Review of Competence Requirements Related to EASA Part CAMO Regulatory Obligations
Considerations presented by Sofema Online (SOL) www.sofemaonline.com
Background
Each time EASA updates a major piece of regulatory requirement, AMC & Guidance we can see that they take the opportunity to address several outstanding or ongoing issues. In this case to look at Competence where EASA is digging ever deeper having established (correctly) that competence is a key component to effective oversight, supervision and management of a specific process.
Knowledge, Background and Experience of Nominated Person(s)
AMC1 CAMO.A.305(c) Personnel requirements - ED Decision 2020/002/R - Refers
CAMO.A.305 Personnel requirements - Regulation (EU) 2019/1383 Redacted Summary Follows
(a) The organisation shall appoint an accountable manager, who has corporate authority for ensuring that all continuing airworthiness management activities can be financed and carried out.
The Accountable Manager Shall:
(1) Ensure that all necessary resources are available to manage continuing airworthiness in accordance with this Annex, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, to support the organisation approval certificat.
(2) Establish and promote the safety policy specified in point CAMO.A.200.
(3) Mominate a person or group of persons with the responsibility of ensuring that the organisation always complies with the applicable continuing airworthiness management, airworthiness review and permit to fly requirements of this Annex, Annex I (Part-M) and Annex Vb (Part-ML.
(4) Mominate a person or group of persons with the responsibility for managing the compliance monitoring function as part of the management system;
(5) Nominate a person or group of persons with the responsibility for managing the development, administration, and maintenance of effective safety management processes as part of the management system.
(6) Ensure that the person or group of persons nominated in accordance with points (a)(3) to (a)(5) and (b)(2) of point CAMO.A.305 have direct access to keep him/her properly informed on compliance and safety matters.
(7) Demonstrate a basic understanding of this Regulation.
(b) For organisations also approved as air carriers licensed in accordance with Regulation (EC) No 1008/2008, the accountable manager shall in addition:
(1) Be the person appointed as accountable manager for the air carrier as required by point (a) of point ORO.GEN.210 of Annex III (Part-ORO) to Regulation (EU) No 965/2012.
(2) Nominate a person responsible for the management and supervision of continuing airworthiness, who shall not be employed by an organisation approved in accordance with Annex II (Part-145) under contract to the operator, unless specifically agreed by the competent authority.
Nominated Person(s) should have:
Note - The following only applies to CAMO nominated persons - not in this instance Compliance & Safety Personnel! - EASA has long recognised particular weaknesses in this area and is taking the opportunity to correct (possibly to over correct in some cases) Reference for QM / SM exclusion - AMC1 CAMO.A.305(a)(4);(a)(5) 2(1).
(a) Practical experience and expertise in the application of aviation safety standards and safe operating practices.
(b) A comprehensive knowledge of:
(i) relevant parts of operational requirements and procedures.
(ii) the AOC holder's operations specifications when applicable.
(iii) the need for, and content of, the relevant parts of the AOC holder's operations manual when applicable.
(c) Knowledge of:
(i) HF principles.
(ii) safety management systems based on the EU management system requirements (including compliance monitoring) and ICAO Annex 19.
(d) 5 years of relevant work experience, of which at least 2 years should be from the aeronautical industry in an appropriate position.
(e) A relevant engineering degree or an aircraft maintenance technician qualification with additional education that is acceptable to the competent authority. ‘
Relevant engineering degree’ means an engineering degree from aeronautical, mechanical, electrical, electronic, avionic or other studies that are relevant to the maintenance and/or continuing airworthiness of aircraft/aircraft components.
The above recommendation may be replaced by 5 years of experience in addition to those already recommended by paragraph (d) above. These 5 years should cover an appropriate combination of experience in tasks related to aircraft maintenance and/or continuing airworthiness management and/or surveillance of such tasks.
(f) Thorough knowledge of the organisation's CAME.
(g) Knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course. These courses should be at least at a level equivalent to Part-66 Appendix III Level 1 General Familiarisation and could be provided by a Part-147 organisation, by the manufacturer, or by any other organisation accepted by the competent authority.
‘Relevant sample’ means that these courses should cover typical aircraft and aircraft systems that are within the scope of work.
(h) Knowledge of maintenance methods.
(i) Knowledge of the applicable regulations.
Safety Management and Compliance Monitoring Function
Regarding Competence of CAMO Compliance Manager (CM) and Safety Manager - Please Note the following:
AMC1 CAMO.A.305(a)(4);(a)(5) Personnel requirements -ED Decision 2020/002/R
(a) Safety Management
If more than one person is designated for the development, administration and maintenance of effective safety management processes, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘safety manager’.
b) Compliance Monitoring Function
If more than one person is designated for the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point, i.e. the ‘compliance monitoring manager’.
(2) The Compliance Monitoring Manager should:
(i) not be one of the persons referred to in point CAMO.A.305(a)(3)
(ii) be able to demonstrate relevant knowledge, background and appropriate experience related to the activities of the organisation, including knowledge and experience in compliance monitoring
(iii) have access to all parts of the organisation, and as necessary, any subcontracted organisation.
(c) If the functions related to compliance monitoring or safety management are combined with other duties, the organisation should ensure this does not result in any conflicts of interest. In particular, the compliance monitoring function should be independent from the continuing airworthiness management functions.
(d) If the same person is designated to manage both the compliance monitoring function and safety management-related processes and tasks, the accountable manager, with regard to his or her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the organisation, and the nature and complexity of its activities.
(e) Subject to a risk assessment and/or mitigation actions, and agreement by the competent authority, with due regard to the size of the organisation and the nature and complexity of its activities, the compliance monitoring manager role and/or safety manager role may be exercised by the accountable manager, provided that he or she has demonstrated the related competency as defined in point (b)(2)(ii).
Competency of the Safety Manager - GM3 CAMO.A.305(g) Personnel requirements
ED Decision 2020/002/R
The competency of a safety manager should include, but not be limited to, the following:
(a) Knowledge of ICAO standards and European requirements on safety management
(b) An understanding of management systems, including compliance monitoring systems
(c) An understanding of risk management
(d) An understanding of safety investigation techniques and root cause methodologies
(e) An understanding of HF
(f) Understanding and promotion of a positive safety culture
(g) Operational experience related to the activities of the organisation
(h) Safety management experience
(i) Interpersonal and leadership skills, and the ability to influence staff
(j) Oral and written communications skills
(k) Data management, analytical and problem-solving skills.
Next Steps
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