CAMO.A.305(a) Accountable Manager
The organisation shall appoint an accountable manager, who has corporate authority for ensuring that all continuing airworthiness management activities can be financed and carried out in accordance with Regulation (EU) 2018/1139 and delegated and implementing acts adopted on the basis thereof. The accountable manager shall:
(1) ensure that all necessary resources are available to manage continuing airworthiness in accordance with this Annex, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, to support the organisation approval certificate;
(2) establish and promote the safety policy specified in point CAMO.A.200;
(3) nominate a person or group of persons with the responsibility of ensuring that the organisation always complies with the applicable continuing airworthiness management, airworthiness review and permit to fly requirements of this Annex, Annex I (Part-M) and Annex Vb (Part-ML);
AMC2 CAMO.A.305(a)(3) Management structure for continuing airworthiness management
The person or group of persons nominated under point CAMO.A.305(a)(3) with the responsibility for ensuring compliance should represent the management structure of the organisation, and be responsible for the daily operation of the organisation, for all continuing airworthiness management functions.
Dependent on the size of the operation and the organisational set-up, the continuing airworthiness management functions may be divided under individual managers or combined in any number of ways.
GM1 CAMO.A.305(a)(3) Responsibility for ensuring compliance
The person(s) nominated in accordance with CAMO.A.305(a)(3) are responsible, in the day-to-day continuing airworthiness management activities, for ensuring that the organisation personnel work in accordance with the applicable procedures and regulatory requirements.
These nominated persons should demonstrate a complete understanding of the applicable regulatory requirements, and ensure that the organisation’s processes and standards accurately reflect the applicable requirements. It is their role to ensure that compliance is proactively managed, and that any early warning signs of non-compliance are documented and acted upon.
(4) nominate a person or group of persons with the responsibility for managing the compliance monitoring function as part of the management system;
(5) nominate a person or group of persons with the responsibility for managing the development, administration, and maintenance of effective safety management processes as part of the management system;
AMC1 CAMO.A.305(a)(4);(a)(5) Safety management and compliance monitoring function
(a) Safety management
If more than one person is designated for the development, administration and maintenance of effective safety management processes, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘safety manager’.
The functions of the safety manager should be to:
(i) facilitate hazard identification, risk assessment and management;
(ii) monitor the implementation of actions taken to mitigate risks, as listed in the safety action plan, unless action follow-up is addressed by the compliance monitoring function;
(iii) provide periodic reports on safety performance to the safety review board (the functions of the safety review board are those defined in AMC1 CAMO.A.200(a)(1));
(iv) ensure the maintenance of safety management documentation;
(v) ensure that there is safety training available, and that it meets acceptable standards;
(vi) provide advice on safety matters; and
(vii) ensure the initiation and follow-up of internal occurrence investigations.
(b) Compliance monitoring function
If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘compliance monitoring manager’.
(1) The role of the compliance monitoring manager should be to ensure that:
(i) the activities of the organisation are monitored for compliance with the applicable requirements and any additional requirements as established by the organisation, and that these activities are carried out properly under the supervision of the nominated persons referred to in points CAMO.A.305(a)(3) to (a)(5).
(ii) any contracted maintenance is monitored for compliance with the contract or work order;
(iii) an audit plan is properly implemented, maintained, and continually reviewed and improved; and
(iv) corrections and corrective actions are requested as necessary.
(2) The compliance monitoring manager should:
(i) not be one of the persons referred to in point CAMO.A.305(a)(3);
(ii) be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the organisation, including knowledge and experience in compliance monitoring; and
(iii) have access to all parts of the organisation, and as necessary, any subcontracted organisation.
(c) If the functions related to compliance monitoring or safety management are combined with other duties, the organisation should ensure this does not result in any conflicts of interest. In particular, the compliance monitoring function should be independent from the continuing airworthiness management functions.
(d) If the same person is designated to manage both the compliance monitoring function and safety management-related processes and tasks, the accountable manager, with regard to his or her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the organisation, and the nature and complexity of its activities.
(e) Subject to a risk assessment and/or mitigation actions, and agreement by the competent authority, with due regard to the size of the organisation and the nature and complexity of its activities, the compliance monitoring manager role and/or safety manager role may be exercised by the accountable manager, provided that he or she has demonstrated the related competency as defined in point (b)(2)(ii).
GM1 CAMO.A.305(a)(5) Safety Manager
(a) Depending on the size of the organisation and the nature and complexity of its activities, the safety manager may be assisted by additional safety personnel in performing all the safety management tasks as defined in AMC1 CAMO.A.200(a)(1).
(b) Regardless of the organisational set-up, it is important that the safety manager remains the unique focal point for the development, administration, and maintenance of the organisation’s safety management processes.
(6) ensure that the person or group of persons nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305 have direct access to keep him/her properly informed on compliance and safety matters;
(7) demonstrate a basic understanding of this Regulation.
AMC1 CAMO.A.305(a) Accountable Manager
Accountable manager is normally intended to mean the chief executive officer of the CAMO, who by virtue of his or her position, has overall (including in particular financial) responsibility for running the organisation. The accountable manager may be the accountable manager for more than one organisation, and is not necessarily required to be knowledgeable on technical matters, as the CAME defines the continuing airworthiness standards. When the accountable manager is not the chief executive officer, the organisation should demonstrate to the competent authority that the accountable manager has direct access to the chief executive officer and has the necessary funding allocation for the continuing airworthiness management activities sought.
For organisations also approved as air carriers licensed in accordance with Regulation (EC) No 1008/2008, the accountable manager shall in addition:
(1) be the person appointed as accountable manager for the air carrier as required by point (a) of point ORO.GEN.210 of Annex III (Part-ORO) to Regulation (EU) No 965/2012;
(2) nominate a person responsible for the management and supervision of continuing airworthiness, who shall not be employed by an organisation approved in accordance with Annex II (Part-145) under contract to the operator, unless specifically agreed by the competent authority.
AMC1 CAMO.A.305(b)(2) Post Holder
(a) When the licensed air carrier intends to nominate a CAMO post holder who is also employed by a Part-145 organisation, it should justify why such nomination is being made and support it through a risk assessment and/or mitigation actions.
(b) This paragraph only applies to contracted maintenance and therefore does not affect situations where the organisation approved under Part-145 and the air carrier licensed in accordance with Regulation (EC) No 1008/2008 are the same organisation.
CAMO.A.305(c) CAMO Manager
The person or persons nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305 shall be able to demonstrate relevant knowledge, background and satisfactory experience related to aircraft continuing airworthiness management and demonstrate a working knowledge of this Regulation. Such person(s) shall be ultimately responsible to the accountable manager.
AMC1 CAMO.A.305(c) Knowledge, background and experience of nominated person(s)
Persons or group of persons nominated in accordance with points CAMO.A.305(a) and CAMO.A.305(b) should have:
(a) practical experience and expertise in the application of aviation safety standards and safe operating practices;
(b) a comprehensive knowledge of:
(i) relevant parts of operational requirements and procedures;
(ii) the AOC holder’s operations specifications when applicable;
(iii) the need for, and content of, the relevant parts of the AOC holder’s operations manual when applicable.
(c) knowledge of:
(i) HF principles;
(ii) safety management systems based on the EU management system requirements (including compliance monitoring) and ICAO Annex 19.
(d) 5 years of relevant work experience, of which at least 2 years should be from the aeronautical industry in an appropriate position;
(e) a relevant engineering degree or an aircraft maintenance technician qualification with additional education that is acceptable to the competent authority. ‘Relevant engineering degree’ means an engineering degree from aeronautical, mechanical, electrical, electronic, avionic or other studies that are relevant to the maintenance and/or continuing airworthiness of aircraft/aircraft components;
The above recommendation may be replaced by 5 years of experience in addition to those already recommended by paragraph (d) above. These 5 years should cover an appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks;
(f) thorough knowledge of the organisation’s CAME;
(g) 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.
For all balloons and any other aircraft of 2 730 kg MTOM or less, the formalised training courses may be replaced by a demonstration of the required knowledge by providing documented evidence, or by an assessment performed by the competent authority. This assessment should be recorded.
(h) knowledge of maintenance methods;
(i) knowledge of the applicable regulations.
CAMO.A.305(d) Man-hour plan
The organisation shall have a system in place to plan the availability of staff to ensure that the organisation has sufficient appropriately qualified staff to plan, perform, supervise, inspect and monitor the organisation’s activities in accordance with the terms of approval.
AMC1 CAMO.A.305(d) Sufficient number of personnel
(a) The actual number of persons to be employed and their necessary qualifications is dependent upon the tasks to be performed and thus dependent on the size, nature and complexity of the organisation (general aviation aircraft, corporate aircraft, number of aircraft and the aircraft types, complexity of the aircraft and their age and for commercial air transport, route network, line or charter, ETOPS) and the amount and complexity of maintenance contracting. Consequently, the number of persons needed, and their qualifications may differ greatly from one organisation to another and a simple formula covering the whole range of possibilities is not feasible.
(b) To implement a system to plan the availability of staff and to enable the competent authority to accept the number of persons and their qualifications, the organisation should make an analysis of the tasks to be performed, the way in which it intends to divide and/or combine these tasks, indicate how it intends to assign responsibilities and establish the number of man/hours and the qualifications needed to perform the tasks. This analysis should be kept up to date and reviewed in case of significant changes to the organisation.
(c) In addition, as part of its management system in accordance with point CAMO.A.200, the organisation should have a procedure to assess and mitigate risks:
(1) when actual staff availability is less than the planned staffing level for any particular work shift or period;
(2) in case of a temporary increase of the proportion of contracted staff for the purpose of meeting specific operational needs.
CAMO.A.305(e) Airworthiness review staff
To be approved to carry out airworthiness reviews or recommendations in accordance with point (e) of point CAMO.A.125 and, if applicable, to issue permits to fly in accordance with point (f) of point CAMO.A.125, the organisation shall have airworthiness review staff qualified and authorised in accordance with point CAMO.A.310.
CAMO.A.305(f) ARC extension
For organisations extending airworthiness review certificates in accordance with point (d)(4) of point CAMO.A.125, the organisation shall nominate persons authorised to do so.
GM1 CAMO.A.305(f) Persons authorised to extend airworthiness review certificates
The approval by the competent authority of the exposition, containing, as specified in point CAMO.A.300(a)(5), the list of point CAMO.A.305(f) personnel authorised to extend airworthiness review certificates, constitutes their formal acceptance by the competent authority and also their formal authorisation by the organisation.
Airworthiness review staff are automatically recognised as persons with authority to extend an airworthiness review certificate in accordance with points CAMO.A.125(e)(1), M.A.901(f) and ML.A.901(c).
CAMO.A.305(g) Personnel competency
The organisation shall establish and control the competency of personnel involved in compliance monitoring, safety management, continuing airworthiness management, airworthiness reviews or recommendations, and, if applicable, issuing permits to fly, in accordance with a procedure and to a standard agreed by the competent authority. In addition to the necessary expertise related to the job function, competency must include an understanding of safety management and human factors principles appropriate to the person’s function and responsibilities in the organisation.
AMC1 CAMO.A.305(g) Competency assessment objectives
The procedure referred to in point CAMO.A.305(g) should require amongst others that technical support personnel such as, planners, engineers, and technical record staff, supervisors, post-holders, airworthiness review staff, whether employed or contracted, are assessed for competency before unsupervised work commences and competency is controlled on a continuous basis.
Competency should be assessed by the evaluation of:
— on-the-job performance and/or testing of knowledge by appropriately qualified personnel;
— records for basic, organisational, and/or product type and differences training; and
— experience records.
Validation of the above could include a confirmation check with the organisation(s) that issued such document(s). For that purpose, experience/training may be recorded in a document such as a log book.
As a result of this assessment, an individual’s qualification should determine:
— which level of ongoing supervision would be required and whether unsupervised work could be permitted;
— whether there is a need for additional training.
A record should be kept of each individual’s qualifications and competency assessment (refer also to point CAMO.A.220(c)). This should include copies of all documents that attest to their qualifications, such as an authorisation held, as applicable.
For a proper competency assessment of its personnel, the organisation should consider the following:
(a) In accordance with the job function, adequate initial and recurrent training should be provided and recorded to ensure continued competency so that it is maintained throughout the duration of the employment/contract.
(b) All staff should be able to demonstrate knowledge of, and compliance with, the CAMO procedures, as applicable to their duties.
(c) All staff should be able to demonstrate an understanding of safety management principles including HF, related to their job function and be trained as per AMC3 CAMO.A.305(g).
(d) To assist in the assessment of competency and to establish the training needs analysis, job descriptions are recommended for each job function in the organisation. Job descriptions should contain sufficient criteria to enable the required competency assessment.
(e) Criteria should allow the assessment to establish that, among other aspects (titles might be different in each organisation):
(1) Managers are able to properly manage processes, resources and priorities described in their assigned duties, accountabilities and responsibilities in accordance with the safety policy and objectives and in compliance with the applicable requirements and procedures.
(2) Maintenance programme engineers are able to interpret source data (norms, data issued by the holder of a design approval or by the competent authority, etc.) and use them to develop the aircraft maintenance programme.
(3) Engineering staff are able to interpret source data (norms, data issued by the holder of a design approval or by the competent authority, etc.) and use them as needed (e.g. to make work cards).
(4) Planners are able to organise maintenance activities in an effective and timely manner.
(5) Compliance monitoring staff are able to monitor compliance with this Regulation and to identify non-compliances in an effective and timely manner so that the organisation may remain in compliance with this Regulation.
(6) Staff who have been designated safety management responsibilities are familiar with the relevant processes in terms of hazard identification, risk management, and the monitoring of safety performance.
(7) All staff are familiar with the safety policy and the procedures and tools that can be used for internal safety reporting.
(f) The competency assessment should be based upon the procedure specified in GM1 CAMO.A.305(g).
AMC2 CAMO.A.305(g) Competency assessment procedure
(a) The organisation should develop a procedure that describes the process for conducting competency assessment of personnel. The procedure should specify:
(1) the persons who are responsible for this process;
(2) when the assessment should take place;
(3) how to give credit from previous assessments;
(4) how to validate qualification records;
(5) the means and methods to be used for the initial assessment;
(6) the means and methods to be used for the continuous control of competency, including to gather feedback on the performance of personnel;
(7) the aspects of competencies to be observed during the assessment in relation to each job function;
(8) the actions to be taken if the assessment is not satisfactory; and
(9) how to record assessment results.
(b) Competency may be assessed by having the person work under the supervision of another qualified person for a sufficient time to arrive at a conclusion. Sufficient time could be as little as a few weeks if the person is fully exposed to relevant work. The person need not be assessed against the complete spectrum of their intended duties. If the person has been recruited from another approved CAMO, it is reasonable to accept a written confirmation from the previous organisation.
(c) All prospective continuing airworthiness management staff should be assessed for their competency related to their intended duties.
AMC3 CAMO.A.305(g) Safety training (including human factors)
(a) With respect to the understanding of the application of safety management principles (including HF), all organisation personnel should be assessed for the need to receive initial safety training.
Personnel involved in the delivery of the basic continuing airworthiness management services of the organisation should receive both initial and recurrent safety training, appropriate for their responsibilities.
This should include at least the following staff members:
— nominated persons, line managers;
— persons involved in any compliance monitoring and/or safety management related processes and tasks, including application of HF principles, internal investigations and safety training;
— airworthiness review staff;
— technical support personnel such as, planners, engineers, and technical record staff;
— personnel involved in developing and amending/reviewing the AMP, in assessing its effectiveness and/or working on reliability programme; and
— contract staff in the above categories.
The generic term ‘line managers’ refers to departmental head or person responsible for operational departments or functional units directly involved in the delivery of the basic continuing airworthiness management services of the organisation.
(b) Initial safety training should cover all the topics of the training syllabus specified in GM2 CAMO.A.305(g) either as a dedicated course or else integrated within other training. The syllabus may be adjusted to reflect the particular nature of the organisation. The syllabus may also be adjusted to suit the particular nature of work for each function within the organisation.
Initial safety training compliant with the organisation’s training standards should be provided to personnel identified in accordance with point (a) of this AMC within 6 months of joining the organisation, but temporary staff may need to be trained shortly after joining the organisation to cope with the duration of employment.
Personnel being recruited from another organisation, and temporary staff should be assessed for the need to receive any additional safety training.
(c) The purpose of recurrent safety training is primarily to ensure that staff remain current in terms of SMS principles and HF, and also to collect feedback on safety and HF issues. Consideration should be given to involving compliance monitoring staff and key safety management personnel in this training to provide a consistent presence and facilitate feedback. There should be a procedure to ensure that feedback is formally reported by the trainers through the internal safety reporting scheme to initiate action where necessary.
Recurrent safety training should be delivered either as a dedicated course or else integrated within other training. It should be of an appropriate duration in each 2-year period, in relation to the relevant compliance monitoring audit findings and other internal/external sources of information available to the organisation on safety and HF issues.
(d) Safety training may be conducted by the organisation itself, independent trainers, or any training organisations acceptable to the competent authority.
AMC4 CAMO.A.305(g) Other trainings
(a) The organisation should assess the need for particular training; for example, with regard to the competency standards established in AMC 20-22 ‘Electrical Wiring Interconnection System’ (EWIS), the AMC 20-20 ‘Continuing Structural Integrity Programme’ or ‘Critical Design Configuration Control’ (CDCCL).
(b) Guidance on fuel tank safety training is provided in Appendix III to AMC4 CAMO.A.305(g).
(c) Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting, and recording.
(d) Personnel involved in developing and amending/reviewing the AMP, in assessing its effectiveness and/or working on reliability programme, should have knowledge of or be trained on statistical analysis and reliability method and the applicable methodology used in developing, as part of the instructions for continuing airworthiness (ICA), the manufacturer recommended maintenance programme (such as maintenance steering group logic).
AMC5 CAMO.A.305(g) Initial and recurrent training
(a) Adequate initial and recurrent training should be provided and recorded to ensure that staff remain competent.
(b) Recurrent training should take into account certain information reported through the internal safety reporting scheme (see point (c)(3) of AMC1 CAMO.A.202).
GM1 CAMO.A.305(g) Safety training (including human factors)
(a) The scope of the safety training and the related training programme will differ significantly depending on the size and complexity of the organisation. Safety training should reflect the evolving management system, and the changing roles of the personnel who make it work.
(b) In recognition of this, training should be provided to management and staff at least:
(1) during the initial implementation of safety management processes;
(2) for all new staff or personnel recently allocated to any safety management related task;
(3) on a regular basis to refresh their knowledge and to understand changes to the management system;
(4) when changes in personnel affect safety management roles, and related accountabilities, responsibilities, and authorities; and
NOTE: In the context of safety management, the term ‘authority’ is used in relation to the level of management in the organisation that is necessary to make decisions related to risk tolerability.
(5) when performing dedicated safety functions in domains such as safety risk management, compliance monitoring, internal investigations.
(c) Safety training is subject to the record-keeping requirements in point CAMO.A.220(c).
GM2 CAMO.A.305(g) Training syllabus for initial safety training
The training syllabus below identifies the topics and subtopics that should be addressed during the safety training.
The CAMO may combine, divide, or change the order of any of the subjects in the syllabus to suit its own needs, as long as all the subjects are covered to a level of detail that is appropriate for the organisation and its personnel, including the varying level of seniority of that personnel.
Some of the topics may be covered in separate training courses (e.g. health and safety, management, supervisory skills, etc.) in which case duplication of the training is not necessary.
Where possible, practical illustrations and examples should be used, especially accident and incident reports.
Topics should be related to existing legislation, where relevant. Topics should be related to existing guidance/advisory material, where relevant (e.g. ICAO HF Digests and Training Manual).
Topics should be related to continuing airworthiness management and maintenance engineering where possible; too much unrelated theory should be avoided.
Search safety training for the related syllabus
GM3 CAMO.A.305(g) Competency of the safety manager
The competency of a safety manager should include, but not be limited to, the following:
(a) knowledge of ICAO standards and European requirements on safety management;
(b) an understanding of management systems, including compliance monitoring systems;
(c) an understanding of risk management;
(d) an understanding of safety investigation techniques and root cause methodologies;
(e) an understanding of HF;
(f) understanding and promotion of a positive safety culture;
(g) operational experience related to the activities of the organisation;
(h) safety management experience;
(i) interpersonal and leadership skills, and the ability to influence staff;
(j) oral and written communications skills;
(k) data management, analytical and problem-solving skills.
Are deputies to nominated persons required in CAMO or CAO?
Part-M Subpart G, Part-CAMO and Part-CAO do not contain specific requirements for the identification of deputies to “nominated persons” as it is foreseen in Part-145 (145.A.30(b)(4)). Nevertheless, the CAMO or CAO needs to take into account the conditions for the continued validity of the approval laid down in M.A.715, CAMO.A.135 or CAO.A.110, in particular in case of findings or in case of changes. The CAMO or CAO should ensure that they remain in compliance even during short/medium absence of the nominated persons, this could be achieved by identifying in the CAME or CAE “one or several deputies” and the conditions under which the deputies will assume such responsibility. For longer absence of the nominated person, it is recommended to identify a new nominated person. For Part-M Subpart G organisations, the nomination and acceptance by the competent authority is done using the EASA Form 4. For Part-CAMO and Part-CAO approvals no EASA Form 4 is foreseen and the acceptance by the competent authority is formalised by the approval of an amendment to the exposition.