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.

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