To first consider the difference between the operator or owner and the maintainer because it is the operator or the owner who is required through the management of technical records to demonstrate that the aircraft meets all requirements to be able to fly, whereas the 145 organisation must demonstrate only that all requested and performed maintenance has been performed in accordance with all requirements and correctly released by an appropriately approved certifying engineer.
Within the Aircraft Operator’s organisation the Technical Records Department typically reports to the Continuing Airworthiness Manager (CAM) and the relevant technical records procedures are written into the Continued Airworthiness Management Exposition (CAME) – section 1
As we know PART M or CAR M is an organisation approval which is dedicated to the management of Continuing Airworthiness. It is mandatory for all Commercial Air Transport organisations (CAT) as well as large aircraft (over 5700 kgs)
The functioning part of the CAMO group including all Technical Records Staff are responsible for managing the following :- Management of aircraft utilisation and ensuring the effective planning of all scheduled maintenance; Development, and management of an approved maintenance programme and the accomplishment of mandatory inspections and modifications.
Regarding the Maintenance organisation, depending on whether the aircraft is Commercial Air Transport, Large Aircraft or a private aircraft below 5700 kgs not Complex Motor Powered Aircraft (CMPA).
A maintenance organisation can be approved to carry out maintenance in one of two ways:
Either It will be approved under Part M, Sub-part F; essentially, this is for small, simple (not CAT) organisations supporting a limited number of aircraft or a Part 145 organisation with approval on the required aircraft type;
‘Detailed continuing Airworthiness maintenance records’ are those records required to be kept by the owner/operator to be able to demonstrate the continuing airworthiness and configuration of the aircraft in accordance with Part-M relevant for future maintenance.
These are different from the detailed maintenance records required to be kept by a maintenance organisation as per M.A.614 (Subpart F Organisation) or 145.A.55(c) Part 145 Organisation).
Whereas maintenance organisations are required to retain all detailed records to demonstrate that they worked in compliance with their respective requirements, aircraft owners/operators need to retain those records required for assessing the aircraft configuration and the airworthiness of the aircraft and all components installed.
Where the maintenance organisation retains the detailed maintenance records in accordance with 145.A.55(c) and M.A.614, the owner/operator should receive the aircraft release to service performed during the maintenance and necessary to determine the aircraft continuing airworthiness and its configuration, which includes references to all: Taskcards to show compliance with the maintenance Program requirements modifications, airworthiness directives, repaired and non-repaired damage, and measurements relating to defects.
Sofema Aviation Services “SAS” is pleased to offer 1 day Technical Records Regulatory Training courses as well as 2 Day Part M and 1 to 5 Day Maintenance Planning courses.
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