Can a part-66 certifying staff perform an airworthiness review on an aircraft in which he or she had released some maintenance?

To avoid compromising the independence of the ARS,  he or she should have not been involved in the release to service of the aircraft of which he or she intends to perform the airworthiness review, except on maintenance tasks performed during the physical survey or performed as a result of findings discovered during the physical survey of the airworthiness review (AMC M.A.707 (a)).

Can an airworthiness review certificate (ARC)/recommendation be issued after an airworthiness review with open findings?

Neither an ARC nor a recommendation can be issued with open findings. Each finding requires a corrective action before the issue of the ARC or recommendation. The corrective action should be adequate to the open finding and it should be carried out and verified by the airworthiness review staff (ARS) before the issue of the ARC/ recommendation.

Does the CAMO quality system need to be subject to monitoring?

Yes, the quality system is part of the activities of the CAMO and therefore it should be monitored.

Point M.A.712(b) requires that the quality system monitors:

• that all CAMO activities are being performed in accordance with the approved procedures, and,
• the continued compliance with requirement of part-M.

The quality system procedures are considered to be within these approved procedures . This implies that quality system must be subject to audits and the CAMO audit programme/plan needs to reflect this.

Besides that the audits to the quality system shall satisfy the requirement of independent audits. This is further explained in AMC M.A.712(b) point 8: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit. Therefore, to audit the quality system, it is acceptable:

• to use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
• to contract the independent audit element of the quality system to another organisation or a qualified competent person, or,
• that the quality system is monitored and certified against an internationally recognised quality standards by a certification organisation

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

Are deputy nominated persons required in CAMO?

Neither M.A.706 (c) nor M.A.706 (d)  contain a specific requirement for the identification of deputy “nominated persons” as in part-145 (145.A.30(b)(4)). So, in principle, we could say that there is no requirement for the nomination or identification of deputy “nominated persons”.

Nevertheless, the CAMO needs to take into account the conditions for the continued validity of the approval contained in M.A.715, in particular point (a)(1) which refers to the continued validity of the approval provided the organisation remains in compliance with the requirements.

The CAMO should ensure that they remain in compliance during the absence of the nominated persons, this could be by identifying in the CAME  “one or several deputies” and the conditions under which the deputies will assume the responsibilities (this option could be acceptable for a short/medium absence). Another option would be to nominate another person. This would be necessary when the absence is going to be of considerable length and in this case the nomination and acceptance by the competent authority is done using the Form 4.

Quality manager for CAMO: Nomination, acceptance, qualification

The quality manager is considered nominated personnel according M.A.706 (c). The minimum qualification and experience requirements are contained in AMC M.A.706.

The nomination of the quality manager shall be performed using the EASA Form 4.

Which are the correct statements to be written in block 11 of EASA Form 1 after maintenance?

Appendix II to part-M describes the following 4 permissible entries in block 11 of EASA Form 1:

• Overhauled,
• Repaired
• Inspected/tested
• Modified

The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of part-M/part-145.  Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.The text in AMC No 2 to 145.A.50(d) point 2.4  “stating ‘Inspected’ in block 11” is an editorial mistake and it will be corrected in the next revision of the AMC to part-145.

Is there any European requirement to maintain the back-to-birth traceability for any component fitted to an European aircraft?

The term “back to birth” is not used in European regulations. The requirements that apply to a service life-limited component (see definition in AMC M.A.305) are basically stated in M.A.305 (e) and (h). All detailed maintenance records of a maintenance action (e.g. a restoration) must be kept until another maintenance action equivalent in scope (another restoration) is done, but never less than 36 months. Keep in mind that:

• a service life limited component log card must be kept with all the relevant information, so the action should be recorded there, and
• the records showing compliance with other requirements stated in M.A.305, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.

What does the term “detailed maintenance records” mean?

“Detailed maintenance records” are those records required to be kept by the owner/operator to be able to determine the continuing airworthiness and configuration of the aircraft in accordance with part-M relevant for future maintenance. These are different from the detailed maintenance records required to be kept by a maintenance organisation as per M.A.614 or 145.A.55(c). Whereas maintenance organisations are required to retain all detailed records to demonstrate that they worked in compliance with their respective requirements, aircraft owners/operators need to retain those records required for assessing the aircraft configuration and the airworthiness of the aircraft and all components installed. ‘Dirty finger prints’ may not need to be transferred from the maintenance organisation to the aircraft owner/operator.

Where the maintenance organisation retains the detailed maintenance records in accordance with 145.A.55(c) and M.A.614, the owner/operator should receive the aircraft release to service of the maintenance performed  and all information necessary to determine the aircraft continuing airworthiness and its configuration, which includes references to all:

• References to taskcards,
• Information and substantiating data on modifications,
• Airworthiness directives,
• Information and substantiating data on repaired and non-repaired damage, and measurements relating to defects.

Can an independent certifying staff maintain ELA1 aircraft used for commercial operations (such as ATO)?

No, ELA1 aircraft used for commercial operations cannot be maintained by independent certifying staff because in accordance with M.A.201(i) commercial operations require maintenance release by an organisation (part-M subpart-F or part-145 approved).

Does an approved training organisation (ATO) need to contract a CAMO?

Point M.A.201 (i) applies to ATO holding an approval from the competent authority, as long as they deliver training as an activity with commercial purposes. In that case the continuing airworthiness management of the aircraft operated by the ATO shall be performed by a CAMO.  The ATO shall either obtain a CAMO approval or contract a CAMO.