Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014)

ED Decision 2020/002/R

SUBCONTRACTED ACTIVITIES

(a)If a CAO subcontracts continuing airworthiness management tasks, all subcontracted organisations should also be audited by the competent authority at periods not exceeding 24 months to ensure that the subcontracted continuing airworthiness management tasks are carried out in compliance with Part-CAO, Part-M and Part-ML, as applicable.

(b)If a CAO subcontracts specialised maintenance tasks, the competent authority should determine whether the subcontracted organisation needs to be audited and included in the oversight programme, taking into account the specific nature and complexity of the subcontracted activities and the results of previous oversight activities of the CAO. Consideration may also be given to subcontracted organisation holding an organisation approval or a certification to an industry standard.

(c)For these audits, the competent authority inspector should ensure that he or she is accompanied throughout the audit by a senior technical member of the CAO.

NOTE: When a CAO subcontracts tasks, the competent authority should also ensure that the CAO has sufficient control over the subcontracted organisation.

Regulation (EU) 2019/1383

(a)When during audits or by any other means, evidence is found showing non-compliance to the Part-CAO requirements, the competent authority shall take the following actions:

(1)for Level 1 findings, immediate action shall be taken by the competent authority to revoke, limit or suspend in whole or in part, depending upon the extent of the Level 1 finding, the CAO approval, until successful corrective action has been taken by the organisation; and

(2)for Level 2 findings, the competent authority shall grant a corrective action period of no more than 3 months, appropriate to the nature of the finding — in certain circumstances, at the end of this first period and subject to the nature of the finding, the competent authority can extend this 3-month period subject to a satisfactory corrective action plan.

(b)Action shall be taken by the competent authority to suspend in whole or in part the approval in case of failure to comply within the timescale set out by the competent authority.

ED Decision 2020/002/R

LEVEL 1 FINDINGS

Where a level 1 finding directly relates to an aircraft, the competent authority should inform the State in which the aircraft is registered.

For a level 1 finding related to maintenance, it may be necessary for the competent authority to ensure that further maintenance and re-certification of all affected products is accomplished, dependent upon the nature of the finding.

CAO.B.065 Changes

Regulation (EU) 2019/1383

(a)Upon receiving an application for a change in accordance with point (a) of point CAO.A.105, the competent authority shall verify the organisation’s compliance with the applicable requirements before issuing the approval of the change.

(b)The competent authority may indicate the conditions under which the CAO shall operate during the change unless the competent authority determines that the organisation’s certificate shall be suspended because of the nature or extent of the changes.

(c)For changes not requiring prior approval, the competent authority shall assess during the oversight activities that the CAO complies with the approved control procedure provided for in point (b) of point CAO.A.105 and complies with the applicable requirements.

Regulation (EU) 2019/1383

The competent authority shall:

(a)suspend an approval on reasonable grounds in the case of a potential safety threat; or

(b)suspend, revoke or limit an approval pursuant to point CAO.B.060.

APPENDICES TO ANNEX Vd (Part-CAO)

Regulation (EU) 2020/270

(a)Within the approval class(es) and rating(s) established by the competent authority, the scope of work specified in the CAE defines the exact limits of approval. It is therefore essential that the approval class(es) and rating(s) and the organisations scope of work are matching.

(b)An aircraft rating, in relation to the maintenance privileges, means that the CAO may carry out maintenance on the aircraft and any component (including engines), in accordance with aircraft maintenance data or, if agreed by the competent authority, in accordance with component maintenance data, only whilst such components are fitted to the aircraft. Nevertheless, such aircraft-rated CAO may temporarily remove a component for maintenance in order to improve access to that component except when such removal creates the need for additional maintenance not eligible for the requirements of point (b). This will be subject to a control procedure in the CAE to be approved by the competent authority.

(c)An engine rating (turbine, piston or electrical) means that the CAO may carry out maintenance on the uninstalled engine and engine components, in accordance with engine maintenance data or, if agreed by the competent authority, in accordance with component maintenance data, only whilst such components are fitted to the engine. Nevertheless, such engine-rated CAO may temporarily remove a component for maintenance in order to improve access to that component except when such removal creates the need for additional maintenance not eligible for the requirements of point (c). An engine-rated CAO may also carry out maintenance on an installed engine during base and line maintenance subject to a control procedure in the CAE to be approved by the competent authority.

(d)A component rating (other-than-complete engines) means that the CAO may carry out maintenance on uninstalled components (excluding complete engines) intended for fitment to the aircraft or engine. This CAO may also carry out maintenance on an installed component (other-than-complete engines) during base and line maintenance or at an engine maintenance facility subject to a control procedure in the CAE to be approved by the competent authority.

(e)An non-destructive testing (NDT) rating is a self-contained rating not necessarily related to a specific aircraft, engine or other component. The NDT rating is only necessary for a CAO that carries out NDT as a particular task for another organisation. A CAO approved with an aircraft, engine or component rating may carry out NDT on products they are maintaining subject to the CAE containing NDT procedures, without the need for an NDT rating.

(*)or EASA if EASA is the competent authority

(**)delete for non-EU Member States or EASA.

EASA Form 3-CAO, Issue 1

(*)or EASA if EASA is the competent authority

(**)delete as appropriate if the organisation is not approved.

(***)complete as appropriate

EASA Form 3-CAO, Issue 1

APPENDICES TO AMC AND GM TO ANNEX Vd (Part-CAO)

ED Decision 2021/009/R

ED Decision 2023/013/R

Depending on the complexity of the small organisation (number and type of aircraft, number of different fleets, privilege to perform airworthiness reviews, etc.), the organisational review system may vary from a system using the principles and practices of a quality system (except for the requirement of independence) to a simplified system adapted to the low complexity of the organisation and the aircraft managed.

As a core minimum, the organisational review system should have the following features, which should be described in the CAE:

(a)Identification of the person responsible for the organisational review programme

By default, this person should be the accountable manager, unless he or she delegates this responsibility to (one of) the CAO.A.035(b) person(s).

(b)Identification and qualification criteria for the person(s) responsible for performing the organisational reviews

These persons should have a thorough knowledge of the regulations and of the organisation procedures. They should also have knowledge of audits, acquired through training or through experience (preferably as an auditor, but also possibly because they actively participated in several audits conducted by the competent authority).

(c)Elaboration of the organisational review programme

(1)Checklist(s) covering all items necessary to be satisfied that the organisation delivers a safe product and complies with the regulation. All procedures described in the CAE should be addressed.

(2)A schedule for the accomplishment of the checklist items. Each item should be checked at least every 12 months. The organisation may choose to conduct one full review annually or to conduct several partial reviews.

(d)Performance of organisational reviews

Each checklist item should be answered using an appropriate combination of:

review of records, documentation, etc.;

sample check of aircraft under contract or being maintained under a work order;

interview of personnel involved;

review of discrepancies and internal reports (e.g. notified difficulties when using current procedures and tools, systematic deviations from procedures, etc.);

review of complaints filed by customers.

(e)Management of findings and occurrence reports

All findings should be recorded and notified to the affected persons.

(1)All findings that lower the safety standard and seriously hazard flight safety should be immediately notified to the competent authority and all necessary actions on aircraft in service should be immediately taken.

(2)All occurrence reports should be reviewed with the aim of continuous improvement of the system by identifying possible corrective and preventive actions. This should be done in order to find prior indicators (e.g. notified difficulties when using current procedures and tools, systematic deviations from procedures, unsafe behaviours, etc.), and dismissed alerts that, had they been recognised and appropriately managed before the event, could have resulted in the undesired event being prevented.

(3)Corrective and preventive actions should be approved by the person responsible for the organisational review programme and implemented within a specified time frame.

(4)Once the person responsible for the organisational review programme is satisfied that the corrective action is effective, the closure of the finding should be recorded along with a summary of the corrective action.

(5)The accountable manager should be notified of all significant findings and, on a regular basis, of the global results of the organisational review programme.

Below is a typical example of a simplified organisational review checklist, to be adapted as necessary to cover the CAE procedures used and the privileges held by the organisation:

1.Scope of work

Check that all aircraft under contract are covered in EASA Form 3-CAO.

Check that the scope of work in the CAE is consistent with EASA Form 3-CAO.

Check that no work has been performed outside the scope of EASA Form 3-CAO and the CAE.

Is it justified to retain in the approved scope of work aircraft types for which the organisation has no longer aircraft under contract?

2.Maintenance data

Check that the maintenance data is present and up to date for the ongoing maintenance activity.

Check that no change has been made to the maintenance data from the design approval holder (DAH) or the declarant of a declaration of design compliance without the DAH or declarant being notified.

3.Equipment and tools

Check the availability of maintenance equipment and tools against the lists in the CAE and check if they are still appropriate with regard to the maintenance data.

Check tools for proper calibration (sample check).

4.Stores

Do the stores meet the criteria of the CAE procedures?

Check by sampling some items in the store for presence of proper documentation and any overdue items.

5.Certification of maintenance

Has maintenance on products and components been properly certified?

Have implementations of modifications/repairs been carried out with appropriate approval of such modifications/repairs (sample check)?

6.Maintenance contracted

Sample check of maintenance records:

Existence and adequacy of the work order;

Data received from the maintenance organisation:

•valid CRS including any deferred maintenance;

•list of removed and installed components and copy of the associated EASA Form 1 or equivalent.

Obtain a copy of the current approval certificate (EASA Form 3) of the maintenance organisations contracted.

7.Maintenance subcontracted

Check that subcontractors for specialised services are properly controlled by the organisation.

8.Relations with the owners/operators — maintenance

Has maintenance been carried out with suitable work orders?

When a maintenance contract has been signed with an owner/operator, have the obligations of the contracts been respected by both parties?

9.Relations with the owners/operators — continuing airworthiness management

Has a contract (in accordance with Appendix I to Part-M or Appendix I to Part-ML) been signed with each external owner/operator, covering all the aircraft whose airworthiness is managed by the CAO?

Have the owners/operators under contract fulfilled their obligations identified in the contract? As appropriate:

•Are the pre-flight checks correctly performed? (interview of pilots)

•Is the technical log or equivalent correctly used (record of flight hours/cycles, defects reported by the pilot, identification of what maintenance is next due, etc.)?

•Have flights occurred with overdue maintenance or with defects not properly rectified or deferred? (sample check from the aircraft records)

•Has maintenance been performed without notifying the CAO (sample check from the aircraft records, interview of the owner/operator)?

10.Maintenance records

Have the maintenance actions been properly recorded?

Perform a sample check of maintenance records (including EASA Form 1 or equivalent, and certificates of conformity) to ensure completeness and storage during the appropriate periods.

11.Continuing airworthiness records

Perform a sample check of continuing airworthiness records to ensure completeness and storage during the appropriate periods.

Is storage of computerised data properly ensured?

12.Airworthiness review and permit to fly records

Perform a sample check of airworthiness review and permit to fly records to ensure completeness and storage during the appropriate periods.

13.Airworthiness situation of the fleet

Does the continuing airworthiness status (AD, maintenance programme, life-limited components, deferred maintenance, ARC validity) show any expired items? If so, are the aircraft grounded?

14.Aircraft maintenance programme (AMP) development and control

For Part-ML aircraft, ensure that the AMP has been approved by the CAO and has been subject to annual review.

For Part-M aircraft, check that all revisions to the DAH or the declarant of a declaration of design compliance instructions for continuing airworthiness (ICA), since the last review, have been (or are planned to be) incorporated in the maintenance programme, unless otherwise approved by the competent authority.

Has the maintenance programme taken into account all modifications or repairs?

Have all maintenance programme amendments been approved at the right level (CAO, competent authority or indirect approval)?

Does the status of compliance with the maintenance programme reflect the latest approved maintenance programme?

How has the organisation managed:

•the tolerances (variations) to the AMP intervals?

•the deviations from the maintenance tasks to be performed in accordance with the AMP?

Have the deviations from the DAH or the declarant of a declaration of design compliance ICA in the development of the AMP been properly justified and recorded?

15.ADs (and other safety measures mandated by the competent authority or EASA)

Have all ADs issued since the last review been incorporated into the AD status?

Does the AD status correctly reflect the AD content: applicability, compliance date, periodicity, etc.? (sample check on ADs)

16.Modifications/repairs

Are all modifications/repairs listed in the corresponding status approved in accordance with M.A.304 or ML.A.304? (sample check on modifications/repairs)

Have all the modifications/repairs which have been installed since the last review been incorporated in the corresponding status? (sample check from the aircraft/component logbooks or equivalent)

17.Personnel

Check that the current accountable manager and other nominated persons are correctly identified in the approved CAE.

If the number of personnel has decreased or if the activity has increased, check that the organisation has still sufficient and adequate staff.

Check that the qualification of all new personnel (or personnel with new functions) has been appropriately assessed.

Check that the staff has been trained, as necessary, to cover changes in:

•regulations;

•competent authority publications;

•the CAE and associated procedures;

•the approved scope of work;

•maintenance data (significant ADs, ICA amendments, etc.).

18.Occurrence reporting procedures

Check that reporting is properly performed, actions taken and recorded.

19.Airworthiness review and permit to fly procedures

Have airworthiness reviews been properly performed and the airworthiness review certificate or recommendation been properly issued?

Have permits to fly been properly issued and the approved flight condition been complied with?

ED Decision 2020/002/R

The provisions of Appendix IX to AMC M.A.602 and AMC M.A.702 EASA Form 2 apply.