Sofema Aviation Services (SAS) www.sasofia.com considers the regulatory drivers ref APPENDIX II TO AMC CAR M.711(a)(3) – Sub-Contracting of Continuing Airworthiness Management Tasks
Sub-contracted Operator’s Continuing Airworthiness Management Tasks
- To control Standards Person or Group Competent with respect to CAR-M Subpart G.
o Responsible for Determining What Maintenance is
o When Maintenance is Required
o To Ensure the Standard of Maintenance is Acceptable
- Pre Contract Audit Required performed by the CAMO to ensure CAR-M Standards
o Sufficient Persons – Trained & Competent
o Consider Needs of Activities and Existing Commitments
- CAMO approval to subcontract requires a procedure for the management of subcontract arrangements
o Exposition – Relevant Procedures for Sub-Contract Arrangements
o Continue to monitor the manpower & competence of the Subcontractor
- Contract between CAMO & Subcontract – an obligation to notify CAMO and CAMO responsible to notify GCAA regarding any changes
o CAMO personnel should have access to all relevant data in order to fulfil their responsibilities.
o The contract should provide for GCAA monitoring.
o Any findings arising from the GCAA monitoring will be closed to the satisfaction of the GCAA.
- Subcontracted Organisation Procedures either own or CAMO provided
o Own procedures compatible with CAME and Contract
o Sub-contracted organisation’s procedures may only be amended with the agreement of the CAMO. (CAMO to verify compliance and compatibility)
o Procedures to be accepted by GCAA as extended procedures of the CAMO & cross-referenced
- One current copy is kept by the CAMO and should be accessible to the GCAA where needed.
Note: CAMO process and procedures take precedence & CAMO may override any recommendation made by the Sub-contracted Organisation
CAMO nominate the person responsible for continued monitoring and acceptance of the sub-contracted organisation procedures and their amendments. (Controls to be documented in CAME with Level of Involvement)
Scope of work
- A/C type & registrations plus CAW tasks specified
- Maintenance programme development and amendment
o The CAMO may sub-contract the preparation of the draft maintenance programme and any subsequent amendments. (CAMO remains responsible and obtains GCAA approval)
o The contract should also stipulate that any data necessary to substantiate the approval of the initial programme or an amendment to this programme should be provided for CAMO agreement and/or GCAA review upon request.
- Maintenance programme effectiveness and reliability
o CAMO System to monitor and assess the effectiveness
o Data collection and initial assessment by the sub-contracted organisation (endorsed by CAMO)
- Reliability Monitoring may be subcontracted (procedure to manage – CAMO personnel to attend meetings)
- Pooling of reliability data is permitted if acceptable to the GCAA.
Permitted variations to the maintenance programme
- Prepared by Subcontracted Organisation (approved and Accepted by CAMO)
- When outside the limits set out in the maintenance programme, the CAMO is required to obtain approval from the GCAA.
Scheduled maintenance
- Sub-contracted organisation – CAMO Liaison regarding the definition of maintenance checks or inspections IAW AMP.
- Documentation specified for planning control -identify CAMO Level of Involvement
- Routine line maintenance checks may be controlled on a day-to-day basis by the sub-contracted organisation subject to appropriate liaison and CAMO controls to ensure timely compliance.
o Applicable work package, including job cards,
o Scheduled component removal list,o ADs to be incorporated,
o Modifications to be incorporated.
Quality monitoring
- Quality System to monitor
o Adequacy of the sub-contracted continuing airworthiness management task performance
o Compliance with the contract and with CAR-M Subpart G. (contract should include a provision allowing the CAMO to perform quality surveillance, including audits)
- Audit report to be made available to GCAA if required
- GCAA Access to Sub Contract Organisation as required.
The CAMO should establish a ‘fast track’ means to ensure that urgent data is transmitted to the subcontractor in a timely manner.
Maintenance Data
Maintenance data may include, but is not necessarily limited to:
- Maintenance programme,
- ADs,
- Service Bulletins,
- Major repairs/modification data,
- Aircraft Maintenance Manual,
- Engine overhaul manual,
- Aircraft IPC,
- Wiring diagrams,
- Troubleshooting manual.
Airworthiness Directives
- The CAMO is responsible for ensuring the timely embodiment of applicable ADs and is to be provided with notification of compliance. (CAMO should ensure that they are in receipt of current mandatory continued airworthiness information for the aircraft and equipment it is managing.)
- The relevant procedures should specify:
o What information (e.g. AD publications, continuing airworthiness records, flight hours/cycles, etc.) the sub-contracted organisation needs from the CAMO?
o What information (e.g. AD planning listing, detailed engineering order, etc.) the CAMO needs from the sub-contracted organisation in order to ensure timely compliance with ADs?
Service Bulletin Modifications
- Subcontract Assessment SB and other associated non-mandatory
o Policy established by the CAMO & specified in the contract.
- Mandatory life limitation or scheduled maintenance controls and component control/removal forecast.
- Sub-contract planning activities specified that the organisation should receive the current flight cycles; flight hours; landings and/or calendar-controlled details, as applicable, at a frequency to be specified in the contract. (liaison between the CAMO, the contracted maintenance organisation(s) and the sub-contracted organisation.)
- The contract should specify how the CAMO will be in possession of all current flight cycles, flight hours, etc. so that it may assure the timely accomplishment of the required maintenance.
Engine health monitoring
For sub-contracts the on-wing engine health monitoring
- A sub-contracted organisation should receive all the relevant information, including any parameter reading deemed necessary to be supplied by the CAMO for this control.
- The contract should also specify what kind of feedback information (such as engine limitation, appropriate technical advice, etc.) the organisation should provide to the CAMO.
Defect control
- CAMO has sub-contracted the day-to-day control of technical log deferred defects, this should be specified in the contract and should be adequately described in the appropriate procedures. (Use of operators MEL/CDL & AOG procedures)
- Procedure for repetitive defects, and damage beyond type certificate holder’s limits.
- Defects identified during maintenance are brought to the attention of the CAMO which depending upon the procedural authority granted by the GCAA may determine that some defects can be deferred.
- Liaison between the CAMO, its sub-contracted organisation and the contracted maintenance organisation
- The sub-contracted organisation should make a positive assessment of potential deferred defects and consider the potential hazards arising from the cumulative effect of any combination of defects.
o The sub-contracted organisations should liaise with the CAMO to gain its agreement following this assessment.
Deferment of MEL/CDL allowable defects can be accomplished by a contracted maintenance organisation in compliance with the relevant technical log procedures, subject to acceptance by the aircraft commander.
Mandatory occurrence reporting
The CAMO should ensure adequate liaison exists between the sub-contracted organisation and the maintenance organisation. (all reporting requirements to comply with)
Continuing airworthiness records
- Records may be maintained and kept by the sub-contracted organisation on behalf of the CAMO who remains the owner of these documents. However, the CAMO should be provided with the current status of AD compliance and life-limited parts and time-controlled components in accordance with the agreed procedures.
- The CAMO should also be granted unrestricted and timely access to original records as and when needed. Online access to the appropriate information systems is acceptable.
- The record-keeping requirements of CAR M should be met. Access to the records by duly authorised members of the GCAA should be granted upon request.
Maintenance Check flight (MCF) procedures
MCF is performed under the control of the operator in coordination with the CAMO. MCF requirements from the sub-contracted organisation or contracted maintenance organisations should be agreed by the operator/CAMO.
Communication between the CAMO and sub-contracted organisation
- In order to fulfil its airworthiness responsibility, the CAMO needs to receive all the relevant reports and relevant maintenance data.
- The contract should specify what information should be provided and when.
- Meetings provide one important cornerstone whereby the CAMO can fulfil part of its responsibility for ensuring the airworthiness of the operated aircraft. They should be used to establish good communications between the CAMO, the sub-contracted organisation and the contracted maintenance organisation.
- The terms of the contract should include, whenever appropriate, the provision for a certain number of meetings to be held between the involved parties. Details of the types of liaison meetings and associated terms of reference for each meeting should be documented. The meetings may include but are not limited to all or a combination of:
o Contract review
o Work scope planning meeting
o Technical meeting
- Scheduled meetings should be organised in order to review on a regular basis and agree on actions on technical matters such as ADs, SBs, future modifications, major defects found during shop visits, reliability, etc…
o Quality meeting
- To examine matters raised by the CAMO’s quality surveillance and the GCAA’s monitoring activity and to agree on necessary corrective actions.
o Reliability meeting
- When a reliability programme exists, the contract should specify the involvement of the CAMO and of the subcontracted organization in that programme, including the participation to reliability meetings.
- Provision to enable the GCAA participation in the periodical reliability meetings should also be made.
Next Steps
Sofema Aviation Services (SAS) www.sassofia.com Sofema Online (SOL) www.sofemaonline.com provide Classroom, Webinar & Online Training in support of UAE GCAA Regulations please see the relevant website or email team@sassofia.com
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SAS blogs, CAR-M Subpart G, Maintenance Check Flight (MCF), Aircraft Maintenance Manual (AMM), service bulletin (SB), Sub-Contract, Aicraft Maintenance, Maintenance Data, Alert Service Bulletins, Continuing Airworthiness (CA), Aircraft, UAE GCAA, Repairs, Aircraft Reliability, CAR M, Airworthiness, continuing airworthiness management, Quality System, Compliance, CAMO
