Part-M: Continuing airworthiness requirements (Annex I to EC 2042/2003)

Juan Anton
Continuing Airworthiness Manager Rulemaking Directorate

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European Aviation Safety Agency

M.1 Competent Authority

Oversight of aircraft and issue ARC: Authority of Member State of Registry. Oversight of Subpart F organisations: Authority of Member State of Principle Place of Business. EASA for organisations located in third country. Oversight of CAMOs: Authority of Member State of Principle Place of Business if independent CAMO (no AOC). Authority of Member State of operator (if part of AOC). EASA for organisations located in a third country. Approval of maintenance programmes: Authority of Member State of Registry. In commercial air transport, the authority agreed by Member State of Registry and Member State of operator (if different).

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M.A.201 Responsibilities (for continuing airworthiness)

Pre-flight inspection: Responsibility of Pilot-in-command (or operator in case of CAT: Commercial Air Transport). Performed by the pilot or another qualified person. No need to be done by approved maintenance organisations or Part-66 certifying staff. Maintenance of large aircraft and aircraft used in CAT: Must be performed in Part-145 organisations. Maintenance of other aircraft: By Subpart F organisations, by independent Part-66 certifying staff and by the pilot-owner (depending on the type of tasks and as required by M.A.502 and M.A.801(b)).
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M.A.201 Responsibilities (for continuing airworthiness)

Aircraft used in Commercial Air Transport (CAT): Operator is responsible for continuing airworthiness. Shall be approved as a CAMO (part of the AOC). Shall be approved as Part-145 or contract a Part-145. If Member State requires a certificate for the operational activities (other than CAT): Operator is responsible for continuing airworthiness. Shall be approved as CAMO or contract a CAMO. Shall be approved as Subpart F or Part-145 (as applicable for the size of aircraft) or contract such organisations.
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M.A.201 Responsibilities (for continuing airworthiness)

Private large aircraft: Owner is responsible for continuing airworthiness. Shall contract a CAMO. Maintenance has to be performed in Part-145 (no need for contract). Private aircraft (other than large) Owner is responsible for continuing airworthiness. It is not mandatory to contract a CAMO. Maintenance by Subpart F, independent certifying staff and pilot-owner (depending on the type of tasks and as required by M.A.502 and M.A.801(b)).
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M.A.201 Responsibilities (for continuing airworthiness)

When contracting a CAMO: The contract must comply with Appendix I. Appendix I describes the responsibilities of the owner and the responsibilities of the CAMO. For CAT it is not possible to contract a CAMO. The operator must be approved as a CAMO: The operator may sub-contract, under its Quality System, some tasks as per AMC to M.A.201(h)1 and its Appendix II. The subcontracted organisation does not need to be a CAMO. The responsibility for the tasks is always of the operator CAMO.
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M.A.202 Occurrence reporting

Must be done by all persons responsible under M.A.201. Reported to State of Registry, State of operator (if applicable) and TC/STC holders. Maintenance organisations and independent certifying staff shall report to the owner / operator. Reports shall be done before 72 hours.

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M.A.301 Continuing airworthiness tasks

This article shows the list of continuing airworthiness tasks: Preflight-inspections Rectification of defects to a recognised standard Accomplishment of maintenance per the maintenance programme Analysis of effectiveness of maintenance programme (for CAT and large aircraft) Accomplishment of ADs, operational ADs and other requirements established by EASA or the authority Accomplishment of repairs and modifications Policy for embodiment of non-mandatory modifications and inspections (for CAT and large aircraft) Flight checks when necessary
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M.A.302 Maintenance programme

A maintenance programme approved by the Competent Authority is always required.

Provisions for indirect approval may be introduced through approved procedures in the exposition (CAME).

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M.A.303 Airworthiness Directives

Airworthiness Directives are mandatory.

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M.A.304 Data for modifications and repairs

Data must be approved by EASA or by Part-21 design organisations.

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M.A.305 Aircraft continuing airworthiness record system

Contains the records that must be kept by the owner / operator and the conditions of storage and control. This is additional to the record keeping requirements for Part145, Subpart-F and CAMO organisations. Contains the period of time during which they have to be maintained. M.A.306 requires for Commercial Air Transport, an additional Operators Technical Log System. M.A.307 covers the transfer of those records to a new owner / operator.
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Maintenance Standards
M.A.401: Maintenance data. M.A.402: Performance of Maintenance. All maintenance performed by qualified personnel and following M.A.401 maintenance data. Independent duplicate inspection required for flight sensitive maintenance tasks. Use of M.A.401 tools, equipment and materials. Appropriate facilities. Final check that no tools or other parts and material are left in the aircraft / component. M.A.403: Aircraft defects.
These requirements are additional to Part-145 and Subpart F in order to cover also independent certifying staff, pilot owner maintenance and maintenance performed in AOG situations.
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M.A.501 Installation of components

Documentation needed for components: New components: EASA Form 1 or FAA 8130-3 or TCCA240078. Maintained components: EASA Form 1 or FAA 8130-3 (dual release) or TCCA24-0078 (dual release) Standard parts and materials (raw / consumable) do not need a Form 1 or equivalent. Certificate of Conformance is enough. Installer must check eligibility of component: Particular attention to modifications and configuration of aircraft, engines, etc.

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M.A.502 Component maintenance

Maintenance of components has to be done in approved organisations (no independent certifying staff), except: While maintained on the aircraft or, Temporarily removed to facilitate access if permitted by aircraft maintenance data.

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M.A.504 Control of unserviceable components

Unserviceable components identified and stored in a secure location. Components that reached their life limit or that can not be repaired, shall be classified unsalvageable:
Not permitted to re-enter the supply chain. Kept in a secure location or have it mutilated. Responsibility can be transferred without mutilating the component to a training organisation.

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Subpart F: Maintenance Organisation

Subpart F maintenance organisation can only maintain aircraft and components when not used in commercial air transport and not used in large aircraft. Main differences with Part-145: No need for independent quality system (organisational reviews required). No privileges for sub-contracting. No base maintenance and no category C Part-66 personnel required. No category A personnel. Some organisations may prefer to move-up to a Part-145 approval (includes the privileges of Subpart F organisations).
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Subpart G: Continuing Airworthiness Management Organisation Privileges (M.A.711)

A CAMO may: Manage aircraft not involved in CAT as listed in the certificate Manage CAT aircraft when listed in its AOC. Subcontract tasks to an organisation that works under its quality system (this organisation does not need to be a CAMO) A CAMO may additionally be approved to: Issue ARCs (following M.A.901) Make recommendations for an ARC to a Member State of Registry (any Member State) THIS PRIVILEGE CAN ONLY BE GRANTED TO CAMOs REGISTERED IN A MEMBER STATE.

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Subpart G: Continuing Airworthiness Management Organisation Personnel

M.A.706: 1 Accountable Manager: corporate financial authority. A person or group of persons responsible for ensuring that the organisation is always in compliance with Part-M. 1 Nominated Postholder (only for CAT): responsible for the management and supervision of the continuing airworthiness activities of the paragraph above. M.A.712(a): 1 Quality Manager (except for small organisations not involved in CAT, per M.A.712(e) and (f)).

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Subpart G: Continuing Airworthiness Management Organisation Airworthiness Review Staff (M.A.707)

Qualifications required:
5 years experience in continuing airworthiness. An appropriate Part-66 licence or aeronautical degree or equivalent. Formal aeronautical maintenance training. A position in the organisation with the appropriate responsibilities Independent from the continuing airworthiness management process, or Overall authority. Must be approved by the competent authority after performing an airworthiness review under supervision.

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M.A.901 Aircraft airworthiness review (M.A.901)

An ARC has to be issued with a validity of 1 year. Controlled environment means:
Aircraft managed by CAMO during the previous 12 months, and Maintained only by approved organisations (no independent certifying staff, except for pilot owner maintenance)

If the aircraft is in a controlled environment:

The CAMO (if it has Subpart I privileges) can issue the ARC after performing a full airworthiness review in accordance with M.A.710. If the aircraft continues under their control, they can extend the ARC twice. They can not extend ARCs issued by another organisation or by the authority.

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M.A.901 Aircraft airworthiness review (M.A.901)

If the aircraft is NOT in a controlled environment or managed by a CAMO without Subpart I privileges:
The ARC will be issued by the Competent Authority based on a recommendation issued by a CAMO with appropriate privileges (the CAMO has to do the airworthiness review).

If there is a safety concern, the authority may decide to do the review and issue the ARC themselves.

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