Part-M, Subpart G Transition to Part-CAMO

(Current state)
(Future state)
Is there a gap?Gap descriptionComments
M.A.702 ApplicationCAMO.A.115 Application for an organizationNo
N/ACAMO.A.120 Means of complianceYesThe 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 approvalCAMO.A.125(a), (b), (c) Terms of approval and privileges of the organizationNo
M.A.711 Privileges of the organizationCAMO.A.125(d), (e), (f) Terms of approval and privileges of the organizationNo
M.A.713 Changes to the approved continuing airworthiness organizationCAMO.A.130(a)(1) Changes to the organizationYesNot 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 organizationCAMO.A.130 Changes to the organizationYesChanges 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 organizationCAMO.A.130 Changes to the organizationYesThe 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 organizationCAMO.A.130 Changes to the organizationYesIntroduction 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 organizationCAMO.A.130(b) Changes to the organizationYesClarification of when the changes become effective and that proper documentation is needed.
M.A.713 Changes to the approved continuing airworthiness organizationCAMO.A.130(b) Changes to the organizationYesThe 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 organizationCAMO.A.130 Changes to the organizationYesThere 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 organizationCAMO.A.130(c) Changes to the organizationYesWording change. “Changes not requiring prior approval” replaces the term indirect approval”.
M.A.715 Continued validity of the approvalCAMO.A.135(a)(1) Continued validityYesPoint (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 approvalCAMO.A.135(a)(2) Continued validityYesReference for the access to the competent authority has been changed.
M.A.715 Continued validity of the approvalCAMO.A.135(a)(3) Continued validityYesThe term certificate is used instead of approval certificate.
M.A.715 Continued validity of the approvalCAMO.A.135(b) Continued validityYesThe regulation addresses the case of invalidation of the AOC and the consequences to the related CAMO.
M.A.715(b) Continued validity of the approvalCAMO.A.135(c) Continued validityNo
M.A.715(a)(2) Continued validity of the approvalCAMO.A.140 AccessYesCompliance to Regulation (EU) 2018/1139 is required.
M.A.716 FindingsCAMO.A.150 FindingsYesThe 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 FindingsCAMO.B.350YesEnriched 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 problemYesNew requirement, also included in M.A.305(c).
M.A.202 Occurrence reportingCAMO.A.160 Occurrence reportingYesA 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 reportingCAMO.A.160(b) Occurrence reportingYesThe conditions under which the organization shall proceed to reporting are identified.
CAMO.A.160 Occurrence reportingYesIdentify a unique focal point for occurrence reporting.
CAMO.A.160 Occurrence reportingYesOccurrence 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 SystemYesSMS 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 SystemYesThe 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 SystemYesThe 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 SystemYesProcedures 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 SystemYesThe current training procedures are not in line with the standards established by the SMS.
CAMO.A.200(a)(5) Management SystemYesSMS key processes are identified.
M.A.712 Quality SystemCAMO.A.200(a)(6) Management SystemYesCompliance 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 SystemYesOther topics not referenced in CAMO.A.200 are: occurrence reporting, internal safety reporting scheme.
CAMO.A.200(b) Management SystemYesNew requirement.The SMS shall be customized to the particular organization size, structure, capability etc.
M.A.712(e) Quality SystemCAMO.A.200(c), (d) Management SystemNo
CAMO.A.202 Internal safety reporting schemeYesNew 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 organizationCAMO.A.205(a) Contracting and subcontractingYesMore 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 organizationCAMO.A.205(b) Contracting and subcontractingYesMore detailed procedures introduced. Responsibilities are further analyzed.For subcontracted reference to Appendix II to AMC1 CAMO.A.125(d)(3).
M.A.705 FacilitiesCAMO.A.215 FacilitiesNoThere 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 keepingCAMO.A.220(a)(1)-(2) Records keepingNo
M.A.714(b) Record keepingCAMO.A.220(a)(3) Records keepingNo
M.A.714(c) Record keepingCAMO.A.220(a)(4) Records keepingNo
M.A.714(d) Record keepingCAMO.A.220(a)(5) Records keepingYesFrom 2 years, the retention period increases to 3 years.
The requirement permanently transferred to another person/organization is added.
M.A.714(h) Record keepingCAMO.A.220(a)(6) Records keepingNo
CAMO.A.220(b) Records keepingYesManagement 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 keepingYesAll 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 keepingYesThis point was not specifically mentioned in Part-M/G. The term traceability for the records is introduced.
CAMO.A.220(e) Records keepingYesThe format that the records are held shall be documented.
M.A.714(e) Record keepingCAMO.A.220(f) Records keepingNo
M.A.704(a)(1) CAMECAMO.A.300(a)(1) CAMEYesAccountable Manager’s statement has different wording and little differences. The CEO title is added.
CAMO.A.300(a)(2) CAMEYesThe organization’s safety policy introduced.
M.A.704(a)(2) CAMECAMO.A.300(a)(3) CAMENo
§0.3(e)(1) to Appendix V to AMC1 M.A.704 CAMECAMO.A.300(a)(4) CAMENoThe 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) CAMECAMO.A.300(a)(5) CAMENoQuality manager is replaced by compliance monitoring manager. Safety manager is introduced.
§0.3 to Appendix V to AMC1 M.A.704 CAMECAMO.A.300(a)(6) CAMENoAdd 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) CAMECAMO.A.300(a)(7) CAMENoAmend the organization’s chart to include the new nominated post holders.
M.A.704(a)(5) CAMECAMO.A.300(a)(8) CAMENo
M.A.704(a)(6) CAMECAMO.A.300(a)(9) CAMENo
CAMO.A.300(a)(10) CAMEYesThe 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)YesCompliance 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) CAMEYesSafety management system is a new requirement.Attention to already existent management system procedures.
CAMO.A.300(a)(11)(ii) CAMEYesNew requirement to document in CAME the control of (sub)contracted activities.
CAMO.A.300(a)(11)(iii) CAMEYesThere 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) CAMECAMO.A.300(a)(11)(iv) CAMEYesThe term “indirect approval” is replaced with the term “not requiring prior approval”.
M.A.704(a)(8) CAMECAMO.A.300(a)(11)(v) CAMENo
M.A.704(a)(9) CAMECAMO.A.300(a)(12) CAMEYesNo longer required to issue generic or baseline maintenance programs.
Appendix V to AMC1 M.A.704 CAME § 5.3CAMO.A.300(a)(13) CAMEYesThe 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) CAMEYesNew requirement to document the alternative means of compliance. The capability to use AltMoC was not addressed in Part-M/G.
M.A.704(b) CAMECAMO.A.300(b) CAMENo
M.A.704(c) CAMECAMO.A.300(c) CAMENo
Appendix V to AMC1 M.A.704 CAMECAMO.A.300 (AMC1- table of contents)YesNew 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)YesAccountable 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)YesIn Part-M/G there was not a requirement for the accountable manager to establish and promote safety. SMS was not in required.
CAMO.A.305(a)(4)YesA new requirement for nominating a compliance monitoring manager is added.AMC1 CAMO.A.305(a)(4);(a)(5)
CAMO.A.305(a)(5)YesA 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)YesNominated post holders shall have direct access to the accountable manager for compliance and safety matters.
CAMO.A.305(a)(7)YesA new requirement for the accountable manager to demonstrate a basic understanding of (EU) 1321/2014 is added.
M.A.706(f),(g),(h)CAMO.A.305(c)YesIt 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)YesThe 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)YesPersonnel issuing ARC (or PtF) or recommendations are required if the CAMO has the related capability.
M.A.706(k)CAMO.A.305(g)YesDetailed 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 staffCAMO.A.310 Airworthiness review staff qualificationYesAirworthiness 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 managementCAMO.A.315(a) Continuing airworthiness managementNo
M.A.708(b)(1) Continuing airworthiness managementCAMO.A.315(b)(1) Continuing airworthiness managementNo
M.A.708(b)(2) Continuing airworthiness managementCAMO.A.315(b)(2) Continuing airworthiness managementNo
M.A.708(b)(3) Continuing airworthiness managementCAMO.A.315(b)(3) Continuing airworthiness managementNo
(Superseded M.A.201, not the current)CAMO.A.315(b)(4) Continuing airworthiness managementYesPreviously 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 managementCAMO.A.315(b)(5) Continuing airworthiness managementYesMinor change in wordings.
M.A.708(b)(5)-(b)(10) Continuing airworthiness managementCAMO.A.315(b)(6) Continuing airworthiness managementNo
M.A.708(c) Continuing airworthiness managementCAMO.A.315(c) Continuing airworthiness managementNoThere 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 managementCAMO.A.315(d) Continuing airworthiness managementYesIn case of requesting maintenance by individual work orders, the propeller is added.
CAMO.A.315(e) Continuing airworthiness managementYesA new requirement to consider human factors and human performance limitations during continuing airworthiness management, including (sub)contracted activities is added.
M.A.710 Airworthiness reviewCAMO.A.320 Airworthiness reviewNo
M.A.709 DocumentationCAMO.A.325 Continuing airworthiness management dataNo
Updated on 06/07/2021

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