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Contracting continuous airworthiness management

According to the Continuing Airworthiness Regulation 2042/2003 Annex I (Part-M), Commercial Air Transport (CAT) Air Operators Certificate (AOC) holders need to be approved as a Continuing Airworthiness Management Organisation (CAMO), and may subcontract certain CAM tasks to a non-approved third party under its quality system.

In July 2006, the European Aviation Safety Agency (EASA) started rulemaking task M.014 to provide AOC holders with an alternative option for applying to be  a Continuing Airworthiness Controlling Organisation (CACO), and contract all CAM tasks to an approved external CAMO.

In August 2010, EASA Notice of Proposed Amendment NPA 2010-09 Part 1 reinforces the current rule with additional Guidance Material on (sub)contracting and Part 2 introduces a new Subpart J to Part-M for Continuing Airworthiness Controlling Organisation (CACO).

The nature of the comments made during the subsequent EASA workshop in September 2010 showed significant objections, for example. There were concerns about AOC/CAMO subcontracting some CAM tasks to unapproved organisations without having the necessary resources to exercise properly their CAMO responsibilities. Authorities are concerned that the proposed CACO will worsen the situation and further dilute the responsibilities, especially when AOC holders are allowed to contract all CAM tasks to an external CAMO. 

In March 2011, the EASA Comments Review Group, chaired by Monarch Airlines, held its first meeting.

This year EASA announced it will hold a thematic workshop at the end of June to present the feedback and allow stakeholders and competent authorities to express their views and proposals on two issues:

• Issue 1: AOC holders subcontracting to an unapproved organisation under its quality system
• Issue 2: AOC holders contracting to an approved CAMO

Whether the latter may further subcontract some CAM tasks (Issue 3) is being debated internally at EASA.