When is a CAO considered small according to CAO.A.100(e)?

Since a CAO organization only has a single approval, regardless of privileges (maintenance only, continued airworthiness only, or both), it cannot be considered simultaneously small and large. That is, if it were small for one privilege and large for the other, the organization would be considered large as a whole.

According to CAO.A.100(e):

• If the scope of the organization only has aircraft listed in Part-ML (CAO.A.100 and (1)) then the CAO can be considered small, regardless of the number of workers (FTE)
• Other options to be considered small, must meet the following two conditions:

1. The organization does not exceed 10 FTEs involved in maintenance, if such privilege is applicable.
2. And the organization does not exceed the 5 FTEs involved in continuing airworthiness management, if such privilege is applicable.

As a CAO organisation will have only a single approval, independent of the number of privileges (only maintenance, only continuing airworthiness or maintenance and continuing airworthiness), it cannot be simultaneous small and big.

Please see below our interpretation of (CAO.A.100(e)):

- If ‘The scope of the CAO does only contain aircraft covered by Part‐ML’(CAO.A.100(e)(1)) Then ‘A CAO shall be considered as a small CAO’ (regardless of the number of FTE)

If the first condition is not valid, then we have to check how many FTE staff are working.

- To still be considered as a small CAO:

• The organisation does not exceed 10 FTE staff involved in maintenance (if privilege is applicable, CAO.A.100(e)(2))
• And the organisation does not exceed 5 FTE staff involved in continuing airworthiness management (if privilege is applicable, CAO.A.100(e)(3)).