M.A.704 Continuing airworthiness management exposition
Regulation (EU) 2020/270
(a) The continuing airworthiness management organisation shall provide a continuing airworthiness management exposition containing the following information:
1. a statement signed by the accountable manager confirming that the organisation will at all times work in accordance with this Annex (Part-M) and Annex Vb (Part-ML), as applicable;
2. the organisation's scope of work, and;
3. the title(s) and name(s) of person(s) referred to in points M.A.706(a), M.A.706(c), M.A.706(d) and M.A.706(i), and;
4. an organisation chart showing associated chains of responsibility between all the person(s) referred to in points M.A.706(a), M.A.706(c), M.A.706(d) and M.A.706(i), and;
5. a list of the airworthiness staff referred to in point M.A.707, specifying, where applicable, the staff authorised to issue permits to fly in accordance with point M.A.711(c), and;
6. a general description and location of the facilities, and;
7. the procedures specifying how the organisation ensures compliance with this Annex (Part-M) and Annex Vb (Part-ML), as applicable, and;
8. the continuing airworthiness management exposition amendment procedures, and;
9. the list of approved aircraft maintenance programmes, or, for aircraft not used by licenced air carriers in accordance with Regulation (EC) No 1008/2008, the list of ‘generic’ and ‘baseline’ maintenance programmes.
(b) The continuing airworthiness management exposition and its amendments shall be approved by the competent authority.
(c) Notwithstanding point (b), minor amendments to the exposition may be approved indirectly through an indirect approval procedure. The indirect approval procedure shall define the minor amendment eligible, be established by the continuing airworthiness management organisation as part of the exposition and be approved by the competent authority responsible for that continuing airworthiness management organisation.
AMC1 M.A.704 Continuing airworthiness management exposition
ED Decision 2020/002/R
1. The purpose of the continuing airworthiness management exposition is to set forth the procedures, means and methods of the CAMO. Compliance with its contents will assure compliance with Part-M and, as applicable, Part-ML requirements.
2. A continuing airworthiness management exposition should comprise:
Part 0 General organisation
Part 1 Continuing airworthiness procedures
Part 2 Quality system or organisational review (as applicable)
Part 3 Contracted maintenance — management of maintenance (liaison with maintenance organisations)
Part 4 Airworthiness review procedures (if applicable)
3. Personnel should be familiar with those parts of the continuing airworthiness management exposition that are relevant to their tasks.
4. The CAMO should specify in the exposition who is responsible for the amendment of the document. Unless otherwise agreed by the approving competent authority, the person responsible for the management of the quality system or for the organisational review should be responsible for monitoring and amending the continuing airworthiness management exposition, including associated procedure’s manuals, and the submission of proposed amendments to the competent authority. The competent authority may agree to a procedure, and its agreement will be stated in the amendment control section of the continuing airworthiness management exposition defining the class of amendments, which can be incorporated without the prior consent of the competent authority (‘indirect approval procedure’).
5. The CAMO may use electronic data processing (EDP) for the publication of the continuing airworthiness management exposition. The continuing airworthiness management exposition should be made available to the approving competent authority in a form acceptable to the latter. Attention should be paid to the compatibility of the EDP publication systems with the necessary dissemination, both internally and externally, of the continuing airworthiness management exposition.
6. The continuing airworthiness management exposition should contain information, as applicable, on how the CAMO complies with CDCCL instructions.
7. Appendix V to AMC1 M.A.704 contains an example of a continuing airworthiness management exposition layout.
EXPOSITION LAYOUT FOR A CAMO HOLDING A MAINTENANCE ORGANISATION APPROVAL
1. Where a CAMO is also approved to another Part, the exposition or manual required by the other Part may form the basis of the continuing airworthiness management exposition in a combined document.
2. Example for a combined CAMO and Part-145 organisation:
Part-145 Exposition (see equivalent paragraphs in AMC 145.A.70(a))
Part 0 General organisation
Part 1 Management
Part 2 Maintenance procedures
Part L2 Additional line maintenance procedures
Part 3 Quality system and/or organisational review (as applicable)
This chapter should cover the functions specified in M.A.712 ‘Quality system’ and 145.A.65 ‘Safety and quality system’.
Part 4 Contracts
This chapter should include:
the contracts of the CAMO with the owners/operators as per Appendix I to Part-M or Appendix I to Part-ML;
the CAMO procedures for the management of maintenance and liaison with maintenance organisations.
Part 5 Appendices (sample of documents)
Part 6 Continuing airworthiness management procedures
Part 7 FAA supplement (if applicable)
Part 8 TCCA supplement (if applicable)
Part 9 Airworthiness review procedures (if applicable)
3. Example for a combined CAMO and M.A. Subpart F organisation:
Part 0 General organisation
Part 1 General
Part 2 Description
Part 3 General procedures
Part 4 Working procedures
This part should contain, among other things, procedures for quality system or organisation review, as applicable.
Part 5 Appendices
Part 6 Continuing airworthiness management procedures
Part 7 Airworthiness review procedures (if applicable)
AMC M.A.704(a)(1) Continuing airworthiness management exposition
ED Decision 2020/002/R
1. Part 0 ‘General organisation’ of the continuing airworthiness management exposition should include a corporate commitment by the CAMO, signed by the accountable manager, confirming that the continuing airworthiness management exposition and any associated manuals define the organisation’s compliance with Part-M and, as applicable, with Part-ML and will be complied with at all times.
2. The accountable manager’s exposition statement should embrace the intent of the following paragraph, and in fact this statement may be used without amendment. Any amendment to the statement should not alter its intent:
‘This exposition defines the organisation and procedures upon which the competent authority’s* CAMO approval is based.
These procedures are approved by the undersigned and should be complied with, as applicable, in order to ensure that all continuing airworthiness tasks are carried out on time to an approved standard.
It is accepted that these procedures do not override the necessity of complying with any new or amended regulation published from time to time where these new or amended regulations are in conflict with these procedures.
It is understood that the competent authority* will approve this organisation whilst the competent authority* is satisfied that the procedures are followed and the work standard is maintained. It is understood that the competent authority* reserves the right to suspend, limit or revoke the CAMO approval or the air operator certificate, as applicable, if the competent authority* has evidence that the procedures are not followed and standards not upheld.
Signed .....................................
Dated ......................................
Accountable manager and ... (quote position) ...
For and on behalf of ... (quote organisation’s name) ... ’
*Where ‘competent authority’ is stated, please insert the actual name of the approving competent authority organisation or administration delivering the CAMO approval or the air operator certificate.’
3. Whenever the accountable manager is changed, it is important to ensure that the new accountable manager signs the paragraph 2 statement at the earliest opportunity as part of the acceptance by the approving competent authority. Failure to carry out this action invalidates the CAMO approval or the air operator certificate.
M.A.706 Personnel requirements
Regulation (EU) 2020/270
(a) The organisation shall appoint an accountable manager, who has corporate authority for ensuring that all continuing airworthiness management activities can be financed and carried out in accordance with this Annex (Part-M) and Annex Vb (Part-ML), as applicable.
Regulation (EU) 2015/1536
(b) For licenced air carriers in accordance with Regulation (EC) No 1008/2008 the accountable manager referred to in point (a) shall be the person who also has corporate authority for ensuring that all the operations of the operator can be financed and carried out to the standard required for the issue of an air operator's certificate.
Regulation (EU) No 2020/270
(c) A person or group of persons shall be nominated with the responsibility of ensuring that the organisation always complies with the applicable continuing airworthiness management, airworthiness review and permit to fly requirements of this Annex (Part-M) and Annex Vb (Part-ML). Such person(s) shall be ultimately responsible to the accountable manager.
Regulation (EU) 2015/1536
(d) For licenced air carriers in accordance with Regulation (EC) No 1008/2008, the accountable manager shall designate a nominated post holder. This person shall be responsible for the management and supervision of continuing airworthiness activities, pursuant to point (c).
Regulation (EU) No 1321/2014
(e) The nominated post holder referred to in point (d) shall not be employed by a Part-145 approved organisation under contract to the operator, unless specifically agreed by the competent authority.
Regulation (EU) No 1321/2014
(f) The organisation shall have sufficient appropriately qualified staff for the expected work.
Regulation (EU) No 1321/2014
(g) All point (c) and (d) persons shall be able to show relevant knowledge, background and appropriate experience related to aircraft continuing airworthiness.
Regulation (EU) No 1321/2014
(h) The qualification of all personnel involved in continuing airworthiness management shall be recorded.
Regulation (EU) 2020/270
(i) For organisations extending airworthiness review certificates in accordance with points M.A.711(a)(4) and M.A.901 of this Annex (Part-M) or point ML.A.901(c) of Annex Vb (Part-ML) as applicable, the organisation shall nominate persons authorised to do so, subject to approval by the competent authority.
Regulation (EU) No 1321/2014
(j) The organisation shall define and keep updated in the continuing airworthiness management exposition the title(s) and name(s) of person(s) referred to in points M.A.706(a), M.A.706(c), M.A.706(d) and M.A.706(i).
Regulation (EU) 2015/1536
(k) For complex motor-powered aircraft and for aircraft used by licenced air carriers in accordance with Regulation (EC) No 1008/2008, the organisation shall establish and control the competence of personnel involved in the continuing airworthiness management, airworthiness review and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority.
M.A.707 Airworthiness review staff
Regulation (EU) 2020/270
(a) To be approved to carry out airworthiness reviews and, if applicable, to issue permits to fly, an approved continuing airworthiness management organisation shall have appropriate airworthiness review staff to issue airworthiness review certificates or recommendations referred to in Section A, Subpart I of Annex I (Part-M) or in Section A, Subpart I of Annex Vb (Part-ML) and, if applicable, to issue a permit to fly in accordance with point M.A.711(c):
1. For aircraft used by licenced air carriers in accordance with Regulation (EC) No 1008/2008, and aircraft above 2 730 kg MTOM, except balloons, these staff shall have acquired:
(a) at least 5 years' experience in continuing airworthiness, and;
(b) an appropriate license in compliance with Annex III (Part-66) or an aeronautical degree or a national equivalent, and;
(c) formal aeronautical maintenance training, and;
(d) a position within the approved organisation with appropriate responsibilities.
(e) Notwithstanding points (a) to (d), the requirement laid down in point M.A.707(a)1(b) may be replaced by 5 years of experience in continuing airworthiness additional to those already required by point M.A.707(a)1(a).
2. For aircraft not used by licenced air carriers in accordance with Regulation (EC) No 1008/2008 of 2 730 kg MTOM and below, and balloons, these staff shall have acquired:
(a) at least 3 years' experience in continuing airworthiness, and;
(b) an appropriate license in compliance with Annex III (Part-66) or an aeronautical degree or a national equivalent, and;
(c) appropriate aeronautical maintenance training, and;
(d) a position within the approved organisation with appropriate responsibilities;
(e) Notwithstanding points (a) to (d), the requirement laid down in point M.A.707(a)2(b) may be replaced by 4 years of experience in continuing airworthiness additional to those already required by point M.A.707(a)2(a).
Regulation (EU) 2015/1088
(b) Airworthiness review staff nominated by the approved continuing airworthiness organisation can only be issued an authorisation by the approved continuing airworthiness organisation when formally accepted by the competent authority after satisfactory completion of an airworthiness review under the supervision of the competent authority or under the supervision of the organisation's airworthiness review staff in accordance with a procedure approved by the competent authority.
Regulation (EU) No 1321/2014
(c) The organisation shall ensure that aircraft airworthiness review staff can demonstrate appropriate recent continuing airworthiness management experience.
Regulation (EU) No 1321/2014
(d) Airworthiness review staff shall be identified by listing each person in the continuing airworthiness management exposition together with their airworthiness review authorisation reference.
Regulation (EU) No 1321/2014
(e) The organisation shall maintain a record of all airworthiness review staff, which shall include details of any appropriate qualification held together with a summary of relevant continuing airworthiness management experience and training and a copy of the authorisation. This record shall be retained until two years after the airworthiness review staff have left the organisation.
M.A.708 Continuing airworthiness management
Regulation (EU) 2020/270
(a) The organisation shall ensure that all continuing airworthiness management is carried out in accordance with Section A, Subpart C of this Annex (Part-M), and Section A, Subpart C of Annex Vb (Part-ML), as applicable.
(b) For every aircraft managed, the approved continuing airworthiness management organisation shall:
1. ensure that an aircraft maintenance programme including any applicable reliability programme, as required by point M.A.302 of this Annex (Part-M) or ML.A.302 of Annex Vb (Part-ML), as applicable, is developed and controlled,
2. for aircraft not used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, provide a copy of the aircraft maintenance programme to the owner or operator responsible in accordance with point M.A.201 of this Annex (Part-M) or ML.A.201 of Annex Vb (Part-ML), as applicable,
3. manage the approval of modification and repairs,
4. ensure that all maintenance is carried out in accordance with the approved maintenance programme and released in accordance with Section A, Subpart H of this Annex (Part-M) or Section A, Subpart H of Annex Vb (Part-ML), as applicable,
5. ensure that all applicable airworthiness directives and operational directives with a continuing airworthiness impact, are applied,
6. ensure that all defects discovered during scheduled maintenance or reported are corrected by an appropriately approved maintenance organisation,
7. ensure that the aircraft is taken to an appropriately approved maintenance organisation whenever necessary,
8. coordinate scheduled maintenance, the application of airworthiness directives, the replacement of service life limited parts, and component inspection to ensure the work is carried out properly,
9. manage and archive all continuing airworthiness records and/or operator's technical log.
10. ensure that the mass and balance statement reflects the current status of the aircraft.
(c) In the case of complex motor-powered aircraft or aircraft used for CAT, or aircraft used for commercial specialised operations or commercial ATO or commercial DTO operations, when the CAMO is not appropriately approved in accordance with Annex II (Part-145) or Subpart F of this Annex (Part-M) or Annex Vd (Part-CAO), the organisation shall, in consultation with the operator, establish a written maintenance contract with an organisation approved in accordance with Annex II (Part-145) or Subpart F of this Annex (Part-M) or Annex Vd (Part-CAO) or with another operator, detailing the functions specified under points M.A.301(b), M.A.301(c), M.A.301(f) and M.A.301(g) of this Annex (Part-M), or points ML.A.301(b) to (e) of Annex Vb (Part-ML), ensuring that all maintenance is ultimately carried out by a maintenance organisation approved in accordance with Annex II (Part-145) or Subpart F of this Annex (Part-M) or Annex Vd (Part-CAO) and defining the support of the quality functions referred to in point M.A.712(b) of this Annex (Part-M).
(d) Notwithstanding point (c), the contract may be in the form of individual work orders addressed to the maintenance organisation approved in accordance with Annex II (Part-145) or Subpart F of this Annex (Part-M) or Annex Vd (Part-CAO) in the case of:
1. an aircraft requiring unscheduled line maintenance;
2. component maintenance, including engine maintenance.
Regulation (EU) 2020/270
(a) The approved continuing airworthiness management organisation shall hold and use applicable current maintenance data in accordance with point M.A.401 of this Annex (Part-M) or point ML.A.401 of Annex Vb (Part-ML), as applicable, for the performance of continuing airworthiness tasks referred to in point M.A.708 of this Annex (Part-M). That data may be provided by the owner or the operator, subject to an appropriate contract being established with such an owner or operator. In such case, the continuing airworthiness management organisation only needs to keep such data for the duration of the contract, except when required by point M.A.714 of this Annex (Part-M).
(b) For aircraft not used by licenced air carriers in accordance with Regulation (EC) No 1008/2008, the approved continuing airworthiness management organisation may develop ‘baseline’ or ‘generic’ maintenance programmes, or both, in order to allow for the initial approval or the extension of the scope of an approval, without having the contracts referred to in Appendix I to this Annex (Part‑M) or Appendix I to Annex Vb (Part-ML), as applicable. Those ‘baseline’ and ‘generic’ maintenance programmes however do not preclude the need to establish an adequate Aircraft Maintenance Programme in compliance with point M.A.302 of this Annex (Part-M) or ML.A.302 of Annex Vb (Part-ML), as applicable, in due time before exercising the privileges referred to in point M.A.711 of this Annex (Part-M).
Regulation (EU) 2020/270
When the organisation approved in accordance with point M.A.711(b) of this Annex (Part-M) performs airworthiness reviews, they shall be performed in accordance with point M.A.901 of this Annex (Part-M) or point ML.A.903 of Annex Vb (Part-ML), as applicable.
Responsibilities of airworthiness review staff:
The following is a summary of the requirements contained in M.A.710 as well as the associated AMCs and Appendices, in relation to the responsibilities of the airworthiness review staff:
Airworthiness review staff are responsible for performing both the documental and the physical survey.
Procedures must be established by the CAMO in order to perform the airworthiness review, including the depth of samplings (refer to Appendix V to AMC1 M.A.704, paragraphs 4.2 and 4.3).
Procedures must make very clear that the final word about the depth of the inspections (both documental and physical) belongs to the airworthiness review staff, who can go beyond the depth contained in the CAME if they find it necessary. At the end, it is the responsibility of the airworthiness review staff to be satisfied that the aircraft complies with Part-M or Part-ML, as applicable, and is airworthy, and the organisation must ensure that no pressure or restrictions are imposed on the airworthiness review staff when performing their duty.
A compliance report must be produced by the airworthiness review staff, detailing all items checked and the outcome of the review.
Airworthiness review staff are responsible for the items checked during the airworthiness review. However, they do not take over the responsibilities of the CAMO, Part-145, DOA, POA or any other organisations, not being responsible for problems not detected during the airworthiness review or for the possibility that the approved or declared maintenance programme may not include certain recommendations from the Design Approval Holder. Obviously, if the airworthiness review staff are not independent of the airworthiness management process and were nominated on the basis of the option of having overall authority on such a process, they will be responsible for the full continuing airworthiness of such aircraft. Nevertheless, this responsibility will be a consequence of their position related to M.A.706 and not of their position as airworthiness review staff (M.A.707).
The issuance of the airworthiness review certificate (ARC) by the airworthiness review staff only certifies that the aircraft is considered airworthy in relation to the scope of the airworthiness review performed and the fact that the airworthiness review staff are not aware of instances of non-compliance which endanger flight safety. Furthermore, it only certifies that the aircraft is considered airworthy at the time of the review.
It is the responsibility of the owner or contracted CAMO to ensure that the aircraft is fully airworthy at any time.
M.A.711 Privileges of the organisation
Regulation (EU) 2020/270
(a) A continuing airworthiness management organisation approved in accordance with Section A, Subpart G of this Annex (Part-M) may:
1. manage the continuing airworthiness of aircraft, except those used by licenced air carriers in accordance with Regulation (EC) No 1008/2008, as listed on the approval certificate;
2. manage the continuing airworthiness of aircraft used by licenced air carriers in accordance with Regulation (EC) No 1008/2008, when listed both on its approval certificate and on its Air Operator Certificate (AOC);
3. arrange to carry out limited continuing airworthiness tasks with any contracted organisation, working under its quality system, as listed on the approval certificate;
4. extend, under the conditions set out in point M.A.901(f) of this Annex (Part-M) or ML.A.901(c) of Annex Vb (Part-ML), as applicable, an airworthiness review certificate that has been issued by the competent authority or by another organisation or person, as applicable;
5. Approve the AMP, in accordance with point (b)(2) of point ML.A.302, for aircraft managed in accordance with Annex Vb (Part-ML).
(b) An approved continuing airworthiness management organisation registered in one of the Member States may, additionally, be approved to carry out airworthiness reviews referred to in point M.A.710 and:
1. issue the related airworthiness review certificate and extend it in due time under the conditions set out in points M.A.901(c)(2) or M.A.901(e)(2) of this Annex (Part-M) or point ML.A.901(c) of Annex Vb (Part-ML), as applicable; and,
2. issue a recommendation for the airworthiness review to the competent authority of the Member State of registry.
(c) A continuing airworthiness management organisation whose approval includes the privileges referred to in point M.A.711(b) may additionally be approved to issue a permit to fly in accordance with point 21.A.711(d) of Annex I (Part-21) to Regulation (EU) No 748/2012 for the particular aircraft for which the organisation is approved to issue the airworthiness review certificate, when the continuing airworthiness management organisation is attesting conformity with approved flight conditions, subject to an adequate approved procedure in the exposition referred to in point M.A.704.
ED Decision 2020/002/R
1. The primary objectives of the quality system are to enable the CAMO to ensure airworthy aircraft and to remain in compliance with the Part-M and, as applicable, Part-ML requirements.
2. An essential element of the quality system is the independent audit.
3. The independent audit is an objective process of routine sample checks of all aspects of the CAMO ability to carry out continuing airworthiness management to the required standards. It includes some product sampling as this is the end result of the process.
4. The independent audit represents an objective overview of the complete continuing airworthiness management related activities. It is intended to complement the M.A.902 or ML.A.902 requirement for an airworthiness review to be satisfied that all aircraft managed by the organisation remain airworthy.
5. The independent audit should ensure that all aspects of M.A. Subpart G compliance are checked annually, including all the sub-contracted activities, and may be carried out as a complete single exercise or subdivided over the annual period in accordance with a scheduled plan. The independent audit does not require each procedure to be checked 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 checked every year without resultant findings. Where findings have been identified, the particular procedure should be rechecked against other product lines until the findings have been rectified after which the independent audit procedure may revert back to the annual interval for the particular procedure. Provided that there are no safety related findings, the audit time periods specified in this AMC may be increased by up to 100% subject to agreement by the competent authority.
6. Where the organisation has more than one location approved the quality system should describe how these are integrated into the system and include a plan to audit each location every year.
7. A report should be raised each time an audit is carried out describing what was checked and the resulting findings against applicable requirements, procedures and products.
8. The independence of the audit should be established by always ensuring that audits are carried out by personnel not responsible for the function, procedure or products being checked.
9. An organisation should establish a quality plan acceptable to the competent authority to show when and how often the activities as required by M.A. Subpart G will be audited.
Regulation (EU) 2020/270
(a) The continuing airworthiness management organisation shall record all details of work carried out. The records required under point M.A.305 of this Annex (Part-M) or ML.A.305 of Annex Vb (Part-ML), as applicable, and if applicable point M.A.306 of this Annex (Part-M), shall be retained.
(b) If the continuing airworthiness management organisation has the privilege referred to in point M.A.711(b), it shall retain a copy of each airworthiness review certificate and recommendation issued or, as applicable, extended, together with all supporting documents. In addition, the organisation shall retain a copy of any airworthiness review certificate that it has extended under the privilege referred to in point M.A.711(a)4.
(c) If the continuing airworthiness management organisation has the privilege referred to in point M.A.711(c), it shall retain a copy of each permit to fly issued in accordance with the provisions of point 21A.729 of Annex I (Part-21) to Regulation (EU) No 748/2012.
(d) The continuing airworthiness management organisation shall retain a copy of all records referred to in points (b) and (c) until two years after the aircraft has been permanently withdrawn from service.
(e) The records shall be stored in a manner that ensures protection from damage, alteration and theft.
(f) All computer hardware used to ensure backup shall be stored in a different location from that containing the working data in an environment that ensures they remain in good condition.
(g) Where continuing airworthiness management of an aircraft is transferred to another organisation or person, all retained records shall be transferred to the said organisation or person. The time periods prescribed for the retention of records shall continue to apply to the said organisation or person.
(h) Where a continuing airworthiness management organisation terminates its operation, all retained records shall be transferred to the owner of the aircraft.
Regulation (EU) 2020/270
(a) A level 1 finding is any significant non-compliance with the requirements of this Annex (Part-M) or Annex Vb (Part-ML), as applicable, which lowers the safety standard and hazards seriously the flight safety;
(b) A level 2 finding is any non-compliance with the requirements of this Annex (Part-M) or Annex Vb (Part-ML), as applicable, which could lower the safety standard and possibly hazard the flight safety.
(c) After receipt of notification of findings according to point M.B.705, the holder of the continuing airworthiness management organisation approval shall define a corrective action plan and demonstrate corrective action to the satisfaction of the competent authority within a period agreed with this authority.