M.A.711 Privileges of the organisation

SUBCONTRACTING OF CONTINUING AIRWORTHINESS TASKS

1.The CAMO may subcontract certain continuing airworthiness management tasks to qualified persons or organisations. The subcontracted person or organisation performs the continuing airworthiness management tasks as an integral part of the CAMO’s continuing airworthiness management system, irrespective of any other approval held by the subcontracted person or organisation (including CAMO or Part-145 approval).

2.The CAMO remains accountable for the satisfactory completion of the continuing airworthiness management tasks irrespective of any contract that may be established.

3.In order to fulfil this responsibility, the CAMO should be satisfied that the actions taken by the subcontracted person or organisation meet the standards required by Subpart G. Therefore, the CAMO management of such activities should be accomplished:

(a)by active control through direct involvement, and/or

(b)by endorsing the recommendations made by the subcontracted person or organisation.

4.In order to retain ultimate responsibility, the CAMO should limit subcontracted tasks to the activities specified below:

(a)airworthiness directive analysis and planning;

(b)service bulletin analysis;

(c)planning of maintenance;

(d)reliability monitoring, engine health monitoring;

(e)maintenance programme development and amendments;

(f)any other activities, which do not limit the CAMO responsibilities, as agreed by the competent authority.

5.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 continuing airworthiness management exposition. When such tasks are subcontracted, the continuing airworthiness management system is considered to be extended to the subcontracted persons or organisations.

6.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.

7.Contracts should not authorise the subcontracted organisation to subcontract to other organisations elements of the continuing airworthiness management tasks.

8.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.

9.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.

10.Appendix II to AMC M.A.711(a)(3) provides information on the subcontracting of continuing airworthiness management tasks.

An organisation may be approved for the privileges of M.A.711(a) only, without the privilege to carry out airworthiness reviews. This can be contracted to another appropriately approved organisation. In such a case, it is not mandatory that the contracted organisation is linked to an AOC holder, being possible to contract an appropriately approved independent continuing airworthiness management organisation which is approved for the same aircraft type. In order to be approved for the privileges of M.A.711(b) for a particular aircraft type, it is necessary to be approved for the privileges of M.A.711(a) for that aircraft type. As a consequence, the normal situation in this case is that the organisation will be performing continuing airworthiness management tasks and performing airworthiness reviews on every aircraft type contained in the approval certificate. 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. 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 Subpart G requirements (facilities, documentation, qualified personnel, quality system, etc.) required for initial approval.

The sentence ‘for the particular aircraft for which the organisation is approved to issue the airworthiness review certificate’ contained in M.A.711(c) means that: For aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, and for aircraft above 2 730kg MTOM, the permit to fly can only be issued for aircraft which are in a controlled environment and are managed by that CAMO. The permit to fly can be issued for any other aircraft for which the organisation can exercise the privilege in M.A.711(b).