Frequently asked questions

According to paragraph 3 of point M.1 of Annex I (Part-M) to Regulation 1321/2014: 

• the authority designated by the Member State of registration of the aircraft, or
• if, prior to the approval of the aircraft maintenance programme, the Member State of registry agrees, one of the following:
  • a)the authority designated by the Member State where the operator has its head office or, where the operator does not have a head office, the authority designated by the Member State where the operator has its place of establishment or residence;
  • b)the authority responsible for the oversight of the organisation in charge of managing the continuing airworthiness of the aircraft or with which the owner has concluded a limited contract in accordance with point M.A.201, letter i), punto 3.

Yes, but only for aircraft included in TAE.AER.GEN.300.  
For the rest of the aircraft included in TAE.AER.GEN.100 and TAE.AER.GEN.200, maintenance must be performed in organizations with EASA certificate (Part 145 or Part CAO).

No, maintenance and airworthiness shall be carried out in national centres approved by EASA.

It is considered subcontracting if it manages the information, the duplication of information, or similar. It would not be subcontracting, if only the rental of equipment or space to store them were contracted, and the control and management of information was the responsibility of CAMO.

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”.

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.

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.

In principle, to maintain the privilege as a PRA in a CAMO Y, the experience demonstrated by performing work on a CAMO X will also be considered valid.

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.

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).