What are the main principles governing the development of the AMP under Part-ML?
For aircraft complying with Part-ML (refer to Article 3(2) of Regulation (EU) No 1321/2014, the AMP should be based either on the applicable ICA or on the Minimum Inspection Programme (MIP) defined in ML.A.302(d).
The owner, when she/he has not contracted the continuing airworthiness management to a CAMO or CAO [see ML.A.201(f)], should ‘declare’ the AMP assuming responsibility for its content. Such declared AMP does not need to be sent to the competent authority. Except for the mandatory requirements (see also remark below) the owner may decide, under his/her full responsibility, to deviate from the applicable scheduled maintenance recommendations (including ICA if the AMP is not based on the MIP) without the need to justify such deviation(s) (see GM1 ML.A.302).
If the aircraft is managed by a CAMO or CAO, such organisation should ‘approve’ the AMP. Deviations from the applicable scheduled maintenance recommendations (including ICA if the AMP is not based on the MIP) should be justified and properly recorded.
In both scenarios though (AMP declared by owner or approved by CAMO/CAO), when the AMP is not based on the MIP, the deviations to the applicable ICA shall not result in a less restrictive task than the corresponding MIP task. A clear overview of the different options for the development (including the source of information and potential customisation) and approval of such an AMP is provided by ‘GM1 ML.A.201’, ‘GM2 ML.A.302’.
In addition, the AMP shall be reviewed annually. For declared AMP, this review should be done by the person who performs the airworthiness review during its accomplishment (see AMC1 ML.A.302(c)(9)). For approved AMP, the review can be done either by the Airworthiness Review Staff (ARS) during the airworthiness review or by the CAMO itself.
If during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the aircraft maintenance programme, the AMP must be amended. The competent authority shall be informed in the case where the ARS does not agree with the measures taken to amend the AMP.
In accordance with ML.A.302 and in particular ML.A.302(c)(4), the AMP, declared or approved, shall in all cases include all the mandatory maintenance/continuing airworthiness requirements, such as repetitive Airworthiness Directives or the Airworthiness Limitation Section (ALS).
Please refer also to ‘AMC2 ML.A.302’ (EASA Form AMP), ‘GM1 ML.A.302’ and ‘AMC1 ML.A.302(d)’ (content of MIP).