Considerations Related to Compliance with U.S. 14 CFR Part 121 Air Carrier

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Sofema Aviation Services (SAS) considers the Maintenance Annex Guidance Procedures (MAG change 8) related to Air Carrier Obligations.


Part 121 carrier is a regularly scheduled air carrier. Typically large, U.S.-based airlines, regional air carriers, and cargo carriers operating under 14 CFR Part 121 must be certified as such through the Federal Aviation Administration (FAA).

Part 125 - certification and operations: airplanes having a seating capacity of 20 or more passengers or a maximum payload capacity of 6,000 pounds or more; and rules governing persons on board such aircraft.

Part 121 and Part 125 both allow for carrying people, however, whereas Part 121 permits carriers to operate scheduled flights, Part 125 only makes provisions for carrying passengers without receiving compensation in return.

Part 135 operations are conducted by companies who provide air charter service for a profit. These operators can offer their services directly to the end user. Part 135 regulations establish a minimum standard for safety.)

CAMP (Continuous Airworthiness Maintenance Program) is a certificate holder/program manager-developed maintenance program and is authorized for use by FAA-issued Operations Specification. (OpSpec)/Management Specification (MSpec) D072.


Procedures will describe how the organization will comply with appropriate portions of a U.S. air carrier’s or operator’s CAMP or 14 CFR part 125 operator’s manual as provided by the operator.

» Include procedures the AMOs should use to ensure that their personnel have been properly trained and qualified to perform work in accordance with the 14 CFR part 121 or part 135 air carrier or operator requirements, or those of the 14 CFR part 125 operator.

» State that the AMO understands that any deviation from the certificate holder’s maintenance manuals or supplemental instructions will require documented approval from the 14 CFR part 121 or part 135 air carrier or operator, or the 14 CFR part 125 operator.

» State that the AMO’s maintenance procedures that are different from the air carrier’s or operator’s CAMP procedures must be identified in a written agreement between the air carrier or operator and the AMO, and accepted if determined to be equivalent.

NOTE: Under 14 CFR 145.205, the AMO is required to comply with the air carrier’s or operator’s CAMP.

» This requires the AMO to comply with those certificate holders’ requirements; for example, approval for release or return to service procedures, parts, tagging, shelf life of expendable materials, tool and equipment calibration intervals, etc., in accordance with their CAMP.

» This is normally accomplished by the air carrier or operator auditing the AMO and providing the AMO with a written agreement accepting the AMO’s processes and procedures as meeting or exceeding the air carrier’s or operator’s requirements.

» It is imperative that the AMO receive and retain copies of the written agreement from the air carrier or operator and have it available for review by the AA or FAA.322b.

Sofema Aviation Services ( and Sofema Online ( offer EASA Regulatory Compliant and Vocational Training across a range of Aviation Areas – please see our Websites or email

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