Quality manager for CAMO: Nomination, acceptance, qualification
The quality manager is considered nominated personnel according M.A.706 (c). The minimum qualification and experience requirements are contained in AMC M.A.706.
The nomination of the quality manager shall be performed using the EASA Form 4.
Are deputy nominated persons required in CAMO?
Neither M.A.706 (c) nor M.A.706 (d) contain a specific requirement for the identification of deputy “nominated persons” as in part-145 (145.A.30(b)(4)). So, in principle, we could say that there is no requirement for the nomination or identification of deputy “nominated persons”.
Nevertheless, the CAMO needs to take into account the conditions for the continued validity of the approval contained in M.A.715, in particular point (a)(1) which refers to the continued validity of the approval provided the organisation remains in compliance with the requirements.
The CAMO should ensure that they remain in compliance during the absence of the nominated persons, this could be by identifying in the CAME “one or several deputies” and the conditions under which the deputies will assume the responsibilities (this option could be acceptable for a short/medium absence). Another option would be to nominate another person. This would be necessary when the absence is going to be of considerable length and in this case the nomination and acceptance by the competent authority is done using the Form 4.
Under which condition can a CAMO use the indirect approval procedure to amend AMP (Aircraft Maintenance Programme) task?
The indirect approval procedures may only be used for:
- de-escalated tasks as described in example 1 of FAQ n.48249
- additional tasks as described in example 2 of FAQ n.48249
- editorial issues, typos, etc., (without having an effect on the AMP content)
In such case, as required by M.A.302(c) and M.B.301(c), the CAME (Continuing Airworthiness Management Exposition) must include, and the competent authority shall approve, a procedure describing as a minimum:
- Which AMP amendments are eligible for indirect approval
- Who in the CAMO is responsible to issue of the indirect approval
- How the amendments are controlled
- How and when the competent authority is informed of an amendment
Based on M.A.302(c), the indirect approval may only be used when:
- The aircraft is managed by a CAMO or there is a limited contract between the owner and the CAMO for the development and approval of the AMP;
- The aircraft managed by the CAMO is registered in the Member State ensuring the oversight of this CAMO (unless an agreement exists between the competent authority for the AMP and the competent authority of the CAMO).
Do the maintenance contracts need to be submitted for the approval to the competent authorities after Commission Regulation (EU) 2015/1536 applies?
M.A.708(c) requires the CAMO to establish a written maintenance contract for CMPA or aircraft used for CAT or commercial specialised operations or commercial ATO operations.
The individual contracts need not to be submitted for approval to the competent authority. The competent authority shall approve the procedures for contracted maintenance as part of the CAME Part 3 and the basic information of the contracted maintenance should be included in a list of contracted maintenance organisations in the CAME part 5.4.
The amendment to the list mentioned in 5.4 may be managed through the indirect approval procedure.
Only for air carriers licenced in accordance with Regulation (EC) 1008/2008, the maintenance contracts need to be submitted to the competent authority as part of the package for initial application or for a change to the Air Operator Certificate as indicated in under M.B.701(a)(4).
Does the CAMO quality system need to be subject to monitoring?
Yes, the quality system is part of the activities of the CAMO and therefore it should be monitored.
Point M.A.712(b) requires that the quality system monitors:
- that all CAMO activities are being performed in accordance with the approved procedures, and,
- the continued compliance with requirement of part-M.
The quality system procedures are considered to be within these approved procedures . This implies that quality system must be subject to audits and the CAMO audit programme/plan needs to reflect this.
Besides that the audits to the quality system shall satisfy the requirement of independent audits. This is further explained in AMC M.A.712(b) point 8: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit. Therefore, to audit the quality system, it is acceptable:
- to use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
- to contract the independent audit element of the quality system to another organisation or a qualified competent person, or,
- that the quality system is monitored and certified against an internationally recognised quality standards by a certification organisation
The way the quality system is going to be audited has to be described in the CAME and approved by the competent authority.