airworthiness limitations contained in the aircraft ICA, modifications, repairs, operational and emergency equipment) and of the required and performed maintenance. The status of aircraft configuration and maintenance should be adequately documented to support the management system.

For CS-25 aeroplanes, adequate knowledge of the airworthiness limitations should cover those contained in CS-25 Book 1, Appendix H, paragraph H25.4 and fuel tank system airworthiness limitations including critical design configuration control limitations (CDCCL).

Updated on 06/07/2021

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