Frequently asked questions

Is it necessary to audit the CAMO quality system?

    Oh, yeah, yeah.
    Quality system procedures are part of the procedures to be approved. This results in the quality system being subject to audit and the CAMO audit plan or programme should be considered.
    Point M.A.712(b) provides:

    • The quality system shall monitor the activities referred to in this Annex (Part-M), Section A, Subpart G. It shall include at least the following functions: 
    1. 1. Monitor that all activities referred to in this Annex (Part-M), Section A, Subpart G are carried out in accordance with approved procedures. 
    2. 2. Monitor that all contracted maintenance is being carried out in accordance with the contract. 
    3. 3. Monitor continued compliance with the requirements of this Part.

    Furthermore, quality system audits must comply with the independence requirement.
    This requirement is developed in AMC M.A.712(b) 8: The independence of audits should be established by ensuring that audits are carried out by staff who are not responsible for the functions, procedures or products to be audited.
    This implies that the quality officer cannot audit the quality system in order to maintain the independence of the audit. 

    • Therefore, in order to audit the quality system, it is acceptable that the audit of the independence of the quality system:
    1. 1. is engaged with competent personnel from another department of the same organisation, who is not responsible for functions or quality procedures of the audited organisation; or 
    2. 2. is engaged with another qualified organisation or competent staff; or
    3. 3. The quality system is supervised and certified by a certification organisation according to internationally recognised quality standards. 

    The way in which the quality system is to be audited should be described in the CAME and approved by the competent authority.

Is it necessary to appoint alternate staff for responsible staff in a CAMO?

    Neither M.A.706 (c) nor M.A.706 (d) contain a specific requirement to identify alternate staff, as is the case in 145.A.30(b)(4). So, in principle, it could be said that there are no requirements for appointing or nominating alternates of responsible staff.
    However, CAMO must comply with the requirement of continued validity of the approval contained in M.A.715, in particular point (a)(1) which refers to compliance with the requirements to maintain the continued validity of the approval.

    CAMO must ensure that it continues to meet the requirements during the absence of the responsible staff, the organisation can meet this requirement by identifying in the CAME one or more alternates and the conditions under which they will assume the responsibilities (this option may be acceptable for the short/medium term). Another option would be to nominate another person responsible. It is necessary when the absence is prolonged and in this case the nomination and acceptance by the authority is carried out using the format F-DAEA-MG-04 Request for Acceptance of Responsible Personnel of the CAMO.

Is it possible to obtain the approval of a Part 147 Maintenance Training Organisation in Spain through AESA having the headquarters outside Spain?

    In order to obtain approval 147 by AESA, the head office (headquarter or social headquarters of the company where the financial functions and operational control of the activities are exercised) must be registered in Spain. Otherwise you will have to make the application in another EU Member State.

Does a CAMO need to have a generic maintenance program when it stops managing specific and registered aircraft of a particular type if you want to keep that type of aircraft in its reach?

    M.A.709(b) allows CAMO to develop so-called Generic or Baseline Maintenance Programmes for non-operating aircraft subject to Regulation 1008/2008 and under Part M, in order to allow for the initial approval or extension of the scope of approval. 
    It is understood that the reason for this permit is to make it easier for CAMO to contract the continuous airworthiness management of specific aircraft. 
    It is understood that the interest of CAMO is to maintain the continuing airworthiness management approval of that type of aircraft in order to obtain the contract for new aircraft of that type, it is therefore reasonable to require it to be able to have such a generic or reference maintenance programme to maintain the approval. 
    As stated in M.A.709(b), the existence of this generic or reference maintenance program does not relieve the need to draft in due time an appropriate maintenance program that complies with M.A.302 so that the CAMO can make use of the powers of its approval, M.A.711.  
    Generic maintenance programs are not applicable to aircraft under Part ML.

Is a Form 1 required for the conformity of a component of a new aircraft?

    The conformity of a component/element of a new aircraft is included in that of the complete aircraft, so it is not necessary to have a Form 1.

     

Could a CAMO or a Part 145 centre issue a certificate on an aircraft that does not have an EASA certificate of airworthiness, such as Kamovs?

    No, I couldn't.

Can the Quality Officer of an organisation Part 145, with certification authorisation with scope of basic maintenance (Category LMA license), sign the CRS for basic maintenance work?

    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.

Can the Airworthiness Review Certificate (ARC) be extended during extensive maintenance/long-term storage?

    The CA(M)O that could issue the extension of the airworthiness review certificate should, inter alia, verify that the following two conditions are met: 

    1. Controlled environment conditions, M.A.901(b) or ML.A.901(c) are met. 

    An aircraft in a controlled environment is an aircraft: 

    a) the airworthiness of which has been managed continuously over the last 12 months by a single CAMO or CAO; 
    b) the maintenance of which has been carried out during the last 12 months by a maintenance organisation approved in accordance with Part 145 or the EAC Party. 

    For aircraft under Part M, this maintenance includes the maintenance tasks referred to in point M.A.803(b) performed and declared fit for service in accordance with points M.A.801(b)1 or M.A.801(b)2. 

    In the case of aircraft under Part ML, the maintenance tasks of the pilot-owner performed and declared fit for service by the pilot-owner or by independent certifying personnel are included. 

    2. There is no evidence or reason to believe that the aircraft is not airworthy, according to M.A.901(k) or ML.A.901(c)3.  
    In the case of an aircraft that is undergoing long-term maintenance/modification or is stored for a long period of time, condition 2 is not met and an extension of ARC should not be issued.

Can a maintenance organisation with rating A perform component maintenance on the aircraft, not covered by this component maintenance by the AMM and yes by the CMM?

    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.

What license is required to perform avionics tasks on aircraft less than 2 000 kg?

    The current regulations do not provide for B2 licences for aircraft under 2000, therefore, for all avionics tasks which, due to their complexity, cannot be performed by a B1 with the rating of the aircraft or the group, they can be carried out by a B2 licensed mechanic with the rating of another aircraft.