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Part-M: Continuing
airworthiness requirements
(Annex I to EC 2042/2003)
Juan Anton
Continuing Airworthiness Manager
Rulemaking Directorate
17-19 DECEMBER 2007
EUROMED CONFERENCE
European Aviation Safety Agency
M.1 Competent Authority
Oversight of aircraft and issue ARC:
Authority of Member State of Registry.
Oversight of Subpart F organisations:
Authority of Member State of Principle Place of Business.
EASA for organisations located in third country.
Oversight of CAMOs:
Authority of Member State of Principle Place of Business if
independent CAMO (no AOC).
Authority of Member State of operator (if part of AOC).
EASA for organisations located in a third country.
Approval of maintenance programmes:
Authority of Member State of Registry.
In commercial air transport, the authority agreed by Member
State of Registry and Member State of operator (if different).
17-19 DECEMBER 2007
Slide 2
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
Pre-flight inspection:
Responsibility of Pilot-in-command (or operator in case
of CAT: Commercial Air Transport).
Performed by the pilot or another qualified person.
No need to be done by approved maintenance
organisations or Part-66 certifying staff.
Maintenance of large aircraft and aircraft used in CAT:
Must be performed in Part-145 organisations.
Maintenance of other aircraft:
By Subpart F organisations, by independent Part-66
certifying staff and by the pilot-owner (depending on
the type of tasks and as required by M.A.502 and
M.A.801(b)).
17-19 DECEMBER 2007
Slide 3
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
Aircraft used in Commercial Air Transport (CAT):
Operator is responsible for continuing airworthiness.
Shall be approved as a CAMO (part of the AOC).
Shall be approved as Part-145 or contract a Part-145.
If Member State requires a certificate for the operational
activities (other than CAT):
Operator is responsible for continuing airworthiness.
Shall be approved as CAMO or contract a CAMO.
Shall be approved as Subpart F or Part-145 (as
applicable for the size of aircraft) or contract such
organisations.
17-19 DECEMBER 2007
Slide 4
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
Private large aircraft:
Owner is responsible for continuing airworthiness.
Shall contract a CAMO.
Maintenance has to be performed in Part-145 (no need
for contract).
Private aircraft (other than large)
Owner is responsible for continuing airworthiness.
It is not mandatory to contract a CAMO.
Maintenance by Subpart F, independent certifying staff
and pilot-owner (depending on the type of tasks and as
required by M.A.502 and M.A.801(b)).
17-19 DECEMBER 2007
Slide 5
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
When contracting a CAMO:
The contract must comply with Appendix I.
Appendix I describes the responsibilities of the owner
and the responsibilities of the CAMO.
For CAT it is not possible to contract a CAMO. The
operator must be approved as a CAMO:
The operator may sub-contract, under its Quality
System, some tasks as per AMC to M.A.201(h)1 and its
Appendix II.
The subcontracted organisation does not need to be a
CAMO.
The responsibility for the tasks is always of the
operator CAMO.
17-19 DECEMBER 2007
Slide 6
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.202 Occurrence reporting
Must be done by all persons responsible under M.A.201.
Reported to State of Registry, State of operator (if
applicable) and TC/STC holders.
Maintenance organisations and independent certifying
staff shall report to the owner / operator.
Reports shall be done before 72 hours.
17-19 DECEMBER 2007
Slide 7
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.301 Continuing airworthiness
tasks
This article shows the list of continuing airworthiness
tasks:
Preflight-inspections
Rectification of defects to a recognised standard
Accomplishment of maintenance per the maintenance
programme
Analysis of effectiveness of maintenance programme
(for CAT and large aircraft)
Accomplishment of ADs, operational ADs and other
requirements established by EASA or the authority
Accomplishment of repairs and modifications
Policy for embodiment of non-mandatory modifications
and inspections (for CAT and large aircraft)
Flight checks when necessary
17-19 DECEMBER 2007
Slide 8
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.302 Maintenance programme
A maintenance programme approved by the
Competent Authority is always required.
Provisions for indirect approval may be introduced
through approved procedures in the exposition
(CAME).
17-19 DECEMBER 2007
Slide 9
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.303 Airworthiness Directives
Airworthiness Directives are mandatory.
17-19 DECEMBER 2007
Slide 10
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.304 Data for modifications and
repairs
Data must be approved by EASA or by Part-21
design organisations.
17-19 DECEMBER 2007
Slide 11
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.305 Aircraft continuing
airworthiness record system
Contains the records that must be kept by the owner /
operator and the conditions of storage and control. This is
additional to the record keeping requirements for Part145, Subpart-F and CAMO organisations.
Contains the period of time during which they have to be
maintained.
M.A.306 requires for Commercial Air Transport, an
additional Operator´s Technical Log System.
M.A.307 covers the transfer of those records to a new
owner / operator.
17-19 DECEMBER 2007
Slide 12
EUROMED CONFERENCE
European Aviation Safety Agency
Maintenance Standards
M.A.401: Maintenance data.
M.A.402: Performance of Maintenance.
All maintenance performed by qualified personnel and
following M.A.401 maintenance data.
Independent duplicate inspection required for flight sensitive
maintenance tasks.
Use of M.A.401 tools, equipment and materials.
Appropriate facilities.
Final check that no tools or other parts and material are left
in the aircraft / component.
M.A.403: Aircraft defects.
These requirements are additional to Part-145 and Subpart F in order to cover
also independent certifying staff, pilot owner maintenance and
maintenance performed in AOG situations.
17-19 DECEMBER 2007
Slide 13
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.501 Installation of
components
Documentation needed for components:
New components: EASA Form 1 or FAA 8130-3 or TCCA240078.
Maintained components: EASA Form 1 or FAA 8130-3 (dual
release) or TCCA24-0078 (dual release)
Standard parts and materials (raw / consumable) do not need a
Form 1 or equivalent. Certificate of Conformance is enough.
Installer must check eligibility of component:
Particular attention to modifications and configuration of
aircraft, engines, etc.
17-19 DECEMBER 2007
Slide 14
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.502 Component maintenance
Maintenance of components has to be done in approved
organisations (no independent certifying staff), except:
While maintained on the aircraft or,
Temporarily removed to facilitate access if permitted
by aircraft maintenance data.
17-19 DECEMBER 2007
Slide 15
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.504 Control of unserviceable
components
Unserviceable components identified and stored in a
secure location.
Components that reached their life limit or that can not be
repaired, shall be classified unsalvageable:
Not permitted to re-enter the supply chain.
Kept in a secure location or have it mutilated.
Responsibility can be transferred without mutilating the
component to a training organisation.
17-19 DECEMBER 2007
Slide 16
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart F: Maintenance
Organisation
Subpart F maintenance organisation can only maintain aircraft
and components when not used in commercial air transport and
not used in large aircraft.
Main differences with Part-145:
No need for independent quality system (organisational
reviews required).
No privileges for sub-contracting.
No base maintenance and no category C Part-66 personnel
required.
No category A personnel.
Some organisations may prefer to move-up to a Part-145
approval (includes the privileges of Subpart F organisations).
17-19 DECEMBER 2007
Slide 17
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart G: Continuing Airworthiness
Management Organisation – Privileges
(M.A.711)
A CAMO may:
Manage aircraft not involved in CAT as listed in the certificate
Manage CAT aircraft when listed in its AOC.
Subcontract tasks to an organisation that works under its
quality system (this organisation does not need to be a
CAMO)
A CAMO may additionally be approved to:
Issue ARCs (following M.A.901)
Make recommendations for an ARC to a Member State of
Registry (any Member State)
THIS PRIVILEGE CAN ONLY BE GRANTED TO CAMOs
REGISTERED IN A MEMBER STATE.
17-19 DECEMBER 2007
Slide 18
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart G: Continuing Airworthiness
Management Organisation – Personnel
M.A.706:
1 Accountable Manager: corporate financial authority.
A person or group of persons responsible for ensuring that
the organisation is always in compliance with Part-M.
1 Nominated Postholder (only for CAT): responsible for
the management and supervision of the continuing
airworthiness activities of the paragraph above.
M.A.712(a):
1 Quality Manager (except for small organisations not
involved in CAT, per M.A.712(e) and (f)).
17-19 DECEMBER 2007
Slide 19
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart G: Continuing Airworthiness
Management Organisation –
Airworthiness Review Staff (M.A.707)
Qualifications required:
5 years experience in continuing airworthiness.
An appropriate Part-66 licence or aeronautical degree or
equivalent.
Formal aeronautical maintenance training.
A position in the organisation with the appropriate
responsibilities
Independent from the continuing airworthiness
management process, or
Overall authority.
Must be approved by the competent authority after performing
an airworthiness review under supervision.
17-19 DECEMBER 2007
Slide 20
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.901 Aircraft airworthiness review
(M.A.901)
An ARC has to be issued with a validity of 1 year.
Controlled environment means:
Aircraft managed by CAMO during the previous 12 months,
and
Maintained only by approved organisations (no independent
certifying staff, except for pilot owner maintenance)
If the aircraft is in a controlled environment:
The CAMO (if it has Subpart I privileges) can issue the ARC
after performing a full airworthiness review in accordance
with M.A.710.
If the aircraft continues under their control, they can extend
the ARC twice. They can not extend ARCs issued by another
organisation or by the authority.
17-19 DECEMBER 2007
Slide 21
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.901 Aircraft airworthiness review
(M.A.901)
If the aircraft is NOT in a controlled environment or
managed by a CAMO without Subpart I privileges:
The ARC will be issued by the Competent Authority based on
a recommendation issued by a CAMO with appropriate
privileges (the CAMO has to do the airworthiness review).
If there is a safety concern, the authority may decide to
do the review and issue the ARC themselves.
17-19 DECEMBER 2007
Slide 22
EUROMED CONFERENCE
airworthiness requirements
(Annex I to EC 2042/2003)
Juan Anton
Continuing Airworthiness Manager
Rulemaking Directorate
17-19 DECEMBER 2007
EUROMED CONFERENCE
European Aviation Safety Agency
M.1 Competent Authority
Oversight of aircraft and issue ARC:
Authority of Member State of Registry.
Oversight of Subpart F organisations:
Authority of Member State of Principle Place of Business.
EASA for organisations located in third country.
Oversight of CAMOs:
Authority of Member State of Principle Place of Business if
independent CAMO (no AOC).
Authority of Member State of operator (if part of AOC).
EASA for organisations located in a third country.
Approval of maintenance programmes:
Authority of Member State of Registry.
In commercial air transport, the authority agreed by Member
State of Registry and Member State of operator (if different).
17-19 DECEMBER 2007
Slide 2
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
Pre-flight inspection:
Responsibility of Pilot-in-command (or operator in case
of CAT: Commercial Air Transport).
Performed by the pilot or another qualified person.
No need to be done by approved maintenance
organisations or Part-66 certifying staff.
Maintenance of large aircraft and aircraft used in CAT:
Must be performed in Part-145 organisations.
Maintenance of other aircraft:
By Subpart F organisations, by independent Part-66
certifying staff and by the pilot-owner (depending on
the type of tasks and as required by M.A.502 and
M.A.801(b)).
17-19 DECEMBER 2007
Slide 3
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
Aircraft used in Commercial Air Transport (CAT):
Operator is responsible for continuing airworthiness.
Shall be approved as a CAMO (part of the AOC).
Shall be approved as Part-145 or contract a Part-145.
If Member State requires a certificate for the operational
activities (other than CAT):
Operator is responsible for continuing airworthiness.
Shall be approved as CAMO or contract a CAMO.
Shall be approved as Subpart F or Part-145 (as
applicable for the size of aircraft) or contract such
organisations.
17-19 DECEMBER 2007
Slide 4
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
Private large aircraft:
Owner is responsible for continuing airworthiness.
Shall contract a CAMO.
Maintenance has to be performed in Part-145 (no need
for contract).
Private aircraft (other than large)
Owner is responsible for continuing airworthiness.
It is not mandatory to contract a CAMO.
Maintenance by Subpart F, independent certifying staff
and pilot-owner (depending on the type of tasks and as
required by M.A.502 and M.A.801(b)).
17-19 DECEMBER 2007
Slide 5
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.201 Responsibilities (for
continuing airworthiness)
When contracting a CAMO:
The contract must comply with Appendix I.
Appendix I describes the responsibilities of the owner
and the responsibilities of the CAMO.
For CAT it is not possible to contract a CAMO. The
operator must be approved as a CAMO:
The operator may sub-contract, under its Quality
System, some tasks as per AMC to M.A.201(h)1 and its
Appendix II.
The subcontracted organisation does not need to be a
CAMO.
The responsibility for the tasks is always of the
operator CAMO.
17-19 DECEMBER 2007
Slide 6
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.202 Occurrence reporting
Must be done by all persons responsible under M.A.201.
Reported to State of Registry, State of operator (if
applicable) and TC/STC holders.
Maintenance organisations and independent certifying
staff shall report to the owner / operator.
Reports shall be done before 72 hours.
17-19 DECEMBER 2007
Slide 7
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.301 Continuing airworthiness
tasks
This article shows the list of continuing airworthiness
tasks:
Preflight-inspections
Rectification of defects to a recognised standard
Accomplishment of maintenance per the maintenance
programme
Analysis of effectiveness of maintenance programme
(for CAT and large aircraft)
Accomplishment of ADs, operational ADs and other
requirements established by EASA or the authority
Accomplishment of repairs and modifications
Policy for embodiment of non-mandatory modifications
and inspections (for CAT and large aircraft)
Flight checks when necessary
17-19 DECEMBER 2007
Slide 8
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.302 Maintenance programme
A maintenance programme approved by the
Competent Authority is always required.
Provisions for indirect approval may be introduced
through approved procedures in the exposition
(CAME).
17-19 DECEMBER 2007
Slide 9
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.303 Airworthiness Directives
Airworthiness Directives are mandatory.
17-19 DECEMBER 2007
Slide 10
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.304 Data for modifications and
repairs
Data must be approved by EASA or by Part-21
design organisations.
17-19 DECEMBER 2007
Slide 11
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.305 Aircraft continuing
airworthiness record system
Contains the records that must be kept by the owner /
operator and the conditions of storage and control. This is
additional to the record keeping requirements for Part145, Subpart-F and CAMO organisations.
Contains the period of time during which they have to be
maintained.
M.A.306 requires for Commercial Air Transport, an
additional Operator´s Technical Log System.
M.A.307 covers the transfer of those records to a new
owner / operator.
17-19 DECEMBER 2007
Slide 12
EUROMED CONFERENCE
European Aviation Safety Agency
Maintenance Standards
M.A.401: Maintenance data.
M.A.402: Performance of Maintenance.
All maintenance performed by qualified personnel and
following M.A.401 maintenance data.
Independent duplicate inspection required for flight sensitive
maintenance tasks.
Use of M.A.401 tools, equipment and materials.
Appropriate facilities.
Final check that no tools or other parts and material are left
in the aircraft / component.
M.A.403: Aircraft defects.
These requirements are additional to Part-145 and Subpart F in order to cover
also independent certifying staff, pilot owner maintenance and
maintenance performed in AOG situations.
17-19 DECEMBER 2007
Slide 13
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.501 Installation of
components
Documentation needed for components:
New components: EASA Form 1 or FAA 8130-3 or TCCA240078.
Maintained components: EASA Form 1 or FAA 8130-3 (dual
release) or TCCA24-0078 (dual release)
Standard parts and materials (raw / consumable) do not need a
Form 1 or equivalent. Certificate of Conformance is enough.
Installer must check eligibility of component:
Particular attention to modifications and configuration of
aircraft, engines, etc.
17-19 DECEMBER 2007
Slide 14
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.502 Component maintenance
Maintenance of components has to be done in approved
organisations (no independent certifying staff), except:
While maintained on the aircraft or,
Temporarily removed to facilitate access if permitted
by aircraft maintenance data.
17-19 DECEMBER 2007
Slide 15
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.504 Control of unserviceable
components
Unserviceable components identified and stored in a
secure location.
Components that reached their life limit or that can not be
repaired, shall be classified unsalvageable:
Not permitted to re-enter the supply chain.
Kept in a secure location or have it mutilated.
Responsibility can be transferred without mutilating the
component to a training organisation.
17-19 DECEMBER 2007
Slide 16
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart F: Maintenance
Organisation
Subpart F maintenance organisation can only maintain aircraft
and components when not used in commercial air transport and
not used in large aircraft.
Main differences with Part-145:
No need for independent quality system (organisational
reviews required).
No privileges for sub-contracting.
No base maintenance and no category C Part-66 personnel
required.
No category A personnel.
Some organisations may prefer to move-up to a Part-145
approval (includes the privileges of Subpart F organisations).
17-19 DECEMBER 2007
Slide 17
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart G: Continuing Airworthiness
Management Organisation – Privileges
(M.A.711)
A CAMO may:
Manage aircraft not involved in CAT as listed in the certificate
Manage CAT aircraft when listed in its AOC.
Subcontract tasks to an organisation that works under its
quality system (this organisation does not need to be a
CAMO)
A CAMO may additionally be approved to:
Issue ARCs (following M.A.901)
Make recommendations for an ARC to a Member State of
Registry (any Member State)
THIS PRIVILEGE CAN ONLY BE GRANTED TO CAMOs
REGISTERED IN A MEMBER STATE.
17-19 DECEMBER 2007
Slide 18
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart G: Continuing Airworthiness
Management Organisation – Personnel
M.A.706:
1 Accountable Manager: corporate financial authority.
A person or group of persons responsible for ensuring that
the organisation is always in compliance with Part-M.
1 Nominated Postholder (only for CAT): responsible for
the management and supervision of the continuing
airworthiness activities of the paragraph above.
M.A.712(a):
1 Quality Manager (except for small organisations not
involved in CAT, per M.A.712(e) and (f)).
17-19 DECEMBER 2007
Slide 19
EUROMED CONFERENCE
European Aviation Safety Agency
Subpart G: Continuing Airworthiness
Management Organisation –
Airworthiness Review Staff (M.A.707)
Qualifications required:
5 years experience in continuing airworthiness.
An appropriate Part-66 licence or aeronautical degree or
equivalent.
Formal aeronautical maintenance training.
A position in the organisation with the appropriate
responsibilities
Independent from the continuing airworthiness
management process, or
Overall authority.
Must be approved by the competent authority after performing
an airworthiness review under supervision.
17-19 DECEMBER 2007
Slide 20
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.901 Aircraft airworthiness review
(M.A.901)
An ARC has to be issued with a validity of 1 year.
Controlled environment means:
Aircraft managed by CAMO during the previous 12 months,
and
Maintained only by approved organisations (no independent
certifying staff, except for pilot owner maintenance)
If the aircraft is in a controlled environment:
The CAMO (if it has Subpart I privileges) can issue the ARC
after performing a full airworthiness review in accordance
with M.A.710.
If the aircraft continues under their control, they can extend
the ARC twice. They can not extend ARCs issued by another
organisation or by the authority.
17-19 DECEMBER 2007
Slide 21
EUROMED CONFERENCE
European Aviation Safety Agency
M.A.901 Aircraft airworthiness review
(M.A.901)
If the aircraft is NOT in a controlled environment or
managed by a CAMO without Subpart I privileges:
The ARC will be issued by the Competent Authority based on
a recommendation issued by a CAMO with appropriate
privileges (the CAMO has to do the airworthiness review).
If there is a safety concern, the authority may decide to
do the review and issue the ARC themselves.
17-19 DECEMBER 2007
Slide 22
EUROMED CONFERENCE
