| Part-M/G (Current state) | Part-CAMO (Future state) | Is there a gap? | Gap description | Comments |
|---|---|---|---|---|
| M.A.702 Application | CAMO.A.115 Application for an organization | No | ||
| N/A | CAMO.A.120 Means of compliance | Yes | The use of the organization’s AltMoC is introduced. Currently there is no procedure to develop and propose AltMoC for CAMOs. | Develop in line with the respective chapter of the OPS manual (if applicable). |
| M.A.703 Extend of approval | CAMO.A.125(a), (b), (c) Terms of approval and privileges of the organization | No | ||
| M.A.711 Privileges of the organization | CAMO.A.125(d), (e), (f) Terms of approval and privileges of the organization | No | ||
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130(a)(1) Changes to the organization | Yes | Not all cases that require prior approval were listed in the regulation. | Document in CAME all the cases the require prior approval. Try to link the MoC described in Part-2 with this par. CAMO par. 0.5 and 0.6 are now merged. Change of par. 0.5 title |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130 Changes to the organization | Yes | Changes that affect the scope of the certificate or the terms of approval are introduced in the regulation as GM. | Document the changes that affect the scope of the certificate or the terms of approval. (Identify is there are any during the transition.) |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130 Changes to the organization | Yes | The regulation introduces the procedure to be followed when the name of the organization changes. | Establish the procedure to be followed when the name of the organization changes. |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130 Changes to the organization | Yes | Introduction of time frames for changes notification. | Document the time frames for each change (that requires approval). |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130(b) Changes to the organization | Yes | Clarification of when the changes become effective and that proper documentation is needed. | |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130(b) Changes to the organization | Yes | The organization shall operate according to the conditions established by the competent authority until the approval of the changes. | |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130 Changes to the organization | Yes | There is not an established procedure for the management of change (MoC). | Establish a procedure (if not already established). Par. 0.5 could contain general information and the procedure should be addressed in Part-2. |
| M.A.713 Changes to the approved continuing airworthiness organization | CAMO.A.130(c) Changes to the organization | Yes | Wording change. “Changes not requiring prior approval” replaces the term indirect approval”. | |
| M.A.715 Continued validity of the approval | CAMO.A.135(a)(1) Continued validity | Yes | Point (a)(1) changed from reference of Annex I to (EU) 2018/1139 and findings’ reference has been changed from Annex I to Annex Vc. | |
| M.A.715 Continued validity of the approval | CAMO.A.135(a)(2) Continued validity | Yes | Reference for the access to the competent authority has been changed. | |
| M.A.715 Continued validity of the approval | CAMO.A.135(a)(3) Continued validity | Yes | The term certificate is used instead of approval certificate. | |
| M.A.715 Continued validity of the approval | CAMO.A.135(b) Continued validity | Yes | The regulation addresses the case of invalidation of the AOC and the consequences to the related CAMO. | |
| M.A.715(b) Continued validity of the approval | CAMO.A.135(c) Continued validity | No | ||
| M.A.715(a)(2) Continued validity of the approval | CAMO.A.140 Access | Yes | Compliance to Regulation (EU) 2018/1139 is required. | |
| M.A.716 Findings | CAMO.A.150 Findings | Yes | The root causes and the contributing factors of findings should be identified. The definition of findings has been revised and included in Section B (of Part-CAMO). | Amend the definition of findings. Establish a procedure for root cause analysis. Establish a procedure for the identification of contributing factors. |
| M.A.716 Findings | CAMO.B.350 | Yes | Enriched definition of findings. There is a further explanation and clarification for level 1 findings. | Rephrase the definition of findings in CAME. |
| CAMO.A.155 Immediate reaction to a safety problem | Yes | New requirement, also included in M.A.305(c). | ||
| M.A.202 Occurrence reporting | CAMO.A.160 Occurrence reporting | Yes | A new reference is made to the Regulations (EU) 376/2014 and (EU) 2015/1018. These regulations include procedures/ processes not included in the CAW regulation (i.e. 1 month and 3 months reporting after the initial occurrence report). | Review (EU) 376/2014, (EU) 2015/1018 and AMC 20-8, and document all relevant procedures for occurrence reporting, in order for the CAME to act as the main source of information for CAMO personnel. |
| M.A.202 Occurrence reporting | CAMO.A.160(b) Occurrence reporting | Yes | The conditions under which the organization shall proceed to reporting are identified. | |
| CAMO.A.160 Occurrence reporting | Yes | Identify a unique focal point for occurrence reporting. | ||
| CAMO.A.160 Occurrence reporting | Yes | Occurrence reports should now be documented in par. 2.11 of CAME (instead of par. 1.8 that was in majority documented) | ||
| CAMO.A.200 Management System | Yes | SMS replaces the QMS in total. | Review the operator’s SMS (if applicable). Nominate a Safety Manager (attention to the qualifications of the OPS Safety Manager and CAMO Safety Manager). | |
| CAMO.A.200(a)(1) Management System | Yes | The lines of responsibility and accountability are are changed with the introduction of SMS. | Remove the Quality Manager and add Safety Manager and Compliance Monitoring Manager. | |
| CAMO.A.200(a)(2) Management System | Yes | The safety policy is introduced. | If the organization has an SMS already in place, then perform an SRB to determine if the safety policy needs amendment. | |
| CAMO.A.200(a)(3) Management System | Yes | Procedures for hazard identification, evaluation, safety risk management and mitigating actions are introduced. | An newly established SMS could adopt the procedures refered to ICAO Doc 9859 as a minimum. | |
| CAMO.A.200(a)(4) Management System | Yes | The current training procedures are not in line with the standards established by the SMS. | ||
| CAMO.A.200(a)(5) Management System | Yes | SMS key processes are identified. | ||
| M.A.712 Quality System | CAMO.A.200(a)(6) Management System | Yes | Compliance system’s requirements are already in place as it replaces the quality management system (QMS). | Minor wording changes in the text and audit checklists/ forms, Quality Manager is replaced by the Compliance Monitoring Manager. |
| CAMO.A.200(a)(7) Management System | Yes | Other topics not referenced in CAMO.A.200 are: occurrence reporting, internal safety reporting scheme. | ||
| CAMO.A.200(b) Management System | Yes | New requirement. | The SMS shall be customized to the particular organization size, structure, capability etc. | |
| M.A.712(e) Quality System | CAMO.A.200(c), (d) Management System | No | ||
| CAMO.A.202 Internal safety reporting scheme | Yes | New requirement introduced, to collect safety-related reports. | Install report boxed in the organization facilities, introduce a form the recording of incidents/ accidents/ violations, etc. | |
| M.A.711 (a)(3) Privileges of the organization | CAMO.A.205(a) Contracting and subcontracting | Yes | More detailed procedures introduced. Responsibilities are further analyzed. | Develop risk assessment procedures for the selection and oversight of the (sub)contracted organizations. |
| M.A.711 (a)(3) Privileges of the organization | CAMO.A.205(b) Contracting and subcontracting | Yes | More detailed procedures introduced. Responsibilities are further analyzed. | For subcontracted reference to Appendix II to AMC1 CAMO.A.125(d)(3). |
| M.A.705 Facilities | CAMO.A.215 Facilities | No | There is no gap in the regulation. | The CAME layout as presented in the EASA’s CAW regulation does not have a provision to document the facilities. Many competent authoritieshave issued technical orders requiring such a documentation. With the change in nominated personnel, the facilities layout shall be changed (safety manager office, compliance monitoring manager office, a secure space for SMS documentation). |
| M.A.714(a) Record keeping | CAMO.A.220(a)(1)-(2) Records keeping | No | ||
| M.A.714(b) Record keeping | CAMO.A.220(a)(3) Records keeping | No | ||
| M.A.714(c) Record keeping | CAMO.A.220(a)(4) Records keeping | No | ||
| M.A.714(d) Record keeping | CAMO.A.220(a)(5) Records keeping | Yes | From 2 years, the retention period increases to 3 years. The requirement permanently transferred to another person/organization is added. | |
| M.A.714(h) Record keeping | CAMO.A.220(a)(6) Records keeping | No | ||
| CAMO.A.220(b) Records keeping | Yes | Management system and (sub)contracting records retention periods introduced. | ||
| M.A.706(h) Personnel M.A.707(e) Airworthiness Review Staff | CAMO.A.220(c) Records keeping | Yes | All CAMO personnel records retention period introduced to 3 years. The airworthiness review staff records retention period is increased by 1 year. | |
| CAMO.A.220(d) Records keeping | Yes | This point was not specifically mentioned in Part-M/G. The term traceability for the records is introduced. | ||
| CAMO.A.220(e) Records keeping | Yes | The format that the records are held shall be documented. | ||
| M.A.714(e) Record keeping | CAMO.A.220(f) Records keeping | No | ||
| M.A.704(a)(1) CAME | CAMO.A.300(a)(1) CAME | Yes | Accountable Manager’s statement has different wording and little differences. The CEO title is added. | |
| CAMO.A.300(a)(2) CAME | Yes | The organization’s safety policy introduced. | ||
| M.A.704(a)(2) CAME | CAMO.A.300(a)(3) CAME | No | ||
| §0.3(e)(1) to Appendix V to AMC1 M.A.704 CAME | CAMO.A.300(a)(4) CAME | No | The man-hour plan shall be amended based on the change in the post-holders positions. Also, a procedure to plan the availability of staff should be added. The SMS procedures shall be taken into account while designing such a procedure, ref to CAMO.A.305(d) for more details. | |
| M.A.704(a)(3) CAME | CAMO.A.300(a)(5) CAME | No | Quality manager is replaced by compliance monitoring manager. Safety manager is introduced. | |
| §0.3 to Appendix V to AMC1 M.A.704 CAME | CAMO.A.300(a)(6) CAME | No | Add the duties and responsibilities of compliance monitoring manager and safety manager. Amend the duties and responsibilities iaw CAMO.A.305. | |
| M.A.704(a)(4) CAME | CAMO.A.300(a)(7) CAME | No | Amend the organization’s chart to include the new nominated post holders. | |
| M.A.704(a)(5) CAME | CAMO.A.300(a)(8) CAME | No | ||
| M.A.704(a)(6) CAME | CAMO.A.300(a)(9) CAME | No | ||
| CAMO.A.300(a)(10) CAME | Yes | The procedures related to internal safety reporting are introduced. | Refer to CAMO.A.202. This shall be documented in Part-2. | |
| M.A.704(a)(7) | CAMO.A.300(a)(11) | Yes | Compliance with Part-CAMO is required, additionally to Part-M(L). | Amend the compliance checklists to include the Part-CAMO references. |
| CAMO.A.300(a)(11)(i) CAME | Yes | Safety management system is a new requirement. | Attention to already existent management system procedures. | |
| CAMO.A.300(a)(11)(ii) CAME | Yes | New requirement to document in CAME the control of (sub)contracted activities. | ||
| CAMO.A.300(a)(11)(iii) CAME | Yes | There is a gap for the documentation in CAME of the ARC/PtF procedures. | Procedures already documented in CAME Part-4 & Part-4B. | |
| M.A.704(c) CAME | CAMO.A.300(a)(11)(iv) CAME | Yes | The term “indirect approval” is replaced with the term “not requiring prior approval”. | |
| M.A.704(a)(8) CAME | CAMO.A.300(a)(11)(v) CAME | No | ||
| M.A.704(a)(9) CAME | CAMO.A.300(a)(12) CAME | Yes | No longer required to issue generic or baseline maintenance programs. | |
| Appendix V to AMC1 M.A.704 CAME § 5.3 | CAMO.A.300(a)(13) CAME | Yes | The list of maintenance contracts need to be listed in par. 5.4. | Update the list of contracted maintenance organization(s) to include a reference to the maintenance contract(s). |
| CAMO.A.300(a)(14) CAME | Yes | New requirement to document the alternative means of compliance. The capability to use AltMoC was not addressed in Part-M/G. | ||
| M.A.704(b) CAME | CAMO.A.300(b) CAME | No | ||
| M.A.704(c) CAME | CAMO.A.300(c) CAME | No | ||
| Appendix V to AMC1 M.A.704 CAME | CAMO.A.300 (AMC1- table of contents) | Yes | New CAME layout introduced. | Paragraphs to be changed: 0.1 Add safety policy 0.7 Introduce a procedure for AltMoC Part 2 All new 2.8 is same with the quality management system with minor changes 4.8 Document separately the ARC extension procedures 5.6 List the approved AMPs 5.7 List the approved AltMoCs |
| M.A.706(a),(b) | CAMO.A.305(a)(1) | Yes | Accountable manager’s authorities are amended in order to cover the Basic regulation and not only the continuing airworthiness regulation. The responsibility to ensure resources in order for the organisation to be in compliance with Part-M/-ML is added. | |
| CAMO.A.305(a)(2) | Yes | In Part-M/G there was not a requirement for the accountable manager to establish and promote safety. SMS was not in required. | ||
| M.A.706(c) | CAMO.A.305(a)(3) | No | ||
| CAMO.A.305(a)(4) | Yes | A new requirement for nominating a compliance monitoring manager is added. | AMC1 CAMO.A.305(a)(4);(a)(5) | |
| CAMO.A.305(a)(5) | Yes | A new requirement for nominating a safety manager is added. | The functions of the safety manager and the compliance manager are further analysed in the above AMC. | |
| CAMO.A.305(a)(6) | Yes | Nominated post holders shall have direct access to the accountable manager for compliance and safety matters. | ||
| CAMO.A.305(a)(7) | Yes | A new requirement for the accountable manager to demonstrate a basic understanding of (EU) 1321/2014 is added. | ||
| CAMO.A.305(b)(1) | No | |||
| M.A.706(d),(e) | CAMO.A.305(b)(2) | No | ||
| M.A.706(f),(g),(h) | CAMO.A.305(c) | Yes | It is clarified that all nominated post holders are ultimately responsible to the accountable manager. In the related AMC the knowledge, background and experience of NPHs are analysed, where the knowledge for quality systems is replaced by HF principles and SMS. | |
| CAMO.A.305(d) | Yes | The procedure to plan the man-hours availability has not been changed. A new requirement to perform safety risk management is introduced with the AMC1 CAMO.A.305(d). | ||
| M.A.706(i) | CAMO.A.305(e) | Yes | Personnel issuing ARC (or PtF) or recommendations are required if the CAMO has the related capability. | |
| M.A.706(i) | CAMO.A.305(f) | No | ||
| M.A.706(k) | CAMO.A.305(g) | Yes | Detailed procedures for initial and recurrent competency assessment of personnel. Safety training is introduced. Compliance monitoring personnel need to be trained in audit techniques, reporting and recording. | |
| M.A.707 Airworthiness review staff | CAMO.A.310 Airworthiness review staff qualification | Yes | Airworthiness review staff are formally accepted by the competent authority when referenced to CAME, previously they were accepted through an EASA Form 4. | Attention if the competent authority (approving your CAME) has issued different instructions. |
| M.A.708(a) Continuing airworthiness management | CAMO.A.315(a) Continuing airworthiness management | No | ||
| M.A.708(b)(1) Continuing airworthiness management | CAMO.A.315(b)(1) Continuing airworthiness management | No | ||
| M.A.708(b)(2) Continuing airworthiness management | CAMO.A.315(b)(2) Continuing airworthiness management | No | ||
| M.A.708(b)(3) Continuing airworthiness management | CAMO.A.315(b)(3) Continuing airworthiness management | No | ||
| (Superseded M.A.201, not the current) | CAMO.A.315(b)(4) Continuing airworthiness management | Yes | Previously only SBs were required to be assessed for applicability and the final decision lay to the accountable manager/owner. A new provision is introduced, to assess all non-mandatory modification/inspections (SB, SL, SI). Also, this procedure has to be performed in line with the management system’s safety risk management. The title of CAME §1.6 has been amended. | Amend the (existing) procedure and the related form(s) iaw the management system’s safety risk management procedures (hazard identification, risk analysis, risk assessment, risk mitigation) |
| M.A.708(b)(4) Continuing airworthiness management | CAMO.A.315(b)(5) Continuing airworthiness management | Yes | Minor change in wordings. | |
| M.A.708(b)(5)-(b)(10) Continuing airworthiness management | CAMO.A.315(b)(6) Continuing airworthiness management | No | ||
| M.A.708(c) Continuing airworthiness management | CAMO.A.315(c) Continuing airworthiness management | No | There in no gap in the “hard law”, but there are differences in the contracts. | -Monitoring instead of quality monitoring (§2.5) -Life limited parts and time-time controlled components instead of service life limited components (§2.11) -In deferred tasks, the reference to regulation is amended (§2.16) -Maintenance check flight instead of test flight (§2.18) -Compliance and performance meeting instead of quality meeting (§2.34.4) |
| M.A.708(d) Continuing airworthiness management | CAMO.A.315(d) Continuing airworthiness management | Yes | In case of requesting maintenance by individual work orders, the propeller is added. | |
| CAMO.A.315(e) Continuing airworthiness management | Yes | A new requirement to consider human factors and human performance limitations during continuing airworthiness management, including (sub)contracted activities is added. | ||
| M.A.710 Airworthiness review | CAMO.A.320 Airworthiness review | No | ||
| M.A.709 Documentation | CAMO.A.325 Continuing airworthiness management data | No |
Part-M, Subpart G Transition to Part-CAMO
Updated on 06/07/2021