Frequently asked questions

Is there any requirement to maintain "back-to-birth traceability" for any component installed on a European aircraft?

    The term “back to birth” is not used in European regulation. The requirements for a limited life component (see definition in GM M.A.305) are basically defined in M.A.305 (d) and (e) and ML.A. 305 (e) and (h). All records of the details of a maintenance task (e.g. a restoration) must be retained until another equivalent maintenance task in its scope (another restoration) is performed, but never for a period of less than 36 months. It should be considered that:

    1.  A log card with all relevant information must be saved, so the action should be noted on it, and 

    2.  Records that show compliance with other requirements set out in M.A.305 or ML.A.305, e.g. An airworthiness directive, or any other information that may affect the configuration of the aircraft, must be kept as well.

For the purposes of the aeronautical regulation of continuous airworthiness, when should such airworthiness of an aircraft be considered to be assigned to a CAMO? What consideration should be given to contracts that operators and owners can sign with CAMO?

    It is at the time of approval of the CAME that the aircraft is included when it is considered that it starts to be managed by the corresponding CAMO.

    The contract for the provision of airworthiness management services by operators and owners with a CAMO, although its characteristics are not required by EASA, is very useful in assessing the circumstances leading to the approval of the corresponding CAME.

    It is possible to recommend to those responsible for CAMO that clauses concerning the temporal extension, beginning and end of the agreement, contracted time and resources, availability of the aircraft and its technical records, etc., are established in the clearest and most explicit manner possible.

Clarification regarding continuous training of certifying and support staff in 145.A.35.

    Part-145 does not require continuous training for certifying personnel in the fleet. The required course in new technologies does not have to be focused on an aircraft, but on new tools, test methods, software, etc. Therefore, it does not have to be an aircraft course and yes of these new techniques. If the same new technologies have been developed for an aircraft similar to the range, a course on that aircraft covering them would be valid.

With regard to the application of the requirements of M.A.711(a)3, in particular what Appendix II to AMC M.A.711(a)(3) provides regarding the control that CAMO (and subsequently the authority’s supervision) has to have over the subcontractor of CAMO tasks, when that subcontractor is the TCH of the product, should CAMO audit it as an additional subcontractor and AESA go to supervise it like any other subcontractor or, taking into account that the subcontractor is the TCH, are exceptions allowed?

    If the TCH only sends data and then it is the CAMO that analyses it, then it is NOT considered a subcontractor.
    However, if the TCH sends both data and the analysis thereof, then if it is considered a subcontractor.

When a CAMO organisation hires a company to retain its data on an “external” server, is this contractual relationship considered as subcontracting?

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

, maintenance personnel may be designated as a PRA of an aircraft, as long as they have not been involved in the issuance of the CRS of that aircraft. Should the same independence requirement be fulfilled when CAMO and the maintenance organisation are not the same?

    In the event that CAMO and the maintenance organisation are independent (other than the same company), the independence requirement of AMC M.A.707(a) for the PRA must also be met if it is related to both organisations.

Point CAT.GEN.MPA.195 (a) of Regulation 965/2012 AIR OPS requires that "After an accident or incident subject to mandatory notification, the operator of an aircraft shall retain the original recorded data for a period of time 60 days unless otherwise provided by the investigating authority." While the responsibility lies with the operator, it is the 145 centre that performs the action in accordance with its procedures. Where should the extra requirements you want to put the CAMO to 145 be collected?

    While it is a regulatory requirement to be met by the Operator/CAMO, they do so through their organisation P145. It should therefore be reflected in contract CAMO-145.

In relation to electronic notification, the company has an electronic FNMT certificate in its name. Could it be used for the purpose of receiving notifications and read permissions regardless of which user(s) are designated and communicate to AESA? In the case of authorised users in the Company, which personal certificates are accepted by the agency?

    The company’s certificate should be valid in accordance with Articles 9 and 10 of Law 39/2015 on the Common Administrative Procedure of Public Administrations. 
    The electronic ID is one of the valid certificates accepted. However, if you want to avoid the use of personal IDs, you can opt for one of the other certificates accepted by the agency: 

    • Certificate of the FNMT
    • Digital certificates accepted by @firma. 
For aircraft with a national certificate of airworthiness only, could maintenance and airworthiness management be performed in part 145 centres and EASA-approved camos?

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

A CAMO 1 uses the 90-day advance notice to perform an airworthiness review or uses the 30-day advance notice for an extension. After issuing the ARC or the extension, the aircraft is transferred during the advance period from “CAMO 1” to a “CA(M)O 2”. As a consequence, the “CA(M)O 2” manages the aircraft for a period of time longer than 12 months. Could the ARC be extended on the understanding that the requirements of M.A.901(b)(1) are met?

    No, you couldn't. 

    The purpose of paragraph M.A.901(b)(1) is to define a part of the concept “controlled environment”, stating that the aircraft must be managed over the last 12 months by a single CAMO or CAO with regard to the validity of an ARC. 

    In the case described, although the “CA(M)O 2” may have been managing the airworthiness of the aircraft for a period of more than 12 months, such as the CA(M)O that issued the ARC or the previous extension, the aircraft shall be deemed to have been managed by more than one CAMO or CAO since the date of issuance of the last ARC or the last extension, implying that the condition “controlled environment” is not met. 

    This is to prevent the transfer of the aircraft within the 90-day advance period (ARC) or 30 days (extensions) with the intention of avoiding the completion of a complete airworthiness review at the time of expiry of the airworthiness review certificate. 
    This does not apply to Part ML aircraft, as referred to in paragraph (c) of point ML.A.901, the CA(M)O may extend the ARC regardless of who issued the original ARC.