- Part-M: General
- Airworthiness review
- Technical records
- AMP (Aircraft Maintenance Programme)
- CAMO (Continuing Airworthiness Management Organisation)
Maintenance for each type of aircraft/operation
Licenced air carriers 
Maintenance to be performed by Part-145 organisations
Commercial specialised operations or CAT other than licenced air carriers or commercial ATOs
Complex motor-powered aircraft 
Maintenance to be performed by Part-145 organisations
Other than complex motor-powered aircraft (CMPA)
Maintenance to be performed by:
Other than commercial operations
Maintenance to be performed by part-145 organisations
Other than CMPA and limited operations 
Maintenance may be performed by:
 Licensed air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008
 Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.
 Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p)
 Only limited to non-CMPA of 2730 kg MTOM and below
Continuing airworthiness management for each type of operator/ aircraft
|CONTINUING AIRWORTHINESS MANAGEMENT|
Licenced air carriers 
Continuing airworthiness shall be performed by a CAMO. Operator shall be CAMO approved (CAMO linked to the AOC).
|Commercial specialised operations or CAT operations other than licensed air carriers or commercial ATOs||
Continuing airworthiness shall be performed by a CAMO. Operator shall obtain CAMO approval, or operator shall contract a CAMO
|Other than commercial operations||Complex motor-powered aircraft ||Continuing airworthiness shall be performed by a CAMO. Owner shall contract a CAMO|
|Other than complex motor-powered aircraft (CMPA) and limited operations ||
Continuing airworthiness management may be performed by the owner. CAMO is not required.
 Licenced air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008
 Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.
 Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p).
Can an independent certifying staff maintain ELA1 aircraft used for commercial operations (such as ATO)?
No, ELA1 aircraft used for commercial operations cannot be maintained by independent certifying staff because in accordance with M.A.201(i) commercial operations require maintenance release by an organisation (part-M subpart-F or part-145 approved).
Which are the correct statements to be written in block 11 of EASA Form 1 after maintenance?
Appendix II to part-M describes the following 4 permissible entries in block 11 of EASA Form 1:
The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of part-M/part-145. Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.
Can a licenced pilot without a valid medical certificate perform pilot-owner maintenance?
This question arises because of the different understandings of license validity in Commission Regulation (EU) No 1178/2011 (Aircrew) and No 1321/2014 (Continuing Airworthiness).
In Reg. (EU) 1321/2014, the pilot-owner authorisation described in M.A.803 assumes that a pilot has sufficient technical knowledge to perform certain maintenance tasks. While exercising such pilot-owner authorisation, the pilot-owner even further develops his/her competency in maintenance. Hence, in the case where the medical examination has not been conducted or not been passed and the licence has therefore lost its validity, it is the intent of the rule to allow the pilot-owner to continue using this authorisation as long as he/she still considers himself/herself physically fit (including good visual acuity) and competent to carry out such maintenance (ref. point (a)(2) of Appendix VIII to Part-M).
This is the reason why a new point (5) was introduced in AMC M.A.803 in 2016 (ED Decision 2016/011/R) stating: “not holding a valid medical examination does not invalidate the pilot licence (or equivalent) required for the purpose of the pilot-owner authorisation”.
What are the responsibilities relevant to pre-flight inspection?
The pre-flight inspection forms part of the essential requirements for air operation, as required in Annex V (point 6.2) of the ‘Basic Regulation’ (Regulation (EU) 2018/1139). Being relevant to the aircraft’s fitness for the intended flight, this essential requirement is implemented by the Commission Regulation (EU) 1321/2014 for continuing airworthiness in the following way:
Carry out pre-flight inspection satisfactorily
Pilot-in-command or, in case of Licensed Air Carrier, a qualified staff under the responsibility of the operator (e.g. maintenance staff - see note)
Ensure pre-flight inspection is carried out
Owner or CAMO (according to M.A.201)
Ensure pre-flight inspection includes the actions necessary to ensure that the aircraft is fit to carry out the intended flight
AMC M.A.301(1) point(1) and (2) elaborates those actions
If a/c managed by CAMO: Provide training to ensure that pre-flight inspection is carried out adequately [AMC M.A.301(1) point (3)]
Pre-flight inspection training described in the CAME in part 1.11 [‘Appendix V to AMC M.A.704’]
If a/c managed by CAMO:
|This is important because the pre-flight inspection contributes in feeding the process of aircraft continuing airworthiness|
As per the definition of ‘maintenance’ in article 2 point(h) of Commission Regulation (EU) 1321/2014, ‘pre-flight inspection’ (as defined in article 2(j)) is not considered maintenance. Therefore it does not require a certificate of release to service [M.A.201(d)].
What are the plans of EASA concerning the Continuing Airworthiness of aircraft operated under the new Part-DTO (Annex VIII to Reg. (EU) No 1178/2011 as amended)?
Regulation (EU) No 1178/2011 was amended in July 2018 to introduce Part-DTO as regards to declared training organisations (ref. Reg. (EU) 2018/1119). This amendment of Aircrew Regulation requires also an amendment of Part-M, which has not been adopted to date but will be reflected in the next amendment of Reg. (EU) 1321/2014.
The intent is to specify that commercial training organisations, whether ATO or DTO, will have the same Continuing Airworthiness obligations.
This amendment of Part-M will, in particular, clarify the following:
|Complex motor-powered aircraft||Other than complex motor-powered aircraft|
CAMO* is required
|Non-commercial DTO||M.A.201(g) applicable
CAMO* not required
NOTE: With adoption of Part-ML (Opinion 05/2016), CAMO* will not be required for organisations that operate Part-ML aircraft under Part-NCO. That means any DTO organisation operating Part-ML aircraft under Part-NCO will not be required to contract (or be approved as) a CAMO*.
* or CAO organisation with continuing airworthiness management privilege, once Opinion 05/2016 is adopted
Can an airworthiness review certificate (ARC)/recommendation be issued after an airworthiness review with open findings?
Neither an ARC nor a recommendation can be issued with open findings. Each finding requires a corrective action before the issue of the ARC or recommendation. The corrective action should be adequate to the open finding and it should be carried out and verified by the airworthiness review staff (ARS) before the issue of the ARC/ recommendation.
Can an extension of an ARC be anticipated more than 30 days?
As long as the conditions established for controlled environment (M.A.901 (b): continuously managed during the previous 12 months by a unique CAMO and maintained for the previous 12 months by part-145/part-M subpart F maintenance organisations or maintenance tasks referred to in point M.A.803(b) carried out and released to service by independent certifying staff (M.A.801(b)2) or pilot owner (M.A.801(b)3) are met, the validity of the ARC can be extended for a period of one year. Should the ARC extension be anticipated more than 30 days, you will lose the continuity of the airworthiness review pattern, being the next date of expiry one year after the date of extension.
Can an Airworthiness Review Staff (ARS) perform an airworthiness review on an aircraft in which he/ she had released some maintenance as Certifying Staff (CS)?
To avoid possible conflict of interests, the ARS (Airworthiness Review Staff) should not be or have been involved in the release of the maintenance for the aircraft on which he or she intends to perform the airworthiness review (AR), except in one of the following cases:
- Such maintenance has been released as part of the airworthiness review’s physical survey of the aircraft (e.g. release necessary after visual inspections requiring panel opening).
- Such maintenance has been released as a result of findings discovered during the physical survey of the aircraft (defect rectification)
Note: cases 1 and 2 are justified by the fact that such specific maintenance activity is part of the AR and therefore does not require independence between maintenance and the AR.
- Such maintenance has been released as part of the annual inspection contained in the maintenance programme conducted together with the Airworthiness Review (for ELA1 aircraft not involved in commercial operations). Refer to M.A.901(l).
From regulatory perspective, cases 1 and 2 are explicitly considered by AMC M.A.707(a) [2nd bullet of point (5)] for an ARS belonging to a CAMO also holding a AMO approval. Although not explicitly mentioned in any AMC, considering the note above, the Agency understands that this principle is also permitted in other cases where the ARS is also Certifying staff. Such cases include for example standalone ARS as per M.A.901(g) or ARS personnel of an AMO with 145.A.75(f) or M.A.615(e) privilege.
Remark: iaw AMC M.A.710(b) and (c) points 1 and 2, when the ARS is not Certifying Staff, he/she must be assisted by a Certifying Staff to release the maintenance mentioned in cases 1 and 2.
Can the airworthiness review certificate (ARC) of the large aircraft be extended during the extensive maintenance/long term storage?
An ARC extension could be performed as long as:
- the conditions established for controlled environment (M.A.901 (b)) are met. This means:
- continuously managed during the previous 12 months by a unique CAMO, and
- maintained for the previous 12 months by Part 145 organisations.
- there is no evidence or reason to believe that the aircraft is not airworthy, as stated in M.A.901(k).
Thus, the procedure for the extension established in the CAMO has to address verification of the compliance with 3 above mentioned conditions. An aircraft going through the lengthy maintenance/modification or long-term storage is not considered to meet the condition number 2.
CAMO 1 uses the anticipation when performing the airworthiness review or extension for 90 or 30 days correspondingly. After the issue or extension of the ARC, the aircraft is transferred during the anticipation period from CAMO 1 to CAMO 2. As the consequence CAMO 2 has solely continuously managed the aircraft for more than 12 months due to the term of the validity of the ARC accordingly being more than 12 month. Are the requirements of the M.A.901(b)(i) satisfied?
The intent of the article M.A.901(b)(i) is to define the ‘controlled environment’ by indicating that the aircraft must be managed during last 12 months by unique CAMO, which indirectly refers to a standard term of validity of the ARC. Therefore, if the aircraft has been managed by more than one CAMO since the date of issue of the last ARC or the date of issue of the ARC extension, it actually indicates that controlled environment was discontinued.
In addition in accordance with M.A.710(d) the 90 days anticipation shall be used to allow the physical review to be performed during a maintenance check. However, the intention of the rule was never to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review. Concerning the 30 days anticipation for the ARC extension, point M.A.901(f) is intended for 2 consecutive extensions by the same CAMO managing the continuing airworthiness of the aircraft from the date of issue of the ARC, so the extended ARC could not be extended 2nd time by another organisation, because this constitutes a ‘breach’ of controlled environment.
Is EASA Forms 1 required during the import of the aircraft in the EU?
For the import of aircraft in the EU, the provisions of M.A.904 require the accomplishment of the airworthiness review, associated AMC M.A.904(a)(2) defines work to be performed in order to determine the airworthiness status of the aircraft.
When performing the airworthiness review there would be certain provisions of part-M where it might be not possible to show the full compliance with M.A.710 e.g. availability of EASA Form 1 for all relevant components. In such case, other releases to service or serviceable tags may be acceptable for the competent authority of the importing country.
Nevertheless, it must be ensured that the information required by M.A.305(d) related to the status of ADs, determination of remaining life, modifications and repairs is available (see also AMC M.A.305(d)).
Is there any European requirement to maintain the back-to-birth traceability for any component fitted to an European aircraft?
The term “back to birth” is not used in European regulations. The requirements that apply to a service life-limited component (see definition in AMC M.A.305) are basically stated in M.A.305 (e) and (h). All detailed maintenance records of a maintenance action (e.g. a restoration) must be kept until another maintenance action equivalent in scope (another restoration) is done, but never less than 36 months. Keep in mind that:
- a service life limited component log card must be kept with all the relevant information, so the action should be recorded there, and
- the records showing compliance with other requirements stated in M.A.305, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.
What does the term “detailed maintenance records” mean?
There has been a certain confusion about the understanding of “detailed maintenance records”, because this term is used in a different context for continuing airworthiness management and approved maintenance organisation (AMO).
“Detailed maintenance records” as defined in M.A.614 or 145.A.55(c) are required to be kept by an AMO (respectively Part-M/F organisation or Part-145 organisation). Maintenance organisations are required to retain all detailed records in order to be able to demonstrate that they maintained aircraft and components in compliance with applicable requirements (see also remark).
“Detailed maintenance records” as defined in M.A.305(h)(1) are those records, coming from the AMO1 having performed maintenance, required to be kept by the owner/operator (or the CAMO when required by M.A.201) allowing to determine the aircraft configuration, the airworthiness status of the aircraft and all components installed, as well as to plan future maintenance as required by the AMP, based on the last accomplishment.
Consequently, the AMO should transmit to the owner/operator/CAMO a certain subset of the AMO maintenance records, including the certificates of release to service and repair/modification data related to the performed maintenance, so that the owner/operator/CAMO can demonstrate compliance with M.A.305.
Not all AMO maintenance records need to be transferred from the AMO to the owner/operator unless they specifically contain information relevant to aircraft configuration/ status and future maintenance. Thus, incoming certificates of conformity, batch number references and individual task card sign-offs verified by and/or generated by the maintenance organisation are not required to be transferred to the owner/operator/CAMO. However, dimensional information contained in the task card sign-offs or work packages may need to be transferred and kept by the owner/ operator.
It is to be noted that the record-retention period requirements are slightly different for the AMO and the CAMO. The AMO shall retain the records for 3 years, whereas the CAMO has to retain their records until they are superseded by new information (equivalent in scope and detail), but not less than 3 years. The starting point in both cases is when the aircraft or component maintenance has been released.
Remark: It is considered a best practice as part of the AMO record-keeping system, (and it is also required by certain competent authorities) to record information (e.g. batch number or other tracking reference) relevant to the identification of all standard parts and material used during any maintenance. This practice may limit safety and industrial risks in the case where a batch is recalled by the manufacturer. Such record does not need to be transmitted to the owner/operator/CAMO.
*: Transmitted records is a subset of AMO maintenance records provided to the CAMO. Certain transmitted records do not need to be kept as a record by the CAMO such as EASA Form 1 for a component with no scheduled maintenance task selected and not subject to AD or modification/repair.
**: by new information equivalent in scope and detail
1 Or pilot-owner [M.A.803], or independent certifying staff [M.A.801(b)(2)]
Must the EASA Form 1 be kept for on-condition components ?
There is no specific requirement to retain the EASA Form 1 of such components unless needed to comply with the requirements set forth in M.A.305 (h)(1), (h)(4), (h)(5) and (h)(6) for determining the continuing airworthiness and configuration of the aircraft.
What are the alleviations introduced by M.A.302(h) on the maintenance programme for General Aviation?
In accordance with M.A.302(h), for ELA1 aircraft not involved in commercial operation, the owner, whether he has contracted a CAMO or not [see M.A.201(i)], has the option not to submit the Aircraft Maintenance Programme (AMP) to the competent authority for approval, but instead ‘declare’ an AMP, subject to compliance with the conditions described therein. In this respect, the owner may decide to deviate from the applicable scheduled maintenance recommendations (see also remark below) without the need to justify such deviation(s), but under his/her full responsibility. Such declared AMP does not need to be sent to the competent authority.
In this scenario though, the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i).
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 ‘GM M.A.201(i), M.A.302(h) and M.A.901(l)’.
In addition, such declared AMP shall be reviewed annually and this review can be done either by the person who performs the airworthiness review, during the accomplishment of the airworthiness review, or by a CAMO if contracted to manage the continuing airworthiness of the aircraft [see M.A.302(h)5].
Besides, if during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the maintenance programme, the competent authority shall be informed and the AMP amended.
- In accordance with M.A.302 and in particular M.A.302(h)(3), 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).
- In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.
Please refer also to AMC M.A.302(e) (maintenance programme template), AMC M.A.302(h), GM M.A.302(h) and AMC M.A.302(i) (content of MIP).
Please refer to Article 2 (point k) of Regulation (EU) 1321/2014 for the definition of ELA1.
Please refer to point 2(a) of Article 140 of Regulation (EU) 2018/1139 for the definition of ‘commercial operation’.
The Agency also advises the owner who intends to transition from conventional to declared AMP to contact the competent authority for their guidance.
When does the interval for the next calendar aircraft maintenance check/task or the calendar interval for the next component check/overhaul starts?
In a normal scenario :
- The date of signing the certificate of release to service (CRS) should be considered the date of the accomplishment.
- The next due date should be calculated using this date.
However, there may be a lot of different considerations that change the normal scenario and make the statements above no longer valid. For example:
Case 1: The interval of the maintenance task has been ‘extended’ using a procedure included in the aircraft maintenance programme and approved by competent authority (refer to Appendix I to AMC M.A.302 point 4). Such procedure is often referred as permitted variation or ’tolerance’. In this case the next due date calculated using the original due date.
Case 2: The maintenance task refers to a component maintenance task, for example the landing gear overhaul. In this case the start of the interval would be the date of the release to service after the overhaul of the landing gear or in some particular cases when specified in the maintenance data the interval may start from the date of installation.
Case 3: The task is part of a maintenance check, where the duration of the check is significant compared to the interval of the task. For example, a check that lasts for 2 months and an inspection that has an interval of 3 months. In this case, it is reasonable to think that the performance of this task would need to be planned for the last days of the maintenance check, when possible. Otherwise, the inspection also can be done on the first day, but in that case, it is reasonable to expect that it will be released the same day (then the next due date would be 3 months after the CRS is signed). It also applies to the specific cases of mandatory tasks (ADs, CMRs, ALIs, etc.) defining repetitive action with a calendar limit.
There are many other examples, the key is to use sound engineering judgment and the guidance provided in the Instructions for Continuing Airworthiness to calculate the next due date.
When should I revise my Aircraft Maintenance Programme (AMP)?
In accordance with M.A.302(g), the Aircraft Maintenance Programme (AMP) shall be subject to ‘periodic reviews’ and amended accordingly when necessary.
This means that the owner/operator/CAMO should review at a regular interval:
- new/modified maintenance instructions by the TC holder,
- modifications and repairs embodied in the particular a/c, which may require compliance to additional maintenance instructions (by Design Approval Holder),
- in-service experience collected for the particular a/c or for the fleet and
- changes in the type and specificity of operations
Such a review allows to determine if an AMP revision is necessary to still comply with the obligations of M.A.302(d)(ii)/(iii) and ensure that the AMP continues to be valid in light of the operating experience. As a minimum, point (3) of AMC M.A.302 states it should be at least a 1-year review interval (annual review).
However, this should not prevent amending the AMP outside of this formal periodic review, when a specific need arises. This may depend for example on in-service experience (e.g. adverse trend), nature of instruction revisions (e.g. significant reduction of TBO (time between overhaul)), the extent of instruction revisions (amount of affected tasks) as well as source of instruction revisions (e.g. MRBR, ALS, etc.)
When a revision of the ALS (Airworthiness Limitation Section) introduces a new or more restrictive task, EASA has the policy to issue an AD (Airworthiness Directive). Such an AD would typically mandate on one side the revised task accomplishment and on the other side the revision of the AMP itself, together with a compliance time for these two actions.
However, in accordance with point (3) of AMC M.A.302, EASA recommends to review the AMP as soon as possible in this case to avoid a disconnection between accomplished maintenance task(s) and maintenance task(s) listed in the AMP.
If the aircraft’s continuing airworthiness is being managed by a CAMO, the CAME (Continuing Airworthiness Management Exposition) should describe the AMP revision policy (including ‘periodic review’) under point 1.2 [Appendix V to AMC M.A.704].
Remark: In the case where the source documents are amended without having an effect on the AMP content, it is acceptable to use an indirect approval procedure (if granted by the competent authority in accordance with M.A.302(c)) to amend the relevant source document references in the AMP.
Can a competent authority require the owner/ CAMO to include national requirements in the Aircraft Maintenance Programme (AMP), based on M.A.302(d)(i)?
Although the Member State’s competent authorities are responsible for approving the AMP, the intention of the rule is that they should not impose aeronautical instructions (such as national requirements) in addition to the instructions for continuing airworthiness (ICA) issued by the design approval holder during the certification process with the Agency. The Agency is, on behalf of the Member States, the competent authority for initial airworthiness as per Article 77(1) of Regulation (EU) 2018/1139 (the EASA ‘Basic Regulation’). Following M.A.302(d)(ii), those ICA shall be the basis to develop an AMP.
Nevertheless, competent authorities may issue alternate instructions to ICA when such instructions aim to offer flexibility to the operator [AMC M.A.302(d) point (2)].
Additionally, the mentioned AMC facilitates the rare case, where there have been no ICA issued by the design approval holder for a particular aircraft, modification, repair or STC (Supplemental Type Certificate): competent authorities may issue relevant instructions for the AMP in this case.
- The airworthiness (initial and continuing) of the aircraft for which the Basic Regulation is not applicable, has to comply solely with the national rules of the state of registry.
- If the AMP is self-declared, based on the M.A.302(h) alleviation for ELA1 aircraft not involved in commercial operation, it cannot be initially challenged by the competent authority and the owner assumes full responsibility for its content (including potential deviations to ICA - see FAQ n.43423).
- There is no equivalent of US CFR Title 14 Part-43 Appendix E/Part-91 (§91.411) or Part-43 Appendix F/Part-91 (§91.413) in the EU system.
How is it possible to escalate AMP task intervals?
Some general expectations for escalation initiatives are described in the following paragraph:
a) It should be ensured that the AMP continues to be valid in light of the operating experience [M.A.302(g) – see FAQ n.47406].
b) It should form part of the analysis of the effectiveness of the AMP (if required by M.A.301(4)),
c) The AMP should include a procedure to manage the escalation of established intervals [AMC M.A.302 point (4) and point (2) of AMC M.B.301(c)].
- formal reliability programme if required by M.A.302(f) or voluntarily implemented [AMC M.A.302(d) point (6)] or
- collection and analysis of in-service experience.
‘Appendix I to AMC M.A.302 and AMC M.B.301(b)’ provides detailed guidelines for the integration of this information into the AMP.
d) If there is a CAMO involved, those points also have to be emphasised within the CAME, as specified in Appendix V to AMC M.A.704.
Two different cases:
The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/ CAMO [M.A.302(d) point (iii)] and distinguishes in the following cases:
Escalation of safety-related task intervals, which consist of all mandatory tasks (Airworthiness Limitation Section) as well as certain non-mandatory tasks issued by the DAH (Design Approval Holder) such as various MRBR (Maintenance Review Board Report) tasks [see note below], tasks related to emergency equipment, critical components…
Escalation of non-safety-related task (e.g. non-safety related MRBR task or a task recommended by a Service Letter) intervals
In cases, where the aircraft type has been subjected to the MRB process, the following MRBR tasks should be considered safety-related:
- Failure Effect Category (FEC) ‘5’ (evident safety) and ‘8’ (hidden safety) tasks (systems and powerplant)
- SSI (Structural Significant Item) tasks
- L/HIRF (Lightning / High Intensity Radiated Field) tasks (as applicable)
- Stand-alone EWIS tasks (EZAP procedure)
The approval of a task escalations is addressed separately for each case:
Regarding case 1:
1.1 Escalation of mandatory tasks represents a change of the initial type design and therefore must be discussed and agreed between the DAH and the Agency*.
1.2 The AMP revision proposal and the information used to substantiate the escalation of non-mandatory tasks [AMC M.B.301(d)] have to be evaluated by the competent authority [AMC M.B.301(b) point (2)]. Following a positive evaluation, a direct approval of the AMP revision will be issued by the competent authority, as stated in M.A.302(d) point (iii).
Regarding case 2:
An indirect approval of the AMP through a CAMO is possible and described in more detail in FAQ n.19061.
- In all cases, task de-escalation may need to be considered based on the supporting data [AMC M.A.302(f) point (4)].
- Escalation should not be confused with ‘permitted variations’ to AMP intervals, which applies to a unique aircraft for a unique occasion [‘Appendix I to AMC M.A.302 and AMC M.B.301(b)’ point (4)].
What kind of alternative (other than escalation) or additional instructions can be introduced in the AMP?
For guidance on the escalation of AMP task intervals, please refer to FAQ no.48248.
Examples of alternative/ additional instructions to the Design Approval Holder’s (DAH) Instructions for Continuing Airworthiness (ICA) are listed below [see point (7) of AMC M.A.302(d)]:
1. De-escalation of task intervals (i.e. ‘more restrictive intervals’). Regardless of the source of the task, this may be eligible to indirect approval [see FAQ n.19061].
2. Additional scheduled maintenance tasks selected by the operator on voluntary basis (e.g. operator policy for interiors), or manufacturer recommendations outside ICA (e.g. Service Letter) linked to product improvements or maintenance practices... Depending on their nature, those tasks may be added, changed and deleted through the indirect approval [see FAQ n.19061].
Remark: Additional and de-escalated tasks may originate from the reliability programme as indicated in point (4) of AMC M.A.302(f).
3. Concerning changes in task type (e.g. from General Visual Inspection to Detailed Inspection, or from Operational Check to Functional Check), by analogy with the escalation [see FAQ no.48248] EASA recommends that for safety-related tasks such changes are directly approved by the competent authority. For non-safety related tasks, the competent authority may accept an indirect approval.
Finally, please be aware of the alleviations applicable for AMPs of ELA1 aircraft not involved in commercial operation, which are elaborated in FAQ n.43423.
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.