Managing the CAMO in a Subcontract Environment

Reasons for “contracting” CAM Tasks

There can be a range of reasons to choose to contract Continuing Airworthiness Tasks including

  • Small operators and Start-up operations choosing to typically contract all CAM tasks
  • Medium size operators may choose to contract specific CAM tasks including

AD/SB evaluations

Maintenance program development & upkeep

Reliability control

Engine condition monitoring

  •  Large operators may choose to share or pool certain CAM activities for both aircraft and or engines types
  •  The opportunity for the operator to “buy” turnkey solutions “ready to use” manpower with the appropriate knowledge and experience

 

Conditions Related to Contracting Continuing Airworthiness Tasks

For Commercial Air Transport – Not possible to Contract – Only Subcontract

For Commercial other than CAT & Private Owners Full Contract is possible

 

What should be in a Contract

Conditions that should need to be established:

• A clear and detailed contract with an interface procedure document as attachment

• An appointed person from the CAMO may be required to participate in the operators management meetings in addition to the ”daily” contact for the operation.

• The appointed person may have to be nominated by the operator and accepted by the operator NAA.

• The operator must audit the contracted CAMO and sub-contractor as well as provide continuous Quality Control oversight (QC).

• The MEL and repetitive defect management system shall be specified in the contract.

• The Technical log (Techlog) system shall be specified in the contract.

• The mandatory and voluntary occurrence reporting system shall be specified in the contract.

 

Use of Subcontracting – Advantages

To gain knowledge, experience and manpower during the airline start-up phase or when introducing a new aircraft type or in the case of limited operations.

Reduction in direct staffing levels

Existing System & Process available – Turnkey

Financial Benefits

 

Use of Subcontracting – Disadvantages

The operator may face challenges to ensure full oversight acceptable to the Competent Authority (CA)

Subcontracting can lead to reduction or dilution of competence related to the management and control of airworthiness tasks in the responsible organisation.

The possibility for miscommunication between the Operator & CAMO leading to potential exposure.

The operator may become disconnected from core responsibilities related to Commercial Air Transport (CAT) Continuing Airworthiness Mandatory Responsibilities

Operators (without sufficient resources to ensure appropriate oversight) may subcontract Continuing Airworthiness Management CAM to unapproved organisations (who are not accountable)

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