Part-M

Continuing airworthiness shall be performed by a CAMO. Operator shall be CAMO approved (CAMO linked to the AOC).

Continuing airworthiness shall be performed by a CAMO. Operator shall obtain CAMO approval, or operator shall contract a CAMO

Continuing airworthiness management may be performed by the owner. CAMO is not required.

[1] Licenced air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008

[2] Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.

[3] Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p).

Last updated

Was this helpful?

Can an independent certifying staff maintain non-complex motor-powered aircraft used by commercial ATO or commercial DTO?

No, non-complex motor-powered aircraft used by commercial ATO or commercial DTO cannot be maintained by independent certifying staff because in accordance with M.A.201(h) or ML.A.201(e)(2), these aircraft require maintenance release by an approved maintenance organisation (Part-CAO with maintenance privilege, Part-M Subpart F or Part-145).

Note: ‘GM1 ML.A.201(e)’ provides examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO.

Last updated

Was this helpful?

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

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

The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of Part-M/Part-145. Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.

Last updated

Was this helpful?

Can a licenced pilot without a valid medical certificate perform pilot-owner maintenance?

This question arises because of the different understandings of license validity in Commission Regulation (EU) No 1178/2011 This question arises because of the different understandings of license validity in Commission Regulation (EU) No 1178/2011 (Aircrew) and No 1321/2014 (Continuing Airworthiness).

In Reg. (EU) 1321/2014, the pilot-owner authorisation described in M.A.803 or ML.A.803 assumes that a pilot has sufficient technical knowledge to perform certain maintenance tasks. While exercising such pilot-owner authorisation, the pilot-owner even further develops his/her competency in maintenance. Hence, in the case where the medical examination has not been conducted or not been passed and the licence has therefore lost its validity, it is the intent of the rule to allow the pilot-owner to continue using this authorisation as long as he/she still considers himself/herself physically fit (including good visual acuity) and competent to carry out such maintenance (ref. point (a)(2) of Appendix VIII to Part-M or Appendix II of Part-ML).

This is the reason why a new point (5) was introduced in AMC M.A.803 in 2016 (ED Decision 2016/011/R) stating: “not holding a valid medical examination does not invalidate the pilot licence (or equivalent) required for the purpose of the pilot-owner authorisation”. For Part-ML the same information can be found in AMC1 ML.A.803 (ED Decision 2020/002/R).

Last updated

Was this helpful?

What are the responsibilities relevant to pre-flight inspection?

The pre-flight inspection forms part of the essential requirements for air operation, as required in Annex V (point 6.2) of the ‘Basic Regulation’ (Regulation (EU) 2018/1139). Being relevant to the aircraft’s fitness for the intended flight, this essential requirement is implemented by the Commission Regulation (EU) 1321/2014 for continuing airworthiness in the following way:

Carry out pre-flight inspection satisfactorily

Part-M: Pilot-in-command or, in case of Licensed Air Carrier, a qualified staff under the responsibility of the operator (e.g. maintenance staff - see note)

Part-ML: Pilot-in-command or a qualified person under the responsibility of the pilot-in-command

Ensure pre-flight inspection is carried out

Owner or CA(M)O (according to M.A.201/ML.A.201)

Ensure pre-flight inspection includes the actions necessary to ensure that the aircraft is fit to carry out the intended flight

If a/c managed by CA(M)O:
Ensure pre-flight inspection is subject to the quality system/compliance monitoring
[AMC M.A.301(a) point (3)]

Note:

As per the definition of ‘maintenance’ in article 2 (h) of Commission Regulation (EU) 1321/2014, ‘pre-flight inspection’ (as defined in article 2(j)) is not considered maintenance. Therefore, it does not require a certificate of release to service [M.A.201(d)/ML.A.201(d)].

Last updated

Was this helpful?

Do declared training organisations (DTO) need a CAMO/CAO and approved maintenance organisations?

Regulation (EU) No 1178/2011 was amended in July 2018 to introduce Part-DTO as regards to declared training organisations (ref. Reg. (EU) 2018/1119). Regulation (EU) No 1321/2014 was therefore amended and aligned the Continuing Airworthiness obligations of ATO with those of DTO.

Complex motor-powered aircraft

Other than complex motor-powered aircraft

M.A.201(f) is applicable

M.A.201(h) or, for aircraft specified in Article 3(2), ML.A.201(e) are applicable

Continuing airworthiness management

CAMO is required

CAO (with continuing airworthiness management privilege) or CAMO is required

Part-145 organisation is required

CAO (with maintenance privilege) or Part-145 or Part-M Subpart F organisation is required

M.A.201(g) is applicable

M.A.201(i) or, for aircraft specified in Article 3(2), ML.A.201(f) are applicable

Continuing airworthiness management

CAMO is required

CAMO is not required

CAO (with continuing airworthiness management privilege) is not required

Part-145 organisation is required

With the exception of complex maintenance tasks under Part-M:

CAO (with maintenance privilege) is not required

Part-145 organisation not required

Part-M Subpart F organisation is not required

Please also refer to GM1 ML.A.201(e) which provides examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO.

Last updated

Was this helpful?

Airworthiness review

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

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

Last updated

Was this helpful?

Can the extension of an ARC be anticipated more than 30 days?

Assuming the aircraft satisfies the conditions for extension established in M.A.901 or ML.A.901, 30 days is the maximum allowed period for which the ARC extension can be anticipated without losing the continuity of the airworthiness review pattern. This means that the new expiry date is established as one year after the previous expiry date (AMC M.A.901(c)2, (e)2 and (f), ML.A.901(d)).

If the extension is anticipated by more than 30 days, the new expiry date will be established as one year after the date of extension.

Last updated

Was this helpful?

Can an Airworthiness Review Staff (ARS) perform an airworthiness review on an aircraft in which he/ she had released some maintenance as Certifying Staff (CS)?

To avoid possible conflict of interests, the ARS (Airworthiness Review Staff) should not be or have been involved in the release of the maintenance for the aircraft on which he or she intends to perform the airworthiness review (AR), except in one of the following cases:

  1. Such maintenance has been released as part of the airworthiness review’s physical survey of the aircraft (e.g. release necessary after visual inspections requiring panel opening);
  2. Such maintenance has been released as a result of findings discovered during the physical survey of the aircraft (defect rectification)
    Note:cases 1 and 2 are justified by the fact that such specific maintenance activity is part of the AR and therefore does not require independence between maintenance and the AR.
  3. Such maintenance has been released as part of the 100-h/annual inspection contained in the maintenance programme conducted together with the Airworthiness Review of the Part-ML aircraft:

Remark

From regulatory perspective, cases 1 and 2 are explicitly considered by ‘AMC M.A.707(a)’ and ‘AMC1 CAMO.A.310(a)’ [2nd bullet of point (5), respectively point (e)] for an ARS belonging to a CAMO also holding a AMO approval. Although not explicitly mentioned in any AMC, considering the Note above, the Agency understands that this principle is also permitted in other cases where the ARS happens to be also Certifying staff (including independent certifying staff).

Remark:
Iaw M.A.901(l) or ML.A.903(b), when the ARS is not Certifying Staff, he/she must be assisted by a Certifying Staff to release the maintenance mentioned in cases 1 and 2.

Last updated

Was this helpful?

Can the airworthiness review certificate (ARC) of the Part-M aircraft be extended during the extensive maintenance/long term storage?

An ARC extension could be performed as long as:

  1. the conditions established for controlled environment (M.A.901 (b)) are met. This means:
    1. continuously managed during the previous 12 months by a unique CAMO or CAO, and
    2. maintained for the previous 12 months by Part-145, Part-M Subpart F or Part-CAO organisations.
    1. there is no evidence or reason to believe that the aircraft is not airworthy, as stated in M.A.901(j).

    Thus, the procedure for the extension established in the CAMO or CAO has to address verification of the compliance with 3 above mentioned conditions. An aircraft going through the lengthy maintenance/modification or long-term storage is not considered to meet the condition number 2.

    Last updated

    Was this helpful?

    Is an aircraft considered to be in controlled environment at the end of the ARC validity when that aircraft was received by the CA(M)O during the 90/30 days anticipation of the ARC issue/extension performed by the preceding CA(M)O?

    CA(M)O 1 uses the anticipation when performing the airworthiness review or extension for 90 or 30 days correspondingly. After the issue or extension of the ARC, the aircraft is transferred during the anticipation period from CA(M)O 1 to CA(M)O 2. As the consequence CA(M)O 2 has solely continuously managed the aircraft for more than 12 months due to the term of the validity of the ARC accordingly being more than 12 months. Are the requirements of the M.A.901(b) point 1 satisfied?

    The intent of the point M.A.901(b) point 1 is to define the ‘controlled environment’ (see also ML.A.901(c)(1)) by indicating that the aircraft must be managed during last 12 months by unique CA(M)O, which indirectly refers to a standard term of validity of the ARC. Therefore, if the aircraft has been managed by more than one CA(M)O since the date of issue of the last ARC or the date of issue of the ARC extension, it actually indicates that controlled environment was discontinued.

    In addition, in accordance with M.A.901(n) or ML.A.903(d) the 90 days anticipation for the ARC issue shall be used to allow the physical review to be performed during a maintenance check. Hence the intention of the rule is not to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review.

    Concerning the ARC extension and its 30 days anticipation, point M.A.901(f) [AMC M.A.901(c)2, (e)2 and (f)] or ML.A.901(d) are intended for 2 consecutive extensions by the same CA(M)O managing the continuing airworthiness of the aircraft from the date of issue of the ARC. Therefore, an ARC extended for the first time by an organisation cannot be extended a 2nd time by another organisation, because this constitutes a ‘breach’ in controlled environment.

    Last updated

    Was this helpful?

    Are EASA Forms 1 required during the import in the EU of an aircraft subject to Part-M?

    For the import of an aircraft in the EU under Part-M regime, the provisions of M.A.904 require the accomplishment of an airworthiness review in accordance with point M.A.901.

    Note: AMC M.A.904(a)(2) defines specific elements to be considered for imported aircraft.

    However, when performing the airworthiness review of an imported aircraft in accordance with point M.A.901 and its AMC, it may happen that ‘AMC M.A.901(k)’ is not fully satisfied in which certain components subject to the review may not hold an EASA Form 1 (or equivalent under a bilateral agreement) In such a case, other component releases to service or serviceable tags may be acceptable for the competent authority of the importing Member State.

    Nevertheless, it is important to ensure that the information required by M.A.305(c) and (d) related to the status of ADs, life accumulated by life-limited parts and time-controlled components, modifications and repairs is available.

    Last updated

    Was this helpful?

    Technical records

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

    The term “back to birth” is not used in European regulations. The requirements that apply to a life-limited part or a service life-limited component (see definition in ML.A.503(a)) are basically stated in M.A.305 (d)&(e) or ML.A.305(e). All detailed maintenance records of a maintenance action (e.g. a restoration) must be kept until another maintenance action equivalent in scope (another restoration) is done, but never less than 36 months. Keep in mind that:

    Last updated

    Was this helpful?

    What does the term “detailed maintenance records” mean?

    There has been a certain confusion about the understanding of “detailed maintenance records”, because this term is used in a different context for continuing airworthiness management and approved maintenance organisation (AMO).

    “Detailed maintenance records” as defined in M.A.614, 145.A.55(c) or CAO.A.90(a) are required to be kept by an AMO (respectively Part-M/F organisation, Part-145 organisation or CAO with maintenance privileges). Maintenance organisations are required to retain all detailed records in order to be able to demonstrate that they maintained aircraft and components in compliance with applicable requirements (see also remark).

    “Detailed maintenance records” as defined in M.A.305(e)(2) or ML.A.305(h)(1) are those records, coming from the AMO1 having performed maintenance, required to be kept by the owner/operator (or the CAMO or CAO with Continuing airworthiness management privileges when required by M.A.201 or ML.A.201) allowing to determine the aircraft configuration, the airworthiness status of the aircraft and all components installed, as well as to plan future maintenance as required by the AMP, based on the last accomplishment.

    Consequently, the AMO should transmit to the owner/operator/CA(M)O a certain subset of the AMO maintenance records, including the certificates of release to service and repair/modification data related to the performed maintenance, so that the owner/operator/CA(M)O can demonstrate compliance with M.A.305 or ML.A.305.

    Not all AMO maintenance records need to be transferred from the AMO to the owner/operator unless they specifically contain information relevant to aircraft configuration/status and future maintenance. Thus, incoming certificates of conformity, batch number references and individual task card sign-offs verified by and/or generated by the maintenance organisation are not required to be transferred to the owner/operator/CA(M)O. However, dimensional information contained in the task card sign-offs or work packages may need to be transferred and kept by the owner/ operator.

    It is to be noted that the record-retention period requirements are slightly different for the AMO and the CAMO and CAO with Continuing airworthiness management privileges. The AMO shall retain the records for 3 years, whereas the CAMO and CAO with Continuing airworthiness management privileges has to retain their records until they are superseded by new information (equivalent in scope and detail), but not less than 3 years. The starting point in both cases is when the aircraft or component maintenance has been released.

    Remark: It is considered a best practice as part of the AMO record-keeping system, (and it is also required by certain competent authorities) to record information (e.g. batch number or other tracking reference) relevant to the identification of all standard parts and material used during any maintenance. This practice may limit safety and industrial risks in the case where a batch is recalled by the manufacturer. Such record does not need to be transmitted to the owner/operator/CAMO/CAO with Continuing airworthiness management privileges.

    FAQ Technical Records


    *: Transmitted records is a subset of AMO maintenance records provided to the CA(M)O. Certain transmitted records do not need to be kept as a record by the CA(M)O such as EASA Form 1 for a component with no scheduled maintenance task selected and not subject to AD or modification/repair.

    **: by new information equivalent in scope and detail
    _______________________________________________________________________________________________________

    1 Or pilot-owner [M.A.803 or ML.A.803], or independent certifying staff [M.A.801(b)point 1 or ML.A.801(b)(2)]