Frequently asked questions

Certifying or releasing a maintenance task by means of a TLB, CRS or EASA Form 1 is considered to be the last action in the production process of a maintenance facility, and this task is the privilege of the certifying staff duly authorised to do so. A Quality Manager of a maintenance centre, as well as the Quality System auditors, should not be involved in this production process (AMC 145.A.65 (c) 1-11), since when managing/performing quality audits, an essential component of the Quality System, the required independent nature of the quality system would be infringed. 
 
Depending on the size of the organisation in some cases, and in the reverse direction of the case being dealt with, competent personnel, without being quality auditors, are allowed to carry out quality audits of production processes in which they are not directly involved, but it is not admitted that the Head of the Quality System or Personnel Auditor exercises the certification privileges.

Oh, yeah, yeah. In relation to maintenance of aircraft components by an organisation with rating A, maintenance not covered by the AMM and yes by the CMM, Regulation 1321/2014 makes two references: 

1.- Appendix IV to Part M, paragraph 4
It argues that an A-rating organisation can maintain components in the aircraft according to the CMM. 
Limitation: That component must be fixed on the aeroplane and may only be disassembled to improve access to that component during maintenance. Such disassembly cannot generate additional maintenance. This maintenance should be included in section 1.9.1 of the Organisation’s Manual (MOE/MOM) and approved by EASA. 

2.- M.A.502 (b) 
It argues that for this maintenance it is not necessary to issue an EASA Form 1, it is sufficient to refer this maintenance in the CRS (CMM task) of the aircraft.

As provided in point CAMO.A.125(d)(3), a CAMO may organise the performance of limited continuing airworthiness tasks with any subcontracted undertaking, working under its Management System, which shall be included in its certificate of approval (AC-CAMO-P01-F14).
Tasks that can be outsourced include reliability control and engine health control (reliability monitoring & engine health monitoring). 
However, when these tasks are entrusted to the manufacturers or owners of the aircraft or engine designs and their feedback is limited to reporting to CAMO the reading of the data provided, it will be considered as non-subcontracting and, therefore, will not be included in the CAMO approval certificate.

“Details of maintenance work performed” according to GM M.A.305(g) are the records that must be maintained by the person or organisation responsible for the continuing airworthiness of the aircraft in accordance with M.A.201 in order to be able to fulfil its obligations under Part M. They are only part of the records referred to in points CAO.A.090(a) or 145.A.55(a).
Maintenance organizations must keep all detailed records to demonstrate that they have worked in accordance with their respective requirements and procedures.
It is not necessary to transfer all records from the maintenance organisation to the person or organisation responsible for the continuing airworthiness of the aircraft in accordance with M.A.201, unless they specifically contain information relevant to the configuration of the aircraft and its future maintenance. Therefore, it is not necessary for the person or organisation responsible in accordance with M.A.201 to keep the certificates of conformity, the references to the batch numbers of the material used or the individual work cards verified and/or generated by the maintenance organisation. However, the owner/CAMO may request such information from the maintenance organisation to verify and demonstrate the effectiveness of the aircraft maintenance programme.
Information relevant to future maintenance may be contained in specific documents related to:

• amendments;
• airworthiness directives;
• repaired and unrepaired damage;
• components mentioned in M.A.305(d); and
• measures relating to defects.

Yes, regardless of owner/operator approvals and scope, you have the option to sign a contract with a CAMO. The important thing is that continued airworthiness is managed by an appropriate CAMO.

Electric load analysis (ELA) is provided by the aircraft manufacturer to the operator.
These data are part of the ICAs (see AMC to Appendix H, H25.5 Instructions for continuing airworthiness applicable to point 5 of the EWIS). Changes to ICAs are changes to the type certificate that must be approved in accordance with Part 21.
Where relevant, a change or modification should contain a difference sheet for ELA, so that the operator can update the current ELA.
CAMO is responsible for the condition of the ELA, which must be in accordance with the design of the aircraft, including its approved changes.
The aircraft owner should have access to all relevant information to fulfil its continuing airworthiness obligations under Regulation (EU) 1321/2014, for example to provide that information to the competent authority on request or to transfer the continuing airworthiness records of the aircraft to a new owner when the aircraft changes ownership or in similar circumstances.
The new CAMO, which receives the aircraft, will verify this data when developing the aircraft maintenance program (see M.A.302).

The standard does not impose a "basic" or "generic" maintenance program; however, Chapter 1.2 of the CAME should describe how the organisation will develop the AMP. 
The organization must define the means to demonstrate that they are competent for the management that is intended to be carried out. Certain elements, such as the IT tool to manage the AMP, access to applicable technical documentation and/or staff experience in AMP matters, can contribute to achieving this objective.

Yes, an organization with Part CAMO approval may have a generic scope on its approval certificate (AC-CAMO-P01-F14). However, even if the organisation approval has a generic scope, the continuing airworthiness management exposition (CAME) shall always reflect the specific scope of the organisation; It is therefore recommended that the generic scope of approval should not be excessively broad compared to the scope defined in the CAME.  
Organisations shall request from AESA any change to the scope defined in the approval certificate.

There must be an agreement between the auditor and the auditee that includes:

• The platform to be used (e.g.: WebEx, Teams, Lync, etc.);
• Pre-audit platform compatibility testing;
• Consider using cameras when a physical evaluation is required. Check beforehand that there is data/wifi coverage in all areas to be audited and that they need to be viewed with the remote camera.
• Establish an audit plan that identifies the IT means that will be used and the use that will be given to them to optimize and, at the same time, maintain the integrity of the process;
• If necessary, consider time differences in order to be able to coordinate at reasonable times for both parties;
• A written statement that the auditee will cooperate to the fullest extent possible and provide the truthful information requested, including the cooperation of subcontracted companies if necessary;
• Data protection aspects.

This applies both to remote audits carried out by the competent authority and to audits carried out by organisations on their own suppliers and subcontractors.  
Authorities/organisations that decide to use remote audits should describe the functioning of remote audits in their procedures and should consider at least the following points:

• The use of an information technology methodology flexible enough to optimize the conventional audit process.
• The definition and implementation of controls to avoid abuses that could compromise the integrity of the audit process.
• Measures to ensure that security and confidentiality are maintained during audit activities (data protection and intellectual property of organisations must also be safeguarded).

Further information can be found in the guidance material “GM1 CAMO.A.200(a)(6) and CAMO.B.300 Management system and Oversight principles”.