Part M Regulatory Requirements driven by EASA Regulation (EU) 2019/1383
Sofema Online (www.sofemaonline.com) considers regulatory complacencies following the introduction of the new EASA Part M requirements.
Notes Concerning Part CAMO & PART CAO
a) Part-CAMO provides requirements for Continuing Airworthiness Management Organisation (CAMO): compared with Part-M Subpart G organization, the main difference is the introduction of SMS principles.
b) Part-CAO provides a new set of requirements for Combined Airworthiness Organisation: such an organization may perform CAMO activities or Maintenance Organisation activities, or both, but limited to non-complex aircraft not used by a licensed air carrier.
c) These Part-CAMO and Part-CAO organizations are supposed to gradually replace Part-M Subpart F and Part-M Subpart G organizations.
d) In accordance with Article 4 of Regulation (EU) 1321/2014 as amended, after 24 September 2021, there should be no more Part-M Subpart F and Part-M Subpart G organizations.
e) This is the reason why, to be able to continue their activities, the existing Part-M Subpart F and Part-M Subpart G organizations must eventually receive a new approval.
Operator (CAT) Air Carrier (AC)
The operator shall be responsible for the satisfactory accomplishment of the pre-flight inspection. (PFI) That inspection shall be carried out by the pilot or another qualified person and shall not need to be carried out by an approved maintenance organization or by certifying staff.
In the case of aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008 the operator shall be responsible for the continuing airworthiness of the aircraft it operates and shall:
(1) Ensure that no flight takes place unless the PFI conditions are met;
(2) Take the necessary steps to ensure its approval as a continuing airworthiness management organization (‘CAMO’) pursuant to Annex Vc (Part-CAMO), as part of air operator certificate for the aircraft it operates;
(3) take the necessary steps to ensure its approval in accordance with Annex II (Part-145) or conclude a written contract in accordance with point (c) of point CAMO.A.315 of Annex Vc (Part-CAMO) with an organization which has been approved in accordance with Annex II (Part-145).
Approved Training Organisations (‘ATO’) and Declared Training Organisations (‘DTO’)
For complex motor-powered aircraft used for commercial specialized operations, for CAT operations other than those performed by air carriers licensed in accordance with Regulation (EC) No 1008/2008 or by commercial Approved Training Organisations (‘ATO’) and Declared Training Organisations (‘DTO’) referred to in Article 10a of Regulation (EU) No 1178/2011, the operator shall ensure that:
(1) No flight takes place unless the conditions set out in point (a) are met;
(2) The tasks associated with continuing airworthiness are performed by a CAMO approved in accordance with Annex Vc (Part-CAMO); when the operator is not itself approved in accordance with that Section it shall conclude a written contract as regards the performance of those tasks in accordance with Appendix I to this Annex with an organization approved in accordance with Annex Vc (Part-CAMO);
(3) The CAMO referred to in point (2) is approved in accordance with Annex II (Part-145) as an organization to qualify for the issue of an approval for the maintenance of aircraft and of components for installation thereon, or that CAMO has concluded a written contract in accordance with point (c) of point CAMO.A.315 of Annex Vc (Part-CAMO) with organizations approved in accordance with Annex II (Part-145).
For complex motor-powered aircraft not CAT or COM the owner shall ensure that:
(1) No flight takes place unless the PFI conditions are met;
(2) The tasks associated with continuing airworthiness are performed by a CAMO approved in accordance with Annex Vc (Part-CAMO); when the owner is not a CAMO approved in accordance with Annex Vc (Part-CAMO), it shall conclude a written contract as regards the performance of those tasks in accordance with Appendix I to this Annex with an organization approved in accordance with Annex Vc (Part-CAMO);
(3) The CAMO referred to in point (2) is approved in accordance with Annex II (Part-145) as an organization to qualify for the issue of an approval for the maintenance of aircraft and of components for installation thereon, or that CAMO has concluded a written contract in accordance with point (c) of point CAMO.A.315 of Annex Vc (Part-CAMO) with organisations approved in accordance with Annex II (Part-145).
Other than Complex Motor Powered Aircraft
For aircraft other than complex motor-powered aircraft used for commercial specialized operations or for CAT operations other than those performed by air carriers licensed in accordance with Regulation (EC) No 1008/2008, or by commercial ATOs and commercial DTOs referred to in Article 10a of Regulation (EU) No 1178/2011, the operator shall ensure that:
(1) No flight takes place unless the PFI conditions are met;
(2) The tasks associated with continuing airworthiness are performed by a CAMO approved in accordance with Annex Vc (Part-CAMO) or a combined airworthiness organization (‘CAO’) approved in accordance with Annex Vd (Part-CAO); when the operator is not a CAMO approved in accordance with Annex Vc (Part-CAMO) or a CAO approved in accordance with Annex Vd (Part-CAO) it shall conclude a written contract in accordance with Appendix I to this Annex with a CAMO approved in accordance with Annex Vc (Part-CAMO) or a CAO approved in accordance with Annex Vd (Part-CAO);
(3) The CAMO or CAO referred to in point (2) above is approved in accordance with Annex II (Part-145) or in accordance with Part-M, Subpart F of this Annex or as a CAO with maintenance privileges, or that CAMO has concluded a written contract in accordance with point (c) of point CAMO.A.315 of Annex Vc (Part-CAMO) with organiZations approved in accordance with Annex II (Part-145) or in accordance with Subpart F of Part-M of this Annex or Annex Vd (Part-CAO) with maintenance privileges.
Other than Complex Motor Powered Aircraft – (Private)
For aircraft other than complex motor-powered aircraft not used for commercial purposes, the owner shall ensure that flight takes place only if the PFI conditions are met.
To that end, the owner shall, alternatively:
(1) Attribute the continuing airworthiness tasks referred to in point M.A. 301 to a CAMO or CAO through a written contract concluded in accordance with Appendix I;
(2) Carry out those tasks himself. If the owner chooses to carry out those tasks himself then he may decide not to carry out the tasks of the development of and the processing of the approval of the AMP only if those tasks are performed by a CAMO or CAO through a written contract concluded in accordance with point M.A.302.’
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