CAO.A.010 Scope

Regulation (EU) 2019/1383

This Annex establishes the requirements to be met by a combined airworthiness organisation (CAO) in order to be issued, upon application, an approval for the maintenance and continuing airworthiness management of aircraft and components for installation thereon, and to continue carrying out those activities, where such aircraft are not classified as complex motor-powered aircraft and are not listed in the air operator certificate of an air carrier licensed in accordance with Regulation (EC) No 1008/2008.

CAO.A.015 Application

Regulation (EU) 2019/1383

CAOs shall apply for the issuance of, or change to, a CAO approval to the competent authority in a form and manner established by that authority.

AMC1 CAO.A.015  Application

ED Decision 2020/002/R

An application should be made on an EASA Form 2 (Appendix III to AMC1 CAO.A.015) or an equivalent form that is acceptable to the competent authority.

Draft documents should be submitted at the earliest opportunity so that the assessment of the application can begin. The initial certification or approval of changes cannot take place until the competent authority has received the completed documents.

CAO.A.017 Means of compliance

Regulation (EU) 2020/270

(a) Alternative means of compliance to the acceptable means of compliance adopted by the Agency may be used by an organisation to demonstrate compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.

(b) When an organisation wishes to use alternative means of compliance, it shall, prior to using it, provide the competent authority with a full description of those alternative means of compliance. That description shall include an assessment demonstrating compliance of alternative means of compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.

The organisation may use those alternative means of compliance subject to prior approval by the competent authority, and upon receipt of the notification as provided for in point CAO.B.017.

CAO.A.020 Terms of approval

Regulation (EU) 2019/1383

(a) The CAO shall specify the approved scope of work in its combined airworthiness exposition (CAE), as provided for in point CAO.A.025.

(1) For aeroplanes of more than 2 730 kg maximum take-off mass (MTOM) and for helicopters of more than 1 200 kg MTOM or certified for more than 4 occupants, the scope of work shall indicate the particular aircraft types. Changes to this scope of work shall be approved by the competent authority in accordance with point (a) of point CAO.A.105 and point (a) of point CAO.B.065.

(2) For complete turbine engines, the scope of work shall indicate the engine manufacturer or group or series or type or the maintenance task(s). Changes to this scope of work shall be approved by the competent authority in accordance with point (a) of point CAO.A.105 and point (a) of point CAO.B.065.

(3) A CAO which employs only one person for both planning and carrying out of all maintenance tasks cannot hold privileges for the maintenance of:

(a) aeroplanes equipped with a turbine engine (in the case of aircraft-rated organisations);

(b) helicopters equipped with a turbine engine or with more than one piston engine (in the case of aircraft-rated organisations);

(c) complete piston engines of 450 HP and above (in the case of engine-rated organisations); and

(d) complete turbine engines (in the case of engine-rated organisations).

(4) For aircraft other than those mentioned in point (1), for components different from complete turbine engines and for non-destructive testing (NDT)-specialised services, the scope of work shall be controlled by the CAO in accordance with the procedure set out in point (a)(11) of point CAO.A.025. For maintenance of components different from complete engines, the scope of work shall be classified in accordance with the following system ratings:

(i) C1: air conditioning and pressurisation;

(ii) C2: auto flight;

(iii) C3: communications and navigation;

(iv) C4: doors and hatches;

(v) C5: electrical power and lights;

(vi) C6: equipment;

(vii) C7: engine;

(viii) C8: flight controls;

(ix) C9: fuel;

(x) C10: helicopter and rotors;

(xi) C11: helicopter transmission;

(xii) C12: hydraulic power;

(xiii) C13: indicating and recording system;

(xiv) C14: landing gear;

(xv) C15: oxygen;

(xvi) C16: propellers;

(xvii) C17: pneumatic and vacuum systems;

(xviii) C18: protection from ice/rain/fire;

(xix) C19: windows;

(xx) C20: structural;

(xxi) C21: water ballast; and

(xxii) C22: propulsion augmentation.

Organisations obtaining an approval in accordance with this Annex on the basis of an existing organisation approval issued in accordance with Subpart G or Subpart F of Annex I (Part-M) or Annex II (Part-145) in accordance with paragraph 4 of Article 4, shall include in the scope of work all the necessary details to ensure that the privileges are identical to the ones included in the existing approval.

(b) The CAO approval shall be issued on the basis of the template set out in Appendix I to this Annex.

(c) A CAO may fabricate, in conformity with maintenance data, a restricted range of parts for use in the course of undergoing work within its own facilities, as indicated in their CAE.

GM1 CAO.A.020  Terms of approval

ED Decision 2020/002/R

SCOPE OF WORK — AIRCRAFT CLASS

In the combined airworthiness exposition (CAE), the following guidance can be used as a minimum aircraft information to be indicated while specifying the scope of work of an organisation in the aircraft class.

(a) For aeroplanes above 2 730 kg maximum take-off mass (MTOM):

The particular aircraft types included (the use of the list of type ratings contained in the AMC to Part-66 is acceptable).

(b) For aeroplanes up to 2 730 kg MTOM:

               The type of propulsion (turbine engine, piston engine)

               The category (ELA1, ELA2, up to 2 730 kg)

(c) For helicopters above 1 200 kg MTOM and four occupants:

The particular aircraft types included (the use of the list of type ratings contained in Appendix I to AMC to Part-66 is acceptable).

(d) For helicopters up to 1 200 kg MTOM and four occupants:

The type of propulsion (turbine engine, piston engine)

(e) For sailplanes:

ELA1

(f) For balloons:

               Hot-air balloons

               Gas-balloons

               Roziere balloons

(g) For airships:

               The particular airship type for those which are not classified as ELA2

               For ELA2 airships, whether it covers hot-air airships or gas-airships

Each category or type of aircraft specified in the scope of work is to be completed with the privileges held (maintenance, continuing airworthiness management, airworthiness review, permit to fly) for that aircraft category or type.

GM1 CAO.A.020(a)  Terms of approval

ED Decision 2020/002/R

EXAMPLES OF CHANGE TO THE SCOPE OF WORK

In the case of helicopter Bell 206B model (above 1 200 kg MTOM) with regard to the scope of work, adding Bell 206L model to the scope of work would require approval by the competent authority in accordance with point CAO.A.020(a)(1).

If the scope of work contains the Rotax 912 A Series complete piston engine, the combined airworthiness organisation (CAO) shall control changes to the scope of work for additional complete piston engines (e.g. Rotax 914 series or LOM M 332 Series) in accordance with CAO.A.105(b) through an approved procedure.

AMC1 CAO.A.020(c)   Terms of approval

ED Decision 2020/002/R

FABRICATION

(a) The agreement by the competent authority for the fabrication of parts by the maintenance organisation should be formalised through the approval of a detailed procedure in the CAE. This AMC contains principles and conditions to be taken into account for the preparation of an acceptable procedure.

(b) Fabrication, inspection, assembly and test should be clearly within the technical and procedural capability of the approved maintenance organisation.

(c) The approved data necessary to fabricate the part is that approved by either the Agency, the type certificate (TC) holder, the Part 21 design organisation approval holder, or the supplemental type certificate (STC) holder.

(d) Items fabricated by an approved maintenance organisation may only be used by that organisation in the course of overhaul, maintenance, modifications, or repair of aircraft or components undergoing work within its own facilities. The permission to fabricate does not constitute approval for manufacturing, or for supplying externally and the parts do not qualify for certification on EASA Form 1. This also applies to the bulk transfer or surplus inventory, in that locally fabricated parts are physically segregated and excluded from any delivery certification.

(e) Fabrication of parts, modification kits, etc. for onward supply and/or sale may not be conducted under a CAO approval.

(f) The data specified in point (c) may include repair procedures involving the fabrication of parts. Where the data on such parts is sufficient to facilitate fabrication, the parts may be fabricated by an approved maintenance organisation. Care should be taken to ensure that the data includes details on part numbering, dimensions, materials, processes, and any special manufacturing techniques, special raw material specification or/and incoming inspection requirement and that the approved organisation has the necessary capability. That capability should be defined within the CAE. Where special processes or inspection procedures are defined in the approved data, which are not available at the approved maintenance organisation, that organisation cannot fabricate the part unless the TC/STC holder gives an approved alternative.

(g) Examples of fabrication under the scope of a CAO approval can include but are not limited to the following:

(1) fabrication of bushes, sleeves and shims;

(2) fabrication of secondary structural elements and skin panels;

(3) fabrication of control cables;

(4) fabrication of flexible and rigid pipes;

(5) fabrication of electrical cable looms and assemblies; and

(6) formed or machined sheet metal panels for repairs.

It is not acceptable to fabricate any item to pattern unless an engineering drawing of the item is produced which includes any necessary fabrication processes and which is accepted to the competent authority.

(h) Where a TC holder or an approved production organisation is prepared to make available complete data which is not referred to in aircraft manuals or service bulletins, but provides manufacturing drawings for items specified in parts lists, the fabrication of these items is not considered to be within the scope of a CAO approval unless agreed otherwise by the competent authority in accordance with a procedure specified in the CAE.

(i) Inspection and identification

Any locally fabricated part should be subject to an inspection stage before, separately, and preferably independently from, any inspection of its installation. The inspection should establish full compliance with the relevant manufacturing data, and the part should be unambiguously identified as fit for use by stating conformity to the approved data. Adequate records should be maintained of all such fabrication processes including heat treatment and the final inspections. All parts, except those with inadequate space, should carry a part number which clearly relates them to the manufacturing/inspection data. Additionally to the part number, the approved maintenance organisation’s identity should be marked on the part for traceability purposes.

CAO.A.025 Combined airworthiness exposition

Regulation (EU) 2019/1383

(a) The CAO shall provide a manual containing at least the following information:

(1) a statement signed by the accountable manager confirming that the organisation will at all times work in accordance with the requirements of this Annex and the CAE;

(2) the CAE’s scope of work;

(3) the title(s) and name(s) of the person(s) referred to in points (a) and (b) of point CAO.A.035;

(4) an organisation chart showing the chains of responsibility between the person(s) referred to in points (a) and (b) of CAO.A.035;

(5) a list of certifying staff with their scope of approval, if such staff exist;

(6) a list of staff responsible for the development and approval of aircraft maintenance programmes (AMPs) with their scope of approval, if such staff exist;

(7) a list of airworthiness review staff with their scope of approval, if such staff exist;

(8) a list of staff responsible for the issuance of permits to fly, if such staff exist;

(9) a general description and location of the facilities;

(10) procedures specifying how the CAO shall ensure compliance with the requirements of this Annex;

(11) the CAE amendment procedure, as provided for in point (b) of point CAO.A.105.

(b) The initial CAE shall be approved by the competent authority.

(c) Amendments to the CAE shall be handled in accordance with point CAO.A.105.

AMC1 CAO.A.025  Combined airworthiness exposition (CAE)

ED Decision 2020/002/R

This AMC provides an outline of the layout of an acceptable CAE.

AMC2 CAO.A.025   Combined airworthiness exposition (CAE)

ED Decision 2020/002/R

(a) Personnel should be familiar with those parts of the CAE that are relevant to their tasks.

(b) The CAO may use electronic data processing (EDP) for the publication of the CAE. Attention should be paid to the compatibility of the EDP systems with the necessary dissemination, both internally and externally, of the CAE.

CAO.A.030 Facilities

Regulation (EU) 2019/1383

The CAO shall ensure that all necessary facilities, including adequate office accommodation are provided for it to be able to carry out all the planned work.

In addition, where the scope of approval of the organisation includes maintenance activities, the CAO shall ensure that:

(a) specialised workshops, hangars and bays provide adequate protection from contamination and the environment;

(b) secure storage facilities are provided for components, equipment, tools and material, under conditions ensuring that unserviceable components and materials are segregated from all other components, material, equipment and tools, that the manufacturer’s instructions for storage are complied with and that access to the storage facilities is restricted to authorised personnel.

AMC1 CAO.A.030  Facilities

ED Decision 2020/002/R

FACILITIES FOR AN ORGANISATION HOLDING MAINTENANCE PRIVILEGES

(a) Where a hangar is not owned by the organisation, it may be necessary to establish proof of tenancy. In addition, sufficiency of hangar space to carry out planned maintenance should be demonstrated by the preparation of a projected aircraft hangar visit plan relative to the AMP. The aircraft hangar visit plan should be updated on a regular basis.

(b) For balloons and airships, a hangar may not be required where maintenance of the envelope and bottom-end equipment can more appropriately be performed outside, providing all necessary maintenance can be accomplished in accordance with ML.A.402. For complex repairs or component maintenance requiring an EASA Form 1, suitable approved workshops should be provided. The facilities and environmental conditions required for inspection and maintenance should be defined in the CAE.

(c) Subject to agreement by the competent authority, the organisation may use alternative suitable facilities other than a hangar at the approved location for certain aircraft maintenance tasks, provided that adequate protection from contamination and environment are ensured for the particular work package.

(d) Protection from the weather elements relates to the normal prevailing local weather elements that are expected throughout any 12-month period. Aircraft hangar and aircraft component workshop structures should be to a standard that prevents the ingress of rain, hail, ice, snow, wind and dust, etc. Aircraft hangar and aircraft component workshop floors should be sealed to minimise dust generation.

(e) Aircraft maintenance staff should be provided with an area where they may study maintenance instructions and complete continuing airworthiness records in a proper manner.

(f) Special case for aircraft to which Part-ML applies:

(1) It is acceptable not to have access to a hangar or dedicated workshops. Depending on the scope of work, other facilities are acceptable as long as protection is ensured from inclement weather and contamination. This may include, for example, working in the field or in non-aviation premises (closed or not).

(2) These facilities do not need to be individually approved by the competent authority as long as the CAE describes for each type of facility the scope of work, the tooling and equipment available, and the permitted environmental conditions (weather, contamination).

(3) The organisation should include, as part of the quality system/organisational review, a sampling of the compliance with these conditions during certain maintenance events.

(g) It is acceptable to combine any or all of the office accommodation requirements into one office subject to the staff having sufficient room to carry out the assigned tasks.

(h) Storage facilities for serviceable aircraft components should be clean, well ventilated and maintained at an even dry temperature to minimise the effects of condensation. The manufacturer’s storage recommendations should be followed for those aircraft components identified in such published recommendations.

(i) Adequate storage racks should be provided and strong enough to hold aircraft components and provide sufficient support for large aircraft components such that the component is not damaged during storage.

(j) All aircraft components, wherever practicable, should remain packaged in their protective material to minimise damage and corrosion during storage. A shelf life control system should be utilised and identity tags used to identify components.

(k) ‘Segregation' refers to storing unserviceable components in a separate secured location from serviceable components.

(l) Segregation and management of any unserviceable component should be ensured according to the pertinent procedure approved to that organisation.

(m) Procedures should be defined by the organisation describing the decision process for the status of unserviceable components. This procedure should identify at least the following:

(1) role and responsibilities of the persons managing the decision process;

(2) description of the decision process to choose between maintaining, storing or mutilating a component; and

(3) traceability of decision.

(n) Once unserviceable components or materials have been identified as unsalvageable in accordance with M.A.501(a)(3) or ML.A.504(c), the organisation should establish secure areas in which to segregate such items and to prevent unauthorised access. Unsalvageable components should be managed through a procedure to ensure that these components receive the appropriate final disposal according to M.A.504(b) or ML.A.504(d) or (e). The person responsible for the implementation of this procedure should be identified.

CAO.A.035 Personnel requirements

Regulation (EU) 2019/1383

(a) The CAO shall appoint an accountable manager, who shall have an authority for ensuring that all activities of the organisation can be financed so that those activities are carried out in accordance with the requirements of this Annex.

(b) The accountable manager shall nominate a person or group of persons who shall be responsible for ensuring that the CAO is always in compliance with the requirements of this Annex. Those person(s) shall ultimately be responsible to the accountable manager.

(c) All persons referred to in point (b) shall have the relevant knowledge, background and experience related to continuing airworthiness management or maintenance, as appropriate for their functions.

(d) The CAO shall have sufficient appropriately qualified staff for it to be able to carry out the planned work. The CAO shall be entitled to use temporarily subcontracted staff.

(e) The CAO shall assess and record the qualification of all personnel.

(f) Personnel who carry out specialised tasks, such as welding, or non-destructive testing (‘NDT’) inspection other than colour contrast inspections shall be qualified in accordance with an officially-recognised standard

AMC1 CAO.A.035(c)  Personnel requirements

ED Decision 2020/002/R

KNOWLEDGE, BACKGROUND AND EXPERIENCE OF NOMINATED PERSON(S)

Persons or group of persons nominated in accordance with point CAO.A.035(b) should have:

(a) practical experience and expertise in the application of aviation safety standards and safe operating practices;

(b) comprehensive knowledge of:

(1)  Part-M, Part-ML and any associated requirements and procedures; and

(2)  the CAE;

(c) 5 years aviation experience of which at least 2 years should be from the aeronautical industry in an appropriate position;

(d) knowledge of a relevant sample of the type(s) of aircraft or components that are within the scope of work. This knowledge may be demonstrated by documented evidence or by an assessment performed by the competent authority.

Training courses, when used as documented evidence, should be as a minimum 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; and

(e) knowledge of:

(1) maintenance standards (including human factor principles); and

(2) quality system (or organisational review).

AMC1 CAO.A.035(e) Personnel requirements

ED Decision 2020/002/R

QUALIFICATION ASSESSMENT

(a) Personnel involved in maintenance and continuing airworthiness management should be assessed for competence by ‘on-the-job’ evaluation and/or by examination relevant to their particular job role within the organisation before unsupervised work is permitted.

(b) Adequate initial and recurrent training should be provided and recorded to ensure continued competence.

CAO.A.040 Certifying staff

Regulation (EU) 2019/1383

(a) Certifying staff shall comply with the requirements of Article 5. They shall only exercise their privileges to release maintenance if the CAO has ensured:

(1) that these certifying staff meet the requirements of point (b) of point 66.A.20 of Annex III (Part-66) except when paragraph 6 of Article 5 refers to a national regulation of a Member State, in which case, they shall meet the requirements of such a regulation;

(2) that these certifying staff have an adequate understanding of the relevant aircraft or aircraft component(s) to be maintained, or both, as well as of the organisation procedures required to perform such maintenance.

(b) By derogation from point (a), in unforeseen circumstances where an aircraft is grounded at a location other than the main base where no appropriate certifying staff are available, the CAO contracted to provide maintenance support may issue a one-off certification authorisation, alternatively:

(1) to one of their employees holding type qualifications for aircraft of similar technology, construction and systems;

(2) to any person with no less than 3 years of maintenance experience and holding a valid ICAO aircraft maintenance licence rated for the aircraft type requiring certification, provided that there is no organisation approved in accordance with this Annex at that location and that the contracted CAO obtains and holds on file evidence of the experience and licence of that person.

The issuance of a one-off certification authorisation shall be reported by the CAO to the competent authority within 7 days of the issuance. The CAO issuing the one-off certification authorisation shall ensure that any such maintenance that could affect flight safety is rechecked.

(c) By derogation from point (a), the CAO may use certifying staff qualified in accordance with the following requirements when providing maintenance support to operators involved in commercial operations, subject to appropriate procedures to be approved as part of the CAE:

(1) for a repetitive preflight airworthiness directive (AD) which specifically states that the flight crew may carry out such an AD, the CAO may issue a limited certifying-staff authorisation to the pilot-in-command on the basis of the flight crew licence held, provided that the CAO ensures that sufficient practical training has been carried out by the pilot-in-command so he/she can accomplish the AD to the required standard;

(2) in the case of aircraft operating away from a supported location, the CAO may issue a limited certifying-staff authorisation to the pilot-in-command, on the basis of the flight crew licence held, provided that the organisation ensures that sufficient practical training has been carried out so that such a commander can accomplish the task to the required standard.

(d) The CAO shall record the details concerning certifying staff and maintain an up-to-date list of all certifying staff, together with details on their scope of approval, as part of the organisation’s exposition.

CAO.A.045 Airworthiness review staff

Regulation (EU) 2021/700

(a) In order for it to be approved to carry out airworthiness reviews and, if applicable, to issue permits to fly, a CAO shall have appropriate airworthiness review staff who shall comply with all of the following requirements:

(1) they acquired experience in continuing airworthiness of at least 1 year for sailplanes and balloons and of at least 3 years for all other aircraft;

(2) they hold an appropriate licence issued in accordance with Article 5 of this Regulation or an aeronautical degree or equivalent, or they acquired experience in continuing airworthiness in addition to that referred to in point (1) of at least 2 years for sailplanes and balloons and at least 4 years for all other aircraft;

(3) they acquired appropriate aeronautical-maintenance training.

(b) Before the CAO issues an authorisation to an airworthiness review staff to perform airworthiness review, the CAO shall nominate the person who will perform an airworthiness review of an aircraft under supervision of the competent authority or under the supervision of a person already authorised as airworthiness review staff of the CAO. If this supervision is satisfactory, the competent authority shall formally accept the staff to become airworthiness review staff.

(c) The CAO shall ensure that its airworthiness review staff can demonstrate appropriate recent continuing airworthiness experience.

(d) Each airworthiness review staff shall be identified in the CAE in a list that contains the airworthiness review authorisation referred in point (b).

(e) The CAO shall maintain a record of all its airworthiness review staff, which shall include details of any appropriate qualification and a summary of relevant continuing airworthiness experience and training of the person concerned, as well as a copy of his or her authorisation. It shall retain that record for a period of at least 2 years after the date at which the person concerned no longer works for the CAO.

AMC1 CAO.A.045  Airworthiness review staff

ED Decision 2020/002/R

(a) Airworthiness review staff already authorised to perform airworthiness review for an organisation approved in accordance Part-M Subpart F, Part-M Subpart G, Part-CAMO or Part-145 is considered to be authorised in accordance with Part-CAO when such organisation applies for a Part-CAO approval. This means that no additional supervision is needed to be authorised to be accepted to continue carrying out airworthiness reviews. This does not supersede the requirement for the organisation to ensure that all personnel is competent for the job they are authorised.

(b) ‘Experience in continuing airworthiness’ in CAO.A.045(a) refers to any appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks.

(c) ‘Appropriate recent continuing airworthiness experience’ in CAO.A.045(c) refers to the fact that in order to keep the validity of the airworthiness review staff authorisation, the airworthiness review staff should have either:

(1) been involved in continuing airworthiness management activities for at least 6 months in every 2-year period; or

(2) conducted at least one airworthiness review in the last 12-month period.

(d) In order to restore the validity of the authorisation, the airworthiness review staff should conduct at a satisfactory level an airworthiness review under the supervision of the competent authority or, if accepted by the competent authority, under the supervision of another currently valid authorised airworthiness review staff of the CAO concerned in accordance with an approved procedure.

(e) A person that holds a relevant engineering degree or an aircraft maintenance technician qualification with additional education should be considered as holding the equivalent to an aeronautical degree. ‘Relevant engineering degree’ refers to an engineering degree from mechanical, electrical, electronic, avionic or other studies relevant to the maintenance and continuing airworthiness of aircraft/aircraft components.

CAO.A.050 Components, equipment and tools

Regulation (EU) 2019/1383

(a) The CAO shall:

(1) hold the equipment and tools specified in the maintenance data provided for in point CAO.A.055, or verified equivalents as listed in the CAE, as necessary for day-to-day maintenance within the scope of the organisation's approval;

(2) have a procedure to ensure that it has access to all other equipment and tools necessary to carry out its work, used only on an occasional basis, where needed.

(b) The CAO shall ensure that the tools and equipment it uses are controlled and calibrated to an officially recognised standard. It shall keep records of such calibrations and the standards used and comply with point CAO.A.090.

(c) The CAO shall inspect, classify and appropriately segregate all incoming components in accordance with points M.A.501 and M.A.504 of Annex I (Part-M) or with points ML.A.501 and ML.A.504 of Annex Vb (Part-ML), as applicable.

AMC1 CAO.A.050(a)  Components, equipment and tools

ED Decision 2020/002/R

(a)  The tools ‘necessary for day-to-day maintenance’ refers to those needed to perform standard maintenance practices plus those needed in order to complete the normal servicing tasks as well as those needed up to the annual/100-hour or equivalent inspections and which are common to the majority of aircraft contained in the scope of approval.

(b) The availability of tools rarely used because the particular maintenance task is very rarely performed can be handled through a procedure in accordance with CAO.A.050(a)(2).

CAO.A.055 Maintenance data and work orders

Regulation (EU) 2019/1383

(a) The CAO shall hold and use applicable current maintenance data specified in point M.A.401 of Annex I (Part-M) or in point ML.A.401 of Annex Vb (Part-ML), as applicable, in the performance of maintenance, including modifications and repairs. However, in the case of customer-provided maintenance data, it shall only be required to hold such data when the work is in progress.

(b) Before the commencement of maintenance, a written work order shall be agreed between the CAO and the person or organisation requesting maintenance, in a manner that clearly establishes the maintenance to be carried out.

AMC1 CAO.A.055   Maintenance data and work orders

ED Decision 2020/002/R

It is not required to continuously hold all the maintenance data. It is acceptable to have a procedure to ensure that the specific maintenance data required for a particular maintenance activity will be available before that maintenance takes place.

CAO.A.060 Maintenance standards

Regulation (EU) 2019/1383

When performing maintenance, the CAO shall comply with all of the following requirements:

(a) ensure that any person performing maintenance is qualified in accordance with the requirements of this Annex;

(b) ensure that the area in which maintenance is carried out is well organised and clean (no dirt or contamination);

(c) use the methods, techniques, standards and instructions specified in the maintenance data and work orders referred to in point CAO.A.055;

(d) use the tools, equipment and material specified in point CAO.A.050;

(e) ensure that maintenance is performed in accordance with any environmental limitations specified in the maintenance data referred to in point CAO.A.055;

(f) ensure that proper facilities are used in case of inclement weather or lengthy maintenance;

(g) ensure that the risk of multiple errors during maintenance and the risk of errors being repeated in identical maintenance tasks are minimised;

(h) ensure that an error-capturing method is implemented after the performance of any critical maintenance task;

(i) perform a general verification after completion of maintenance in order to ensure that the aircraft or component is clear of all tools, equipment and any extraneous parts and material and that all access panels removed have been refitted;

(j) ensure that all maintenance performed is properly recorded and documented.

AMC1 CAO.A.060(g)  Maintenance standards

ED Decision 2020/002/R

(a)  To minimise the risk of errors and to prevent omissions, the approved CAO when performing maintenance, should ensure that:

(1)  every maintenance task is signed off only after completion;

(2)  the grouping of tasks for the purpose of sign-off allows critical steps to be clearly identified; and

(3)  any work performed by personnel under supervision (i.e. temporary staff, trainees) is checked and signed off by an authorised person.

(b)  To minimise the possibility of an error being repeated in identical tasks that involve removal/installation or assembly/disassembly of several components of the same type fitted to more than one system, whose failure could have an impact on safety, the approved CAO when performing maintenance should plan different persons to perform identical tasks in different systems. However, when only one person is available, then this person should perform reinspection of the tasks as described in AMC2 CAO.A.060(h).

AMC1 CAO.A.060(h)   Maintenance standards

ED Decision 2020/002/R

CRITICAL MAINTENANCE TASKS

The following maintenance tasks should primarily be reviewed to assess their impact on safety:

(a)  tasks that may affect the control of the aircraft’s flight path and attitude, such as the installation, rigging and adjustments of flight controls;

(b)  tasks that may affect aircraft stability control systems (autopilots, fuel transfer);

(c)  tasks that may affect the propulsive force of the aircraft, including the installation of aircraft engines, propellers and rotors; and

(d)  the overhaul, calibration or rigging of engines, propellers, transmissions and gearboxes.

AMC2 CAO.A.060(h)  Maintenance standards

ED Decision 2020/002/R

INDEPENDENT INSPECTION

Independent inspection is one possible error-capturing method.

(a)  What is an independent inspection

An independent inspection is an inspection, which is performed by an ‘independent qualified person’, of a task carried out by an ‘authorised person’, taking into account that:

(1)  the ‘authorised person’ is the person who performs the task or supervises the task, and assumes the full responsibility for the completion of the task in accordance with the applicable maintenance data;

(2)  the ‘independent qualified person’ is the person who performs the independent inspection and attests to the satisfactory completion of the task, and that no deficiencies have been found. The ‘independent qualified person’ does not issue a certificate of release to service (CRS); therefore, he or she is not required to hold certification privileges;

(3)  the CRS is issued by the ‘authorised person’ after the independent inspection has been carried out satisfactorily; and

(4)  the work card system should record the identification of each person, the date and the details of the independent inspection, as necessary, before the CRS is issued.

(b)  Qualifications of personnel performing independent inspections

The organisation should have procedures to demonstrate that the ‘independent qualified person’ has been trained and has gained experience in the specific control systems to be inspected. This training and experience could be demonstrated, for example, by:

(i)  holding a Part-66 licence in the same subcategory as the licence subcategory or equivalent necessary to release or sign off the critical maintenance task; or

(ii)  holding a Part-66 licence in the same category and specific training in the task to be inspected; or

(iii)  having received appropriate training and having gained relevant experience in the specific task to be inspected.

(c)  How to perform an independent inspection

The independent inspection should ensure, for example, the correct assembly, locking and sense of operation of the parts involved. When inspecting control systems that have undergone maintenance, the ‘independent qualified person’ should consider the following points independently:

(1)  all those parts of the system that have actually been disconnected or disturbed should be inspected for their correct assembly and locking;

(2)  the system as a whole should be inspected for full and free movement over the complete range;

(3)  cables should be tensioned correctly with adequate clearance at secondary stops;

(4)  the operation of the control system as a whole should be observed to ensure that the controls operate in the correct sense;

(5)  if different control systems are interconnected so that they affect each other, all the interactions should be checked through the full range of the applicable controls; and

(6)  software that is part of the critical maintenance task should be checked; for example, its version and its compatibility with the aircraft configuration.

(d)  What to do in unforeseen cases when only one person is available

REINSPECTION

(1)  Reinspection is subject to the same conditions as the independent inspection is, except that the ‘authorised person’ performing the maintenance task is also acting as ‘independent qualified person’ and performs the inspection.

(2)  For critical maintenance tasks, reinspection should only be used in unforeseen circumstances when only one person is available to carry out the task and perform the independent inspection. The circumstances cannot be considered to be unforeseen if the person or organisation has not assigned a suitable ‘independent qualified person’ to that particular task.

(3)  The CRS is issued by the ‘authorised person’ after the reinspection has been performed satisfactorily.

(4)  The work card system should record the identification of the ‘authorised person’ and the date and the details of the reinspection, as necessary, before the CRS is issued.

CAO.A.065 Aircraft certificate of release to service

Regulation (EU) 2019/1383

At the completion of any aircraft maintenance carried out in accordance with this Annex, an aircraft CRS shall be issued in accordance with point M.A.801 of Annex I (Part-M) or point ML.A.801 of Annex Vb (Part-ML), as applicable.

CAO.A.070 Component certificate of release to service

Regulation (EU) 2019/1383

(a) At the completion of all component maintenance in accordance with this Annex, a component CRS shall be issued in accordance with point M.A.802 of Annex I (Part-M) or point ML.A.802 of Annex Vb (Part-ML), as applicable. An EASA Form 1 shall be issued in accordance with Appendix II to Annex I (Part-M), except as provided for in points (b) or (d) of point M.A.502 of Annex I (Part-M) and point ML.A.502 of Annex Vb (Part-ML) and for components fabricated in accordance with point (c) of point CAO.A.020.

(b) The EASA Form 1 referred to in point (a) may be generated from a computer database.

GM1 CAO.A.070   Component certificate of release to service

ED Decision 2020/002/R

COMPONENTS MAINTAINED BY A CAO

Appendix II to Part-M, point (5), blocks 12 and 14a describe how the component maintenance release is formalised by the CAO on EASA Form 1.

Used components maintained by a CAO appropriately approved for component maintenance and released on an EASA Form 1 cannot be installed on complex motor-powered aircraft or aircraft used by an air carrier licensed in accordance with Regulation (EC) No 1008/2008.

AMC1 CAO.A.070(a)  Component certificate of release to service

ED Decision 2020/002/R

1. An aircraft component which has been maintained off the aircraft requires the issuance of a CRS for such maintenance and another CRS in regard to being installed properly on the aircraft when such installation occurs. When an organisation maintains a component for use by the same organisation, an EASA Form 1 may not be necessary depending upon the organisation’s internal release procedures defined in the CAE.

2. In the case of components in storage prior to Part-145, Part-M and Part 21 and not released on an EASA Form 1 or equivalent in accordance with M.A.501(a)(1) or ML.A.501(a), or removed serviceable from a serviceable aircraft or from an aircraft which has been withdrawn from service, the following applies:

2.1. An EASA Form 1 may be issued for an aircraft component which has been:

               maintained before Part-145 or Part-M became effective, or manufactured before Part 21 became effective;

               used on an aircraft and removed in a serviceable condition. Examples include leased and loaned aircraft components;

               removed from aircraft which have been withdrawn from service, or from aircraft which have been involved in abnormal occurrences such as accidents, incidents, heavy landings or lightning strikes;

               maintained by an unapproved organisation.

2.2. An appropriately rated Part-CAO maintenance organisation may issue an EASA Form 1 as detailed in points 2.5 to 2.9, as appropriate, in accordance with the procedures detailed in the CAE as approved by the competent authority. The appropriately rated Part-CAO maintenance organisation is responsible for ensuring that all reasonable measures have been taken to ensure that only approved and serviceable aircraft components are issued with an EASA Form 1 under this point 2.

2.3. For the purposes of this point 2 only, ‘appropriately rated’ refers to an organisation with an approval class rating for the type of component or for the product in which it may be installed.

2.4. An EASA Form 1 issued in accordance with this point 2 should be issued by signing in block 14b and stating ‘Inspected/Tested’ in block 11. In addition, block 12 should specify:

2.4.1. when the last maintenance was carried out and by whom;

2.4.2. if the component is unused, when the component was manufactured and by whom with a cross reference to any original documentation which should be included in the Form;

2.4.3. a list of all airworthiness directives (ADs), repairs and modifications known to have been incorporated. If no ADs or repairs or modifications are known to be incorporated, then this should be so stated;

2.4.4. the detail of life used for service life-limited parts being any combination of fatigue, overhaul or storage life;

2.4.5. for any aircraft component having its own maintenance history record, reference to the particular maintenance history record as long as the record contains the details that would otherwise be required in block 12. The maintenance history record and acceptance test report or statement, if applicable, should be attached to EASA Form 1.

2.5. New/unused aircraft components

2.5.1. Any unused aircraft component in storage without an EASA Form 1 up to the effective date(s) for Part 21 that was manufactured by an organisation acceptable to the competent authority at the time may be issued with an EASA Form 1 by an appropriately rated maintenance organisation approved under Part-CAO. EASA Form 1 should be issued in accordance with the following points, which should be included in a procedure within the CAE.

Note 1: It should be understood that the release of a stored but unused aircraft component in accordance with this point represents a maintenance release under Part-CAO and not a production release under Part 21. It is not intended to bypass the production release procedure agreed by the Member State for parts and subassemblies intended for fitment on the manufacturers’ own production line.

(a) An acceptance test report or statement should be available for all used and unused aircraft components that are subject to acceptance testing after manufacturing or maintenance as appropriate.

(b) The aircraft component should be inspected for compliance with the manufacturer’s instructions and limitations for storage and condition including any requirement for limited storage life, inhibitors, controlled climate and special storage containers. In addition, or in the absence of specific storage instructions, the aircraft component should be inspected for damage, corrosion and leakage to ensure good condition.

(c) The storage life used of any storage life-limited parts should be established.

2.5.2. If it is not possible to establish satisfactory compliance with all applicable conditions specified in point 2.5.1 (a) to (c) inclusive, the aircraft component should be disassembled by an appropriately rated organisation and subjected to a check for incorporated ADs, repairs and modifications and inspected/tested in accordance with the maintenance data to establish satisfactory condition and, if relevant, all seals, lubricants and life-limited parts replaced. Upon satisfactory completion after reassembly, an EASA Form 1 may be issued stating what was carried out and the reference to the maintenance data included.

2.6. Used aircraft components removed from a serviceable aircraft

2.6.1. Serviceable aircraft components removed from a Member State registered aircraft may be issued with an EASA Form 1 by an appropriately rated organisation subject to compliance with this point 2.6.1.

(a) The organisation should ensure that the component was removed from the aircraft by an appropriately qualified person.

(b) The aircraft component may only be deemed serviceable if the last flight operation with the component fitted revealed no faults on that component or related system.

(c) The aircraft component should be inspected for satisfactory condition including in particular damage, corrosion or leakage and compliance with any additional maintenance data.

(d) The aircraft record should be researched for any unusual events that could affect the serviceability of the aircraft component such as involvement in accidents, incidents, heavy landings or lightning strikes. Under no circumstances may an EASA Form 1 be issued in accordance with this point 2.6 if it is suspected that the aircraft component has been subjected to extremes of stress, temperatures or immersion which could affect its operation.

(e) A maintenance history record should be available for all used serialised aircraft components.

(f) Compliance with known modifications and repairs should be established.

(g) The flight hours/cycles/landings as applicable of any service life-limited parts including time since overhaul should be established.

(h) Compliance with known applicable airworthiness directives should be established.

(i) Subject to satisfactory compliance with this point 2.6.1, an EASA Form 1 may be issued and should contain the information as specified in point 2.4 including the aircraft from which the aircraft component was removed.

2.6.2. Serviceable aircraft components removed from a non-Member State registered aircraft may only be issued with an EASA Form 1 if the components are leased or loaned from the maintenance organisation approved under Part-CAO that retains control of the airworthiness status of the components. An EASA Form 1 may be issued and should contain the information as specified in point 2.4 including the aircraft from which the aircraft component was removed.

2.7. Used aircraft components removed from an aircraft withdrawn from service

Serviceable aircraft components removed from a Member State registered aircraft withdrawn from service may be issued with an EASA Form 1 by a maintenance organisation approved under Part-CAO subject to compliance with this point 2.7.

(a) Aircraft withdrawn from service are sometimes dismantled for spares. This is considered to be a maintenance activity and should be accomplished under the control of an organisation approved under Part-CAO, employing procedures approved by the competent authority.

(b) To be eligible for installation, components removed from such aircraft may be issued with an EASA Form 1 by an appropriately rated organisation following a satisfactory assessment.

(c) As a minimum, the assessment will need to satisfy the standards set out in points 2.5 and 2.6 as appropriate. This should, where known, include the possible need for the alignment of scheduled maintenance that may be necessary to comply with the maintenance programme applicable to the aircraft on which the component is to be installed.

(d) Irrespective of whether the aircraft holds a certificate of airworthiness or not, the organisation responsible for certifying any removed component should ensure that the manner in which the components were removed and stored are compatible with the standards required by Part-CAO.

(e) A structured plan should be formulated to control the aircraft disassembly process. The disassembly is to be carried out by an appropriately rated organisation under the supervision of certifying staff, who will ensure that the aircraft components are removed and documented in a structured manner in accordance with the appropriate maintenance data and disassembly plan.

(f) All recorded aircraft defects should be reviewed and the possible effects these may have on both normal and standby functions of removed components are to be considered.

(g) Dedicated control documentation is to be used as detailed by the disassembly plan, to facilitate the recording of all maintenance actions and component removals performed during the disassembly process. Components found to be unserviceable are to be identified as such and quarantined pending a decision on the actions to be taken. Records of the maintenance accomplished to establish serviceability are to form part of the component maintenance history.

(h) Suitable Part-CAO facilities for the removal and storage of removed components are to be used which include suitable environmental conditions, lighting, access equipment, aircraft tooling and storage facilities for the work to be undertaken. While it may be acceptable for components to be removed, given local environmental conditions, without the benefit of an enclosed facility, subsequent disassembly (if required) and storage of the components should be in accordance with the manufacturer’s recommendations.

2.8. Used aircraft components maintained by organisations not approved in accordance with Part-M Subpart F, Part-CAO or Part-145

For used components maintained by a maintenance organisation not approved under Part-M Subpart F, Part-CAO or Part-145, due care should be taken before acceptance of such components. In such cases, an appropriately rated maintenance organisation approved under Part-CAO should establish satisfactory conditions by:

(a) dismantling the component for sufficient inspection in accordance with the appropriate maintenance data;

(b) replacing all service life-limited components when no satisfactory evidence of life used is available and/or the components are in an unsatisfactory condition;

(c) reassembling and testing as necessary the component; and

(d) completing all certification requirements as specified in CAO.A.070.

In the case of used components maintained by an FAA Part-145 repair station (USA) or by a TCCA CAR573 approved maintenance organisation (Canada) that does not hold an EASA Part-145, Part-CAO or Part-M Subpart F approval, the conditions (a) through (d) described above may be replaced by the following conditions:

(a) availability of a Form 8130-3 (FAA) or TCCA 24-0078 (TCCA) or an Authorized Release Certificate Form One (TCCA);

(b) verification of compliance with all applicable airworthiness directives;

(c) verification that the component does not contain repairs or modifications that have not been approved in accordance with Part 21;

(d) inspection for satisfactory condition including in particular damage, corrosion or leakage; and

(e) issuance of an EASA Form 1 in compliance with points 2.2, 2.3 and 2.4.

These alleviated requirements are based on the fact that credit can be taken for their technical capabilities and their competent authority oversight, as attested by the following documents:

               Maintenance Annex Guidance (MAG) between the FAA and EASA

               Maintenance Annex Guidance (MAG) between the TCCA and EASA

2.9. Used aircraft components removed from an aircraft involved in an accident or incident

Such components should only be issued with an EASA Form 1 when processed in accordance with point 2.7 and a specific work order including all additional necessary tests and inspections made necessary by the accident or incident. Such a work order may require input from the TC holder or original manufacturer as appropriate. This work order should be referenced in block 12.

3. A certificate should not be issued for any component when it is known that the component is unserviceable except in the case of a component undergoing a series of maintenance processes at several approved maintenance organisations and the component needs a certificate for the previous maintenance process carried out for the next approved maintenance organisation to accept the component for subsequent maintenance processes. In such a case, a clear statement of limitation should be endorsed in block 12.

4. The certificate is to be used for export/import purposes, as well as for domestic purposes, and serves as an official certificate for components from the manufacturer/maintenance organisation to users. It should only be issued by organisations approved by a competent authority or the Agency as applicable within the scope of the approval.

CAO.A.075 Continuing-airworthiness management

Regulation (EU) 2019/1383

(a) All continuing airworthiness management shall be carried out in accordance with the requirements of Subpart C of Annex I (Part-M) or Subpart C of Annex Vb (Part-ML), as applicable.

(b) For every aircraft managed, the CAO shall:

(1) develop and control the AMP for the aircraft managed and:

(i) in the case of aircraft complying with Annex Vb (Part-ML), approve the AMP and its amendments, or

(ii) in the case of aircraft complying with Annex I (Part-M), present the AMP and its amendments to the competent authority for approval, unless the approval is covered by an indirect approval procedure in accordance with point (c) of point M.A.302 of Annex I (Part-M);

(2) provide a copy of the AMP to the owner;

(3) ensure that data used for any modification and repairs complies with points  M.A.304 or ML.A.304, as applicable;

(4) ensure that all maintenance is performed in accordance with the AMP and released in accordance with Section A, Subpart H of Annex I (Part-M), Section A of Annex II (Part-145) or Section A, Subpart H of Annex Vb (Part-ML), as applicable;

(5) ensure that all applicable ADs and all operational directives with a continuing airworthiness impact are implemented;

(6) ensure that all defects discovered during maintenance or reported are corrected by an appropriately approved maintenance organisation or by independent certifying staff;

(7) ensure that the aircraft is brought for maintenance to an appropriately approved organisation or to independent certifying staff, whenever necessary;

(8) coordinate the scheduled maintenance, application of ADs, replacement of service-life-limited parts and component inspection in order to ensure the work is carried out properly;

(9) manage and archive all continuing-airworthiness records and, if applicable, the aircraft technical log;

(10) ensure that the mass-and-balance statement reflects the current status of the aircraft.

AMC1 CAO.A.075  Continuing airworthiness management

ED Decision 2020/002/R

(a) The CAO holding the CAO.A.095(b) privilege is in charge of the continuing airworthiness management and this includes the tasks specified respectively in M.A.301 points (b), (c), (f), (g) and (h), and ML.A.301 points (b), (c), (d) and (e).

(b) If the CAO does not hold the appropriate maintenance privilege, then the CAO should conclude a contract with the appropriate maintenance organisation(s) in agreement with the owner/operator.

(c) The CAO bears the responsibility for the airworthy condition of the aircraft for which it performs the continuing airworthiness management. Thus, it should be satisfied before the intended flight that all required maintenance has been properly carried out.

(d) The fact that the CAO has contracted a maintenance organisation should not prevent it from checking at the maintenance facilities on any aspect of the contracted work to fulfil its responsibility for the airworthiness of the aircraft.

(e) The contract between the CAO and the maintenance organisation(s) should specify in detail the responsibilities and the work to be performed by each party.

CAO.A.080 Continuing airworthiness management data

Regulation (EU) 2020/270

The CAO shall hold and use applicable current maintenance data specified in point M.A.401 of Annex I (Part-M) or point ML.A.401 of Annex Vb (Part-ML), as applicable, for the performance of the continuing airworthiness management tasks referred to in point CAO.A.075 of this Annex (Part-CAO). That data may be provided by the owner, subject to a contract as referred in points M.A.201(h)(2) or M.A.201(i)(1) or M.A.201(i)(3) of Annex I (Part-M), or points ML.A.201(e)(1) or ML.A.201(f) of Annex Vb (Part-ML), in which case the CAO only needs to hold such data for the duration of the contract, unless where it is to retain the data pursuant to point CAO.A.090(b) of this Annex (Part-CAO).

AMC1 CAO.A.080   Continuing airworthiness management data

ED Decision 2020/002/R

When there is no contract yet for continuing airworthiness management, there is no need to hold the current continuing airworthiness management data.

CAO.A.085 Airworthiness review

Regulation (EU) 2020/270

The CAO shall perform any airworthiness reviews in accordance with point M.A.901 of Annex I (Part-M) or point ML.A.903 of Annex Vb (Part-ML), as applicable.

CAO.A.090 Record-keeping

Regulation (EU) 2019/1383

(a) The CAO shall retain the following records:

(1) the maintenance records necessary to demonstrate that all requirements of this Annex have been met for the issuance of the CRS, including the subcontractor’s release documents; the CAO shall provide a copy of each CRS to the owner of the aircraft, together with a copy of any specific repair or modification data used for the repairs or modifications carried out;

(2) the continuing airworthiness management records required by any of the following:

(i) point M.A.305 and, if applicable, point M.A.306 of Annex I (Part-M);

(ii) point ML.A.305 of Annex Vb (Part-ML);

(3) where the CAO has the privilege referred to in point (c) of point CAO.A.095, it shall retain a copy of each airworthiness review certificate (ARC) issued in accordance with point (a) of point ML.A.901 of Annex Vb (Part-ML) and recommendation issued or, as applicable, extended, together with all supporting documents;

(4) where the CAO has the privilege referred to in point (d) of point CAO.A.095, it shall retain a copy of each permit to fly issued in accordance with point 21.A.729 of Annex I (Part-21) to Regulation (EU) No 748/2012.

(b) The CAO shall retain a copy of the records described in point (a)(1), and any associated maintenance data, for a period of 3 years from the date at which it released to service the aircraft or aircraft component to which the work relates.

(c) The CAO shall retain a copy of the records referred to in points (a)(2) to (a)(4) for a period of 2 years from the date at which the aircraft has been permanently withdrawn from service.

(d) All records shall be stored in a manner that ensures protection from damage, alteration and theft.

(e) All computer hardware used for backup of the maintenance records shall be stored in a different location from that containing those data and in an environment that ensures that they remain in good condition.

(f) Where the continuing airworthiness management of an aircraft is transferred to another organisation or person, all the records retained under points (a)(2) to (a)(4) shall be transferred to that organisation or person. From the moment of the transfer, points (b) and (c) shall apply to that organisation or person.

(g) Where the CAO terminates its operation, all retained records shall be transferred as follows:

(1) the records referred to in point (a)(1) shall be transferred to the last owner or customer of the respective aircraft or component or shall be stored as specified by the competent authority;

(2) the records referred to in point (a)(2) to (a)(4) shall be transferred to the owner of the aircraft.

CAO.A.095 Privileges of the organisation

Regulation (EU) 2020/270

The CAO shall have the following privileges:

(a) Maintenance

(1) Maintain any aircraft or component for which it is approved at the locations specified in the approval certificate and the CAE.

(2) Arrange for the performance of specialised services at another organisation appropriately qualified under the control of the CAO, in accordance with the appropriate procedures set out in the CAE and approved by the competent authority.

(3) Maintain any aircraft or component for which it is approved at any location, where the need of such maintenance arises either from the unserviceability of the aircraft or the need for supporting occasional maintenance, in accordance with the conditions specified in the CAE.

(4) Issue certificates of release to service upon completion of maintenance, in accordance with point CAO.A.065 or CAO.A.070.

(b) Continuing airworthiness management

(1) Manage the continuing airworthiness of any aircraft for which it is approved.

(2) Approve the AMP, in accordance with point (b)(2) of point ML.A.302, for aircraft managed in accordance with Annex Vb (Part-ML).

(3) Carry out limited continuing airworthiness tasks with any contracted organisation working under their quality system, as listed on the approval certificate.

(4) Extend, in accordance with point M.A.901(f) of Annex I (Part-M) or point ML.A.901(c) of Annex Vb (Part-ML), an ARC that has been issued by the competent authority, another organisation or person as applicable.

(c) Airworthiness review:

(1) A CAO with its principal place of business in one of the Member States, the approval of which includes the privileges referred to in point (b), may be approved to carry out airworthiness reviews in accordance with point M.A.901 of Annex I (Part-M) or point ML.A.903 of Annex Vb (Part-ML), as applicable, and:

(i) issue the related ARC or recommendation for the issuance of the ARC;

(ii) extend the validity of an existing ARC.

(2) A CAO with its principal place of business in one of the Member States, the approval of which includes the privileges referred to in point (a), may be approved to carry out airworthiness reviews in accordance with point ML.A.903 of Annex Vb (Part-ML) and issue the related ARC.

(d) Permit to fly

A CAO with its principal place of business in one of the Member States, the approval of which includes the privileges referred to in point (c), may be approved to issue a permit to fly in accordance with point (d) of point 21.A.711 of Annex I (Part-21) to Regulation (EU) No 748/2012 for those aircraft for which it can issue the ARC when it attests conformity with the approved flight conditions, in accordance with an adequate procedure provided for in the CAE.

(e) A CAO may be approved for one or more privileges.

GM1 CAO.A.095   Privileges of the organisation

ED Decision 2020/002/R

A CAO can be approved to perform airworthiness reviews although it does not hold the privileges of continuing airworthiness management (for aircraft to which Part-ML is applicable). This means that the certificate will show the boxes ‘maintenance’ and ‘airworthiness reviews’ ticked.

AMC1 CAO.A.095(b)(3)  Privileges of the organisation

ED Decision 2020/009/R

SUBCONTRACTING OF CONTINUING AIRWORTHINESS TASKS

(a) The CAO may subcontract certain continuing airworthiness management tasks to qualified organisations. The subcontracted organisation performs the continuing airworthiness management tasks as an integral part of the CAO quality system, irrespective of any other approval held by the subcontracted organisation (including CAMO, CAO or Part-145 approval).

(b) The CAO remains accountable for the satisfactory completion of the continuing airworthiness management tasks irrespective of any contract that may be established.

(c) In order to fulfil this responsibility, the CAO should be satisfied that the actions taken by the subcontracted organisation meet the standards required by Part-CAO. Therefore, the CAO management of such activities should be accomplished by:

(1) active control through direct involvement; and/or

(2) endorsing the recommendations made by the subcontracted organisation.

(d) In order to retain ultimate responsibility, the CAO should limit subcontracted tasks to the activities specified below:

(1) airworthiness directive analysis and planning;

(2) service bulletin analysis;

(3) planning of maintenance;

(4) reliability monitoring, engine health monitoring;

(5) maintenance programme development and amendments; and

(6) any other activities, which do not limit the CAO responsibilities, as agreed by the competent authority.

(e) The CAO’s controls associated with subcontracted continuing airworthiness management tasks should be reflected in the associated contract and be in accordance with the CAO policy and procedures defined in the CAE. When such tasks are subcontracted, the quality system is considered to be extended to the subcontracted organisations.

(f) With the exception of engines and auxiliary power units, contracts would normally be limited to one organisation per aircraft type for any combination of the subcontracted activities. Where contracts are made with more than one organisation, the CAO should demonstrate that adequate coordination controls are in place and that the individuals’ responsibilities are clearly defined in the related contracts.

(g) Contracts should not authorise the subcontracted organisation to subcontract elements of the continuing airworthiness management tasks to other organisations.

(h) The competent authority should exercise oversight of the subcontracted activities through the CAO approval. The contracts should be acceptable to the competent authority. The CAO should only subcontract to organisations which are specified by the competent authority on EASA Form 3-CAO (page 2, block titled ‘List of organisation(s) working under a quality system’).

(i) The subcontracted organisation should agree to notify the CAO of any changes affecting the contract as soon as practical. The CAO should then inform its competent authority. Failure to do so may invalidate the competent authority’s acceptance of the contract.

(j) Appendix II to AMC1 CAMO.A.125(d)(3) provides information on the subcontracting of continuing airworthiness management tasks by the CAMO. The same principles may be applied to the CAO.

CAO.A.100 Quality system and organisational review

Regulation (EU) 2019/1383

(a) To ensure that the CAO continues to meet the requirements of this Annex, this organisation shall establish a quality system and designate a quality manager.

(b) The quality system shall monitor the carrying out of the activities of the organisation covered by this Annex. It shall monitor in particular:

(1) that all those activities are performed in accordance with the approved procedures;

(2) that all contracted maintenance tasks are carried out in accordance with the contract;

(3) that the organisation continues to comply with the requirements of this Annex.

(c) The records of that monitoring shall be retained for at least the previous 2 years.

(d) Where the organisation holding a CAO approval is additionally approved in accordance with an Annex other than this Annex, the quality system may be combined with that required by the other Annex.

(e) A CAO shall be considered as a small CAO when one of the following condition is met:

(1) the scope of the CAO does only contain aircraft covered by Part-ML.

(2) the CAO does not exceed 10 full-time equivalent staff involved in maintenance.

(3) the CAO does not exceed 5 full-time equivalent staff involved in continuing airworthiness management.

(f) In the case of a small CAO, the quality system may be replaced by regular organisational reviews, subject to the approval of the competent authority. In that case, the CAO shall not contract continuing airworthiness management tasks to other parties.

GM1 CAO.A.100(a)   Quality system and organisational review

ED Decision 2020/002/R

QUALITY SYSTEM — GENERAL

(a) The primary objectives of the quality system are to provide an independent monitoring function on how the organisation ensures compliance with the applicable requirements, policies and procedures, and to request actions where non-compliances are identified.

(b) The independence of the quality system is established by always ensuring that audits are carried out by personnel who are not responsible for the functions, procedures or products that are audited.

AMC1 CAO.A.100(a)  Quality system and organisational review

ED Decision 2020/002/R

QUALITY SYSTEM — FEEDBACK

(a) The quality system should include a feedback system: it should ensure that all findings resulting from the independent audits are properly investigated and corrected in a timely manner. It should address who is required to rectify each non-compliance and the procedure to be followed if rectification is not completed within appropriate timescales. The procedure should enable the accountable manager to be kept informed of any safety issues and the extent of compliance with Part-CAO.

(b) The audit reports referenced in AMC1 CAO.A.100(b) should be sent to the relevant department for rectification action giving target rectification dates. Rectification dates should be discussed with such department before the quality department or nominated auditor confirms such dates in the report. The relevant department is required to rectify findings and inform the quality manager or the auditor of such rectification.

(c) The accountable manager should hold regular meetings with staff to check the progress of any corrective actions. If these meetings are delegated to the quality manager on a day-to-day basis, then the accountable manager should:

(1) meet the senior staff involved at least twice per year to review the overall performance of the compliance monitoring function; and

(2) receive at least a half-yearly summary report on non-compliance findings.

AMC1 CAO.A.100(b)   Quality system and organisational review

ED Decision 2020/002/R

QUALITY SYSTEM — INDEPENDENT AUDIT

(a) An essential element of the quality system is the independent audit.

(b) The independent audit should be an objective process of routine sample checks of all aspects of the organisation’s ability to carry out continuing airworthiness management and/or maintenance to the standards required by Regulation (EU) No 1321/2014. It should include some product sampling (e.g. product audit) as this is the end result of the process.

(c) The independent audit should provide an objective overview of the complete set of continuing-airworthiness-management- and/or maintenance-related activities.

(d) The organisation should establish an audit plan to show when and how often the activities as required by Part-M, Part-ML and Part-CAO will be audited.

(e) The audit plan should ensure that all aspects of Part-CAO compliance are verified every year, including all the subcontracted activities, and the auditing may be carried out as a complete single exercise or (sub)divided over the annual period. The independent audit should not require each procedure to be verified against each product line when it can be shown that the particular procedure is common to more than one product line and the procedure has been verified every year without resultant findings. Where findings have been identified, the particular procedure should be verified against other product lines until the findings have been rectified, after which the independent audit procedure may revert to a 1-year interval for the particular procedure.

(f) Provided that there are no safety-related findings, the audit planning cycle specified in this AMC may be increased by up to 100 %, subject to agreement by the competent authority.

(g) Where the organisation has more than one location approved, the quality system should include a description of how these locations are integrated into the system, and include a plan to audit each location at a frequency consistent with the extent of activity at the particular location, not exceeding 2 years.

(h) A report should be issued each time an audit is carried out describing what was checked and the resulting non-compliance findings against applicable requirements and procedures.

GM1 CAO.A.100(b) and CAO.B.055 Quality system and organisational review and Continuing oversight

ED Decision 2022/011/R

THE USE OF INFORMATION AND COMMUNICATION TECHNOLOGIES (ICT) FOR PERFORMING REMOTE AUDITS

Similar provisions to those in GM1 145.A.200(a)(6) and 145.B.300 apply.

GM1 CAO.A.100(e)   Quality system and organisational review

ED Decision 2020/002/R

An organisation that holds both maintenance and continuing airworthiness management privileges can be considered to be at the same time:

               a small CAO for one privilege; and

               not a small CAO for the other privilege.

In these situations, the organisation is not considered to be a small CAO as a whole.

AMC1 CAO.A.100(f)  Quality system and organisational review

ED Decision 2020/002/R

ORGANISATIONAL REVIEW

(a) The primary objectives of organisational review are to provide a monitoring function on how the organisation ensures compliance with the applicable requirements, policies and procedures, and to request actions where non-compliances are identified.

(b) The CAO should identify the:

(1)  person responsible for the organisational review;

(2)  frequency of the reviews;

(3)  scope and content of the reviews;

(4) persons accomplishing the reviews;

(5) procedure for planning, performing and processing review findings; and

(6) procedure for ensuring corrective actions are carried out in the appropriate time frame.

(c) Appendix II to AMC1 CAO.A.100(f) should be used to manage the organisational reviews.

(d) The following continuing airworthiness management activities should not be considered to be subcontracting and, as a consequence, they may be performed without a quality system, although they need to be described in the CAE and be approved by the competent authority:

(1) Subscription to a technical publisher that provides maintenance data (aircraft maintenance manuals, illustrated parts catalogues, service bulletins, etc.).

(2) Contracting the use of a software tool for the management of CAO.A.080 continuing airworthiness data and CAO.A.090 records, provided that:

(i) if the tool is used by several organisations, each organisation has access to its own data only;

(ii) introduction of data can only be performed by personnel of the CAO; and

(iii) the data can be retrieved at any time.

CAO.A.105 Changes to the organisation

Regulation (EU) 2021/700

(a) In order to enable the competent authority to determine continued compliance with this Annex, the CAO shall notify the competent authority of any proposal to carry out any of the following changes, before such changes take place:

(1) changes affecting the information contained in the approval certificate laid down in Appendix I and the terms of approval of this Annex;

(2) changes of the persons referred to in points CAO.A.035(a) and (b);

(3) changes in the aircraft types covered by the scope of work referred to in point (a)(1) of point CAO.A.020 in the case of aeroplanes of more than 2 730 kg maximum take-off mass (MTOM) and in the case of helicopters of more than 1 200 kg MTOM or certified for more than 4 occupants;

(4) changes in the scope of work referred to in point (a)(2) of CAO.A.020 in the case of complete turbine engines;

(5) changes in the control procedure set out in point (b) of this point.

(b) Any other changes in locations, facilities, equipment, tools, material, procedures, scope of work and staff shall be controlled by the CAO through a control procedure provided for in the CAE. The CAO shall submit a description of those changes and the corresponding CAE amendments to the competent authority within 15 days from the day on which the change took place.

CAO.A.110 Continued validity

Regulation (EU) 2019/1383

(a) An approval shall be issued for an unlimited duration and shall remain valid subject to:

(1) the organisation remaining in compliance with the requirements of this Annex, in particular how the findings are handled in accordance with point CAO.A.115;

(2) the competent authority being granted access to the organisation to determine continued compliance with the requirements of this Annex;

(3) the competent authority not having surrendered or revoked the approval.

(b) Upon surrender or revocation of the approval, the organisation shall return the approval certificate to the competent authority.

CAO.A.115 Findings

Regulation (EU) 2019/1383

(a) A Level 1 finding is any significant non-compliance with Part-CAO requirements which lowers the safety standard and seriously hazards flight safety.

(b) A Level 2 finding is any non-compliance with the Part-CAO requirements which may lower the safety standard and possibly hazard flight safety.

(c) After receiving a notification of a finding in accordance with point CAO.B.060, the CAO shall adopt a corrective action plan and demonstrate to the satisfaction of the competent authority that it has taken the necessary corrective action to address the finding within the time period set by that authority.