Guidance for Part-CAMO approval holders

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.

It has been accepted that existing Safety Managers may not meet the requirements of the first paragraph of point (e) of AMC1 CAMO.A.305(c).

As a result, an AltMoC (Alternative Means of Compliance) to the first paragraph of point (e) of AMC1 CAMO.A.305(c) Personnel Requirements has been approved for existing Safety Managers already approved under UK Regulation (EU) No 965/2012, for air operations who were in post on 20 September 2020. Alternative Means of Compliance reference 2020-00026 published in CAP1721 provides further details.

Any change to the personnel structure applied under this alternative means of compliance shall be notified to the Civil Aviation Authority (CAA) in line with CAMO.A.130(a)(5).