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Part 145 Maintenance Organisation Approval holders provide maintenance services in accordance with Regulation (EU) No 1321/2014 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018

This page includes details and links to regulation, policy and guidance. It will provide approval holders resources to ensure they remain compliant with not only the regulations but also UK Civil Aviation Authority (CAA) policy.

Guidance material provides interpretation or amplify in greater detail certain areas or aspects of regulation and/or policy to allow an approval holder to fully implement quality systems which remain compliant and perform well.

Alerts and notifications

Tailored news, notifications and alerts from the CAA, including alerts issue in the last 12 months are available through SkyWise.

Policy

Maintenance Organisation Exposition (MOE) should be constructed using the Part 145 MOE Guidance (CAP 2375) and associated UK Part 145 Maintenance Organisation Approval Compliance Checklist (SRG1775)

Part 145 Occasional and Temporary Line Stations sets out what the CAA considers as a Part 145 occasional or temporary line station, how they may be established and the periods of time that they may remain in place.

Acceptance of maintenance tasks carried out by pilots; Part 145 caters for certain maintenance tasks to be carried out by the aircraft commander at an unsupported location. AMC to Part 145.A.30(j)4 lists a number of maintenance tasks which a qualified pilot may be issued an Authorisation to carry out. Other checks or replacements involving simple techniques which are not listed in Part 145 AMC 145.A.30(j)4 require specific agreement from the CAA.

Part 145 Maintenance Staff Employment Status, the Information Notice provides guidance to enable Part-145 organisations to establish the employment status of staff engaged on zero hours contracts and those engaged indirectly for the purposes of Part 145.A30(d).

Part 145 Applicability of AMC2 145.A.50(d) and Certification of Used Aircraft Components clarifies the use of AMC2 145.A.50(d) so that the CAA, installers and operators have confidence that used aircraft components have been satisfactorily removed from the aircraft, inspected, assessed and tested, as necessary, before being certified and made eligible for installation on an aircraft registered in the UK.

There have been various interpretations of the requirements which at times have led to organisations not being fully prepared or capable of providing the scope of work that they have applied for or have been approved to provide.

The purpose of this policy note is to remove ambiguity about what the UK CAA expects of an organisation applying for Part 145 approval or wishing to continue to hold Part 145 approval.

Part 145 Guidance for developing a receiving & inspection system for aircraft parts and materials (CAP3037) includes regulation, policy and guidance to support Part 145 approval holders in developing a parts receiving system.

Changes to a Part 145 Approval



Changes to a Part 145 approval requiring prior approval by the CAA (145.A.85)

UK CAA Part 145 approval is based on the management, organisation, resources, facilities and scope of work described in Part 1 of the Maintenance Organisation Exposition (MOE). Any significant change may therefore affect the conditions under which the approval was granted.

This guidance defines the changes requiring an application to the UK CAA using a UK CAA Form 2 (or equivalent online form) and the ones that can be notified to apply@caa.co.uk  

Note: As per 145.A.85, the organisation should notify the CAA of any proposed changes before such changes take place.

Organisations shall have a procedure in Part 1, paragraph 1.10 of their MOE, which details which changes require the organisation to submit a correctly completed application form (including the associated MOE amendment and any supporting documents, as applicable) and which changes can be submitted to apply@caa.co.uk, for onward submission to their assigned Airworthiness Surveyor for approval (via an MOE amendment, including any supporting documents, as applicable). The procedure shall include:

  • When to notify the change.
  • How to notify the change (Using CAA Form 2 (or equivalent online form), or not)
  • Who in the organisation is responsible for notifying the CAA of the change.
  • Where to send the notification (apply@caa.co.uk)

Changes to an existing UK Part 145 approval requiring prior approval by the CAA and an application to be submitted.

The following Changes to an existing UK Part 145 approval requiring prior approval by the CAA shall be made by submission of a correctly completed application form, including the associated MOE amendment and any supporting documents, as applicable:

  • Change of name of the organisation.
  • Change to the locations/facilities of the maintenance organisations with or without amendment to the scope or
  • Increase or reduction in the scope of work or scope of approval under Ax
  • Increase or reduction in the scope of work or scope of approval under Bx
  • Increase or reduction in the scope of work or scope of approval under Cx
  • Increase or reduction in the scope of work or scope of approval under a D
  • Any addition in Specialised Services under any of the approval ratings.
  • A change of Accountable Manager or Nominated Postholder.

For a change to the Accountable Manager or Nominated Post Holder, please complete the Notification of a change to the Accountable Manager or Nominated Post Holder for one or multiple approvals (caa.co.uk) form, rather than the Part 145 Initial Approval or Variation application form.

Changes to an existing UK Part 145 approval requiring prior approval by the CAA through an amendment to the MOE only.

The following Changes to an existing UK Part 145 approval requiring prior approval by the CAA shall be made by submission of an MOE amendment and any supporting documents, as applicable, to apply@caa.co.uk

  • Any change to the equipment, tools, materials that could affect the
  • Any change to procedures that could affect the approval.
  • Reduction or increase of the number of Certifying Staff, Component Certifying Staff or Base Maintenance Support staff when the variation is:
  • more than 10% of the total staff number declared in MOE 1.7; or
  • affecting the approval.

Note: Permanent and contracted staff shall be considered.

Changes to an existing Part 145 approval that do not require prior approval by the CAA before implementation. 

Changes not requiring prior approval before implementation must still be notified to the CAA. The notification should be sent to apply@caa.co.uk

A procedure that sets out the scope of changes not requiring prior approval and that describes how such changes will be managed and notified to the CAA by the organisation must be fully detailed in section 1.11 of the approved MOE (as required by 145.A.70(a)(10) and detailed in CAP2375: Part 145 Maintenance Organisation Exposition Guidance) | Civil Aviation Authority (caa.co.uk).

Notification of the following changes should be submitted without delay to apply@caa.co.uk, including any supporting documents and an MOE amendment, if applicable:

  • Change of postal address of the registered organisation without any change of the maintenance
  • Expansion or transfer of offices / storage facility
  • Changes to the approved line station list providing that it does not add scope or additional locations (See IN 2017/011) for further guidance.
  • Addition or cancellation to the approved capability list where the UK CAA Part-145 “C” rating is held, and any additional component capability is of similar technology & within existing ATA chapter capability (MOE 9 refers).
  • Change to the MOE and its associated procedures/lists called out in the MOE 1.11 that do not affect the
  • Changes to the number of Certifying Staff, Component Certifying Staff or Base Maintenance Support Staff less than 10% of the total staff number declared in the MOE.
  • Changes to sub-contracted / contracted organisations (detailed in Section 5) of the MOE.
Close Changes to a Part 145 Approval

Part 145 Loss of Capability



UK Regulation (EU) No. 1321/2014, Part 145.A.85 requires the organisation to notify the Civil Aviation Authority (CAA) of any proposal to make changes to the organisation. This also includes changes to the facilities, equipment, tools, material, procedures, work scope, certifying staff and airworthiness review staff that could affect the approval.

Part 145.A.80 and its Acceptable Means of Compliance (AMC) provides for the situation where an organisation may temporarily not hold all the necessary tools, equipment and so on, for an aircraft type or variant specified in its exposition and/or approval certificate. The regulation provides a means for the CAA to defer revoking the lost capability when it considers the loss to be temporary, and where there is a demonstrable commitment from the organisation to re-establish full capability before maintenance recommences.

Actions to be taken where Capability to perform the full scope of work is temporarily lost

The CAA have decided that it will not immediately revoke an aircraft type or rating from an organisation’s approval certificate when the capability to maintain a particular product, part or appliance is considered to be temporarily lost. This is based on the organisation agreeing to amend their Maintenance Organisation Exposition (MOE) to reflect the change of capability and to have procedures in place to re-establish compliance with Part 145 before reinstating the particular capability. This policy is not applicable when the CAA considers that an organisation is generally failing to meet its regulatory obligations and that it would be more appropriate to suspend, limit or revoke the approval.

An organisation that temporarily does not have the ability to fulfil the Part 145 requirements, (such as the loss of personnel within an organisation and so on), the CAA will allow six months for the organisation to re-establish full compliance before suspension/revocation of the capability in question is considered. (This corresponds to the normal maximum permitted duration of a level 2 finding).

If the organisation has not re-established the capability after six months, they will be informed in writing that the affected type/rating should be greyed out in the scope of work section of the MOE, signifying that the organisation has temporarily lost the identified capability, and consequently is unable to exercise the privileges of the approval granted in accordance with Part 145.A.75. Unless the organisation can demonstrate a commitment to re-instate the capability, the affected capability will be revoked and the approval certificate amended accordingly.

Please note that demonstration of commitment must be presented; acceptable examples are purchase orders, invoices, Letters of Intent, contracts, press/publication adverts.

To re-instate greyed out capability the organisation will need to demonstrate compliance with all applicable paragraphs of Part 145, before an amendment to the MOE can be approved reinstating the approval privileges.

Where an organisation has not re-established a capability greyed out in accordance with this Policy at the time when the continuation recommendation is required, unless the organisation can demonstrate full compliance, the CAA will consider that the capability is lost and that it will be unable to make a continuation recommendation. The specific product, part, appliance, or process will be revoked and removed from the organisation’s approval certificate. The greying out of a capability will not be allowed to continue past the point at which a continuation recommendation in accordance with Part 145.B.30 is required.

Organisations who do not follow the process, will be subject to normal procedures for the resolution of findings and may have an aircraft type or rating revoked immediately when the capability to maintain a particular product, part or appliance is lost.

Close Part 145 Loss of Capability

Facilities (145.A.25)

Any Part 145 organisation must have facilities commensurate with the scope of work for which it is approved to provide.

Line Maintenance providers are expected to have an office, storage facilities and, for larger providers, possibly a workshop. These facilities must be of a fixed or permanent nature with a fixed address, and located airside or at the very least within a short drive. The distance should be reasonable and appropriate for the activity being provided from the airside area. This is to ensure personnel from the organisation are not operating remotely from the approved facility.

It is not permissible for an organisation to use a ‘mobile’ facility (e.g. vehicle), unless this is to supplement an existing fixed or permanent location at the line station.

Base maintenance providers must have a hangar which accommodates the aircraft types for which they are approved to maintain with offices, storage facilities and workshops as required. The aircraft type must be able to be completely enclosed by the facility. It is not acceptable for the aircraft tail to be outside the hangar while performing base maintenance. Work may be performed outside the hangar subject to procedures being approved in the Organisations Maintenance Organisation Exposition (MOE).

Close Facilities (145.A.25)

Maintenance Data (145.A.45)

Generic Maintenance data for each aircraft type within the requested or approved scope of work must be available at the organisation at all times. This data should be used in the initial approval stages to define tooling requirements and assist in the creation of the manpower plan. It will define manpower requirements for each task. It will also need to be available during subsequent Civil Aviation Authority (CAA) audits. This helps to demonstrate the organisation's overall capability to perform maintenance.

The data does not have to be up to date at all times (although it needs to be controlled) and may be supplemented with customer supplied data specific to a particular model/fleet. Where customer supplied data is not used, a subscription service will need to be in place prior to commencement of any work. The organisation must have procedures in place that demonstrate how they control the data and ensure that it is up to date before use.

It is not acceptable for data to be supplied solely by the customer directly prior to an aircraft input. This will not allow appropriate production planning to take place prior to any work being performed.

 

Close Maintenance Data (145.A.45)

Tooling and Equipment (145.A.40)

Organisations must have all tooling which is required to complete the maintenance tasks within their scope of work permanently available at their facilities. The exception to this requirement is where a task is only performed infrequently (as a guide, tasks that are performed at one in three of similar inputs) then the tooling can be acquired at the time the task is performed (through loan or pool arrangements).

The appropriate tooling for the scope of work may be supplied through a contract with an organisation that supplies, maintains and updates/replaces the tooling held by the Part 145 organisation is acceptable. The tooling should be provided on a permanent basis and its availability should not be dependent on a contract with an operator. It remains the responsibility of the Part 145 organisation to determine that the tooling is of the correct type and is in a condition that is suitable for use.

Each organisation must ensure it has sufficient staging and access equipment to gain access to all areas of the aircraft that fall within the approved scope of work. Access equipment or staging should be of a suitable type to allow the maintenance task to be performed in an effective manner. Staging and access equipment should provide a stable working area where tools and materials can be located while performing the task to ensure that potential Human Factors issues are minimised.

All tooling and equipment must be controlled through a register and maintained or calibrated to Original Equipment Manufacturer (OEM) requirements/national standards. This includes servicing of Aircraft Jacks, Staging and Access Equipment.

Alternative or locally fabricated tools may only be used when there is an approved procedure in the Maintenance Organisation Exposition (MOE) that ensures an assessment of the suitability of alternative tooling has been carried out, and that the use of the alternative tool has been properly validated. This is to ensure any such tools are of an equivalent specification, standard and accuracy as those specified in the applicable maintenance data provided by the OEM.

Close Tooling and Equipment (145.A.40)

Certifying staff and Manpower Resources (145.A.30, 145.A.35)

The organisation shall have sufficient staff to plan, perform, supervise, inspect and quality monitor the activities which the organisation is approved to perform. This must be supported with a manpower plan which shows either Planned vs Actual man-hours for work which is scheduled and has been completed at the organisation or provides a capacity projection based on number of staff available and envisaged scope of work, including the assumptions made to develop the plan (such as number of staff needed to complete a check or number of persons to run a roster at a line station, typical level of defects and scheduled maintenance workload for a night stopping aircraft). This can then be used to establish the maximum capacity and scope of work the organisation can undertake.

The plan must take into consideration the following:

Training, leave and an allowance for sickness and so on.

An efficiency level should be declared by the organisation. It is not feasible to be 100% efficient. Human performance principles suggest that a figure of 80% or less is more realistic when taking account of human factors.

Resilience within the organisation: it is not possible to hold an approval based on one person's licence for aircraft where an A1 rating is required. The GM to 145.A.10 explains the limitations and permissible arrangements for organisations maintaining non-complex aircraft.

Part 145.A.30(h) requires an organisation to have appropriate aircraft type rated certifying staff qualified in category C in accordance with Part-66, supported by sufficient aircraft type rated staff qualified as category B1 and B2 in accordance with Part-66. Organisations must be able to demonstrate their ability to maintain compliance, even when some staff are not available. This will ensure an aircraft's maintenance is not compromised or halted due to sickness or other non-availability of some staff.

Close Certifying staff and Manpower Resources (145.A.30, 145.A.35)

Component Certifying Staff

 Component Certifying Staff (145.A.30(i) and 145.A.35)

UK Part 145.A.30(i) sets out the requirements for Component Certifying Staff and refers to such staff being qualified in accordance with Article 5(6). However, Article 5(6) doesn’t specify the necessary qualification and experience requirements either.

To assist organisations develop their MOE procedures and processes for the issue of component certifying staff authorisations, and to provide a level of standardisation across organisations holding UK Part 145 ‘B and C rating’ approvals, the CAA has published Component, Engine and APU Certifying Staff Qualification Guidance (CAP2995)

Close Component Certifying Staff

Authorisations issued under UK Part 145.A.30(j) and Appendix IV

Appendix IV to UK Regulation (EU) No 1321/2014, Annex II (UK Part 145) prescribes the conditions under which authorisations may be issued by UK CAA approved Part 145 organisations that are based outside the UK, or UK based organisations that have some facilities outside the UK, to certifying staff not qualified in accordance with UK Part 66.

To prevent any misunderstanding of this requirement, our  policy is outlined below. 

A maintenance organisation using UK Part 145 Appendix IV certifying staff, who do not hold an appropriate UK Part 66 Aircraft Maintenance Licence, is required to comply with UK Part 145 Appendix IV in full, even if they have the aircraft type endorsed on the licence issued by their National Aviation Authority.

Where appendix IV to UK Part 145 refers to certifying staff and base maintenance support staff, they need to demonstrate that they have received type training and passed examinations at the category B1, B2 or B3 level, as applicable and referred to in Appendix III to UK Regulation (EU) No 1321/2014, Annex III (UK Part 66) for each aircraft type. This means a type training course carried out in accordance with UK Part 66 by a UK CAA approved Part 147 Maintenance Training Organisation. 

The UK, through various exemptions that were applicable up to and including 31 December 2022, has accepted EASA approved Part 147 type training courses as being equivalent to UK Part 147 training courses.  With effect from 1 January 2023, certifying staff authorisations, issued by organisations approved in accordance with UK Part 145 that are based outside the UK, or are UK based and have some facilities located outside the UK, require type training courses to be carried out by a UK Part 147 approved organisation, or have the type training course directly approved by us.

Certificates of Recognition (CofR) for type training courses completed and dated before 1 January 2023 remain acceptable.

Exceptions may apply where there is a bilateral agreement or working arrangement in place.  

Examples where there is no bilateral agreement or working arrangement in place between the UK and the State of the licence holder are;

An EASA Part 66 AML issued on 21 December 2022 with B1 / B2 A350-900 endorsement. Valid for UK Part 145 authorisation.

An individual working for a maintenance organisation in a state outside the EU who holds a national licence of that state which is in compliance with ICAO Annex 1 and holds a CofR for an EASA Part 147 approved type training course completed on 10 June 2022 for a Boeing 777-300. Valid for UK Part 145 authorisation.

An individual holding an EASA Part 66 AML, or national licence issued which is in compliance with ICAO Annex 1, who has completed an EASA Part 147 type training course with a CofR, issued on 3 January 2023. Not valid for UK Part 145 authorisation.

For further guidance, please refer to Part 145 Appendix IV Certifying Staff and Support Staff not qualified to Part 66 | Civil Aviation Authority (caa.co.uk)

Close Authorisations issued under UK Part 145.A.30(j) and Appendix IV

Maintenance Organisation Exposition (145.A.70)

The Maintenance Organisation Exposition (MOE) is integral to an organisation's ability to demonstrate its capability and compliance with Part 145. Statements that are open or ambiguous create the potential for misunderstanding, non-compliance with the regulation and could result in regulatory action, aircraft grounding or worse. The MOE must be fully reviewed on a regular basis by the organisation and by the Civil Aviation Authority (CAA) during the audit cycle. The procedures contained in an exposition should describe the detailed process that the organisation follows to comply with the applicable provision in the regulation. They should not simply be policy statements indicating that the organisation will comply with the relevant elements of the regulation when using a process/procedure.

The exposition should keep up to date and follow the guidance set out in the Part 145 MOE Guidance (CAP 2375) and associated UK Part 145 Maintenance Organisation Approval Compliance Checklist (SRG1775).

Close Maintenance Organisation Exposition (145.A.70)

Fabrication of parts (145.A.42)

UK Part 145.A.42(b)(iii) and the associated Acceptable Means of Compliance (AMC) material provides the possibility for the CAA to agree for a maintenance organisation to fabricate a restricted range of parts to be used during maintenance, within its own facilities, in accordance with a procedure approved in the Maintenance Organisation Exposition (MOE).

The CAA has published Guidance on the fabrication of parts under UK Part 145 (CAP 2999) to assist Part 145 organisations develop their MOE procedure and processes.

Close Fabrication of parts (145.A.42)

Line Maintenance

Line Maintenance generally refers to minor, unscheduled or scheduled maintenance carried out on aircraft that includes:

  • Unscheduled maintenance resulting from unforeseen events (for example, trouble shooting, defect rectification).
  • Scheduled tasks not exceeding the weekly check or equivalent specified in the approved aircraft maintenance programme.
  • Scheduled checks that contain servicing and/or inspections that do not require specialised training, equipment, or facilities, and that have been assessed and accepted for inclusion in the line maintenance scope of work.
  • Component replacement with use of external test equipment if required. Component replacement may include components such as engines and propellers, where environmental conditions are suitable.
  • Maintenance performed on aircraft after a period of being out of service (such as aircraft in storage) when agreed in advance with the Civil Aviation Authority (CAA).
  • The need to access a hangar (even if the activity is permitted under a line maintenance scope of approval) considering the type of aircraft, the maintenance event type/complexity, the environmental and weather conditions.

It is not Line Maintenance when:

There are a significant number of different types of tasks to be carried out during a single input, even if when considered singularly they may still fall within the definition of line maintenance but together clearly require the use of base maintenance production planning support and/or base maintenance release to service process (category C staff supported by B1/B2 support staff) in order to ensure that the maintenance ordered has been properly carried out before release to service.

Replacement of any major component where the related maintenance procedures clearly require the use of a hangar environment requiring special ground support equipment and/or structured production planning and/or complex and lengthy maintenance.

Any scheduled maintenance task which requires extensive disassembly of the aircraft and/or extensive in-depth inspection.

Close Line Maintenance

Major repairs and/or major modifications

Trouble shooting and/or Defect Rectification requiring special ground support usually relevant to base maintenance (for example, special equipment, structured production planning, complex and lengthy maintenance).

A scheduled maintenance event, which in the planning phase has been already identified as significant in terms of duration and/or man-hours.

A work package requiring a complex team composition in terms of numbers and categories (avionic, structure, cabin, NDT and so on.) of staff involved per shift.

The management of the event by B1 and B2 support staff and the release by a C certifying staff.

Close Major repairs and/or major modifications

Global supply chain challenges affecting the industry



The CAA is aware of the impact that current global supply chain constraints are having on aircraft operators, which also affects production, maintenance, and operational resilience throughout the industry.

The global supply chain is still in a recovery phase post Covid-19 pandemic. This is due to economic, material, and resource constraints globally, plus sanctions against Russia due to the ongoing conflict in Ukraine. This is having an impact for the majority of UK operator’s and other aviation organisations with existing mitigations and other available control processes being fully utilised.

UK CAA approved control processes available to operators and maintenance organisations to actively manage aircraft when spares are required but not currently available include:

  • Deferring the aircraft defect (if allowable) in accordance with the approved Minimum Equipment List (MEL) for the aircraft type.
  • Rectification Interval Extension (RIE) process.
  • Temporary amendment to the Aircraft Maintenance Programme (AMP) for a scheduled component replacement. An amendment may require Type Certificate Holder (TCH) acceptance and UK CAA approval beyond previously approved extension limits within the aircraft AMP.
  • Robbery action of a serviceable component from a donor aircraft and installing the component on another aircraft to make another aircraft operational and serviceable.
  • Exemption under Article 71(1) of UK Regulation (EU) 2018/1139. Type Certificate Holder support required.
  • Aircraft on ground (AOG) until a serviceable component or material is available and installed.

Spares and material shortages are not considered a direct safety issue to the operation of the aircraft but may reduce aircraft availability and increase maintenance activity to maintain operational flying of available aircraft. The unintended consequences of the increased use of the control processes could reduce the overall level of operational safety of the aircraft. It is recommended that all operators carry out a safety case for their operation within their Safety Management System (SMS) to identify specific risks and mitigations. The importance of regulatory/safety barriers (specifically the correct use of maintenance procedures and application of the MEL) in preventing possible safety events cannot be overstated. It is essential that all stakeholders understand and respect these requirements.

Unintended consequences of supply chain shortages could include:

  1. Aircraft availability to meet capacity.
  2. Flight deck management of the increase in numbers of deferred defects (MEL items) - Multiple effects of combined defects plus any further inflight faults.
  3. Loss of flight crew confidence in the serviceability of the aircraft that could lead to turn back events.
  4. Additional maintenance inputs for robbery actions - robbery control, increase risk of maintenance errors, production planning.
  5. Engineer and flight crew fatigue.
  6. Non recorded defects.
  7. Recording of defects at main base only.
  8. Repetitive defect control.
  9. Spare aircraft utilisation.
  10.  Aircraft delays - EU261 claims.
  11.  Increase in PMA parts utilisation.
  12.  OEMs/MROs restricting parts supply – this is common practise for OEMs. Component lists are being shared with the operators for components that have a restricted supply and when a target date for normal supply is forecast.
  13.  Operators buying global stock of parts/material.
  14.  Increase in Wet lease-in operations – to cover for unserviceable aircraft.

The UK CAA remains committed to supporting the aviation industry and the challenges it faces with the procurement of parts within the global supply chain. Furthermore, operators are encouraged to engage as early as possible with the appropriate CAA focal point (assigned AW Surveyor or Flight Ops Inspector) if regulatory support is deemed necessary.

Further guidance on the acceptance of components for new and used (maintained) aircraft components eligible to be fitted to a UK registered aircraft can be found on our Guidance on acceptance of components webpage.

 

Close Global supply chain challenges affecting the industry

Requirements for Nominated Persons and Accountable Managers



Accountability, Responsibility and Duties

There are varying degrees of understanding between these words, the nominated persons titles can also add to the confusion. This definition is an aid and to add clarity.

‘Accountability’ refers to an obligation which cannot be delegated, whereas ‘responsibility’ refers to an obligation that can be delegated.

An Accountable Manager has obligations within the role which they are accountable for and cannot delegate. For example, an Accountable Manager has corporate authority for ensuring that all continuing airworthiness management activities can be financed and carried out in accordance with the regulation. This cannot be delegated. However, the regulation does list obligations that the Accountable Manager can delegate. The obligations listed in points (a) and (b) of CAMO.A.305 & 145.A.30 demonstrate this.

For example, Point (a)(4) of CAMO.A.305 & Point (b)(2) of 145.A.30 obligates the Accountable Manager to nominate a person or group of persons with the responsibility for managing the compliance monitoring function as part of the management system. However, there are additional requirements for nominated persons that need to be fulfilled and specified within CAMO.A.305 & 145.A.30 :

  • CAMO.A.305(c) & 145.A.30(c) and its related AMC (AMC1 CAMO.A.305(c) & (AMC1 145.A.30(c)) lists the knowledge, background, and experience requirements
  • CAMO.A.305(g) & 145.A.30(e) and its related AMC’s lists the requirements for an organisation to establish and control the competency of personnel within the organisation.

Once a nominated person meets these knowledge, background, experience and competency requirements, the Accountable Manager has fulfilled their obligations; and the responsibilities for that function can now be delegated to the nominated person.

The nominated person is now responsible for this function. However, for larger organisations there may be persons working under this nominated person. The nominated person may wish to allocate duties to these persons to perform on their behalf. As such, it is the responsibility of the nominated person to ensure that processes and procedures are in place to ensure that all functions within their responsibilities are followed. Any person working under the nominated person must be competence assessed to ensure they can carry out the relevant function.

The nominated person remains responsible for the work performed by the persons working under them, but by ensuring that the processes and procedures are in place, and the persons working under them are competency assessed to perform these duties, then the nominated person has fulfilled their responsibilities.

See additional guidance: Fitness of character policy framework | Civil Aviation Authority (caa.co.uk)

Accountable Manager

Point (a)(7) of CAMO.A.305 & Point (a)(3) of 145.A.30 requires that the Accountable Manager shall demonstrate a basic understanding of the regulation.

A “basic understanding” in this context means that the accountable manager should have a fundamental grasp of the key principles and requirements outlined in Assimilated Regulation (EU) 1321/2014. This includes being familiar with the overall objectives of the regulation, the specific responsibilities, and duties it imposes on the organisation, and the essential procedures and standards for maintaining airworthiness.

The accountable manager does not need to be an expert in every detail but should be knowledgeable enough to ensure compliance and make informed decisions regarding the organisation’s airworthiness management / maintenance activities.

Nominated Persons

Persons nominated in accordance with CAMO.A.305(a)(3) & 145.A.30(a)(1), CAMO.A.305(a)(4) & 145.A.30(a)(2), CAMO.A.305(a)(5) & 145.A.30(a)(3) and CAMO.A.305(b)(2) must meet the knowledge, background and experience requirements listed in AMC1 CAMO.A.305(c) & AMC1 145.A.30(c); and be competence assessed in accordance with CAMO.A.305(g) & 145.A.30(e). An audit demonstrating compliance with these requirements must accompany the SRG1769 application for the nominated person.

Persons nominated in accordance with CAMO.A.305(e) & 145.A.30(k) must meet the requirements of CAMO.A.310 & 145.A.37. They will be required to perform an Airworthiness Review under the supervision of the CAA, unless the nominating organisation holds the privilege to perform this on behalf of the CAA.

Persons nominated in accordance with CAMO.A.305(f) must be competency assessed against the organisations procedure to perform the extension function.

Requirements of AMC1 CAMO.A.305(c) & AMC1 145.A.30(c)

AMC1 CAMO.A.305(c) & AMC1 145.A.30(c) requires a nominated person under CAMO.A.305 points (a)(3) to (a)(5) and (b)(2) or 145.A.30 points (b)(1), (b)(2) and (b)(3) to have the relevant background, knowledge and experience.

Point (d) of this requirement states that the nominated person should have:

  • a relevant engineering or technical degree, or an aircraft technician or maintenance engineer qualification with additional education that is acceptable to the CAA. ‘Relevant engineering or technical degree’ means a degree from aeronautical, mechanical, electrical, electronic,
    avionics or other studies that are relevant to the maintenance and/or continuing airworthiness of aircraft/aircraft components.

    The provision set out in the first paragraph of point (d) may be replaced by 2 years of experience in addition to those already recommended by paragraph (c) above. These 2 years should cover an appropriate combination of experience in tasks/activities related to maintenance and/or continuing airworthiness management and/or the surveillance of such tasks.

    For the person to be nominated in accordance with point (a)(3) to (a)(5) and (b)(2) of Part CAMO or(b)(2) or (b)(3) of point 145.A.30, in the case where the organisation holds one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139 and that person has already an equivalent position (i.e. compliance monitoring manager, safety manager) under the additional certificate(s) held, the provisions set out in the first two paragraphs of point (d) may be replaced by the completion of a specific training programme acceptable to the CAA to gain an adequate understanding of maintenance standards and continuing airworthiness concepts and principles.

In order for the UK CAA to consider acceptance of the training programme referred to in point d, it should include a syllabus scope similar to the one outlined below. This syllabus can be tailored to the individual’s training needs and considers the specific elements and requirements relevant to the Organisation’s scope of approval.

  • a course on UK Regulation (EU) No 1321/2014 should cover all relevant aspects of UK Regulation (EU) No 1321/2014, as amended, is required. This includes the following regulations, and how they interface, as applicable to the scope of approval:
    • Annex I (Part M)
    • Annex II (Part 145)
    • Annex III (Part 66)
    • Annex Vb (Part ML)
    • Annex Vc (Part CAMO)
  • training within a UK CAA approved CAMO or Part 145 department (as applicable) gaining the comprehensive knowledge and practical experience, which should consist of the following criteria, dependant on the needs of the individual, and as applicable to the scope of approval/work:
    • Continuing Airworthiness Tasks and General Principles, cover the requirements of M.A.301/ML.A.301, including:
      • Accomplishment of pre-flight inspections.
      • Rectification of any defect and damage affecting safe operation in accordance with M.A.304 and M.A.401, considering the MEL and configuration deviation list.
      • Accomplishment of all maintenance in accordance with the AMP referred to in M.A.302.
      • Release of all maintenance in accordance with Subpart H.
      • Analysis of the effectiveness of the approved AMP referred to in M.A.302.
      • Accomplishment of any applicable airworthiness directive (AD).
      • Accomplishment of any applicable operational directive with a continuing airworthiness impact.
      • Accomplishment of any applicable continuing airworthiness requirement established by the CAA.
      • Accomplishment of any applicable measures required by the CAA in immediate reaction to a safety problem.
      • Accomplishment of modifications & repairs in accordance with M.A.304.
      • Delivering the mass and balance statement reflecting the current configuration of the aircraft.
      • Maintenance check flights.
    • Development and Management of the Maintenance Programme, including:
      • Maintenance Steering Group methodology .
      • Maintenance Review Board process (MSI/SSI’s).
      • Amendment/Revision Control introduced by TC Holder, Modifications, and Service Experience.
      • Source documentation review.
      • Review of anticipated utilisation (aircraft or fleet).
      • Task and periods (intervals/frequencies) review for Aircraft, Engine(s), APU, Propeller(s), Components, Accessories, Equipment, Instruments, Electrical and radio apparatus.
      • Periods at which components should be checked, cleaned, lubricated, replenished, adjusted, and tested.
      • Aging aircraft system requirements with specific sampling programmes.
      • Specific Structural Maintenance Programmes, including Damage Tolerance and Supplemental Structural Inspection Programmes (SSID), SB review performed by the TC holder, Corrosion prevention and control, Repair Assessment, Widespread Fatigue Damage.
      • Critical Design Configuration Control Limitations.
      • Penalty Factors Review.
      • Identification of Critical Maintenance Tasks and monitoring the health of all Critical components and premature failure.
      • Periodic review of maintenance programme contents.
      • Escalation/de-escalation of tasks and
      • Permitted variations to maintenance periods.
      • National Requirements, including details of who may issue a CRS, define which inspections/checks are considered to be base maintenance, CAAIPs (CAP 562) applicability, Vital points and control systems, UK Mandatory requirements as listed in CAP 747, Engine & APU condition monitored maintenance, Flight data recorder systems, Mode “S” transponder ICAO 24-bit aircraft addresses.
      • Identification of Critical Maintenance Tasks (including performance of maintenance 145.A.48) and monitoring the health of all critical components and any potential premature failure.
      • Maintenance applicable to special operations approvals, including:
        • AWOPS, AWOPS, MNPS, RVSM, ETOPS, Sea Pilot transfers, CAT.POL.H.305, SPA.HOFO.105, SPA.HOFO.155, SPA.HHO.100, CAT.POL.H.420, SPA.HEMS.100, SPA.NVIS.100, Part SPO. Subpart E, SPO.HHO.10
      • Review for Part 26 (Additional Airworthiness) requirements
  • Aircraft Reliability Programmes, including:
    • Tailoring reliability programmes to suit the size and complexity of operation
    • Management of ‘Alert’ levels or standards
    • Pooling Arrangements
    • Source review for reliability programmes, including Pilots Reports, Technical Logs, Aircraft Access Terminal / On-board readouts, Maintenance Worksheets, Workshop Reports, Reports on Functional Checks, Reports on Special Inspections, Stores Issues/Reports, Air Safety Reports, Reports on Delays and Incidents, and other sources such as ETOPS, RVSM, CAT II/III
    • Examination, analysis, and interpretation of the information
  • Management of Mandatory Continuing Airworthiness Instructions, including:
    • Review & understanding of AD’s
    • Review & Understanding of CMR’s
    • Review & understanding of AWL’s
  • Management of Modification and Repair Data, including:
    • SB / SL Familiarisation & Review process
    • Review & use of applicable approved data i.e AMM, EMM, CMM etc (including bilateral arrangements)
  • Aircraft Technical Log, including:
    • Review & Familiarisation of the Aircraft technical log against M.A.306
    • Deferred Defect and use of the approved MEL
  • Maintenance Standards, including:
    • Performance of Maintenance.
    • Control of error capturing methods for critical tasks.
    • Raising work order and work pack.
    • Reviewing completed work pack.
    • Reviewing ongoing work packs.
    • Closing of work packs and SMI/CRS process.
    • Knowledge of the MOE, safety manual and associated safety policy to fully understand what the organisation does and how it is trying to achieve.
    • Understanding the difference between line, base or full heavy  base maintenance etc.
    • Work away from base and maintenance away from approved locations.
    • Production & Manpower Planning - including HF and its use in Part 145 (including fatigue management). Manpower planning should include review of available staff v planned work and should not rely on those off shift due to annual leave or sickness.
  • Airworthiness Review Processes, including:
    • An ARC review in accordance with organisation procedure
  • Permit to Fly Processes, including:
    • Performing a ‘Permit to Fly’ in accordance with organisation procedures
  • Management System Processes, including:
    • Review risk assessment and mitigations.
    • Hazard Identification.
    • Review safety performance monitoring and measurement activities.
    • Review management of Change process.
    • Review safety accountabilities and responsibilities.
    • Review compliance monitoring responsibilities and functions.
    • Review training and education requirements including competency. assessment process.
    • Process control i.e Painting of aircraft, NDT, specialised services.
  • Interface with other organisations, including:
    • Review of contracted arrangements.
    • Review of sub-contracted arrangements.

The training programme should define how the syllabus and requirements are managed, the timeframes required for completion (depending upon the individuals training need, and the assessment process that demonstrate the relevant knowledge has been imparted on the nominated person).

Point (g) of AMC1 CAMO.A.305(c) & Point (g) of AMC1 145.A.30(c) requires a nominated person under CAMO.A.305 points (a)(3) to (a)(5) and (b)(2) & 145.A.30 points (b)(1), (b)(2) and (b)(3) to complete a General Familiarisation course to a level that is at least equivalent to Part-66 Appendix III Level 1 for a relevant sample of the types listed on the organisations approval certificate. If the course proposed by the Part CAMO / 145 approved organisation is not by a Part 147 organisation or by the manufacturer, the following points must be considered before the CAA would consider acceptance of the course.

  • The organisation shall perform an audit to check the content and syllabus of the proposed course against the requirements of Part-66 Appendix III to ensure the depth of training and the level of knowledge is to level 1 for all ATA chapters relevant to the aircraft type.
  • The organisation must ensure that any safety hazards associated with the use of the proposed course are considered as part of the organisation’s management system.
  • Dependant on the previous points, the CAA shall consider the following when determining acceptance of the course:
    • The size and complexity of the organisation
    • The complexity and criticality of the maintenance being performed (e.g. main rotor gearbox overhaul)
    • The background, experience and role of the person attending the course
    • Mitigations used to ensure any identified risks are acceptable
    • The delivery type of the course; in-person, virtual, CBT etc

A ‘Relevant sample’ means that these courses should cover typical aircraft and aircraft systems that are within the current scope of work. This does not necessarily mean that the nominated person or group of persons must have a formalised training courses for each aircraft type listed on the organisation’s approval certificate, rather that similarities with respect to the following sub-categories are demonstrable through a similarity statement:

  • Complex Motor-Powered Aircraft
  • Other than complex motor-powered aircraft (aircraft generic groups)
  • Fixed Wing
  • Rotorcraft
  • Aircraft systems
  • Engine types
  • Manufacturer

Deputy Nominated Personnel

145.A.70(a)(5) permits deputies to be listed in the exposition. To prevent the risk of non-compliance in the event of a nominated person leaving for an extended period of time, it is recommended that ‘deputies’ are listed within the exposition (see Section 1.3.5 of CAP 2375 for guidance).

Unlike Part 145 regulations, which require deputies to be listed in the exposition, there is no requirement within Part CAMO to do this. However, to prevent the risk of non-compliance in the event of a nominated person leaving for an extended period of time, it is recommended that ‘deputies’ are listed within the exposition.

These persons must be able to demonstrate sufficient experience to enable them to assume the functions of the nominated post holder. A SRG1769 form or formal interview is not required although some assurance may be asked by the assigned surveyor of the organisation to demonstrate that the deputy to the postholder would meet the minimum requirements to hold a nominated persons position. The acceptable means of compliance for this obligation is that the competency assessment of the deputy is reviewed by the organisation and if required extended to ensure competencies and qualifications specific to the Nominated Person role they are deputising for are added to their list of required competencies.

‘Persons’ and ‘Group of Persons’

CAMO.A.305(a)(3) & 145.A.30(b)(1), CAMO.A.305(a)(4) & 145.A.30(b)(2) and CAMO.A.305(a)(5) & 145.A.30(b)(3) provides provisions for nominating a person or group of persons.

A ‘person’ nominated under these requirements must take full responsibility for their associated responsibilities and meet the requirements of AMC1 CAMO.A.305(c) & AMC1 145.A.30(c).

A ‘group of persons’ nominated under these requirements need to be individually nominated for the functions they are responsible for. Each individual must meet the requirements of AMC1 CAMO.A.305(c) & AMC1 145.A.30(c) in their own right, and collectively they must cover all the associated responsibilities for that function. There must be no overlap of responsibilities between each person within that group.

Note: An organisation nominating a person under CAMO.A.305(b)(2) cannot also nominate a person or group of persons under CAMO.A.305(a)(3). Therefore, a ‘standalone’ CAMO may have a ‘group of persons’ fulfilling the CAM functions, but an organisation also approved as an air carrier licensed in accordance with UK regulation (EC) No. 1008/2008 must have a single nominated person responsible for the management and supervision of continuing airworthiness.

Resource Plan

As per CAMO.A.305(d) & 145.A.30(d) the organisation must demonstrate the postholders as defined in CAMO.A.305(a)(3), (a)(4) and (a)(5) & 145.A.30 (b)(1),(b)(2) and (b)(3) have sufficient staff to carry out the planned activity. In the case where there is a combined nominated role, then the supporting plan as requested on the SRG 1769 must adequately detail how much time the person has available (taking into account any other contracted commitments elsewhere, as well as steps to mitigate any fatigue risk issues) and how the time will be broken down between the proposed roles i.e. safety manager or compliance manager.

Any resource plan should include the following:

  • Hours applicable to the role and core duties at the organisation
  • Hours at any additional organisation(s) – (If applicable)
  • Travel time (hours) to additional locations sites, contractors / sub-contractors
  • Annual Leave

 

Close Requirements for Nominated Persons and Accountable Managers

Integrated Management System

CAMO.A.200(d) states that for air carriers licensed in accordance with UK Regulation (EC) No 1008/2008, the management system provided for in Annex Vc (Part-CAMO) of UK Regulation (EU) No 1321/2014 shall be an integrated part of the operator's management system.

An integrated management system should include a Safety Review Board the role of which is to consider all strategic safety matters related to both, continuing airworthiness management and air operations in support of the accountable manager's safety accountability.

Additionally, the management system should encompass safety by including a Safety Manager. To satisfy this requirement, the organisational structure may vary between each organisation and the two options for the organisational structure are as follows:

A single safety management process common to both, air operations and continuing airworthiness management, with a Safety Manager satisfying the requirements for air operations and continuing airworthiness management. 

Separate safety management reporting lines for air operations and continuing airworthiness management, both integrated into a single management system with one set of organisational safety procedures, thus ensuring clear and effective communication and preventing duplication. Two Safety Managers may be appointed, although the structure with a single Safety Manager is preferred.

The management system includes a compliance monitoring function performed by a Compliance Monitoring Manager. To satisfy this requirement, the organisational structure may vary between each organisation and the two options for the organisational structure are as follows:

A single compliance monitoring process common to both, air operations and continuing airworthiness management, with a Compliance Monitoring Manager satisfying the requirements for air operations and continuing airworthiness management.

Separate compliance monitoring reporting lines for air operations and continuing airworthiness management, both integrated into a single management system with one set of organisational compliance monitoring procedures, thus ensuring clear and effective communication and preventing duplication. Two Compliance Monitoring Managers may be appointed, although the structure with a single Compliance Monitoring Manager is preferred.

An organisation may wish to nominate a group of persons responsible for the safety management or compliance monitoring management functions in line with CAMO.A.305(a)(4) and (5). In such case the Accountable Manager should identify the person who acts as the unique focal point for the management of the respective functions.

All nominated persons must satisfy the knowledge, background and experience requirements of AMC1 CAMO.A.305(c). Should the appointed Safety Manager not fully meet these requirements, the AltMoC 2020-00026 published in CAP1721 may be followed to demonstrate alternative means of compliance.

Close Integrated Management System

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