June 10, 2024

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Sofema Aviation Services (SAS) www.sassofia.com Reviews Appendix I — CAO management contract Ref. Regulation (EU) 2022/410

Introduction

When an owner or operator contracts with a CAMO or CAO under point M.A.201 to carry out continuing airworthiness management tasks, upon request by the competent authority, the owner or operator shall send a copy of the contract signed by both parties to the competent authority of the Member State of the registry.

  • The contract shall be developed taking into account the requirements of this Annex and shall define the obligations of the signatories in relation to the continuing airworthiness of the aircraft.
  • It shall contain, as a minimum, the following information:

 – aircraft registration, type and serial number;

 – aircraft owner’s or registered lessee’s name or company details, including the address,

 – details of the contracted CAMO or CAO, including the address and

 – the type of operation.

  • It shall state the following:

 – The owner or operator entrusts the CAMO or CAO with managing the aircraft’s continuing airworthiness, including, but not limited to, developing an AMP that shall be approved by the competent authority as detailed in point M.1 and organizing the maintenance of the aircraft according to said AMP.

  • According to the present contract, both signatories undertake to follow the respective obligations of this contract.
  • To the best of their knowledge, the owner or operator declares that all the information given to the CAMO or CAO concerning the continuing airworthiness of the aircraft is and will continue to be accurate and that the aircraft will not be repaired or modified without the prior agreement of the CAMO or CAO.

If either of the signatories does not comply with this contract, the CAMO or CAO and the owner or operator shall assess whether it impacts the continuation of the contract and inform the competent authority(ies) of such organisations.

  • The organisations’ assessments shall consider the safety significance of the non-conformity and whether it is repetitive.
  • If either of the signatories concludes after this assessment that they cannot fulfil their responsibilities due to their own limitations or due to the failures of the signatory, the contract shall be cancelled, and the competent authority(ies) of the organisations shall be informed immediately.
  • In such a case, the owner or operator will retain full responsibility for every task linked to the continuing airworthiness of the aircraft, and the owner or operator will inform the competent authorities of the Member State of the registry within 2 weeks about such non-conformity within the contract. In the case of contract concluded by M.A.201(ea), the competent authority of the Member State of registry shall be informed immediately.’

When an owner or operator contracts a CAMO or a CAO under point M.A.201, the contract shall specify the obligations of each party as follows:

Obligations of the CAMO or CAO:

  • have the aircraft type included in its terms of approval;
  • respect the conditions listed below with regard to maintaining the continuing airworthiness of the aircraft:
  • develop an AMP for the aircraft, including any reliability programme developed, if applicable;
  • declare the maintenance tasks (in the AMP) that may be carried out by the pilot-owner under point (c) of point M.A.803;
  • organise the approval of the AMP;
  • once it has been approved, provide the owner or operator with a copy of the AMP;
  • establish and order the necessary maintenance to ensure an appropriate bridging with the former aircraft maintenance programme;
  • organise for all maintenance to be carried out by an approved maintenance organisation;
  • organise for all applicable ADs to be applied;
  • organise for all defects discovered during scheduled maintenance, airworthiness reviews or reported by the owner to be rectified by an approved maintenance organisation;
  • coordinate the accomplishment of scheduled maintenance, including inspection of components, replacement of life-limited parts and the accomplishment of any applicable AD, and ensure compliance with operational requirements having a continuing airworthiness impact, continuing airworthiness requirements established by the Agency and measures required by the competent authority in immediate reaction to a safety problem;
  • inform the owner or operator each time the aircraft is to be brought to an approved maintenance organisation;
  • manage and archive the aircraft’s continuing airworthiness records;
  • coordinate with the operator or owner on any request to the relevant competent authority for any deviation from the aircraft maintenance programme;
  • support the operator or pilot-owner as regards the aircraft’s continuing airworthiness when they conduct maintenance check flights.
  • organise the approval of any modification to the aircraft under Annex I to Regulation (EU) No 748/2012 (Part-21) before it is embodied;
  • organise the approval of any repair to the aircraft under Annex I to Regulation (EU) No 748/2012 (Part-21) before it is carried out;
  • inform the competent authority of the Member State of registry whenever the aircraft is not presented to the approved maintenance organisation by the owner as requested by the approved organisation;
  • inform the competent authority of the Member State of registry whenever the present contract is not respected;
  • ensure that the airworthiness review of the aircraft is carried out when necessary, and ensure that the airworthiness review certificate is issued or a recommendation is sent to the competent authority of the Member State of registry;
  • send within 10 days a copy of any airworthiness review certificate issued or extended to the competent authority of the Member State of registry;
  • carry out all occurrence reporting mandated by applicable regulations;
  • inform the competent authority of the Member State of the registry when the contract is denounced by either party.

Obligations of the owner or operator:

  • have a general understanding of the approved AMP;
  • have a general understanding of this Annex;
  • present the aircraft to the approved maintenance organisation agreed with the CAMO or CAO at the due time designated at the CAMO’s or CAO’s request;
  • not modify the aircraft without first consulting the CAMO or CAO;
  • inform the CAMO or CAO of all maintenance exceptionally carried out without the knowledge and control of the CAMO or CAO;
  • report all defects found during operations to the CAMO or CAO through the logbook;
  • inform the competent authority of the Member State of registry whenever the present contract is denounced by either party;
  • inform the CAMO or CAO and the competent authority of the Member State of registry whenever the aircraft is sold;
  • carry out all occurrence reporting mandated by applicable regulations;
  • regularly inform the CAMO or CAO about the aircraft flying hours and any other utilisation data, as agreed with the CAMO or CAO;
  • enter the CRS in the logbooks as mentioned in point (d) of point M.A.803 when performing pilot-owner maintenance without exceeding the limits of the maintenance tasks list as declared in the approved AMP as laid down in point (c) of point M.A.803;
  • inform the CAMO or CAO not later than 30 days after completion of any pilot-owner maintenance task under point (a) of point M.A.305.
  • ensure compliance with the approved maintenance programme and coordinate with the CAMO or CAO on any request to the relevant competent authority for any one-time extension to a maintenance programme interval;
  • inform the CAMO or CAO of any non-compliance with operational requirements that may affect the continuing airworthiness of the aircraft;
  • Inform the CAMO or CAO of any operational requirement (e.g., specific approvals) that must be fulfilled in order to maintain the aircraft in the required configuration.
  • When an owner or operator contracts a CAMO or CAO under point M.A.201, each party’s obligations regarding mandatory and voluntary occurrence reporting under Regulation (EU) No 376/2014 of the European Parliament and the Council shall be specified.
  • Additional requirements in the case of applying point M.A.201(ea)

In addition to the above-listed requirements and obligations when a contract between the CAMO and the operator is concluded under point M.A.201(ea), the continuing airworthiness management contract shall also comply with the requirements of the following:

  • Before the contract is signed, the operator shall assess the CAMO to ensure that the CAMO has the capability and capacity to comply with the contract.
  • Airworthiness contracts under M.A.201(ea) shall only be concluded if the air carrier is licensed under Regulation (EC) No 1008/2008 and the CAMO forms part of the same air carrier business grouping. The continuing airworthiness management contract shall clearly describe how the conditions described in M.A.201(ea) are met. It shall, in particular, describe how the organisations’ individual management systems are harmonised.

Additional obligations of the CAMO:

  • become knowledgeable about the operator’s procedure related to the monitoring of the contract;
  • obtain the agreement from the operator before subcontracting continuing airworthiness tasks;
  • inform the competent authority of the Member State of registry immediately whenever the aircraft is not presented to the approved maintenance organisation by the operator as requested by the CAMO, when the present contract is not respected or when the contract is denounced by either party;
  • Provide training for the operator’s staff to ensure that they have an understanding of the CAMO’s:

 – policies and procedures, responsibilities, obligations, duties and areas of interface;

 – lines of communication (for example, aircraft records, exchange of accurate airworthiness information in a timely manner, including outside of normal working hours);

 – procedures pertaining to the CAMO, such as customised software utilisation, reliability monitoring, aircraft technical log system use, and interoperability provisions.

Additional obligations of the operator:

  • develop interface procedures with the CAMO to address the issue and renewal of the airworthiness review certificate;
  • in case of unexpected maintenance needs in locations where no maintenance organisation approved by Annex II (Part-145) to this Regulation is contracted, inform the CAMO immediately;
  • inform the competent authority of the Member State of registry immediately whenever the contract is denounced by either party;
  • provide training for the CAMO staff in order to ensure that they have an understanding of the operator’s:

 – policies and procedures, responsibilities, obligations, duties and areas of interface;

 – lines of communication;

  • procedures pertaining specifically to the operator, such as operational procedures, customised software utilisation, aircraft technical log system use, and interoperability provisions. GM to Appendix I to Part-M — Continuing airworthiness management contract (ED Decision 2020/002/R)

An operator should establish adequate coordination between flight operations and the CAO/CAMO to ensure that both will receive all the necessary information on the aircraft’s condition to enable them to perform their tasks.

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CAMO, EASA, Regulation, Continued Airworthiness, CAO, SAS blogs, Aircraft Maintenance Program (AMP), Regulation (EU) No 748/2012, Annex II (Part-145), Aircraft Airworthiness, Annex I (Part 21), European Parliament, Aircraft Registration, M.A.201