Considerations Related to EASA Part CAMO Management System

Review by Sofema Onlinе

Introduction

Part-CAMO is introduced as a New Annex Vc - Providing a New Structure and a number system that shows a relationship with the existing system for Air Ops 965/2012 and Air Crew Regulations 1178/2011.

Part-CAMO provides requirements for Continuing Airworthiness Management Organisation (CAMO): compared with Part-M Subpart G organisation, the main difference is the introduction of SMS principles.

Part-CAMO organisations will replace Part-M Subpart G organisations in accordance with Article 4 of Regulation (EU) 1321/2014 as amended.

After 24 September 2021, there should be no more Part-M Subpart G organisations.

This is the reason why it is necessary for all existing Part-M Subpart G organisations to transition and to receive a new approval before the cessation.

EASA Part CAMO has not followed the concept of Complex and Non Complex Organisations which is followed by Part OPS & Aircrew Regulation.

Nevertheless, EASA has built into the structure of the AMC & GM a degree of flexibility and proportionality within a single set of AMC’s

Example: Establishment of a safety review board (SRB) except where not justified by the size of the organisation and the nature and complexity of its activities

Part CAMO - Management System 

Part CAMO introduces the familiar concept of a Management System including Safety Management SMS & Compliance Monitoring (The old term of Quality System is discontinued).

Section A for Industry & Section B for the Regulatory Authority are retained.

Existing Part M Subpart G approvals will no longer be valid from 24 September 2021 and it is the responsibility of each organisation to ensure an effective transition to the new Part CAMO environment.

Part-CAMO is mandatory for continuing airworthiness management of:

○ Complex motor-powered a/c, twin-turboprop < 5700 kg MTOM and/or

○ All Aircraft operated by licensed air carriers (Commercial Air Transport CAT) regardless of the aircraft which is utilized.

Additionally Part-CAMO may be used for all other a/c (Note: this is an optional choice for Private Owners of Non-Complex Aircraft)

The main focus of the management system is the development of an effective SMS system with safety risk management as well as the effectiveness of mitigating actions.

SMS can be distilled with a straightforward and simple organisation approach.

To ask the following key questions:

a) What is most likely to be the cause of your next occurrence with the potential to lead to an accident or serious incident?

b) How do you know that?

c) What are you doing about it?

d) Is it working?

In addition, a Compliance Monitoring function will be employed to ensure that the organisation remains fully compliant with EASA regulations as well as organisational requirements.

In all Part CAMO Organisations is required a full Compliance Management System regardless of the size of the organisation.

(The possibility of an Organisational Review is no longer possible for small CAMO Organisations).

Part-CAMO SMS Focus

a) SMS Responsibilities

b) Visibility of the Safety Policy

c) Safety Reporting Procedures employing just culture principles

d) Identification of safety hazards and the management of associated risks including actions to mitigate those risks and effectiveness of those actions

Part-CAMO Compliance Focus

a) Monitor compliance across all business elements

b) Competent personnel informed about significant safety issues

c) Fully Documented

Organisational Approval

An organisation may be approved for the privileges of “CAMO” without the privilege to carry out airworthiness reviews.

In this case, the airworthiness review can be contracted to another appropriately approved organisation.

The important issue in relation to maintaining a particular aircraft type in the organisation approval is whether the organisation continuously fulfills all the Part-CAMO requirements (facilities, documentation, qualified personnel, management system, etc.) required for initial approval.

Regarding Regulatory Approval of Post Holders (Nominated Persons - (NP))

References to the requirement for NP to be approved by the ‘EASA Form 4’ process to be deleted for all Management Personnel.

In future, the acceptance process will be through oversight and exposition approval.

Reporting Requirements (Mandatory & Voluntary)

To comply with Reg. (EU) 376/2014 as well as a Mandatory Occurrence Reporting Process it is necessary to establish an Internal safety reporting scheme to enable the collection and evaluation of all occurrences, errors, hazards etc.

Treatment of Existing Part-M Subpart G Approval Holders

Part M subpart G Organisation will be deemed to have been approved in accordance with Part CAMO and hey will be given 2 years to adapt their procedures and exposition to be compliant with Part-CAMO.

They will then receive a new EASA Form 14 (issue 5) CAMO approval Certificate.

Until the organisation complies with Part-CAMO, oversight will remain in accordance with Subpart G of Part-M.

Next Steps 

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