CAMO.A.220(a) Continuing airworthiness management records
Continuing airworthiness management records
(1) The organisation shall ensure that records required by points M.A.305, ML.A.305 and, if applicable point M.A.306, are retained.
(2) The organisation shall record all details of work carried out.
(3) If the organisation has the privilege referred to in point (e) of point CAMO.A.125, it shall retain a copy of each airworthiness review certificate and recommendation issued or, as applicable, extended, together with all supporting documents. In addition, the organisation shall retain a copy of any airworthiness review certificate that it has extended under the privilege referred to in point (d)(4) of point CAMO.A.125.
(4) If the organisation has the privilege referred to in point (f) of point CAMO.A.125, it shall retain a copy of each permit to fly issued in accordance with the provisions of point 21.A.729 of Annex I (Part-21) to Regulation (EU) No 748/2012.
(5) The organisation shall retain a copy of all records referred to in points (a)(2) to (a)(4) until 3 years after the responsibility for the aircraft in accordance with points M.A.201 or ML.A.201 has been permanently transferred to another person or organisation.
(6) Where the organisation terminates its operation, all retained records shall be transferred to the owner of the aircraft.
Is there any European requirement to maintain the back-to-birth traceability for any component fitted to an European aircraft?
The term “back to birth” is not used in European regulations. The requirements that apply to a life-limited part or a service life-limited component (see definition in ML.A.503(a)) are basically stated in M.A.305 (d)&(e) or ML.A.305(e). All detailed maintenance records of a maintenance action (e.g. a restoration) must be kept until another maintenance action equivalent in scope (another restoration) is done, but never less than 36 months. Keep in mind that: - a life-limited part or service life-limited component log card must be kept with all the relevant information, so the action should be recorded there, and - the records showing compliance with other requirements stated in M.A.305 or ML.A.305, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.
What does the term “detailed maintenance records” mean?
There has been a certain confusion about the understanding of “detailed maintenance records”, because this term is used in a different context for continuing airworthiness management and approved maintenance organisation (AMO). “Detailed maintenance records” as defined in M.A.614, 145.A.55(c) or CAO.A.90(a) are required to be kept by an AMO (respectively Part-M/F organisation, Part-145 organisation or CAO with maintenance privileges). Maintenance organisations are required to retain all detailed records in order to be able to demonstrate that they maintained aircraft and components in compliance with applicable requirements (see also remark). “Detailed maintenance records” as defined in M.A.305(e)(2) or ML.A.305(h)(1) are those records, coming from the AMO1 having performed maintenance, required to be kept by the owner/operator (or the CAMO or CAO with Continuing airworthiness management privileges when required by M.A.201 or ML.A.201) allowing to determine the aircraft configuration, the airworthiness status of the aircraft and all components installed, as well as to plan future maintenance as required by the AMP, based on the last accomplishment. Consequently, the AMO should transmit to the owner/operator/CA(M)O a certain subset of the AMO maintenance records, including the certificates of release to service and repair/modification data related to the performed maintenance, so that the owner/operator/CA(M)O can demonstrate compliance with M.A.305 or ML.A.305. Not all AMO maintenance records need to be transferred from the AMO to the owner/operator unless they specifically contain information relevant to aircraft configuration/status and future maintenance. Thus, incoming certificates of conformity, batch number references and individual task card sign-offs verified by and/or generated by the maintenance organisation are not required to be transferred to the owner/operator/CA(M)O. However, dimensional information contained in the task card sign-offs or work packages may need to be transferred and kept by the owner/ operator. It is to be noted that the record-retention period requirements are slightly different for the AMO and the CAMO and CAO with Continuing airworthiness management privileges. The AMO shall retain the records for 3 years, whereas the CAMO and CAO with Continuing airworthiness management privileges has to retain their records until they are superseded by new information (equivalent in scope and detail), but not less than 3 years. The starting point in both cases is when the aircraft or component maintenance has been released. Remark: It is considered a best practice as part of the AMO record-keeping system, (and it is also required by certain competent authorities) to record information (e.g. batch number or other tracking reference) relevant to the identification of all standard parts and material used during any maintenance. This practice may limit safety and industrial risks in the case where a batch is recalled by the manufacturer. Such record does not need to be transmitted to the owner/operator/CAMO/CAO with Continuing airworthiness management privileges. Maintenance records provided to the CA(M)O. Certain transmitted records do not need to be kept as a record by the CA(M)O such as EASA Form 1 for a component with no scheduled maintenance task selected and not subject to AD or modification/repair.
CAMO.A.220(b) Management system records
Management system, contracting and subcontracting records
(1) The organisation shall ensure that the following records are retained:
(i) records of management system key processes as defined in point CAMO.A.200;
(ii) contracts, both for contracting and subcontracting, as defined in point CAMO.A.205;
(2) Management system records, as well as any contracts pursuant to point CAMO.A.205, shall be kept for a minimum period of 5 years.
CAMO.A.220(c) Personnel records
(1) The organisation shall ensure that the following records are retained:
(i) records of qualification and experience of personnel involved in continuing airworthiness management, compliance monitoring and safety management;
(ii) records of qualification and experience of all airworthiness review staff, as well as staff issuing recommendations and permits to fly.
AMC1 CAMO.A.220(c)(1)(ii) Records of airworthiness review staff
The following minimum information, as applicable, should be kept on record in respect of each airworthiness review staff:
— Date of birth;
— Basic education;
— Aeronautical degree and/or Part-66 qualification and/or nationally-recognised maintenance personnel qualification;
— Initial training received;
— Type of training received;
— Recurrent training received;
— Experience in continuing airworthiness and within the organisation;
— Responsibilities of current role in the organisation;
— Copy of the authorisation.
(2) The records of all airworthiness review staff, staff issuing recommendations and staff issuing permits to fly shall include details of any appropriate qualification held together with a summary of the relevant continuing airworthiness management experience and training and a copy of the authorisation.
(3) Personnel records shall be kept as long as the person works for the organisation, and shall be retained until 3 years after the person has left the organisation.
The organisation shall establish a system of record-keeping that allows adequate storage and reliable traceability of all activities developed.
CAMO.A.220(e) Records’ format
The format of the records shall be specified in the organisation’s procedures.
CAMO.A.220(f) Records storage
Records shall be stored in a manner that ensures protection from damage, alteration and theft.
AMC1 CAMO.A.220 General
(a) The record-keeping system should ensure that all records are accessible within a reasonable time whenever they are needed. These records should be organised in a manner that ensures their traceability and retrievability throughout the required retention period.
(b) Records should be kept in paper form, or in electronic format, or a combination of the two. Records that are stored on microfilm or in optical disc formats are also acceptable. The records should remain legible throughout the required retention period. The retention period starts when the record is created or was last amended.
(c) Paper systems should use robust materials which can withstand normal handling and filing. Computer record systems should have at least one backup system, which should be updated within 24 hours of any new entry. Computer record systems should include safeguards to prevent unauthorised personnel from altering the data.
(d) All computer hardware that is used to ensure the backup of data should be stored in a different location from the one that contains the working data, and in an environment that ensures that the data remains in good condition. When hardware or software changes take place, special care should be taken to ensure that all the necessary data continues to be accessible through at least the full period specified in the relevant provision. In the absence of any such indications, all records should be kept for a minimum period of 3 years.
AMC2 CAMO.A.220 Continuing airworthiness management records
(a) The CAMO should ensure that it always receives a complete certificate of release to service from the approved maintenance organisation, independent certifying staff (M.A.801(b)(1) and ML.A.801(b)(2)) and/or from the Pilot-owner such that the required records can be retained. The system to keep the continuing airworthiness records should be described in the CAME.
(b) When a CAMO arranges for the relevant maintenance organisation to retain copies of the continuing airworthiness records on its behalf, it will nevertheless continue to be responsible for the records under point CAMO.A.220 relating to the preservation of records. If it ceases to be the CAMO of the aircraft, it also remains responsible for transferring the records to any other person or organisation managing continuing airworthiness of the aircraft.
GM1 CAMO.A.220 Records
Microfilming or optical storage of records may be carried out at any time. The records should be as legible as the original record, and remain so for the required retention period.