Regulation (EU) 2019/1383
This Section establishes the requirements to be met by an organisation to qualify for the issue or continuation of a certificate for the management of continuing airworthiness of an aircraft and of components for installation.
CAMO.A.105 Competent authority
Regulation (EU) 2022/410
For the purpose of this Annex, the competent authority shall be:
(a) for organisations having their principal place of business in a territory for which a Member State is responsible under the Chicago Convention, one of the following:
(i) the authority designated by that Member State where that organisation’s principal place of business is located, if the approval is not included in an air operator certificate or if the CAMO is contracted in accordance with M.A.201(ea);
(ii) the authority designated by the Member State of the operator, if the approval is included in an air operator certificate;
(iii) the authority designated by a Member State other than (i) or (ii), if the responsibility has been reallocated to that Member State in accordance with Article 64 of Regulation (EU) 2018/1139;
(iv) the Agency if the responsibility has been reallocated to the Agency in accordance with Articles 64 or 65 of Regulation (EU) 2018/1139;
(b) the Agency if the organisation’s principal place of business is located outside a territory for which a Member State is responsible under the Chicago Convention.
CAMO.A.115 Application for an organisation certificate
Regulation (EU) 2019/1383
(a) The application for a certificate or an amendment to an existing certificate in accordance with this Annex shall be made in a form and manner established by the competent authority, taking into account the applicable requirements of Annex I (Part-M), Annex Vb (Part-ML) and this Annex.
(b) Applicants for an initial certificate pursuant to this Annex shall provide the competent authority with:
(1) the results of a pre-audit performed by the organisation against the applicable requirements provided for in Annex I (Part-M), Annex Vb (Part-ML) and this Annex;
(2) documentation demonstrating how they will comply with the requirements established in this Regulation.
Such documentation shall include, as provided for in point CAMO.A.130, a procedure describing how changes not requiring prior approval will be managed and notified to the competent authority.
AMC1 CAMO.A.115 Application for an organisation certificate
ED Decision 2020/002/R
An application should be made on an EASA Form 2 (Appendix I to AMC1 CAMO.A.115) or an equivalent form that is acceptable to the competent authority.
EASA Form 2 is also valid for application for other types of organisations pursuant to Regulation (EU) No 1321/2014. Organisations that apply for several certificates may do so using a single EASA Form 2.
AMC2 CAMO.A.115 Application for an organisation certificate
ED Decision 2020/002/R
(a) Draft documents should be submitted at the earliest opportunity so that 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.
(b) This information, including the results of the pre-audit specified in point CAMO.A.115(b)(1), will enable the competent authority to conduct its assessment in order to determine the volume of certification and oversight work that is necessary, and the locations where it will be carried out.
(c) The intent of the internal pre-audit referred to in point CAMO.A.115(b)(1) is to ensure that the organisation has internally verified its compliance with the Regulation. This should allow the organisation to demonstrate to the competent authority the extent to which the applicable requirements are complied with, and to provide assurance that the organisation management system is established to a level that is sufficient to perform continuing airworthiness management activities.
GM1 CAMO.A.115(b) Application for an organisation certificate
ED Decision 2020/002/R
PROCEDURE FOR CHANGES NOT REQUIRING PRIOR APPROVAL
The procedure for changes not requiring prior approval should include, as mentioned in point CAMO.A.300(a)(11)(iv), both the scope of those changes and how they will be managed and notified. For applicants for an initial certificate, the scope may be limited by the competent authority for the first period of operation. An extension of such a limited scope may be considered later; see GM1 CAMO.A.130.
AMC1 CAMO.A.115(b)(2) Application for an organisation certificate
ED Decision 2022/017/R
DOCUMENTATION FOR DEMONSTRATION OF COMPLIANCE
(a) Documentation to be provided to the competent authority in the frame of an application for an initial Part-CAMO certificate should include, as a minimum, the continuing airworthiness management exposition (CAME), containing in particular:
for CAT, commercial specialised operations and commercial ATO/DTO operations, the description of the aircraft technical log system;
the technical content of the contract between the CAMO and the organisation subcontracted to carry out continuing airworthiness management tasks, when such arrangement exists.
(b) Upon request by the competent authority, the CAMO should be able to demonstrate that arrangements are in place for all base and scheduled line maintenance for an appropriate period of time.
(c) When point M.A.201(ea) is applied, the continuing airworthiness management contract with the operator(s) in accordance with Appendix I to Annex I (Part-M) to Regulation (EU) No 1321/2014 should be submitted together with the CAME.
CAMO.A.120 Means of compliance
Regulation (EU) 2019/1383
(a) Alternative means of compliance to the AMC adopted by the Agency may be used by an organisation to establish compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.
(b) When an organisation wishes to use an alternative means of compliance, it shall, prior to using it, provide the competent authority with a full description of the alternative means of compliance. The description shall include any revisions to manuals or procedures that may be relevant, as well as an assessment demonstrating compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts.
The organisation may use these alternative means of compliance subject to prior approval by the competent authority, and upon receipt of the notification as provided for in point CAMO.B.120.
CAMO.A.125 Terms of approval and privileges of the organisation
Regulation (EU) 2022/410
(a) The approval is indicated on the certificate, which is included in Appendix I, and is issued by the competent authority.
(b) Notwithstanding point (a), for air carriers licensed in accordance with Regulation (EC) No 1008/2008, the approval shall be part of the air operator certificate issued by the competent authority for the aircraft operated except when, in accordance with point M.A.201(ea) of Annex I (Part-M), the CAMO is contracted by operators forming part of a single air carrier business grouping.
(c) The scope of work shall be specified in the continuing airworthiness management exposition (CAME) in accordance with point CAMO.A.300.
(d) An organisation approved in accordance with this Annex may:
(1) manage the continuing airworthiness of aircraft, except those used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, as listed on the certificate;
(2) manage the continuing airworthiness of aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, when listed both on its certificate and on the air operator certificate or when M.A.201(ea) applies;
(3) arrange to carry out limited continuing airworthiness tasks with any subcontracted organisation, working under its management system, as listed on the certificate;
(4) extend an airworthiness review certificate under the conditions of point M.A.901(f) of Annex I (Part-M) or point ML.A.901(c)of Annex Vb (Part-ML), 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).
(e) An organisation approved in accordance with this Annex and having its principal place of business in one of the Member States, may additionally 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:
(1) issue the related airworthiness review certificate and extend it in due time under the conditions of point M.A.901(c)(2) and point M.A.901(e)(2) of Annex I (Part-M) or point ML.A.901(c) of Annex Vb (Part-ML), as applicable;
(2) issue a recommendation for the airworthiness review to the competent authority of the Member State of registry, under the conditions of point (d) of point M.A.901 or point (b) of point M.A.904 of Annex I (Part-M).
(f) An organisation holding the privileges referred to in point (e) may additionally 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 the particular aircraft for which the organisation is approved to issue the airworthiness review certificate, when the organisation is attesting conformity with approved flight conditions, subject to an adequate procedure in the CAME referred to in point CAMO.A.300.
AMC1 CAMO.A.125(d)(3) Terms of approval and privileges
ED Decision 2020/002/R
SUBCONTRACTING OF CONTINUING AIRWORTHINESS TASKS
(a) The CAMO 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 CAMO’s management system, irrespective of any other approval held by the subcontracted organisation (including CAMO or Part-145 approval).
(b) The CAMO 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 CAMO should be satisfied that the actions taken by the subcontracted organisation meet the standards required by Part-CAMO. Therefore, the CAMO management of such activities should be accomplished:
(1) by active control through direct involvement; and/or
(2) by endorsing the recommendations made by the subcontracted organisation.
(d) In order to retain ultimate responsibility, the CAMO 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;
(6) any other activities, which do not limit the CAMO responsibilities, as agreed by the competent authority.
(e) The CAMO’s controls associated with subcontracted continuing airworthiness management tasks should be reflected in the associated contract and be in accordance with the CAMO policy and procedures defined in the CAME. When such tasks are subcontracted, the management 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 activities described in Appendix II. Where contracts are made with more than one organisation, the CAMO 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 to other organisations elements of the continuing airworthiness management tasks.
(h)The competent authority should exercise oversight of the subcontracted activities through the CAMO approval. The contracts should be acceptable to the competent authority. The CAMO should only subcontract to organisations which are specified by the competent authority on EASA Form 14.
(i) The subcontracted organisation should agree to notify the CAMO of any changes affecting the contract as soon as practical. The CAMO 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.
GM1 CAMO.A.125(e) Terms of approval and privileges
ED Decision 2020/002/R
(a) An organisation may be approved for the privileges of point CAMO.A.125(d) only, without the privilege to carry out airworthiness reviews. In this case, the airworthiness review can be contracted to another appropriately approved organisation. It is not mandatory that this contracted organisation is linked to an AOC holder, and it is possible to contract an appropriately approved independent CAMO which is approved for the same aircraft type.
(b) In order to be approved for the privileges of point CAMO.A.125(e) for a particular aircraft type, it is necessary to be approved for the privileges of point CAMO.A.125(d) for that aircraft type.
(c) Nevertheless, this does not necessarily mean that the organisation needs to be currently managing an aircraft type in order to be able to perform airworthiness reviews on that aircraft type. The organisation may be performing only airworthiness reviews on an aircraft type without having any customer under contract for that type.
(d) Furthermore, this situation should not necessarily lead to the removal of the aircraft type from the organisation approval. As a matter of fact, since in most cases the airworthiness review staff are not involved in continuing airworthiness management activities, it cannot be argued that these airworthiness review staff are going to lose their skills just because the organisation is not managing a particular aircraft type. The important issue in relation to maintaining a particular aircraft type in the organisation approval is whether the organisation continuously fulfils all the Part-CAMO requirements (facilities, documentation, qualified personnel, management system, etc.) required for initial approval.
GM1 CAMO.A.125(f) Terms of approval and privileges
ED Decision 2020/002/R
The sentence ‘for the particular aircraft for which the organisation is approved to issue the airworthiness review certificate’ contained in point CAMO.A.125(f) means that:
for Part-M aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, and for aircraft above 2 730 kg MTOM, the permit to fly can only be issued for aircraft which are in a controlled environment and are managed by that CAMO; and
for Part-M aircraft of 2 730 kg MTOM and below not used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, and for Part-ML aircraft, the permit to fly can be issued for any aircraft.
CAMO.A.130 Changes to the organisation
Regulation (EU) 2019/1383
(a) The following changes to the organisation shall require prior approval:
(1) changes that affect the scope of the certificate or the terms of approval of the organisation;
(2) changes to personnel nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305;
(3) changes to the reporting lines between the personnel nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305, and the accountable manager;
(4) the procedure as regards changes not requiring prior approval referred to in point (c).
(b) For any changes requiring prior approval in accordance with Regulation (EU) 2018/1139 and its delegated and implementing acts, the organisation shall apply for and obtain an approval issued by the competent authority. The application shall be submitted before any such change takes place, in order to enable the competent authority to determine continued compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts and to amend, if necessary, the organisation certificate and related terms of approval attached to it.
The organisation shall provide the competent authority with any relevant documentation.
The change shall only be implemented upon receipt of formal approval by the competent authority in accordance with point CAMO.B.330.
The organisation shall operate under the conditions established by the competent authority during such changes, as applicable.
(c) All changes not requiring prior approval shall be managed and notified to the competent authority as defined in the procedure referred to in point (b) of point CAMO.A.115 and approved by the competent authority in accordance with point (h) of point CAMO.B.310.
AMC1 CAMO.A.130 Changes to the organisation
ED Decision 2020/002/R
(a) The application for the amendment of an organisation certificate should be submitted at least 30 working days before the date of the intended changes.
(b) In the case of a planned change of a nominated person, the organisation should inform the competent authority at least 20 working days before the date of the proposed change.
(c) Unforeseen changes should be notified at the earliest opportunity, in order to enable the competent authority to determine whether there is continued compliance with the applicable requirements, and to amend, if necessary, the organisation certificate and related terms of approval.
AMC2 CAMO.A.130 Changes to the organisation
ED Decision 2020/002/R
The organisation should manage the safety risks related to any changes to the organisation in accordance with AMC1 CAMO.A.200(a)(3) point (e). For changes requiring prior approval, it should conduct a risk assessment and provide it to the competent authority upon request.
GM1 CAMO.A.130 Changes to the organisation
ED Decision 2020/002/R
CHANGES REQUIRING OR NOT REQUIRING PRIOR APPROVAL
The rule point CAMO.A.130 is structured as follows:
Point (a) introduces an obligation of prior approval (by the competent authority) for specific cases listed under (1) to (4).
Point (b) address all instances (including (a)) where the Regulation explicitly requires an approval by the competent authority (e.g. CAME procedure for the completion of an airworthiness review under supervision, ref. CAMO.A.310(c)). Changes relevant to these instances should be considered as changes requiring a prior approval (see list in GM1 CAMO.A.130(b)), unless otherwise specified by the Regulation.
Point (b) also indicates how all changes requiring prior approval are to be handled.
Point (c) introduces the possibility to agree with the competent authority that certain changes to the organisation (other than those covered by (a) or (b)) can be implemented without prior approval depending on the compliance and safety performance of the organisation, and in particular, on its capability to apply change management principles.
GM1 CAMO.A.130(a)(1) Changes to the organisation
ED Decision 2022/017/R
CHANGES THAT AFFECT THE SCOPE OF THE CERTIFICATE OR THE TERMS OF APPROVAL
Typical examples of such changes are listed below (not exhaustive):
(1) the name of the organisation;
(2) the organisation’s principal place of business;
(3) additional aircraft type/series/group;
(4) the accountable manager referred to in point CAMO.A.305(a);
(5) additional subcontracted organisation;
(6) contracts between the CAMO and operators forming part of a single air carrier business grouping, in accordance with point M.A.201(ea).
GM2 CAMO.A.130(a)(1) Changes to the organisation
ED Decision 2020/002/R
CHANGE OF THE NAME OF THE ORGANISATION
A change of the name requires the organisation to submit a new application as a matter of urgency.
If this is the only change to report, the new application can be accompanied by a copy of the documentation that was previously submitted to the competent authority under the previous name, as a means of demonstrating how the organisation complies with the applicable requirements.
GM1 CAMO.A.130(b) Changes to the organisation
ED Decision 2020/002/R
CHANGES REQUIRING PRIOR APPROVAL (OTHER THAN THOSE COVERED BY CAMO.A.130(a))
Following are some examples of changes that require prior approval by the competent authority (other than covered by point CAMO.A.130(a)), as specified in the applicable implementing rules:
(a) changes to the alternative means of compliance [CAMO.A.120(b)]
(b) changes to the CAME procedure for the completion of an airworthiness review under supervision of the organisation’s authorised airworthiness review staff (ARS) [CAMO.A.310(c)]
(c) changes to the procedure to establish and control the competency of personnel [CAMO.A.305(g)]
(d) changes to the system for reporting to the competent authority on the safety performance and regulatory compliance of the organisation (in the case of an extension beyond 36 months of the oversight planning cycle) [CAMO.B.305(d)]
(e) changes to the procedure for the indirect approval of the maintenance programme of Part-M aircraft [M.A.302(c)]
Regulation (EU) 2022/410
(a) The organisation’s certificate shall remain valid subject to compliance with all of the following conditions:
(1) the organisation remaining in compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts, taking into account the provisions related to the handling of findings as specified under point CAMO.B.350;
(2) the competent authority being granted access to the organisation as specified in point CAMO.A.140;
(3) the certificate not being surrendered or revoked.
(b) For air carriers licensed in accordance with Regulation (EC) No 1008/2008, termination, suspension or revocation of the air operator certificate automatically invalidates the organisation certificate in relation to the aircraft registrations specified in the air operator certificate, unless otherwise explicitly stated by the competent authority.
(c) Notwithstanding point (b), when the CAMO is contracted by operators forming part of a single air carrier business grouping in accordance with point M.A.201(ea) of Annex I (Part-M), the termination, suspension or revocation of the air operator certificate does not automatically invalidate the CAMO’s certificate. In this case, the contract in accordance with Appendix I to Annex I (Part-M) to this Regulation becomes void.
(d) Upon revocation or surrender, the organisation certificate shall be returned to the competent authority without delay.
Regulation (EU) 2019/1383
For the purpose of determining compliance with the relevant requirements of Regulation (EU) 2018/1139 and its delegated and implementing acts, the organisation shall grant access at any time to any facility, aircraft, document, records, data, procedures or any other material relevant to its activity subject to certification, whether it is contracted/subcontracted or not, to any person authorised by one of the following authorities:
(a) the competent authority defined in point CAMO.A.105;
(b) the authority acting under the provisions of point (d) of point CAMO.B.300 or point (e) of point CAMO.B.300.
Regulation (EU) 2019/1383
(a) After receipt of notification of findings according to point CAMO.B.350, the organisation shall:
(1) identify the root cause or causes of and contributing factors to the non-compliance;
(2) define a corrective action plan;
(3) demonstrate corrective action implementation to the satisfaction of the competent authority.
(b) Actions referred to in points (a)(1), (a)(2) and (a)(3) shall be performed within the period agreed with that competent authority as defined in point CAMO.B.350.
ED Decision 2020/002/R
The action plan defined by the organisation should address the effects of the non-compliance, as well as its root cause(s) and contributing factor(s).
Depending on the issues, the action plan should address correction/containment of the issue, corrective action and preventive action.
ED Decision 2022/017/R
If a finding that is raised by the competent authority (or non-compliance that is detected by the compliance monitoring function) affects the harmonisation of the management system of the CAMO with the management system of the contracting operator(s), which is required by point M.A.201(ea), the CAMO should inform the operator(s) to ensure that proper actions are taken within the group. The CAMO and operator(s) should agree on the appropriate channel for such communication.
If the group use common standards to facilitate the harmonisation of the organisations’ management systems, the CAMO should inform the group management board or similar group governance body.
ED Decision 2020/002/R
(a) It is important that the analysis does not primarily focus on establishing who or what caused the non-compliance, but on why it was caused. Establishing the root cause or causes of a non‑compliance often requires an overarching view of the events and circumstances that led to it, to identify all the possible systemic and contributing factors (regulatory, human factors (HF), organisational factors, technical, etc.) in addition to the direct factors.
(b) A narrow focus on single events or failures, or the use of a simple, linear model, such as a fault tree, to identify the chain of events that led to the non-compliance, may not properly reflect the complexity of the issue, and therefore there is a risk that important factors that must be addressed in order to prevent a reoccurrence will be ignored.
Such an inappropriate or partial causal analysis often leads to defining ‘quick fixes’ that only address the symptoms of the non-conformity. A peer review of the results of the causal analysis may increase its reliability and objectivity.
(c) A system description of the organisation that considers the organisational structures, processes and their interfaces, procedures, staff, equipment, facilities and the environment in which the organisation operates, will support both effective causal (reactive) and hazard (proactive) analyses.
CAMO.A.155 Immediate reaction to a safety problem
Regulation (EU) 2019/1383
The organisation shall implement:
(a) any safety measures mandated by the competent authority in accordance with point CAMO.B.135;
(b) any relevant mandatory safety information issued by the Agency.
CAMO.A.160 Occurrence reporting
Regulation (EU) 2019/1383
(a) As part of its management system the organisation shall implement an occurrence reporting system that meets the requirements defined in Regulation (EU) No 376/2014 and Implementing Regulation (EU) 2015/101842 Regulation (EU) 2015/1018 of 29 June 2015 laying down a list classifying occurrences in civil aviation to be mandatorily reported according to Regulation (EU) No 376/2014 of the European Parliament and of the Council (OJ L163, 30,06,2015, p. 1)..
(b) Without prejudice to point (a), the organisation shall ensure that any incident, malfunction, technical defect, exceeding of technical limitations, occurrence that would highlight inaccurate, incomplete or ambiguous information contained in data established in accordance with Annex I (Part-21) to Regulation (EU) No 748/2012 or other irregular circumstance that has or may have endangered the safe operation of the aircraft and that has not resulted in an accident or serious incident are reported to the competent authority and to the organisation responsible for the design of the aircraft.
(c) Without prejudice to Regulation (EU) No 376/2014 and Implementing Regulation (EU) 2015/1018, the reports referred to in points (a) and (b) shall be made in a form and manner established by the competent authority and shall contain all pertinent information about the condition known to the organisation.
(d) Reports shall be made as soon as possible, but in any case within 72 hours of the organisation identifying the condition to which the report relates, unless exceptional circumstances prevent this.
(e) Where relevant, the organisation shall produce a follow-up report to provide details of actions it intends to take to prevent similar occurrences in the future, as soon as these actions have been identified. This report shall be produced in a form and manner established by the competent authority.
AMC1 CAMO.A.160 Occurrence reporting
ED Decision 2020/002/R
(a) Where the organisation holds one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and its delegated and implementing acts:
(1) the organisation may establish an integrated occurrence reporting system covering all certificate(s) held; and
(2) single reports for occurrences should only be provided if the following conditions are met:
(i) the report includes all relevant information from the perspective of the different organisation certificates held;
(ii) the report addresses all relevant specific mandatory data fields and clearly identifies all certificate holders for which the report is made;
(iii) the competent authority for all certificates is the same and such single reporting was agreed with that competent authority.
(b) The organisation should assign responsibility to one or more suitably qualified persons with clearly defined authority, for coordinating action on airworthiness occurrences and for initiating any necessary further investigation and follow-up activity.
(c) If more than one person are assigned such responsibility, the organisation should identify a single person to act as the main focal point for ensuring a single reporting channel is established with the accountable manager. This should in particular apply to organisations holding one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and its delegated and implementing acts where the occurrence reporting system is fully integrated with that required under the additional certificate(s) held.
AMC2 CAMO.A.160 Occurrence reporting
ED Decision 2020/002/R
The organisation should share relevant safety-related occurrence reports with the design approval holder of the aircraft in order to enable it to issue appropriate service instructions and recommendations to all owners or operators. Liaison with the design approval holder is recommended to establish whether published or proposed service information will resolve the problem or to obtain a solution to a particular problem.
GM1 CAMO.A.160 Occurrence reporting
ED Decision 2020/002/R
(a) For organisations having their principal place of business in a Member State, Regulation (EU) 2015/1018 lays down a list classifying occurrences in civil aviation to be mandatorily reported. This list should not be understood as being an exhaustive collection of all issues that may pose a significant risk to aviation safety and therefore reporting should not be limited to items listed in that Regulation.
(b) AMC-20 ‘General Acceptable Means of Compliance for Airworthiness of Products, Parts and Appliances’ provides further details on occurrence reporting (AMC 20-8).
GM1 CAMO.A.160(b) Occurrence reporting
ED Decision 2020/002/R
Depending on the case, the ‘organisation responsible for the design of the aircraft’ will be the holder of a type-certificate, a restricted type-certificate, a supplemental type-certificate, a European Technical Standard Order (ETSO) authorisation, an approval for a repair or a change to the type design or any other relevant approval or authorisation for products, parts and appliances deemed to have been issued under Commission Regulation (EU) No 748/2012.
Regulation (EU) 2022/410
(a) The organisation shall establish, implement, and maintain a management system that includes:
(1) clearly defined lines of responsibility and accountability throughout the organisation, including a direct safety accountability of the accountable manager;
(2) a description of the overall philosophies and principles of the organisation with regard to safety, referred to as the safety policy;
(3) the identification of aviation safety hazards entailed by the activities of the organisation, their evaluation and the management of associated risks, including taking actions to mitigate the risks and verify their effectiveness;
(4) maintaining personnel trained and competent to perform their tasks;
(5) documentation of all management system key processes, including a process for making personnel aware of their responsibilities and the procedure for amending this documentation;
(6) a function to monitor compliance of the organisation with the relevant requirements. Compliance monitoring shall include a feedback system of findings to the accountable manager to ensure effective implementation of corrective actions as necessary;
(7) any additional requirements that are laid down in this Regulation.
(b) The management system shall correspond to the size of the organisation and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in these activities.
(c) Where the organisation holds one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and its delegated and implementing acts, the management system may be integrated with that required under the additional certificate(s) held.
(d) Notwithstanding point (c), for air carriers licensed in accordance with Regulation (EC) No 1008/2008, the management system provided for in this Annex shall be an integrated part of the operator’s management system.
(e) When, in accordance with point M.A.201(ea) of Annex I (Part-M), a contract is concluded between a CAMO and operators forming part of a single air carrier business grouping, the CAMO shall ensure that its management system is harmonised with the management systems of the operators forming part of that business grouping.
GM1 CAMO.A.200 Management system
ED Decision 2020/002/R
GENERAL
Safety management seeks to proactively identify hazards and to mitigate the related safety risks before they result in aviation accidents and incidents. Safety management enables an organisation to manage its activities in a more systematic and focused manner. When an organisation has a clear understanding of its role and contribution to aviation safety, it can prioritise safety risks and more effectively manage its resources and obtain optimal results.
The principles of the requirements in points CAMO.A.200, CAMO.A.202, CAMO.A.205 and the related AMC constitute the EU management system framework for aviation safety management. This framework addresses the core elements of the ICAO safety management system (SMS) framework defined in Appendix 2 to Annex 19, and it promotes an integrated approach to the management of an organisation. It facilitates the introduction of the additional safety management components, building upon the existing management system, rather than adding them as a separate framework.
This approach is intended to encourage organisations to embed safety management and risk-based decision-making into all their activities, instead of superimposing another system onto their existing management system and governance structure. In addition, if the organisation holds multiple organisation certificates within the scope of Regulation (EU) 2018/1139, it may choose to implement a single management system to cover all of its activities. An integrated management system may not only be used to capture multiple certification requirements, but also to cover other business management systems such as security, occupational health and environmental management systems. Integration will remove any duplication and exploit synergies by managing safety risks across multiple activities. Organisations may determine the best means to structure their management systems to suit their business and organisational needs.
The core part of the management system framework (CAMO.A.200) focuses on what is essential for safety management, by mandating the organisation to:
(a) clearly define accountabilities and responsibilities;
(b) establish a safety policy and the related safety objectives;
(c) implement safety reporting procedures in line with just culture principles;
(d) ensure the identification of aviation safety hazards entailed by its activities, ensure their evaluation, and the management of associated risks, including:
(1) taking actions to mitigate the risks;
(2) verifying the effectiveness of the actions taken to mitigate the risks;
(e) monitor compliance, while considering any additional requirements that are applicable to the organisation;
(f) keep their personnel trained, competent, and informed about significant safety issues; and
(g) document all the key management system processes.
Compared to the previous Part-M Subpart G quality system ‘framework’, the new elements that are introduced with Part-CAMO are, in particular, those addressed under points (b) to (d). Points (c) and (d)(1) address component 2 ‘Safety Risk Management’ of the ICAO SMS framework. Points (d)(2) and (e) address component 3 ‘Safety Assurance’ thereof.
Point CAMO.A.200 defines the following as key safety management processes; these are further specified in the related AMC and GM:
Hazard identification;
Safety risk management;
Internal investigation;
Safety performance monitoring and measurement;
Management of change;
Continuous improvement;
Immediate safety action and coordination with the aircraft operator’s Emergency Response Plan (ERP).
It is important to recognise that safety management will be a continuous activity, as hazards, risks and the effectiveness of safety risk mitigations will change over time.
These key safety management processes are supported by a compliance monitoring function as an integral part of the management system for safety. Most aviation safety regulations constitute generic safety risk controls established by the ‘regulator’. Therefore, ensuring effective compliance with the regulations during daily operations and independent monitoring of compliance are fundamental to any management system for safety. The compliance monitoring function may, in addition, support the follow-up of safety risk mitigation actions. Moreover, where non-compliances are identified through internal audits, the causes will be thoroughly assessed and analysed. Such an analysis in return supports the risk management process by providing insights into causal and contributing factors, including HF, organisational factors and the environment in which the organisation operates. In this way, the outputs of compliance monitoring become some of the various inputs to the safety risk management functions. On the other hand, the safety risk management processes may be used to determine focus areas for compliance monitoring. In this way, internal audits will inform the organisation’s management of the level of compliance within the organisation, whether safety risk mitigation actions have been implemented, and where corrective or preventive action is required. The combination of safety risk management and compliance monitoring should lead to an enhanced understanding of the end-to-end process and the process interfaces, exposing opportunities for increased efficiencies, which are not limited to safety aspects.
As aviation is a complex system with many organisations and individuals interacting together, the primary focus of the key safety management processes is on the organisational processes and procedures, but it also relies on the humans in the system. The organisation and the way in which it operates can have a significant impact on human performance. Therefore, safety management necessarily addresses how humans can contribute both positively and negatively to an organisation’s safety outcomes, recognising that human behaviour is influenced by the organisational environment.
The effectiveness of safety management largely depends on the degree of commitment of the senior management to create a working environment that optimises human performance and encourages personnel to actively engage in and contribute to the organisation’s management processes. Similarly, a positive safety culture relies on a high degree of trust and respect between the personnel and the management, and it must therefore be created and supported at the senior management level. If the management does not treat individuals who identify hazards and report adverse events in a consistently fair and just way, those individuals are unlikely to be willing to communicate safety issues or to work with the management to effectively address the safety risks. As with trust, a positive safety culture takes time and effort to establish, and it can be easily lost.
It is further recognised that the introduction of processes for hazard identification and risk assessment, mitigation and verification of the effectiveness of such mitigation actions will create immediate and direct costs, while related benefits are sometimes intangible and may take time to materialise. Over time, an effective management system will not only address the risks of major occurrences, but also identify and address production inefficiencies, improve communication, foster a better organisation culture, and lead to more effective control of contractors and suppliers. In addition, through an improved relationship with the authority, an effective management system may result in a reduced oversight burden.
Thus, by viewing safety management and the related organisational policies and key processes as items that are implemented not only to prevent incidents and accidents, but also to meet the organisation’s strategic objectives, any investment in safety should be seen as an investment in productivity and organisational success.
AMC1 CAMO.A.200(a)(1) Management system
ED Decision 2021/009/R
ORGANISATION AND ACCOUNTABILITIES
(a) The management system should encompass safety by including a safety manager, and a safety review board in the organisational structure. The functions of the safety manager are those defined in AMC1 CAMO.A.305(a)(4);(a)(5).
(b) Safety review board
(1) The safety review board should be a high-level committee that considers matters of strategic safety in support of the accountable manager’s safety accountability.
(2) The board should be chaired by the accountable manager and composed of the person or group of persons nominated under point CAMO.A.305(a) and (b).
(3) The safety review board should monitor:
(i) safety performance against the safety policy and objectives;
(ii) that any safety action is taken in a timely manner; and
(iii) the effectiveness of the organisation’s management system processes.
(4) The safety review board may also be tasked with:
(i) reviewing the results of compliance monitoring;
(ii) monitoring the implementation of related corrective and preventive actions.
(c) The safety review board should ensure that appropriate resources are allocated to achieve the established safety objectives.
(d) The safety manager or another person designated by the safety manager may attend, as appropriate, safety review board meetings. He or she may communicate to the accountable manager all information, as necessary, to allow decision-making based on safety data.
(e) Notwithstanding point (a), where justified by the size of the organisation and the nature and complexity of its activities and subject to a risk assessment and agreement by the competent authority, the organisation may not need to establish a formal safety review board. In this case, the tasks normally allocated to the safety review board should be allocated to the safety manager.
GM1 CAMO.A.200(a)(1) Management system
ED Decision 2020/002/R
(a) Depending on the size of the organisation and the nature and complexity of its activities, a safety action group may be established as a standing group or as an ad hoc group to assist, or act on behalf of the safety manager or the safety review board.
(b) More than one safety action group may be established, depending on the scope of the task and the specific expertise required.
(c) The safety action group usually reports to, and takes strategic direction from, the safety review board, and may be composed of managers, supervisors and personnel from operational areas.
(d) The safety action group may be tasked with or assist in:
(1) monitoring safety performance;
(2) defining actions to control risks to an acceptable level;
(3) assessing the impact of organisational changes on safety;
(4) ensuring that safety actions are implemented within agreed timescales;
(5) reviewing the effectiveness of previous safety actions and safety promotion.
GM2 CAMO.A.200(a)(1) Management system
ED Decision 2020/002/R
MEANING OF THE TERMS ‘ACCOUNTABILITY’ AND ‘RESPONSIBILITY’
In the English language, the notion of accountability is different from the notion of responsibility. Whereas ‘accountability’ refers to an obligation which cannot be delegated, ‘responsibility’ refers to an obligation that can be delegated.
AMC1 CAMO.A.200(a)(2) Management system
ED Decision 2020/002/R
(a) The safety policy should:
(1) reflect organisational commitments regarding safety, and its proactive and systematic management, including the promotion of a positive safety culture;
(2) include internal reporting principles, and encourage personnel to report continuing airworthiness-related errors, incidents and hazards;
(3) recognise the need for all personnel to cooperate with the compliance monitoring and internal investigations referred to under point (c) of AMC1 CAMO.A.200(a)(3);
(4) be endorsed by the accountable manager;
(5) be communicated, with visible endorsement, throughout the organisation; and
(6) be periodically reviewed to ensure it remains relevant and appropriate for the organisation.
(b) The safety policy should include a commitment to:
(1) comply with all applicable legislation, to meet all the applicable requirements, and adopt practices to improve safety standard;
(2) provide the necessary resources for the implementation of the safety policy.
(3) apply HF principles;
(4) enforce safety as a primary responsibility of all managers; and
(5) apply ‘just culture’ principles to internal safety reporting and the investigation of occurrences and, in particular, not to make available or use the information on occurrences:
(i) to attribute blame or liability to front line staff or other persons for actions, omissions or decisions taken by them that are commensurate with their experience and training; or
(ii) for any purpose other than the maintenance or improvement of aviation safety.
(c) Senior management should continually promote the safety policy to all personnel, demonstrate its commitment to it, and provide necessary human and financial resources for its implementation.
(d) Taking due account of its safety policy, the organisation should define safety objectives. The safety objectives should:
(1) form the basis for safety performance monitoring and measurement;
(2) reflect the organisation’s commitment to maintain or continuously improve the overall effectiveness of the management system;
(3) be communicated throughout the organisation; and
(4) be periodically reviewed to ensure they remain relevant and appropriate for the organisation.
GM1 CAMO.A.200(a)(2) Management system
ED Decision 2020/002/R
(a) The safety policy is the means whereby the organisation states its intention to maintain and, where practicable, improve safety levels in all its activities and to minimise its contribution to the risk of an aircraft accident or serious incident as far as is reasonably practicable. It reflects the management’s commitment to safety, and should reflect the organisation’s philosophy of safety management, as well as be the foundation on which the organisation’s management system is built. It serves as a reminder of ‘how we do business here’. The creation of a positive safety culture begins with the issuance of a clear, unequivocal policy.
(b) The commitment to apply ‘just culture’ principles forms the basis for the organisation’s internal rules describing how ‘just culture’ principles are guaranteed and implemented.
(c) For organisations having their principal place of business in a Member State, Regulation (EU) No 376/2014 defines the ‘just culture’ principles to be applied (refer in particular to Article 16(11) of that Regulation).
AMC1 CAMO.A.200(a)(3) Management system
ED Decision 2020/002/R
SAFETY MANAGEMENT KEY PROCESSES
(a) Hazard identification processes
(1) A reporting scheme for both reactive event and proactive hazards should be the formal means of collecting, recording, analysing, acting on, and generating feedback about hazards and the associated risks that may affect safety.
(2) The identification should include:
(i) hazards that may be generated from HF issues that affect human performance; and
(ii) hazards that may stem from the organisational set-up or the existence of complex operational and maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included).
(b) Risk management processes
(1) A formal safety risk management process should be developed and maintained that ensures that there is:
(i) analysis (e.g. in terms of the probability and severity of the consequences of hazards and occurrences);
(ii) assessment (in terms of tolerability); and
(iii) control (in terms of mitigation) of risks to an acceptable level.
(2) The levels of management who have the authority to make decisions regarding the tolerability of safety risks, in accordance with (b)(1)(ii), should be specified.
(c) Internal investigation
(1) In line with its just culture policy, the organisation should define how to investigate incidents such as errors or near misses, in order to understand not only what happened, but also how it happened, to prevent or reduce the probability and/or consequence of future recurrences (refer to AMC1 CAMO.A.202).
(2) The scope of internal investigations should extend beyond the scope of the occurrences required to be reported to the competent authority in accordance with point CAMO.A.160, to include the reports referred to in CAMO.A.202(b).
(d) Safety performance monitoring and measurement
(1) Safety performance monitoring and measurement should be the process by which the safety performance of the organisation is verified in comparison with the safety policy and the safety objectives.
(2) This process may include, as appropriate to the size, nature and complexity of the organisation:
(i) safety reporting, addressing also the status of compliance with the applicable requirements;
(ii) safety reviews, including trends reviews, which would be conducted during the introduction of new products and their components, new equipment/technologies, the implementation of new or changed procedures, or in situations of organisational changes that may have an impact on safety;
(iii) safety audits focusing on the integrity of the organisation’s management system, and on periodically assessing the status of safety risk controls; and
(iv) safety surveys, examining particular elements or procedures in a specific area, such as problem areas identified, or bottlenecks in daily continuing airworthiness management activities, perceptions and opinions of management personnel, and areas of dissent or confusion.
(e) Management of change
The organisation should manage the safety risks related to a change. The management of change should be a documented process to identify external and internal changes that may have an adverse effect on the safety of its continuing airworthiness management activities. It should make use of the organisation’s existing hazard identification, risk assessment and mitigation processes.
(f) Continuous improvement
The organisation should continuously seek to improve its safety performance and the effectiveness of its management system. Continuous improvement may be achieved through:
(1) audits carried out by external organisations;
(2) assessments, including assessments of the effectiveness of the safety culture and management system, in particular to assess the effectiveness of the safety risk management processes;
(3) staff surveys, including cultural surveys, that can provide useful feedback on how engaged personnel are with the management system;
(4) monitoring the recurrence of incidents and occurrences;
(5) evaluation of safety performance indicators and review of all the available safety performance information; and
(6) identification of lessons learnt.
(g) Immediate safety action and coordination with the operator’s Emergency Response Plan (ERP)
(1) A procedure should be implemented to enable the organisation to act promptly when it identifies safety concerns with the potential to have immediate effect on flight safety, including clear instructions on who to contact at the owner/operator, and how to contact them, including outside normal business hours. These provisions are without prejudice to the occurrence reporting required by point CAMO.A.160.
(2) If applicable, a procedure should be implemented to enable the organisation to react promptly if the ERP is triggered by the operator and it requires the support of the CAMO.
GM1 CAMO.A.200(a)(3) Management system
ED Decision 2020/002/R
SAFETY RISK MANAGEMENT — INTERFACES BETWEEN ORGANISATIONS
(a) Safety risk management processes should specifically address the planned implementation of, or participation of the organisation in, any complex operational and maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included).
(b) Hazard identification and risk assessment start with an identification of all the parties involved in the arrangement, including independent experts and non-approved organisations. This identification process extends to cover the overall control structure, and assesses in particular the following elements across all subcontract levels and all parties within such arrangements:
(1) coordination and interfaces between the different parties;
(2) applicable procedures;
(3) communication between all the parties involved, including reporting and feedback channels;
(4) task allocation, responsibilities and authorities; and
(5) the qualifications and competency of key personnel with reference to point CAMO.A.305.
(c) Safety risk management should focus on the following aspects:
(1) clear assignment of accountability and allocation of responsibilities;
(2) that only one party is responsible for a specific aspect of the arrangement, with no overlapping or conflicting responsibilities, in order to eliminate coordination errors;
(3) the existence of clear reporting lines, both for occurrence reporting and progress reporting;
(4) the possibility for staff to directly notify the organisation of any hazard that suggests an obviously unacceptable safety risk as a result of the potential consequences of this hazard.
(d) The safety risk management processes should ensure that there is regular communication between all the parties involved to discuss work progress, risk mitigation actions, and changes to the arrangement, as well as any other significant issues.
GM2 CAMO.A.200(a)(3) Management system
ED Decision 2020/002/R
(a) Unless they are properly managed, changes in organisational structure, facilities, the scope of work, personnel, documentation, policies and procedures, etc. can result in the inadvertent introduction of new hazards, and expose the organisation to new or increased risk. Effective organisations seek to improve their processes, with conscious recognition that changes can expose the organisation to potentially latent hazards and risks if they are not properly and effectively managed.
(b) Regardless of the magnitude of change, large or small, its safety implications should always be proactively considered. This is primarily the responsibility of the team that proposes and/or implements the change. However, a change can only be successfully implemented if all the personnel affected by the change are engaged, are involved and participate in the process. The magnitude of a change, its safety criticality, and its potential impact on human performance should be assessed in any change management process.
(c) The process for the management of change typically provides principles and a structured framework for managing all aspects of the change. Disciplined application of the management of change can maximise the effectiveness of the change, engage the staff, and minimise the risks that are inherent in a change.
(d) The introduction of a change is the trigger for the organisation to perform their hazard identification and risk management process.
Some examples of change include, but are not limited to:
(1) changes to the organisational structure;
(2) the inclusion of a new aircraft type in the terms of approval;
(3) the addition of aircraft of the same or a similar type;
(4) significant changes in personnel (affecting key personnel and/or large numbers of personnel, high turn-over);
(5) new or amended regulations;
(6) changes in the security arrangements;
(7) changes in the economic situation of an organisation (e.g. commercial or financial pressure);
(8) new schedule(s), location(s), equipment, and/or operational procedures; and
(9) the addition of new subcontractors.
(e) A change may have the potential to introduce new, or to exacerbate pre-existing, HF issues. For example, changes in computer systems, equipment, technology, personnel changes, including changes in management personnel, procedures, work organisation, or work processes are likely to affect performance.
(f) The purpose of integrating HF into the management of change is to minimise potential risks by specifically considering the impact of the change on the people within a system.
(g) Special consideration, including any HF issues, should be given to the ‘transition period’. In addition, the activities utilised to manage these issues should be integrated into the change management plan.
(h) Effective management of change should be supported by the following:
(1) Implementation of a process for formal hazard identification/risk assessment for major operational changes, major organisational changes, changes in key personnel, and changes that may affect the way continuing airworthiness management is carried out.
(2) Identification of changes that are likely to occur in business which would have a noticeable impact on:
(i) resources — material and human;
(ii) management direction — policies, processes, procedures, training; and
(iii) management control.
(3) Safety cases/risk assessments that are aviation-safety focused.
(4) Involvement of key stakeholders in the change management process as appropriate.
(i) During the management of change process, previous risk assessments, and existing hazards are reviewed for possible effect.
AMC1 CAMO.A.200(a)(4) Management system
ED Decision 2020/002/R
(a) The organisation should establish communication about safety matters that:
(1) ensures that all personnel are aware of the safety management activities, as appropriate, for their safety responsibilities;
(2) conveys safety-critical information, especially related to assessed risks and analysed hazards;
(3) explains why particular actions are taken; and
(4) explains why safety procedures are introduced or changed.
(b) Regular meetings with personnel at which information, actions, and procedures are discussed, may be used to communicate safety matters.
GM1 CAMO.A.200(a)(4) Management system
ED Decision 2020/002/R
(a) Safety training, combined with safety communication and information sharing, forms part of safety promotion.
(b) Safety promotion activities support:
(1) the organisation’s policies, encouraging a positive safety culture, creating an environment that is favourable to the achievement of the organisation’s safety objectives;
(2) organisational learning; and
(3) the implementation of an effective safety reporting scheme and the development of a just culture.
(c) Depending on the particular safety issue, safety promotion may also constitute or complement risk mitigation actions.
(d) Qualification and training aspects are further specified in the AMC and GM to CAMO.A.305.
GM1 CAMO.A.200(a)(5) Management system
ED Decision 2020/002/R
MANAGEMENT SYSTEM DOCUMENTATION
(a) The organisation may document its safety policy, safety objectives and all its key management system processes in a separate manual (e.g. Safety Management Manual or Management System Manual) or in its CAME (cf. AMC1 CAMO.A.300, Part 2 ‘Management system procedures’). Organisations that hold multiple organisation certificates within the scope of Regulation (EU) 2018/1139 may prefer to use a separate manual in order to avoid duplication. That manual or the CAME, depending on the case, should be the key instrument for communicating the approach to the management system for the whole of the organisation.
(b) The organisation may also choose to document some of the information that is required to be documented in separate documents (e.g. policy documents, procedures). In that case, it should ensure that the manual or the CAME contains adequate references to any document that is kept separately. Any such documents are to be considered as integral parts of the organisation’s management system documentation.
AMC1 CAMO.A.200(a)(6) Management system
ED Decision 2020/002/R
COMPLIANCE MONITORING — GENERAL
(a) The primary objectives of compliance monitoring are to provide an independent monitoring function on how the organisation ensures compliance with the applicable requirements, policies and procedures, and to request action where non-compliances are identified.
(b) The independence of the compliance monitoring should be established by always ensuring that audits and inspections are carried out by personnel who are not responsible for the functions, procedures or products that are audited or inspected.
AMC2 CAMO.A.200(a)(6) Management System
ED Decision 2020/002/R
COMPLIANCE MONITORING — INDEPENDENT AUDIT
(a) An essential element of compliance monitoring is the independent audit.
(b) The independent audit should be an objective process of routine sample checks of all aspects of the CAMO ability to carry out continuing airworthiness management to the standards required by this Regulation. It should include some product sampling 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-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-CAMO will be audited.
(e) The audit plan should ensure that all aspects of Part-CAMO compliance are verified every year, including all the subcontracted activities, and the auditing may be carried out as a complete single exercise or subdivided 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 closed, after which the independent audit procedure may revert to a yearly 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 a risk assessment and/or mitigation actions, and agreement by the competent authority.
(g) Where the organisation has more than one location approved, the audit plan should ensure that each location is audited every year or at an interval determined through a risk assessment agreed by the competent authority and not exceeding the applicable audit planning cycle.
(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.
AMC3 CAMO.A.200(a)(6) Management system
ED Decision 2020/002/R
COMPLIANCE MONITORING — CONTRACTING OF THE INDEPENDENT AUDIT
(a) If external personnel are used to perform independent audits:
(1) any such audits are performed under the responsibility of the compliance monitoring manager; and
(2) the organisation remains responsible for ensuring that the external personnel have the relevant knowledge, background, and experience that are appropriate to the activities being audited, including knowledge and experience in compliance monitoring.
(b) The organisation retains the ultimate responsibility for the effectiveness of the compliance monitoring function, in particular for the effective implementation and follow-up of all corrective actions.
AMC4 CAMO.A.200(a)(6) Management system
ED Decision 2020/002/R
COMPLIANCE MONITORING — FEEDBACK SYSTEM
(a) An essential element of the compliance monitoring is the feedback system.
(b) The feedback system should not be contracted to external persons or organisations.
(c) When a non-compliance is found, the compliance monitoring function should ensure that the root cause(s) and contributing factor(s) are identified (see GM1 CAMO.A.150), and that corrective actions are defined. The feedback part of the compliance monitoring function should define who is required to address any non-compliance in each particular case, and the procedure to be followed if the corrective action is not completed within the defined time frame. The principal functions of the feedback system are to ensure that all findings resulting from the independent audits of the organisation are properly investigated and corrected in a timely manner, and to enable the accountable manager to be kept informed of any safety issues and the extent of compliance with Part-CAMO.
(d) The independent audit reports referred to in AMC2 CAMO.A.200(a)(6) should be sent to the relevant department(s) for corrective action, giving target closure dates. These target dates should be discussed with the relevant department(s) before the compliance monitoring function confirms the dates in the report. The relevant department(s) are required to implement the corrective action and inform the compliance monitoring function of the status of the implementation of the action.
(e) Unless the review of the results from compliance monitoring is the responsibility of the safety review board (ref. AMC1 CAMO.A.200(a)(1) point (b)(4)), the accountable manager should hold regular meetings with staff to check the progress of any corrective actions. These meetings may be delegated to the compliance monitoring manager on a day-to-day basis, provided that the accountable manager:
(1) meets the senior staff involved at least twice per year to review the overall performance of the compliance monitoring function; and
(2) receives at least a half-yearly summary report on non-compliance findings.
(f) All records pertaining to the independent audit and the feedback system should be retained for the period specified in point CAMO.A.220(b) or for such periods as to support changes to the audit planning cycle in accordance with AMC2 CAMO.A.200(a)(6), whichever is the longer.
GM1 CAMO.A.200(a)(6) Management system
ED Decision 2020/002/R
COMPLIANCE MONITORING FUNCTION
The compliance monitoring function is one of the elements that is required to be in compliance with the applicable requirements. This means that the compliance monitoring function itself should be subject to independent monitoring of compliance in accordance with point CAMO.A.200(a)(6).
GM1 CAMO.A.200(a)(6) and CAMO.B.300 Management system and Oversight principles
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 CAMO.A.200(e) Management system
ED Decision 2022/017/R
INTEGRATION AND HARMONISATION OF THE MANAGEMENT SYSTEMS
(a) ‘Management system’ within the scope of Regulation (EU) No 1321/2014 means a set of interrelated or interacting organisation policies, procedures, standards and processes to achieve certain objectives under an overarching safety culture.
(b) Under point CAMO.A.200(d), an integrated management system occurs when the same organisation holds several approvals and its management system combines policies, procedures, and standards from various areas into a single structure, thus avoiding isolated procedures for common processes. The lines of responsibility and accountability of the organisation that holds an air operator certificate (AOC) and a CAMO approval are linked directly to the corporate authority of the operator’s accountable manager. This may be supported by a common manual (e.g. a common safety management manual).
(c) If organisations forming part of a single air carrier business grouping decide to facilitate the harmonisation of their management systems through standards, those standards will cover the common or consistent methods and procedures. Other elements of the management system may be covered at the discretion of the organisation, to provide flexibility and thus leverage synergy or cooperation. Harmonising management systems requires extensive and continuous exchange of information on hazard identification, safety risk management methods, strategic decisions, safety actions, compliance monitoring, and best practices.
(d) Within a single air carrier business grouping, the CAMO plays a key role in the cooperation between the operators that use that CAMO, and in the harmonisation of their management systems.
(e) Contracting a CAMO in accordance with point M.A.201(ea) implies that at least two operators will use that CAMO. As the operators’ management systems should be harmonised with the CAMO’s management system, they will also be harmonised with one another.
CAMO.A.202 Internal safety reporting scheme
Regulation (EU) 2019/1383
(a) As part of its management system, the organisation shall establish an internal safety reporting scheme to enable the collection and evaluation of such occurrences to be reported under point CAMO.A.160.
(b) The scheme shall also enable the collection and evaluation of those errors, near misses, and hazards reported internally that do not fall under point (a).
(c) Through this scheme, the organisation shall:
(1) identify the causes of and contributing factors to any errors, near misses, and hazards reported and address them as part of safety risk management in accordance with point (a)(3) of point CAMO.A.200;
(2) ensure evaluation of all known, relevant information relating to errors, the inability to follow procedures, near misses, and hazards, and a method to circulate the information as necessary.
(d) The organisation shall provide access to its internal safety reporting scheme to any subcontracted organisation.
(e) The organisation shall cooperate on safety investigations with any other organisation having a significant contribution to the safety of its own continuing airworthiness management activities.
AMC1 CAMO.A.202 Internal safety reporting scheme
ED Decision 2020/002/R
(a) Each internal safety reporting scheme should be confidential and enable and encourage free and frank reporting of any potentially safety-related occurrence, including incidents such as errors or near misses, safety issues and hazards identified. This will be facilitated by the establishment of a just culture.
(b) The internal safety reporting scheme should contain the following elements:
(1) clearly identified aims and objectives with demonstrable corporate commitment;
(2) a just culture policy as part of the safety policy, and related just culture implementation procedures;
(3) a process to:
(i) identify those reports which require further investigation; and
(ii) when so identified, investigate all the causal and contributing factors, including any technical, organisational, managerial, or HF issues, and any other contributing factors related to the occurrence, incident, error or near miss that was identified;
(iii) if adapted to the size and complexity of the organisation, analyse the collective data showing the trends and frequencies of the contributing factor;
(4) appropriate corrective actions based on the findings of investigations;
(5) initial and recurrent training for staff involved in internal investigations;
(6) where relevant, the organisation should cooperate with the owner or operator on occurrence investigations by exchanging relevant information to improve aviation safety.
(c) The internal safety reporting scheme should:
(1) ensure confidentiality to the reporter;
(2) be closed-loop, to ensure that actions are taken internally to address any safety issues and hazards; and
(3) feed into the recurrent training as defined in AMC2 CAMO.A.305(g) whilst maintaining appropriate confidentiality.
(d) Feedback should be given to staff both on an individual and a more general basis to ensure their continued support of the safety reporting scheme.
GM1 CAMO.A.202 Internal safety reporting scheme
ED Decision 2020/002/R
(a) The overall purpose of the internal safety reporting scheme is to collect information reported by the organisation personnel and use this reported information to improve the level of compliance and safety performance of the organisation. The purpose is not to attribute blame.
(b) The objectives of the scheme are to:
(1) enable an assessment to be made of the safety implications of each relevant incident (errors, near miss), safety issue and hazard reported, including previous similar issues, so that any necessary action can be initiated; and
(2) ensure that knowledge of relevant incidents, safety issues and hazards is shared so that other persons and organisations may learn from them.
(c) The scheme is an essential part of the overall monitoring function and should be complementary to the normal day-to-day procedures and ‘control’ systems; it is not intended to duplicate or supersede any of them. The scheme is a tool to identify those instances in which routine procedures have failed or may fail.
(d) All reports should be retained, as the significance of such reports may only become obvious at a later date.
(e) The collection and analysis of timely, appropriate and accurate data will allow the organisation to react to information that it receives, and apply the necessary action.
CAMO.A.205 Contracting and subcontracting
Regulation (EU) 2019/1383
(a) The organisation shall ensure that when contracting maintenance or when subcontracting any part of its continuing airworthiness management activities:
(1) these activities conform to the applicable requirements; and
(2) any aviation safety hazards associated with such contracting or subcontracting are considered as part of the organisation’s management system.
(b) When the organisation subcontracts any part of its continuing airworthiness management activities to another organisation, the subcontracted organisation shall work under the approval of the organisation. The organisation shall ensure that the competent authority is given access to the subcontracted organisation, to determine continued compliance with the applicable requirements.
GM1 CAMO.A.205 Contracting and subcontracting
ED Decision 2020/002/R
(a) Regardless of the approval status of the subcontracted organisations, the CAMO is responsible for ensuring that all subcontracted activities are subject to hazard identification and risk management, as required by point CAMO.A.200(a)(3), and to compliance monitoring, as required by point CAMO.A.200(a)(6).
(b) A CAMO is responsible for identifying hazards that may stem from the existence of complex operational and maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included) with due regard to the organisations’ interfaces (see GM1 CAMO.A.200(a)(3)). In addition, the compliance monitoring function should at least check that the approval of the contracted maintenance organisation(s) effectively covers the contracted activities, and that it is still valid.
(c) A CAMO is responsible for ensuring that interfaces and communication channels are established with the contracted maintenance organisation for occurrence reporting. This does not replace the obligation of the contracted organisation to report to the competent authority in accordance with Regulation (EU) No 1321/2014.
For subcontracted activities, interfaces and communication channels are also needed for the purpose of the internal safety reporting scheme (CAMO.A.202).
Regulation (EU) 2019/1383
The organisation shall provide suitable office accommodation at appropriate locations for the personnel specified in point CAMO.A.305.
ED Decision 2020/002/R
Office accommodation should be such that the incumbents, whether they are continuing airworthiness management, planning, technical records or management system staff, can carry out their designated tasks in a manner that contributes to good standards. The competent authority may agree to these tasks being conducted from one office subject to being satisfied that there is sufficient space and that each task can be carried out without undue disturbance. Office accommodation should also include an adequate technical library and room for document consultation.
Regulation (EU) 2019/1383
(a) Continuing airworthiness management records
(1) The organisation shall ensure that records required by points M.A.305, ML.A.305 and, if applicable point M.A.306, are retained.
(2) The organisation shall record all details of work carried out.
(3) If the organisation has the privilege referred to in point (e) of point CAMO.A.125, it shall retain a copy of each airworthiness review certificate and recommendation issued or, as applicable, extended, together with all supporting documents. In addition, the organisation shall retain a copy of any airworthiness review certificate that it has extended under the privilege referred to in point (d)(4) of point CAMO.A.125.
(4) If the organisation has the privilege referred to in point (f) of point CAMO.A.125, it shall retain a copy of each permit to fly issued in accordance with the provisions of point 21.A.729 of Annex I (Part-21) to Regulation (EU) No 748/2012.
(5) The organisation shall retain a copy of all records referred to in points (a)(2) to (a)(4) until 3 years after the responsibility for the aircraft in accordance with points M.A.201 or ML.A.201 has been permanently transferred to another person or organisation.
(6) Where the organisation terminates its operation, all retained records shall be transferred to the owner of the aircraft.
(b) Management system, contracting and subcontracting records
(1) The organisation shall ensure that the following records are retained:
(i) records of management system key processes as defined in point CAMO.A.200;
(ii) contracts, both for contracting and subcontracting, as defined in point CAMO.A.205;
(2) Management system records, as well as any contracts pursuant to point CAMO.A.205, shall be kept for a minimum period of 5 years.
(c) Personnel records
(1) The organisation shall ensure that the following records are retained:
(i) records of qualification and experience of personnel involved in continuing airworthiness management, compliance monitoring and safety management;
(ii) records of qualification and experience of all airworthiness review staff, as well as staff issuing recommendations and permits to fly.
(2) The records of all airworthiness review staff, staff issuing recommendations and staff issuing permits to fly shall include details of any appropriate qualification held together with a summary of the relevant continuing airworthiness management experience and training and a copy of the authorisation.
(3) Personnel records shall be kept as long as the person works for the organisation, and shall be retained until 3 years after the person has left the organisation.
(d) The organisation shall establish a system of record-keeping that allows adequate storage and reliable traceability of all activities developed.
(e) The format of the records shall be specified in the organisation’s procedures.
(f) Records shall be stored in a manner that ensures protection from damage, alteration and theft.
AMC1 CAMO.A.220 Record-keeping
ED Decision 2020/002/R
(a) The record-keeping system should ensure that all records are accessible within a reasonable time whenever they are needed. These records should be organised in a manner that ensures their traceability and retrievability throughout the required retention period.
(b) Records should be kept in paper form, or in electronic format, or a combination of the two. Records that are stored on microfilm or in optical disc formats are also acceptable. The records should remain legible throughout the required retention period. The retention period starts when the record is created or was last amended.
(c) Paper systems should use robust materials which can withstand normal handling and filing. Computer record systems should have at least one backup system, which should be updated within 24 hours of any new entry. Computer record systems should include safeguards to prevent unauthorised personnel from altering the data.
(d) All computer hardware that is used to ensure the backup of data should be stored in a different location from the one that contains the working data, and in an environment that ensures that the data remains in good condition. When hardware or software changes take place, special care should be taken to ensure that all the necessary data continues to be accessible through at least the full period specified in the relevant provision. In the absence of any such indications, all records should be kept for a minimum period of 3 years.
AMC2 CAMO.A.220 Record-keeping
ED Decision 2020/002/R
CONTINUING AIRWORTHINESS MANAGEMENT RECORDS
(a) The CAMO should ensure that it always receives a complete certificate of release to service from the approved maintenance organisation, independent certifying staff (M.A.801(b)(1) and ML.A.801(b)(2)) and/or from the Pilot-owner such that the required records can be retained. The system to keep the continuing airworthiness records should be described in the CAME.
(b) When a CAMO arranges for the relevant maintenance organisation to retain copies of the continuing airworthiness records on its behalf, it will nevertheless continue to be responsible for the records under point CAMO.A.220 relating to the preservation of records. If it ceases to be the CAMO of the aircraft, it also remains responsible for transferring the records to any other person or organisation managing continuing airworthiness of the aircraft.
ED Decision 2020/002/R
Microfilming or optical storage of records may be carried out at any time. The records should be as legible as the original record, and remain so for the required retention period.
AMC1 CAMO.A.220(c)(1)(ii) Record-keeping
ED Decision 2020/002/R
RECORDS OF AIRWORTHINESS REVIEW STAFF
The following minimum information, as applicable, should be kept on record in respect of each airworthiness review staff:
Name;
Date of birth;
Basic education;
Experience;
Aeronautical degree and/or Part-66 qualification and/or nationally-recognised maintenance personnel qualification;
Initial training received;
Type of training received;
Recurrent training received;
Experience in continuing airworthiness and within the organisation;
Responsibilities of current role in the organisation;
Copy of the authorisation.
CAMO.A.300 Continuing airworthiness management exposition (CAME)
Regulation (EU) 2020/270
(a) The organisation shall provide the competent authority with a CAME and, where applicable, any referenced associated manuals and procedures, containing all of 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, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, and with the approved CAME. When the accountable manager is not the chief executive officer of the organisation, then such chief executive officer shall countersign the statement;
(2) the organisation’s safety policy as defined in point (a)(2) of point CAMO.A.200;
(3) the organisation’s scope of work relevant to the terms of approval;
(4) a general description of the manpower resources and of the system in place to plan the availability of staff as required by point (d) of point CAMO.A.305;
(5) the title(s) and name(s) of person(s) referred to in points (a)(3) to (a)(5), (b)(2) and (f) of point CAMO.A.305;
(6) the duties, accountabilities, responsibilities and authorities of the persons nominated under points (a)(3) to (a)(5), (b)(2), (e) and (f) of point CAMO.A.305;
(7) an organisation chart showing the associated chains of accountability and responsibility between all the person(s) referred to in points (a)(3) to (a)(5), (b)(2), (e) and (f) of point CAMO.A.305, and related to point (a)(1) of point CAMO.A.200;
(8) a list of staff authorised to issue airworthiness review certificates or recommendations referred to in point (e) of point CAMO.A.305, specifying, where applicable, the staff authorised to issue permits to fly in accordance with point (c) of point CAMO.A.125;
(9) a general description and location of the facilities;
(10) the description of the internal safety reporting scheme as required by point CAMO.A.202;
(11) the procedures specifying how the organisation ensures compliance with this Annex, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, including in particular:
(i) the documentation of management system key processes as required by point CAMO.A.200;
(ii) procedures defining how the organisation controls any contracted and subcontracted activities as required by point CAMO.A.205 and point (c) of point CAMO.A.315);
(iii) continuing airworthiness management, airworthiness review and permit to fly procedures, as applicable;
(iv) the procedure defining the scope of changes not requiring prior approval and describing how such changes will be managed and notified, as required by point (b) of point CAMO.A.115 and point (c) of point CAMO.A.130;
(v) the CAME amendment procedures.
(12) the list of approved aircraft maintenance programmes for those aircraft for which a continuing airworthiness management contract exists in accordance with point M.A.201 or ML.A.201;
(13) the list of maintenance contracts in accordance with point (c) of point CAMO.A.315;
(14) the list of currently approved alternative means of compliance.
(b) The initial issue of the CAME shall be approved by the competent authority. It shall be amended as necessary to remain an up-to-date description of the organisation.
(c) Amendments to the CAME shall be managed as defined in the procedures referred to in points (a)(11)(iv) and (a)(11)(v). Any amendments not included in the scope of the procedure referred to in point (a)(11)(iv), as well as amendments related to the changes listed in point CAMO.A.130(a), shall be approved by the competent authority.
AMC1 CAMO.A.300 Continuing airworthiness management exposition (CAME)
ED Decision 2020/002/R
This AMC provides an outline of the layout of an acceptable CAME. Where an organisation uses a different format, for example, to allow the exposition to serve for more than one approval within the scope of Regulation (EU) 2018/1139, then the exposition should contain a cross-reference Annex using this list as an index with an explanation as to where the subject matter can be found in the exposition.
The information required by CAMO.A.300 should be provided, directly or by reference, in the CAME.
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Part 0 |
General organisation, safety policy and objectives |
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0.1 |
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Safety policy, objectives and accountable manager statement |
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0.2 |
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General information and scope of work |
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0.3 |
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Management personnel |
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0.4 |
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Management organisation chart |
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0.5 |
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Procedure for changes requiring prior approval |
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0.6 |
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Procedure for changes not requiring prior approval |
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0.7 |
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Procedure for alternative means of compliance (AltMoC) |
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Part 1 |
Continuing airworthiness management procedures |
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1.1a |
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Use of aircraft continuing airworthiness record system and if applicable, aircraft technical log (ATL) system |
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1.1b |
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MEL application |
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1.2 |
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Aircraft maintenance programme (AMP) — development amendment and approval |
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1.3 |
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Continuing airworthiness records: responsibilities, retention and access |
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1.4 |
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Accomplishment and control of airworthiness directives |
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1.5 |
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Analysis of the effectiveness of the maintenance programme(s) |
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1.6 |
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Non-mandatory modification and inspections |
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1.7 |
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Repairs and modifications |
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1.8 |
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Defect reports |
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1.9 |
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Engineering activity |
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1.10 |
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Reliability programmes |
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1.11 |
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Pre-flight inspections |
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1.12 |
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Aircraft weighing |
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1.13 |
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Maintenance check flight procedures |
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Part 2 |
Management system procedures |
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2.1 |
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Hazard identification and safety risk management schemes |
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2.2 |
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Internal safety reporting and investigations |
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2.3 |
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Safety action planning |
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2.4 |
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Safety performance monitoring |
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2.5 |
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Change management |
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2.6 |
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Safety training and promotion |
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2.7 |
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Immediate safety action and coordination with operator’s Emergency Response Plan (ERP) |
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2.8 |
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Compliance monitoring |
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2.8.1 |
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Audit plan and audit procedure |
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2.8.2 |
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Monitoring of continuing airworthiness management activities |
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2.8.3 |
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Monitoring of the effectiveness of the maintenance programme(s) |
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2.8.4 |
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Monitoring that all maintenance is carried out by an appropriate maintenance organisation |
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2.8.5 |
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Monitoring that all contracted maintenance is carried out in accordance with the contract, including subcontractors used by the maintenance contractor |
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2.8.6 |
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Compliance monitoring personnel |
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2.9 |
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Control of personnel competency |
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2.10 |
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Management system record-keeping |
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2.11 |
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Occurrence reporting |
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Part 3 |
Contracted maintenance — management of maintenance |
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3.1 |
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Maintenance contractor selection procedure |
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3.2 |
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Product audit of aircraft |
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Part 4 |
Airworthiness review procedures |
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4.1 |
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Airworthiness review staff |
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4.2 |
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Documented review of aircraft records |
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4.3 |
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Physical survey |
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4.4 |
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Additional procedures for recommendations to competent authorities for the import of aircraft |
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4.5 |
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ARC recommendations to competent authorities |
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4.6 |
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Issue of ARC |
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4.7 |
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Airworthiness review records, responsibilities, retention and access |
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4.8 |
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ARC extension |
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Part 4B |
Permit to fly procedures |
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4B.1 |
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Conformity with approved flight conditions |
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4B.2 |
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Issue of the permit to fly under the CAMO privilege |
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4B.3 |
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Permit to fly authorised signatories |
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4B.4 |
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Interface with the local authority for the flight |
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4B.5 |
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Permit to fly records, responsibilities, retention and access |
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Part 5 |
Supporting documents |
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5.1 |
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Sample documents, including the template of the ATL system |
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5.2 |
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List of airworthiness review staff |
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5.3 |
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List of subcontractors as per point CAMO.A.125(d)(3) |
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5.4 |
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List of contracted maintenance organisations and list of maintenance contracts as per point CAMO.A.300(a)(13) |
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5.5 |
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Copy of contracts for subcontracted work (Appendix II to AMC1 CAMO.A.125(d)(3)) |
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5.6 |
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List of approved maintenance programme as per point CAMO.A.300(a)(12) |
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5.7 |
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List of currently approved alternative means of compliance as per point CAMO.A.300(a)(13) |
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AMC2 CAMO.A.300 Continuing airworthiness management exposition (CAME)
ED Decision 2020/002/R
(a) Personnel should be familiar with those parts of the continuing airworthiness management exposition that are relevant to their tasks.
(b) The CAMO should designate the person responsible for monitoring and amending the CAME, including associated procedure’s manuals, in accordance with point CAMO.A.300(c).
(c) The CAMO may use electronic data processing (EDP) for the publication of the CAME. Attention should be paid to the compatibility of the EDP systems with the necessary dissemination, both internally and externally, of the CAME.
AMC3 CAMO.A.300 Continuing airworthiness management exposition (CAME)
ED Decision 2022/017/R
If a CAMO is contracted by operators forming part of a single air carrier business grouping (in accordance with point M.A.201(ea)) the CAME should also include how requirements and procedures that are specific to the different operators are implemented.
GM1 CAMO.A.300 Continuing airworthiness management exposition (CAME)
ED Decision 2020/002/R
The purpose of the CAME is to:
specify the scope of work and shows how the organisation intends to comply with this Annex; and
provides all the necessary information and procedures for the personnel of the organisation to perform their duties.
Complying with its contents will ensure the organisation remains in compliance with Part-CAMO and, as applicable, Part-M and/or Part-ML.
AMC1 CAMO.A.300(a)(1) Continuing airworthiness management exposition (CAME)
ED Decision 2022/017/R
1. Part 0 ‘General organisation, safety policy and objectives’ of the CAME should include a statement, signed by the accountable manager (and countersigned by the chief executive officer, if different), confirming that the CAME and any associated manuals will be complied with at all times.
2. The accountable manager’s exposition statement as specified in point CAMO.A.300(a)(1) 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 and any associated referenced manuals define the organisation and procedures upon which the competent authority’s* CAMO approval is based.
These procedures are endorsed by the undersigned and must be complied with, as applicable, in order to ensure that all continuing airworthiness activities, including maintenance of the aircraft managed, are carried out on time to an approved standard.
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 approval of the organisation is based on the continuous compliance of the organisation with Part-CAMO, Part-M and Part-ML, as applicable, and with the organisation’s procedures described in this exposition. The competent authority* is entitled to limit, suspend, or revoke the approval certificate if the organisation fails to fulfil the obligations imposed by Part-CAMO, Part-M and Part-ML, as applicable, or any conditions according to which the approval was issued.
For organisations also approved as air carriers licensed in accordance with Regulation (EC) No 1008/200843, suspension or revocation of the CAMO certificate will invalidate the air operator certificate (AOC) of such air carriers.
Signed .....................................
Dated ......................................
Accountable manager and ... (quote position) ...
Chief Executive Officer …
For and on behalf of ... (quote organisation’s name) ... ’
*Where ‘competent authority’ is stated, please insert the actual name of the competent authority delivering the CAMO approval certificate 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.
CAMO.A.305 Personnel requirements
Regulation (EU) 2022/410
(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 Regulation (EU) 2018/1139 and delegated and implementing acts adopted on the basis thereof. The accountable manager shall:
(1) ensure that all necessary resources are available to manage continuing airworthiness in accordance with this Annex, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, to support the organisation approval certificate;
(2) establish and promote the safety policy specified in point CAMO.A.200;
(3) nominate a person or group of persons 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, Annex I (Part-M) and Annex Vb (Part-ML);
(4) nominate a person or group of persons with the responsibility for managing the compliance monitoring function as part of the management system;
(5) nominate a person or group of persons with the responsibility for managing the development, administration, and maintenance of effective safety management processes as part of the management system;
(6) ensure that the person or group of persons nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305 have direct access to keep him/her properly informed on compliance and safety matters;
(7) demonstrate a basic understanding of this Regulation.
(b) For organisations also approved as air carriers licensed in accordance with Regulation (EC) No 1008/2008, the accountable manager shall in addition:
(1) be the person appointed as accountable manager for the air carrier as required by point (a) of point ORO.GEN.210 of Annex III (Part-ORO) to Regulation (EU) No 965/2012;
(2) nominate a person responsible for the management and supervision of continuing airworthiness, who shall not be employed by an organisation approved in accordance with Annex II (Part-145) under contract to the operator, unless specifically agreed by the competent authority.
(ba) If involved in continuing airworthiness management activities related to a contract established in accordance with point M.A.201(ea), the person or persons nominated in accordance with point (a)(3) of point CAMO.A.305 shall not be employed by an organisation approved in accordance with Annex II (Part-145) under contract to the CAMO, unless specifically agreed by the competent authority.
(c) The person or persons nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305 shall be able to demonstrate relevant knowledge, background and satisfactory experience related to aircraft continuing airworthiness management and demonstrate a working knowledge of this Regulation. Such person(s) shall be ultimately responsible to the accountable manager.
(d) The organisation shall have a system in place to plan the availability of staff to ensure that the organisation has sufficient appropriately qualified staff to plan, perform, supervise, inspect and monitor the organisation’s activities in accordance with the terms of approval.
(e) To be approved to carry out airworthiness reviews or recommendations in accordance with point (e) of point CAMO.A.125 and, if applicable, to issue permits to fly in accordance with point (f) of point CAMO.A.125, the organisation shall have airworthiness review staff qualified and authorised in accordance with point CAMO.A.310.
(f) For organisations extending airworthiness review certificates in accordance with point (d)(4) of point CAMO.A.125, the organisation shall nominate persons authorised to do so.
(g) The organisation shall establish and control the competency of personnel involved in compliance monitoring, safety management, continuing airworthiness management, airworthiness reviews or recommendations, and, if applicable, issuing permits to fly, in accordance with a procedure and to a standard agreed by the competent authority. In addition to the necessary expertise related to the job function, competency must include an understanding of safety management and human factors principles appropriate to the person’s function and responsibilities in the organisation.
AMC1 CAMO.A.305(a) Personnel requirements
ED Decision 2020/002/R
Accountable manager is normally intended to mean the chief executive officer of the CAMO, who by virtue of his or her position, has overall (including in particular financial) responsibility for running the organisation. The accountable manager may be the accountable manager for more than one organisation, and is not necessarily required to be knowledgeable on technical matters, as the CAME defines the continuing airworthiness standards. When the accountable manager is not the chief executive officer, the organisation should demonstrate to the competent authority that the accountable manager has direct access to the chief executive officer and has the necessary funding allocation for the continuing airworthiness management activities sought.
AMC1 CAMO.A.305(a)(3) Personnel requirements
ED Decision 2020/002/R
MANAGEMENT STRUCTURE FOR CONTINUING AIRWORTHINESS MANAGEMENT
The person or group of persons nominated under point CAMO.A.305(a)(3) with the responsibility for ensuring compliance should represent the management structure of the organisation, and be responsible for the daily operation of the organisation, for all continuing airworthiness management functions.
Dependent on the size of the operation and the organisational set-up, the continuing airworthiness management functions may be divided under individual managers or combined in any number of ways.
GM1 CAMO.A.305(a)(3) Personnel requirements
ED Decision 2020/002/R
RESPONSIBILITY FOR ENSURING COMPLIANCE
The person(s) nominated in accordance with CAMO.A.305(a)(3) are responsible, in the day-to-day continuing airworthiness management activities, for ensuring that the organisation personnel work in accordance with the applicable procedures and regulatory requirements.
These nominated persons should demonstrate a complete understanding of the applicable regulatory requirements, and ensure that the organisation’s processes and standards accurately reflect the applicable requirements. It is their role to ensure that compliance is proactively managed, and that any early warning signs of non-compliance are documented and acted upon.
AMC1 CAMO.A.305(a)(4);(a)(5) Personnel requirements
ED Decision 2020/002/R
SAFETY MANAGEMENT AND COMPLIANCE MONITORING FUNCTION
If more than one person is designated for the development, administration and maintenance of effective safety management processes, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘safety manager’.
The functions of the safety manager should be to:
(i) facilitate hazard identification, risk assessment and management;
(ii) monitor the implementation of actions taken to mitigate risks, as listed in the safety action plan, unless action follow-up is addressed by the compliance monitoring function;
(iii) provide periodic reports on safety performance to the safety review board (the functions of the safety review board are those defined in AMC1 CAMO.A.200(a)(1));
(iv) ensure the maintenance of safety management documentation;
(v) ensure that there is safety training available, and that it meets acceptable standards;
(vi) provide advice on safety matters; and
(vii) ensure the initiation and follow-up of internal occurrence investigations.
(b) Compliance monitoring function
If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘compliance monitoring manager’.
(1) The role of the compliance monitoring manager should be to ensure that:
(i) the activities of the organisation are monitored for compliance with the applicable requirements and any additional requirements as established by the organisation, and that these activities are carried out properly under the supervision of the nominated persons referred to in points CAMO.A.305(a)(3) to (a)(5).
(ii) any contracted maintenance is monitored for compliance with the contract or work order;
(iii) an audit plan is properly implemented, maintained, and continually reviewed and improved; and
(iv) corrections and corrective actions are requested as necessary.
(2) The compliance monitoring manager should:
(i) not be one of the persons referred to in point CAMO.A.305(a)(3);
(ii) be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the organisation, including knowledge and experience in compliance monitoring; and
(iii) have access to all parts of the organisation, and as necessary, any subcontracted organisation.
(c) If the functions related to compliance monitoring or safety management are combined with other duties, the organisation should ensure this does not result in any conflicts of interest. In particular, the compliance monitoring function should be independent from the continuing airworthiness management functions.
(d) If the same person is designated to manage both the compliance monitoring function and safety management-related processes and tasks, the accountable manager, with regard to his or her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the organisation, and the nature and complexity of its activities.
(e) Subject to a risk assessment and/or mitigation actions, and agreement by the competent authority, with due regard to the size of the organisation and the nature and complexity of its activities, the compliance monitoring manager role and/or safety manager role may be exercised by the accountable manager, provided that he or she has demonstrated the related competency as defined in point (b)(2)(ii).
GM1 CAMO.A.305(a)(5) Personnel requirements
ED Decision 2020/002/R
(a) Depending on the size of the organisation and the nature and complexity of its activities, the safety manager may be assisted by additional safety personnel in performing all the safety management tasks as defined in AMC1 CAMO.A.200(a)(1).
(b) Regardless of the organisational set-up, it is important that the safety manager remains the unique focal point for the development, administration, and maintenance of the organisation’s safety management processes.
GM1 CAMO.A.305(b) Personnel requirements
ED Decision 2022/017/R
When a CAMO is contracted (in accordance with point M.A.201(ea)) by one or more operators that form part of a single air carrier business grouping but not of the same legal entity, those operator(s) and CAMO do not have to appoint the same accountable manager.
AMC1 CAMO.A.305(b)(2) Personnel requirements
ED Decision 2020/002/R
(a) When the licensed air carrier intends to nominate a CAMO post holder who is also employed by a Part-145 organisation, it should justify why such nomination is being made and support it through a risk assessment and/or mitigation actions.
(b) This paragraph only applies to contracted maintenance and therefore does not affect situations where the organisation approved under Part-145 and the air carrier licensed in accordance with Regulation (EC) No 1008/2008 are the same organisation.
AMC1 CAMO.A.305(c) Personnel requirements
ED Decision 2022/011/R
KNOWLEDGE, BACKGROUND AND EXPERIENCE OF NOMINATED PERSON(S)
The person or persons nominated in accordance with points CAMO.A.305(a) and CAMO.A.305(b) should have:
(a) practical experience and expertise in the application of aviation safety standards and safe operating practices;
(b) a comprehensive knowledge of:
(i) relevant parts of operational requirements and procedures;
(ii) the AOC holder's operations specifications when applicable;
(iii) the need for, and content of, the relevant parts of the AOC holder's operations manual when applicable.
(c) knowledge of:
(i) HF principles;
(ii) safety management systems based on the EU management system requirements (including compliance monitoring) and ICAO Annex 19.
(d) 5 years of relevant work experience, of which at least 2 years should be from the aeronautical industry in an appropriate position;
(e) a relevant engineering degree or an aircraft maintenance technician qualification with additional education that is acceptable to the competent authority. ‘Relevant engineering degree’ means an engineering degree from aeronautical, mechanical, electrical, electronic, avionics or other studies that are relevant to the maintenance and/or continuing airworthiness of aircraft/aircraft components;
The above recommendation may be replaced by 5 years of experience in addition to those already recommended by paragraph (d) above. These 5 years should cover an appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks;
For the person to be nominated in accordance with point (a)(4) or (a)(5) of point CAMO.A.305, in the case where the organisation holds one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and that person has already an equivalent position (i.e. compliance monitoring manager, safety manager) under the additional certificate(s) held, the provisions set out in the first two paragraphs of point (e) may be replaced by the completion of a specific training programme acceptable to the competent authority to gain an adequate understanding of maintenance standards and continuing airworthiness concepts and principles.
(f) thorough knowledge of the organisation's CAME;
(g) knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course. These courses should be at least 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.
‘Relevant sample’ means that these courses should cover typical aircraft and aircraft systems that are within the scope of work.
For all balloons and any other aircraft of 2 730 kg MTOM or less, the formalised training courses may be replaced by a demonstration of the required knowledge by providing documented evidence, or by an assessment performed by the competent authority. This assessment should be recorded.
(h) knowledge of maintenance methods;
(i) knowledge of the applicable regulations.
AMC1 CAMO.A.305(d) Personnel requirements
ED Decision 2020/002/R
SUFFICIENT NUMBER OF PERSONNEL
(a) The actual number of persons to be employed and their necessary qualifications is dependent upon the tasks to be performed and thus dependent on the size, nature and complexity of the organisation (general aviation aircraft, corporate aircraft, number of aircraft and the aircraft types, complexity of the aircraft and their age and for commercial air transport, route network, line or charter, ETOPS) and the amount and complexity of maintenance contracting. Consequently, the number of persons needed, and their qualifications may differ greatly from one organisation to another and a simple formula covering the whole range of possibilities is not feasible.
(b) To implement a system to plan the availability of staff and to enable the competent authority to accept the number of persons and their qualifications, the organisation should make an analysis of the tasks to be performed, the way in which it intends to divide and/or combine these tasks, indicate how it intends to assign responsibilities and establish the number of man/hours and the qualifications needed to perform the tasks. This analysis should be kept up to date and reviewed in case of significant changes to the organisation.
(c) In addition, as part of its management system in accordance with point CAMO.A.200, the organisation should have a procedure to assess and mitigate risks:
(1) when actual staff availability is less than the planned staffing level for any particular work shift or period;
(2) in case of a temporary increase of the proportion of contracted staff for the purpose of meeting specific operational needs.
GM1 CAMO.A.305(f) Personnel requirements
ED Decision 2020/002/R
PERSONS AUTHORISED TO EXTEND AIRWORTHINESS REVIEW CERTIFICATES
The approval by the competent authority of the exposition, containing, as specified in point CAMO.A.300(a)(5), the list of point CAMO.A.305(f) personnel authorised to extend airworthiness review certificates, constitutes their formal acceptance by the competent authority and also their formal authorisation by the organisation.
Airworthiness review staff are automatically recognised as persons with authority to extend an airworthiness review certificate in accordance with points CAMO.A.125(e)(1), M.A.901(f) and ML.A.901(c).
AMC1 CAMO.A.305(g) Personnel requirements
ED Decision 2022/017/R
COMPETENCY ASSESSMENT OBJECTIVES
The procedure referred to in point CAMO.A.305(g) should require amongst others that technical support personnel such as, planners, engineers, and technical record staff, supervisors, post-holders, airworthiness review staff, whether employed or contracted, are assessed for competency before unsupervised work commences and competency is controlled on a continuous basis.
Competency should be assessed by the evaluation of:
on-the-job performance and/or testing of knowledge by appropriately qualified personnel;
records for basic, organisational, and/or product type and differences training; and
experience records.
Validation of the above could include a confirmation check with the organisation(s) that issued such document(s). For that purpose, experience/training may be recorded in a document such as a log book.
As a result of this assessment, an individual’s qualification should determine:
which level of ongoing supervision would be required and whether unsupervised work could be permitted;
whether there is a need for additional training.
A record should be kept of each individual’s qualifications and competency assessment (refer also to point CAMO.A.220(c)). This should include copies of all documents that attest to their qualifications, such as an authorisation held, as applicable.
For a proper competency assessment of its personnel, the organisation should consider the following:
(a) In accordance with the job function, adequate initial and recurrent training should be provided and recorded to ensure continued competency so that it is maintained throughout the duration of the employment/contract.
(b) All staff should be able to demonstrate knowledge of, and compliance with, the CAMO procedures, as applicable to their duties.
(c) All staff should be able to demonstrate an understanding of safety management principles including HF, related to their job function and be trained as per AMC3 CAMO.A.305(g).
(d) To assist in the assessment of competency and to establish the training needs analysis, job descriptions are recommended for each job function in the organisation. Job descriptions should contain sufficient criteria to enable the required competency assessment.
(e) Criteria should allow the assessment to establish that, among other aspects (titles might be different in each organisation):
(1) Managers are able to properly manage processes, resources and priorities described in their assigned duties, accountabilities and responsibilities in accordance with the safety policy and objectives and in compliance with the applicable requirements and procedures.
(2) Maintenance programme engineers are able to interpret source data (norms, data issued by the holder of a design approval or by the competent authority, etc.) and use them to develop the aircraft maintenance programme.
(3) Engineering staff are able to interpret source data (norms, data issued by the holder of a design approval or by the competent authority, etc.) and use them as needed (e.g. to make work cards).
(4) Planners are able to organise maintenance activities in an effective and timely manner.
(5) Compliance monitoring staff are able to monitor compliance with this Regulation and to identify non-compliances in an effective and timely manner so that the organisation may remain in compliance with this Regulation.
(6) Staff who have been designated safety management responsibilities are familiar with the relevant processes in terms of hazard identification, risk management, and the monitoring of safety performance.
(7) All staff are familiar with the safety policy and the procedures and tools that can be used for internal safety reporting.
(8) If the CAMO is contracted by air carriers forming part of a single air carrier business grouping (in accordance with point M.A.201(ea)), the CAMO should ensure that all relevant personnel have sufficient skills in the agreed common language, e.g. English.
(f) The competency assessment should be based upon the procedure specified in AMC2 CAMO.A.305(g).
AMC2 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
COMPETENCY ASSESSMENT PROCEDURE
(a) The organisation should develop a procedure that describes the process for conducting competency assessment of personnel. The procedure should specify:
(1) the persons who are responsible for this process;
(2) when the assessment should take place;
(3) how to give credit from previous assessments;
(4) how to validate qualification records;
(5) the means and methods to be used for the initial assessment;
(6) the means and methods to be used for the continuous control of competency, including to gather feedback on the performance of personnel;
(7) the aspects of competencies to be observed during the assessment in relation to each job function;
(8) the actions to be taken if the assessment is not satisfactory; and
(9) how to record assessment results.
(b) Competency may be assessed by having the person work under the supervision of another qualified person for a sufficient time to arrive at a conclusion. Sufficient time could be as little as a few weeks if the person is fully exposed to relevant work. The person need not be assessed against the complete spectrum of their intended duties. If the person has been recruited from another approved CAMO, it is reasonable to accept a written confirmation from the previous organisation.
(c) All prospective continuing airworthiness management staff should be assessed for their competency related to their intended duties.
AMC3 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
SAFETY TRAINING (INCLUDING HUMAN FACTORS)
(a) With respect to the understanding of the application of safety management principles (including HF), all organisation personnel should be assessed for the need to receive initial safety training.
Personnel involved in the delivery of the basic continuing airworthiness management services of the organisation should receive both initial and recurrent safety training, appropriate for their responsibilities.
This should include at least the following staff members:
nominated persons, line managers;
persons involved in any compliance monitoring and/or safety management related processes and tasks, including application of HF principles, internal investigations and safety training;
airworthiness review staff;
technical support personnel such as, planners, engineers, and technical record staff;
personnel involved in developing and amending/reviewing the AMP, in assessing its effectiveness and/or working on reliability programme; and
contract staff in the above categories.
The generic term ‘line managers’ refers to departmental head or person responsible for operational departments or functional units directly involved in the delivery of the basic continuing airworthiness management services of the organisation.
(b) Initial safety training should cover all the topics of the training syllabus specified in GM2 CAMO.A.305(g) either as a dedicated course or else integrated within other training. The syllabus may be adjusted to reflect the particular nature of the organisation. The syllabus may also be adjusted to suit the particular nature of work for each function within the organisation.
Initial safety training compliant with the organisation’s training standards should be provided to personnel identified in accordance with point (a) of this AMC within 6 months of joining the organisation, but temporary staff may need to be trained shortly after joining the organisation to cope with the duration of employment. Personnel being recruited from another organisation, and temporary staff should be assessed for the need to receive any additional safety training.
(c) The purpose of recurrent safety training is primarily to ensure that staff remain current in terms of SMS principles and HF, and also to collect feedback on safety and HF issues. Consideration should be given to involving compliance monitoring staff and key safety management personnel in this training to provide a consistent presence and facilitate feedback. There should be a procedure to ensure that feedback is formally reported by the trainers through the internal safety reporting scheme to initiate action where necessary.
Recurrent safety training should be delivered either as a dedicated course or else integrated within other training. It should be of an appropriate duration in each 2-year period, in relation to the relevant compliance monitoring audit findings and other internal/external sources of information available to the organisation on safety and HF issues.
(d) Safety training may be conducted by the organisation itself, independent trainers, or any training organisations acceptable to the competent authority.
AMC4 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
(a) The organisation should assess the need for particular training; for example, with regard to the competency standards established in AMC 20-22 ‘Electrical Wiring Interconnection System’ (EWIS), the AMC 20-20 ‘Continuing Structural Integrity Programme’ or ‘Critical Design Configuration Control’ (CDCCL).
(b) Guidance on fuel tank safety training is provided in Appendix III to AMC4 CAMO.A.305(g).
(c) Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting, and recording.
(d) Personnel involved in developing and amending/reviewing the AMP, in assessing its effectiveness and/or working on reliability programme, should have knowledge of or be trained on statistical analysis and reliability method and the applicable methodology used in developing, as part of the instructions for continuing airworthiness (ICA), the manufacturer recommended maintenance programme (such as maintenance steering group logic).
AMC5 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
INITIAL AND RECURRENT TRAINING
(a) Adequate initial and recurrent training should be provided and recorded to ensure that staff remain competent.
(b) Recurrent training should take into account certain information reported through the internal safety reporting scheme (see point (c)(3) of AMC1 CAMO.A.202).
GM1 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
SAFETY TRAINING (INCLUDING HUMAN FACTORS)
(a) The scope of the safety training and the related training programme will differ significantly depending on the size and complexity of the organisation. Safety training should reflect the evolving management system, and the changing roles of the personnel who make it work.
(b) In recognition of this, training should be provided to management and staff at least:
(1) during the initial implementation of safety management processes;
(2) for all new staff or personnel recently allocated to any safety management related task;
(3) on a regular basis to refresh their knowledge and to understand changes to the management system;
(4) when changes in personnel affect safety management roles, and related accountabilities, responsibilities, and authorities; and
NOTE: In the context of safety management, the term ‘authority’ is used in relation to the level of management in the organisation that is necessary to make decisions related to risk tolerability.
(5) when performing dedicated safety functions in domains such as safety risk management, compliance monitoring, internal investigations.
(c) Safety training is subject to the record-keeping requirements in point CAMO.A.220(c).
GM2 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
TRAINING SYLLABUS FOR INITIAL SAFETY TRAINING
The training syllabus below identifies the topics and subtopics that should be addressed during the safety training.
The CAMO may combine, divide, or change the order of any of the subjects in the syllabus to suit its own needs, as long as all the subjects are covered to a level of detail that is appropriate for the organisation and its personnel, including the varying level of seniority of that personnel.
Some of the topics may be covered in separate training courses (e.g. health and safety, management, supervisory skills, etc.) in which case duplication of the training is not necessary.
Where possible, practical illustrations and examples should be used, especially accident and incident reports.
Topics should be related to existing legislation, where relevant. Topics should be related to existing guidance/advisory material, where relevant (e.g. ICAO HF Digests and Training Manual).
Topics should be related to continuing airworthiness management and maintenance engineering where possible; too much unrelated theory should be avoided.
1 General/Introduction to safety management and HF
1.1 Need to address safety management and HF
1a.1. Hazard identification
1a.2. Safety risk assessment
1a.3. Risk mitigation and management
1a.4. Effectiveness of safety risk management
2 Safety Culture/Organisational factors
2.5 Behaviour
2.6 Information
3.2 Types of errors in continuing airworthiness management and maintenance tasks
3.5 Avoiding and managing errors
4 Human performance & limitations
4.7 Claustrophobia and physical access
4.13 Alcohol, medication, drugs
4.15 Repetitive tasks/complacency
5.3 Time pressure and deadlines
5.11 Other hazards in the workplace
5.13 Distractions and interruptions
6 Procedures, information, tools and practices
6.2 Work logging and recording
6.3 Procedure — practice/mismatch/norms
6.4 Technical documentation — access and quality
7.2 Dissemination of information
8.2 Management, supervision and leadership
9 Professionalism and integrity
9.1 Keeping up to date; currency
9.2 Avoiding error-provoking behaviour
10 Organisation’s safety programme
10.1 Safety policy and objectives, just culture principles
10.2 Reporting errors and hazards, internal safety reporting scheme
10.4 Action to address problems
10.5 Feedback and safety promotion
GM3 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
COMPETENCY OF THE SAFETY MANAGER
The competency of a safety manager should include, but not be limited to, the following:
(a) knowledge of ICAO standards and European requirements on safety management;
(b) an understanding of management systems, including compliance monitoring systems;
(c) an understanding of risk management;
(d) an understanding of safety investigation techniques and root cause methodologies;
(e) an understanding of HF;
(f) understanding and promotion of a positive safety culture;
(g) operational experience related to the activities of the organisation;
(h) safety management experience;
(i) interpersonal and leadership skills, and the ability to influence staff;
(j) oral and written communications skills;
(k) data management, analytical and problem-solving skills.
CAMO.A.310 Airworthiness review staff qualifications
Regulation (EU) 2019/1383
(a) Airworthiness review staff issuing airworthiness review certificates or recommendations in accordance with point (e) of point CAMO.A.125 and, if applicable, issuing permits to fly in accordance with point (f) of point CAMO.A.125 shall have:
(1) at least 5 years of experience in continuing airworthiness;
(2) acquired an appropriate licence in compliance with Annex (III) Part-66 or an aeronautical degree or a national equivalent;
(3) received formal aeronautical maintenance training;
(4) held a position within the approved organisation with appropriate responsibilities.
(b) Notwithstanding points (a)(1), (a)(3) and (a)(4), the requirement laid down in point (a)(2) may be replaced with 5 years of experience in continuing airworthiness additional to those already required by point (a)(1).
(c) Airworthiness review staff nominated by the organisation can only be issued an authorisation by that 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 authorised airworthiness review staff, in accordance with a procedure approved by the competent authority as part of the CAME.
(d) The organisation shall ensure that aircraft airworthiness review staff can demonstrate appropriate, recent continuing airworthiness management experience.
AMC1 CAMO.A.310(a) Airworthiness review staff qualifications
ED Decision 2020/002/R
(a) Airworthiness review staff are only required if the CAMO wants to be granted CAMO.A.125(e) airworthiness review and, if applicable, CAMO.A.125(f) permit to fly privileges.
(b) ‘Experience in continuing airworthiness’ means any appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks.
(c) A person qualified according to AMC1 CAMO.A.305(c) subparagraph (e) should be considered as holding the equivalent to an aeronautical degree.
(d) An appropriate licence in compliance with Annex III (Part-66) is any one of the following:
a category B1 or L licence in the subcategory of the aircraft reviewed, or
a category B2 or C licence, or
in the case of piston-engine non-pressurised aeroplanes of 2 000 kg MTOM and below, a category B3 licence.
It is not necessary to satisfy the experience requirements of Part-66 at the time of the review.
(e) To hold a position with appropriate responsibilities means the airworthiness review staff should have a position in the organisation independent from the airworthiness management process or with overall authority on the airworthiness management process of complete aircraft.
Independence from the airworthiness management process may be achieved, among other ways, as follows:
By being authorised to perform airworthiness reviews only on aircraft for which the person has not participated in their management. For example, performing airworthiness reviews on a specific aircraft type, while being involved in the continuing airworthiness management of a different aircraft type.
A CAMO holding a maintenance organisation approval may nominate maintenance personnel from their maintenance organisation as airworthiness review staff, as long as they are not involved in the airworthiness management of the aircraft. These personnel should not have been involved in the release to service of that particular aircraft (other than maintenance tasks performed during the physical survey of the aircraft or performed as a result of findings discovered during such physical survey) to avoid possible conflict of interests.
By nominating as airworthiness review staff personnel from the compliance monitoring department of the CAMO.
Overall authority on the airworthiness management process of complete aircraft may be achieved, among other ways, as follows:
By nominating as airworthiness review staff the accountable manager or the nominated post holder.
By being authorised to perform airworthiness reviews only on those particular aircraft for which the person is responsible for the complete continuing airworthiness management process.
In the case of one-man organisations, this person has always overall authority. This means that this person can be nominated as airworthiness review staff.
AMC1 CAMO.A.310(a)(3) Airworthiness review staff qualifications
ED Decision 2020/002/R
FORMAL AERONAUTICAL MAINTENANCE TRAINING
Formal aeronautical maintenance training means training (internal or external) supported by evidence on the following subjects:
Relevant parts of initial and continuing airworthiness regulations;
Relevant parts of operational requirements and procedures, if applicable;
The organisation’s continuing airworthiness management exposition;
Knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course. These courses should be at least 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.
‘Relevant sample’ means that these courses should cover typical aircraft and aircraft systems that are within the scope of work.
Maintenance methods.
AMC1 CAMO.A.310(c) Airworthiness review staff qualifications
ED Decision 2020/002/R
FORMAL ACCEPTANCE BY THE COMPETENT AUTHORITY
The approval by the competent authority of the CAME, containing, as specified in point CAMO.A.300(a)(8), the nominative list of CAMO.A.305(e) personnel, constitutes the formal acceptance by the competent authority of the airworthiness review staff.
If the airworthiness review is performed under the supervision of existing airworthiness review staff, evidence should be provided to the competent authority.
The inclusion of an airworthiness review staff in such CAME list also constitutes the formal authorisation by the organisation.
AMC1 CAMO.A.310(d) Airworthiness review staff qualifications
ED Decision 2020/002/R
RECENT EXPERIENCE AND VALIDITY
In order to keep the validity of the airworthiness review staff authorisation, the airworthiness review staff should have either:
been involved in continuing airworthiness management activities for at least 6 months in every 2-year period, or
conducted at least one airworthiness review in the last 12-month period.
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 authorised airworthiness review staff of the continuing airworthiness management organisation concerned in accordance with an approved procedure.
CAMO.A.315 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 Annex I (Part-M), or Section A Subpart C of Annex Vb (Part-ML), as applicable.
(b) For every aircraft managed, the organisation shall in particular:
(1) ensure that an aircraft maintenance programme including any applicable reliability programme, as required by point M.A.302 or ML.A.302 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 or ML.A.201 as applicable;
(3) ensure that data used for any modification and repairs complies with points M.A.304 or ML.A.304 as applicable;
(4) for all complex motor-powered aircraft or aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, establish a procedure to assess non-mandatory modifications and/or inspections and decide on their application, making use of the organisation’s safety risk management process as required by point (a)(3) of point CAMO.A.200;
(5) ensure that the aircraft, engine(s), propeller(s) and components thereof are taken to an appropriately approved maintenance organisation referred to in Subpart F of Annex I (Part-M), Annex II (Part-145) or Annex Vd (Part-CAO) whenever necessary;
(6) order maintenance, supervise activities, and coordinate related decisions to ensure that any maintenance is carried out properly and is appropriately released for the determination of aircraft airworthiness.
(c) Where the organisation is not appropriately approved in accordance with Subpart F of Annex I (Part-M), Annex II (Part-145) or Annex Vd (Part-CAO) it shall, in consultation with the operator, manage the written maintenance contracts required by points (e)(3), (f)(3), (g)(3) and (h)(3) of M.A.201 or point ML.A.201 to ensure that:
(1) all maintenance is ultimately carried out by an appropriately approved maintenance organisation;
(2) the functions required under points (b), (c), (f) and (g) of point M.A.301 of Annex I (Part‑M) or point ML.A.301 of Annex Vb (Part-ML), as applicable, are clearly specified.
(d) Notwithstanding point (c), the contract may be in the form of individual work orders addressed to the maintenance organisation in the case of:
(1) an aircraft requiring unscheduled line maintenance;
(2) component maintenance, including engine and propeller maintenance, as applicable.
(e) The organisation shall ensure that human factors and human performance limitations are taken into account during continuing airworthiness management, including all contracted and subcontracted activities.
AMC1 CAMO.A.315 Continuing airworthiness management
ED Decision 2020/002/R
The CAMO should have adequate knowledge of the design information and aircraft configuration (type specification, customer options, airworthiness directives (ADs), airworthiness limitations contained in the aircraft ICA, modifications, repairs, operational and emergency equipment) and of the required and performed maintenance. The status of aircraft configuration and maintenance should be adequately documented to support the management system.
For CS-25 aeroplanes, adequate knowledge of the airworthiness limitations should cover those contained in CS-25 Book 1, Appendix H, paragraph H25.4 and fuel tank system airworthiness limitations including critical design configuration control limitations (CDCCL).
GM1 CAMO.A.315(b)(1) Continuing airworthiness management
ED Decision 2020/002/R
AIRCRAFT MAINTENANCE PROGRAMME
In accordance with M.A.302 and ML.A.302, the CAMO requirement to ‘control’ the AMP includes in particular:
(i) in the case of aircraft complying with Part-ML, the approval of the AMP and its amendments;
(ii) in the case of aircraft complying with Part-M, the presentation of the AMP and its amendments to the competent authority for approval, unless the approval is covered by an indirect approval procedure in accordance with M.A.302(c).
AMC1 CAMO.A.315(b)(3) Continuing airworthiness management
ED Decision 2020/002/R
When managing the approval of modifications or repairs, the organisation should ensure that CDCCL are taken into account.
AMC1 CAMO.A.315(b)(4) Continuing airworthiness management
ED Decision 2020/002/R
ASSESSMENT OF NON-MANDATORY INFORMATION
The CAMO managing the continuing airworthiness of the aircraft should establish and work according to a policy, which assesses non-mandatory information (modification or inspections) related to the airworthiness of the aircraft. Non-mandatory information refers to service bulletins, service letters and other information that is produced for the aircraft and its components by an approved design organisation, the manufacturer, the competent authority or the Agency.
GM1 CAMO.A.315(b)(5) Continuing airworthiness management
ED Decision 2020/002/R
This requirement means that the CAMO is responsible for determining what maintenance is required, when it has to be performed, by whom and to what standard in order to ensure the continuing airworthiness of the aircraft.
AMC1 CAMO.A.315(c) Continuing airworthiness management
ED Decision 2020/002/R
(a) As provided for in M.A.201 or ML.A.201, when the operator is approved as a CAMO, or when the operator/owner contracts a CAMO, this CAMO is in charge of the continuing airworthiness management and this includes the tasks specified:
for Part-M aircraft, in M.A.301 points (b), (c), (e), (f), (g) and (h);
for Part-ML aircraft, in ML.A.301 points (b), (c), (d) and (e).
If the CAMO does not hold the appropriate maintenance organisation approval (Part-M Subpart F, Part-CAO or a Part-145 approval), then the CAMO should conclude a contract with the appropriate organisation(s).
(b) The CAMO 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.
(c) The CAMO should agree with the operator on the process to select a maintenance organisation before concluding any contract with a maintenance organisation.
(d) The fact that the CAMO 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 CAMO and the maintenance organisation(s) should specify in detail the responsibilities and the work to be performed by each party.
(f) Both the specification of work and the assignment of responsibilities should be clear, unambiguous and sufficiently detailed to ensure that no misunderstanding arises between the parties concerned that could result in a situation where work that has an effect on the airworthiness or serviceability of aircraft is not or will not be properly performed.
(g) Special attention should be paid to procedures and responsibilities to ensure that all maintenance work is performed, service bulletins are analysed and decisions are taken on their accomplishment, airworthiness directives are accomplished on time and that all work, including non-mandatory modifications, is carried out to approved data and to the latest standards.
(h) Appendix IV to AMC1 CAMO.A.315(c) gives further details on the subject.
AMC2 CAMO.A.315(c) Continuing airworthiness management
ED Decision 2020/002/R
MAINTENANCE CONTRACT WITH ANOTHER CAMO/OPERATOR
(a) The purpose of point CAMO.A.315(c) is to ensure that all maintenance is carried out by an appropriately approved maintenance organisation. It is acceptable to contract another operator/CAMO (secondary operator/CAMO) that does not hold a maintenance organisation approval when it proves that such a contract is in the interest of the CAMO by simplifying the management of its maintenance, and the CAMO keeps an appropriate control of it. In this case, the CAME should include appropriate procedures to ensure that all maintenance is ultimately carried out on time by approved maintenance organisations in accordance with appropriate maintenance data. In particular, the compliance monitoring and safety risk management procedures should place great emphasis on monitoring compliance with the above and ensuring proper hazard identification, and management of risks associated with such contracting. The list of approved maintenance organisations, or a reference to this list, should be included in the CAME.
(b) This contract should not preclude the CAMO from ensuring that all maintenance is performed by appropriately approved organisations which comply with M.A.201 or ML.A.201. Typical arrangements are the following:
Component maintenance:
The CAMO may find it more appropriate to have a primary contractor (the secondary operator/CAMO) dispatching the components to appropriately approved organisations rather than sending themselves different types of components to various maintenance organisations approved under Part-145. The benefit for the CAMO is that the management of maintenance is simplified by having a single point of contact for component maintenance. The CAMO remains responsible for ensuring that all maintenance is performed by maintenance organisations approved under Part-145 and in accordance with appropriate maintenance data.
Aircraft, engine and component maintenance:
The CAMO may wish to have a maintenance contract with a secondary operator/CAMO not approved as maintenance organisation for the same type of aircraft. A typical case is that of a dry-leased aircraft between operators where the parties, for consistency or continuity reasons (especially for short-term lease agreements), find it appropriate to keep the aircraft under the current maintenance arrangement. Where this arrangement involves various maintenance organisations, it might be more manageable for the lessee CAMO to have a single maintenance contract with the lessor operator/CAMO. Whatever type of acceptable maintenance contract is concluded, the CAMO is required to exercise the same level of control on contracted maintenance, particularly through the person(s) nominated under point CAMO.A.305(a) and the management system as referred to in CAMO.A.200.
GM1 CAMO.A.315(c) Continuing airworthiness management
ED Decision 2020/002/R
For line maintenance, the actual layout of the IATA Standard Ground Handling Agreement may be used as a basis, but this does not preclude the CAMO from ensuring that the content of the contract is acceptable and especially that the contract allows the CAMO to properly exercise its continuing airworthiness management responsibility. Those parts of the contract that have no effect on the technical or operational aspects of airworthiness are outside the scope of this paragraph.
GM1 CAMO.A.315(d) Continuing airworthiness management
ED Decision 2020/002/R
The intent of this paragraph is that maintenance contracts are not necessary when the continuing airworthiness management exposition specifies that the relevant maintenance activity may be ordered through one-time work orders. This includes unscheduled line maintenance and may also include component maintenance up to engines, as long as the maintenance is manageable through work orders, in terms of both volume and complexity. It should be noted that this paragraph implies that even where base maintenance is ordered on a case-by-case basis, there should be a written maintenance contract.
CAMO.A.320 Airworthiness review
Regulation (EU) 2019/1383
When the organisation approved in accordance with point (e) of point CAMO.A.125 performs airworthiness reviews, they shall be performed in accordance with point M.A.901 of Annex I (Part-M) or point ML.A.903 of Annex Vb (Part-ML), as applicable.
CAMO.A.325 Continuing airworthiness management data
Regulation (EU) 2020/270
The organisation shall hold and use applicable current maintenance data in accordance with 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 continuing airworthiness tasks referred to in point CAMO.A.315 of this Annex (Part‑CAMO). 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 shall only keep such data for the duration of the contract, except when otherwise required by point CAMO.A.220(a).
AMC1 CAMO.A.325 Continuing airworthiness management data
ED Decision 2020/002/R
MAINTENANCE DATA PROVIDED BY THE CUSTOMER
When using maintenance data provided by the customer, the CAMO is responsible for ensuring that this data is current. As a consequence, it should establish appropriate procedures or provisions in the contract with the customer.
GM1 CAMO.A.325 Continuing airworthiness management data
ED Decision 2020/002/R
MAINTENANCE DATA PROVIDED BY THE CUSTOMER
The sentence ‘except when otherwise required by point (a) of point CAMO.A.220’ refers to, in particular, the need to keep a copy of the customer data which was used to perform continuing airworthiness activities not only during the contract period but also, if considered as record pursuant to point CAMO.A.220(a)(2), for the period specified in point CAMO.A.220(a)(5).
GM2 CAMO.A.325 Continuing airworthiness management data
ED Decision 2020/002/R
Point CAMO.A.325 refers to ‘continuing airworthiness tasks referred to in point CAMO.A.315’. As a consequence, this covers continuing airworthiness management tasks but not airworthiness reviews.
Airworthiness review requirements are indicated in point CAMO.A.320 and the requirements for the corresponding record retention are contained in point CAMO.A.220.