CAMO.A.315 Continuing airworthiness management

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).

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).

When managing the approval of modifications or repairs, the organisation should ensure that CDCCL are taken into account.

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.

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.

(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 or declared (in accordance with Part 21 Light Subpart C) data and to the latest standards.

(h)Appendix IV to AMC1 CAMO.A.315(c) gives further details on the subject.

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.

LINE MAINTENANCE CONTRACT 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.

WORK ORDERS 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.