Part-M

Does the CAMO quality system need to be subject to monitoring?

Yes, the quality system is part of the activities of the CAMO and therefore it should be monitored.

Point M.A.712(b) requires that the quality system monitors:

  • that all CAMO activities are being performed in accordance with the approved procedures, and,
  • the continued compliance with requirement of part-M.

The quality system procedures are considered to be within these approved procedures . This implies that quality system must be subject to audits and the CAMO audit programme/plan needs to reflect this.

Besides that the audits to the quality system shall satisfy the requirement of independent audits. This is further explained in AMC M.A.712(b) point 8: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit. Therefore, to audit the quality system, it is acceptable:

  • to use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
  • to contract the independent audit element of the quality system to another organisation or a qualified competent person, or,
  • that the quality system is monitored and certified against an internationally recognised quality standards by a certification organisation

The way the quality system is going to be audited has to be described in the CAME and approved by the competent authority.

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Can an airworthiness review certificate (ARC)/recommendation be issued after an airworthiness review with open findings?

Neither an ARC nor a recommendation can be issued with open findings. Each finding requires a corrective action before the issue of the ARC or recommendation. The corrective action should be adequate to the open finding and it should be carried out and verified by the airworthiness review staff (ARS) before the issue of the ARC/ recommendation.

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Can a part-66 certifying staff perform an airworthiness review on an aircraft in which he or she had released some maintenance?

To avoid compromising the independence of the ARS,  he or she should have not been involved in the release to service of the aircraft of which he or she intends to perform the airworthiness review, except on maintenance tasks performed during the physical survey or performed as a result of findings discovered during the physical survey of the airworthiness review (AMC M.A.707 (a)).

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Can an extension of an ARC be anticipated more than 30 days?

As long as the conditions established for controlled environment (M.A.901 (b): continuously managed during the previous 12 months by a unique CAMO and maintained for the previous 12 months by part-145/part-M subpart F maintenance organisations or maintenance tasks referred to in point M.A.803(b) carried out and released to service by independent certifying staff (M.A.801(b)2) or pilot owner (M.A.801(b)3)  are met, the validity of the ARC can be extended for a period of one year. Should the ARC extension be anticipated more than 30 days, you will lose the continuity of the airworthiness review pattern, being the next date of expiry one year after the date of extension.

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Maintenance for each type of aircraft/operation

 

 

 

MAINTENANCE

Commercial operations

Licenced air carriers [1]

Maintenance to be performed by Part-145 organisations

Commercial specialised operations or CAT other than licenced air carriers or commercial ATOs

Complex motor-powered aircraft [2]

Maintenance to be performed by Part-145 organisations

Other than complex motor-powered aircraft (CMPA)

Maintenance to be performed by:

  • Part-M Subpart-F organisations; or,
  • Part-145 organisations.

Other than commercial operations

CMPA

Maintenance to be performed by part-145 organisations

Other than CMPA and limited operations [3]

Maintenance may be performed by:

  • Part-145 organisations,
  • Part-M Subpart-F organisations,
  • Independent certifying staff, or,
  • Pilot-owner maintenance [4]

[1] Licensed air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008

[2] Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.

[3] Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p)

[4] Only limited to non-CMPA of 2730 kg MTOM and below

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Are deputy nominated persons required in CAMO?

Neither M.A.706 (c) nor M.A.706 (d)  contain a specific requirement for the identification of deputy “nominated persons” as in part-145 (145.A.30(b)(4)). So, in principle, we could say that there is no requirement for the nomination or identification of deputy “nominated persons”.

Nevertheless, the CAMO needs to take into account the conditions for the continued validity of the approval contained in M.A.715, in particular point (a)(1) which refers to the continued validity of the approval provided the organisation remains in compliance with the requirements.

The CAMO should ensure that they remain in compliance during the absence of the nominated persons, this could be by identifying in the CAME  “one or several deputies” and the conditions under which the deputies will assume the responsibilities (this option could be acceptable for a short/medium absence). Another option would be to nominate another person. This would be necessary when the absence is going to be of considerable length and in this case the nomination and acceptance by the competent authority is done using the Form 4.

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Which tasks of the aircraft maintenance programme (AMP) could be the subject to deletion or interval extension by a CAMO using the indirect approval procedures?

The indirect approval procedures may only be used for:

  • the tasks, prescribed by the Design Approval Holder (DAH) in accordance with Part-21. The interval of these tasks could be decreased by the CAMO and extended to the values prescribed by the DAH,
  • CAMO originated tasks which could be added, deleted or extended,
  • addition/deletion/interval extension for the tasks arising from recommendations issued by the DAH.

In any case, such processes still should be based on the M.A.301(4) analysis of the effectiveness of the AMP.

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Can the airworthiness review certificate (ARC) of the large aircraft be extended during the extensive maintenance/long term storage?

An ARC extension could be performed as long as:

  1. the conditions established for controlled environment (M.A.901 (b)) are met. This means:
    1. continuously managed during the previous 12 months by a unique CAMO, and
    2. maintained for the previous 12 months by Part 145 organisations.

AND

  1. there is no evidence or reason to believe that the aircraft is not airworthy, as stated in M.A.901(k).

Thus, the procedure for the extension established in the CAMO has to address verification of the compliance with 3 above mentioned conditions. An aircraft going through the lengthy maintenance/modification or long-term storage is not considered to meet the condition number 2.

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Is EASA Forms 1 required during the import of the aircraft in the EU?

For the import of aircraft in the EU, the provisions of M.A.904 require the accomplishment of the airworthiness review, associated AMC M.A.904(a)(2) defines work to be performed in order to determine the airworthiness status of the aircraft.

When performing the airworthiness review there would be certain provisions of part-M where it might be not possible to show the full compliance with M.A.710 e.g. availability of EASA Form 1 for all relevant components. In such case, other releases to service or serviceable tags may be acceptable for the competent authority of the importing country.

Nevertheless, it must be ensured that the information required by M.A.305(d) related to the status of ADs, determination of remaining life, modifications and repairs is available (see also AMC M.A.305(d)).

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CAMO 1 uses the anticipation when performing the airworthiness review or extension for 90 or 30 days correspondingly. After the issue or extension of the ARC, the aircraft is transferred during the anticipation period from CAMO 1 to CAMO 2. As the consequence CAMO 2 has solely continuously managed the aircraft for more than 12 months due to the term of the validity of the ARC accordingly being more than 12 month. Are the requirements of the M.A.901(b)(i) satisfied?

The intent of the article M.A.901(b)(i) is to define the ‘controlled environment’ by indicating that the aircraft must be managed during last 12 months by unique CAMO, which indirectly refers to a standard term of validity of the ARC.  Therefore, if the aircraft has been managed by more than one CAMO since the date of issue of the last ARC or the date of issue of the ARC extension, it actually indicates that controlled environment was discontinued.

In addition in accordance with M.A.710(d) the 90 days anticipation shall be used to allow the physical review to be performed during a maintenance check. However, the intention of the rule was never to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review.  Concerning the 30 days anticipation for the ARC extension, point M.A.901(f) is intended for 2 consecutive extensions by the same CAMO managing the continuing airworthiness of the aircraft from the date of issue of the ARC, so the extended ARC could not be extended 2nd time by another organisation, because this constitutes a ‘breach’ of controlled environment.

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What are the plans of EASA in regards of the guidance relating to components’ Time between overhaul (TBO) extension?

The Decision 2013/025/R of the Executive Director of the Agency of 11 September 2013  "Recommended practice for TBO extension’"was published by EASA in September 2013.  Two months later, in December 2013, the ED Decision 2013/034/R cancelled the ED Decision 2013/025/R - "Recommended practice for TBO extension". That was done in reply to implementation difficulties reported by some NAAs. Afterwards EASA has decided to include the guidance related to the extension of the TBO into the framework of the Rulemaking task Part-M GA Task Force (Phase II).

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Must the EASA Form 1 be kept for on-condition components ?

There is no specific requirement to retain the EASA Form 1 of such components unless needed to comply with the requirements set forth in M.A.305 (h)(1), (h)(4), (h)(5) and (h)(6) for determining the continuing airworthiness and configuration of the aircraft.

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Do the maintenance contracts need to be submitted for the approval to the competent authorities after Commission Regulation (EU) 2015/1536 applies?

M.A.708(c) requires the CAMO to establish a written maintenance contract for CMPA or aircraft used for CAT or commercial specialised operations or commercial ATO operations.

The individual contracts need not to be submitted for approval to the competent authority. The competent authority shall approve the procedures for contracted maintenance as part of the CAME Part 3 and the basic information of the contracted maintenance should be included in a list of contracted maintenance organisations in the CAME part 5.4.

The amendment to the list mentioned in 5.4 may be managed through the indirect approval procedure.

Only for air carriers licenced in accordance with Regulation (EC) 1008/2008, the maintenance contracts need to be submitted to the competent authority as part of the package for initial application or for a change to the Air Operator Certificate as indicated in under M.B.701(a)(4).

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When does the interval for the next calendar aircraft maintenance check/task or the calendar interval for the next component check/overhaul starts?

In a normal scenario :

  • The date of signing the certificate of release to service (CRS) should be considered the date of the accomplishment.
  • The next due date should be calculated using this date.

However, there may be a lot of different considerations that change the normal scenario and make the statements above no longer valid. For example:

Case 1: The interval of the maintenance task has been ‘extended’ using a procedure included in the aircraft maintenance programme and approved by competent authority (refer to Appendix I to AMC M.A.302 point 4). Such procedure is often referred as permitted variation or ’tolerance’. In this case the next due date calculated using the original due date.

Case 2: The maintenance task refers to a component maintenance task, for example the landing gear overhaul. In this case the start of the interval would be the date of the release to service after the overhaul of the landing gear or in some particular cases when specified in the maintenance data the interval may start from the date of installation.

Case 3: The task is part of a maintenance check, where the duration of the check is significant compared to the interval of the task. For example, a check that lasts for 2 months and an inspection that has an interval of 3 months. In this case, it is reasonable to think that the performance of this task would need to be planned for the last days of the maintenance check, when possible. Otherwise, the inspection also can be done on the first day, but in that case, it is reasonable to expect that it will be released the same day (then the next due date would be 3 months after the CRS is signed). It also applies to the specific cases of mandatory tasks (ADs, CMRs, ALIs, etc.) defining repetitive action with a calendar limit.

There are many other examples, the key is to use sound engineering judgment and the guidance provided in the Instructions for Continuing Airworthiness to calculate the next due date.

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Continuing airworthiness management for each type of operator/ aircraft

    CONTINUING AIRWORTHINESS MANAGEMENT

Commercial operations

Licenced air carriers [1]

Continuing airworthiness shall be performed by a CAMO. Operator shall be CAMO approved (CAMO linked to the AOC).

Commercial specialised operations or CAT operations other than licensed air carriers or commercial ATOs

Continuing airworthiness shall be performed by a CAMO. Operator shall obtain CAMO approval, or operator shall contract a CAMO

Other than commercial operations Complex motor-powered aircraft [2] Continuing airworthiness shall be performed by a CAMO. Owner shall contract a CAMO
Other than complex motor-powered aircraft (CMPA) and limited operations [3]

Continuing airworthiness management may be performed by the owner. CAMO is not required.

 [1] Licenced air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008

[2] Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.

[3] Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p).

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Can an independent certifying staff maintain ELA1 aircraft used for commercial operations (such as ATO)?

No, ELA1 aircraft used for commercial operations cannot be maintained by independent certifying staff because in accordance with M.A.201(i) commercial operations require maintenance release by an organisation (part-M subpart-F or part-145 approved).

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What does the term “detailed maintenance records” mean?

“Detailed maintenance records” are those records required to be kept by the owner/operator to be able to determine the continuing airworthiness and configuration of the aircraft in accordance with part-M relevant for future maintenance. These are different from the detailed maintenance records required to be kept by a maintenance organisation as per M.A.614 or 145.A.55(c). Whereas maintenance organisations are required to retain all detailed records to demonstrate that they worked in compliance with their respective requirements, aircraft owners/operators need to retain those records required for assessing the aircraft configuration and the airworthiness of the aircraft and all components installed. ‘Dirty finger prints’ may not need to be transferred from the maintenance organisation to the aircraft owner/operator.

Where the maintenance organisation retains the detailed maintenance records in accordance with 145.A.55(c) and M.A.614, the owner/operator should receive the aircraft release to service of the maintenance performed  and all information necessary to determine the aircraft continuing airworthiness and its configuration, which includes references to all:

  • References to taskcards,
  • Information and substantiating data on modifications,
  • Airworthiness directives,
  • Information and substantiating data on repaired and non-repaired damage, and measurements relating to defects.
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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 service life-limited component (see definition in AMC M.A.305) are basically stated in M.A.305 (e) and (h). 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 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, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.
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Which are the correct statements to be written in block 11 of EASA Form 1 after maintenance?

Appendix II to part-M describes the following 4 permissible entries in block 11 of EASA Form 1:

  • Overhauled,
  • Repaired
  • Inspected/tested
  • Modified

The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of part-M/part-145.  Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.

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Quality manager for CAMO: Nomination, acceptance, qualification

The quality manager is considered nominated personnel according M.A.706 (c). The minimum qualification and experience requirements are contained in AMC M.A.706.

The nomination of the quality manager shall be performed using the EASA Form 4.

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What are the alleviations introduced by M.A.302(h) on the maintenance programme for General Aviation?

In accordance with M.A.302(h), for ELA1 aircraft not involved in commercial operation, the owner, whether he has contracted a CAMO or not [see M.A.201(i)], has the option not to submit the Aircraft Maintenance Programme (AMP) to the competent authority for approval, but instead ‘declare’ an AMP, subject to compliance with the conditions described therein. In this respect, the owner may decide to deviate from the applicable scheduled maintenance recommendations (see also remark below) without the need to justify such deviation(s), but under his/her full responsibility. Such declared AMP does not need to be sent to the competent authority.

In this scenario though, the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i). 

In addition, such declared AMP shall be reviewed annually and this review can be done either by the person who performs the airworthiness review, during the accomplishment of the airworthiness review, or by a CAMO if contracted to manage the continuing airworthiness of the aircraft [see M.A.302(h)5]. 

Besides, if during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the maintenance programme, the competent authority shall be informed and the AMP amended.

Remarks

  1. In accordance with M.A.302 and in particular M.A.302(h)(3), the AMP, declared or approved, shall in all cases include all the mandatory maintenance/continuing airworthiness requirements, such as repetitive Airworthiness Directives or the Airworthiness Limitation Section (ALS).
  2. In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.

References:
Please refer also to AMC M.A.302(e) (maintenance programme template), AMC M.A.302(h), GM M.A.302(h) and AMC M.A.302(i) (content of MIP).

Please refer to Article 2 (point k) of Regulation (EU) 1321/2014 for the definition of ELA1.

Please refer to Article 3 (point i) of Regulation (EU) 216/2008 (Basic Regulation) for the definition of commercial operation.
The agency also advises the owner who intends to transition from conventional to declared AMP to contact the competent authority for their guidance.

 

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