Part M subpart J is a proposed change being introduced by EASA through NPA 2010-09.(EASA is proposing changes to the regulatory structure of EC 2042 /2003 which may have significant outcomes.)
The current rules make it mandatory for the CAT operator to be CAMO approved (M.A.201(h). However, this requirement has created challenges particularly for small operators who may find it difficult in some cases to have the full in-house expertise to manage the continuing airworthiness of their fleet.
NPA 2010-09 proposes that the CAT operator which is not itself CAMO approved must contract the CAM of its aircraft to a CAMO.
Such an approach is radical in as much as the operator opting for this solution will relinquish some of the direct responsibility for its continuing airworthiness. Whilst still be ultimately responsible.
European Community operators are currently required to be approved to Part M Subpart G as part of their AOC. The approval issued is based on the acceptance of the organizations Continuous Airworthiness Management Exposition, and requires the operator to directly responsible for the Continuing airworthiness.
Currently there is an option to subcontract certain continuing airworthiness services to a standalone Part M Subpart G organisation. In this case the operator still remains responsible for the continuing airworthiness of its fleet and must demonstrate both effective control and effective oversight.
If NPA 2010-09 is adopted an operator may choose, not to be Part M subpart G approved, there will become another option, the operator may be approved in accordance with Part M subpart J. In this situation the operator is not required to have the necessary resources to manage the continuing airworthiness tasks directly, but has to have procedures which are approved and documented in the CACE: Continuing Airworthiness Control Exposition. These procedures will include RAA (Risk Assessment Analysis) a risk assessment process to be performed by the operator on the Part M subpart G organisation which will be performing the Continuous Airworthiness activities.
NPA 2010-09 introduces new terminology.
MAC: Means of Active Control for the purpose of CA (Continuing Airworthiness) contracting.
Refers to the process whereby the Part M Subpart G organisation is able to demonstrate active control of the Continuous Airworthiness Tasks under the oversight of the National Airworthiness Authority
RAA: Risk Assessment Analysis (only for CAT)
The process similar to Safety Management System Risk Analysis whereby The Risk Assessment Analysis (RAA) is the way a “Subpart-J compliant” Operator controls the CAM (Continuous Airworthiness Management) contracted to a CAMO.
CACE: Continuing Airworthiness Control Exposition
The CACE manual is a development of the CAME Continuing Airworthiness Management Exposition.
This new proposed arrangement under NPA 2010-09 will require a contract with the CAMO which ensures clear continuing airworthiness responsibilities and that tasks are correctly addressed, in addition theestablishment of a satisfactory channel of communication between the operator and the contracted CAMO.
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Tags:
CAMO, continuing airworthiness, EASA, NPA 2010-09, part M, Subpart J
