EASA Operator Responsibilities Concerning Continuing Airworthiness

Sofema Online (SOL) (www.sofemaonline.com) considers the regulatory responsibilities placed on the operator by EASA.

Introduction - What are the responsibilities of the AOC holder required to implement a management system in accordance with ORO.GEN.200 in regards to continuing airworthiness management and contracted maintenance?

» Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part ORO); Regulation (EU) No 1321/2014 on continuing airworthiness, Part M
» Continuing Airworthiness Management

o The EU-licensed air carrier hereafter referred to as ‘the operator’, needs to consider both the relevant Part ORO rules that will become fully applicable on 29 October 2014 and the applicable Part M requirements.
o For these operators, the Part CAMO approval is an integral part of the AOC (as defined in Part M, M.A.201(h)).
o The Part CAMO requirements have now been amended to align with the management system framework adopted for air operations.
o Additionally the operator should ‘scrutinize’ all its activities under its hazard identification and risk management processes, including the continuing airworthiness activities.

Note 1: It is the operator’s responsibility to ensure that hazards entailed by any continuing airworthiness management task are subject to the applicable hazard identification procedures and that related risks are managed as part of the operator’s management system procedures.

CAMO Essential Roles & Responsibilities

The typical Roles and Responsibilities of EASA Continuing Airworthiness Management Organisation (CAMO) are related to the Engineering & Planning Functions critical to the delivery of effective maintenance.

» Development and management of the maintenance program to ensure continual compliance with all requirements including Airworthiness Directives.
» Reliability program including repetitive defect rectification.
» The process to analyze and evaluate in-service data including Service Bulletins.
» Тhe management of all Continuing Airworthiness Technical Records.

A CAMO shall satisfy the following (CAMO Maintenance Planning):

» A Continuing Airworthiness Management Exposition (CAME),
» Facilities & Manpower (including staffing, offices, and document storage),
» Technical Records Storage,
» Complaint Procedures in accordance with Part CAMO / Part M that meet regulatory acceptance,
» An Independent Quality Assurance System.

Within the CAMO department, the Maintenance Planning Group has a range of responsibilities which include the delivery of the aircraft maintenance work package to ensure the aircraft remains fully compliant with the Maintenance Program.

In fact, this could be considered to be the “fixed” portion of the workload, as it does not fluctuate rather it is based on the Maintenance Planning Document “MPD”.

Together with the fixed workload, there is an associated and variable workload driven by Airworthiness Directives (ADs), Modifications (Mods), and Service Bulletins (SBs) together with Deferred Defects.

Specific Maintenance Planning Duties include the following:

» Aircraft Maintenance Planning & Special Requirement Control and Management;
» Forward planning of Maintenance requirements by definition of proposed fleet utilization data typical either per budget year or rolling plan;
» Preparation of “Short Term”, “Mid Term” & “Long Term” Maintenance forecasts;
» Negotiate with Commercial and Operations to achieve the optimum downtime to facilitate maintenance;
» Scope - Define - Plan and Issue the Aircraft Maintenance Work Package including scheduled and unscheduled activities - issue the work pack to Materials Planning and Base Maintenance Production Planning groups. (Production Planning to ensure that all required tooling is available);
» Continue to Coordinates with Material Planning group and Maintenance Production Planning Group to ensure timely availability of all aircraft parts, tooling, and materials required in support of Maintenance Work packages;

Note 2: much of the CAMO requirements may be “subcontracted” - however, the Operators CAMO remains responsible for the effective management & oversight of continuing airworthiness.

CAMO - EASA Part 145 Relationship

The 145 will perform maintenance in accordance with CAMO Instructions (Works Orders.)

Sofema Aviation Services (www.sassofia.com) and Sofema Online (www.sofemaonline.com) offer EASA Regulatory Compliant and Vocational Training across a range of Aviation Areas including the following 2-Day course. For additional details, please see our Websites or email Team@sassofia.com