5.4 Part-CAMO Organisations, Management Systems & Subcontracting

Introduction to Annex Vc (Part-CAMO): Regulation (EU) 2019/1383

To align European continuing airworthiness management with the international safety management standards of ICAO Annex 19, the European Commission enacted Commission Implementing Regulation (EU) 2019/1383. This regulation introduced Annex Vc (Part-CAMO) into Regulation (EU) No 1321/2014, fundamentally transforming how airlines and continuing airworthiness organisations operate.

Prior to Part-CAMO, continuing airworthiness management organisations operated under Part-M Subpart G, which relied primarily on quality assurance audit loops. Part-CAMO replaced Subpart G for all Complex Motor-Powered Aircraft (CMPA) and all aircraft used in Commercial Air Transport (CAT). It introduced a mandatory Safety Management System (SMS) integrated with traditional continuing airworthiness functions, elevating risk management, human factors, and proactive hazard identification to the same regulatory level as flight operations and aircraft maintenance.

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The Continuing Airworthiness Management Exposition (CAME): CAMO.A.300

The statutory cornerstone of a Part-CAMO organisation is its Continuing Airworthiness Management Exposition (CAME) governed by CAMO.A.300. Similar to the Maintenance Organisation Exposition (MOE) for Part-145 organisations, the CAME represents the formal legal contract between the organisation and its competent National Aviation Authority.

Core Structure and Contents of the CAME

Pursuant to CAMO.A.300, the CAME must describe the organisation's complete operational and safety architecture, containing:

1. Management Commitment Statement: A formal statement signed by the Accountable Manager confirming that the CAME and any associated referenced manuals define the organisation's procedures and that they will be complied with at all times;
2. Safety Policy and Objectives: The formal organizational safety policy endorsed by executive leadership, establishing safety accountabilities and safety promotion commitments;
3. Management Structure and Org Chart: Delineating the clear lines of statutory responsibility and reporting relationships between the Accountable Manager and nominated post holders;
4. Scope of Work: Explicitly identifying the aircraft types, registrations, engine models, and operational profiles (CAT, commercial specialized, private) that the CAMO is approved to manage;
5. Continuing Airworthiness Procedures: Granular operational procedures for:
   • Aircraft maintenance programme (AMP) development, annual review, and amendment;
   • Airworthiness Directive (AD) monitoring, evaluation, and embodiment tracking;
   • Management of deferred defects and MEL compliance;
   • Modification and repair approval tracking under Part-21;
   • Reliability monitoring programme management;
   • Technical log administration and record retention;
6. Airworthiness Review Procedures: Detailed processes governing the qualification of airworthiness review staff, the conduct of documentary reviews, physical surveys, and the issuance or recommendation of ARCs (EASA Form 15a/15b);
7. Subcontracting and Contracting Procedures: Criteria for selecting, contracting, and auditing Part-145 maintenance organisations and subcontracted continuing airworthiness support entities.

Approval and Amendment of the CAME

The CAME must be formally approved by the competent National Aviation Authority. However, under CAMO.A.300(c), the authority may grant the CAMO an indirect approval procedure for minor, routine amendments (such as updating personnel lists or editorial clarifications). All major changes—such as expanding the approved scope of aircraft types, altering airworthiness review procedures, or modifying subcontracting agreements—mandate prior direct approval by the NAA before implementation.

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Key Personnel and Airworthiness Review Staff: CAMO.A.305 & CAMO.A.310

A Part-CAMO organisation operates under strict personnel qualification and competence requirements established by CAMO.A.305 and CAMO.A.310.

1. The Accountable Manager (CAMO.A.305(a))

The Accountable Manager is the chief executive who possesses the corporate authority to ensure that all continuing airworthiness management activities can be financed and carried out to the statutory standard. The Accountable Manager is ultimately and personally accountable for the entire safety and regulatory compliance performance of the organisation.

2. Nominated Post Holders (CAMO.A.305(b))

The Accountable Manager appoints nominated post holders acceptable to the competent authority:

• Continuing Airworthiness Manager (CAM): Responsible for the direct management and daily execution of all continuing airworthiness activities;
• Compliance Monitoring Manager: Responsible for the independent monitoring of compliance with Part-CAMO and the CAME. To ensure complete impartiality, the Compliance Monitoring Manager must maintain an independent reporting channel directly to the Accountable Manager, free from operational or financial pressures;
• Safety Manager: Responsible for the development, administration, and continuous maintenance of the Safety Management System (SMS).

3. Airworthiness Review Staff Qualification (CAMO.A.310)

Personnel authorized by the CAMO to conduct airworthiness reviews and issue EASA Form 15b (or recommendations for Form 15a) must satisfy stringent qualification criteria:

• For Complex Motor-Powered Aircraft (CMPA):
  1. Hold an appropriate Part-66 Aircraft Maintenance Licence (Category B1, B2, or C), or an aeronautical degree (or national equivalent recognized by the authority);
  2. Possess at least 5 years of relevant continuing airworthiness experience;
  3. Have completed comprehensive formal training on the relevant aircraft type(s);
  4. Have completed formal training on Part-M, Part-CAMO, and the organisation's CAME procedures;
  5. Satisfactorily perform an airworthiness review under the supervision of the competent authority or authorized staff before receiving a formal company Airworthiness Review Authorization.
• For Other-Than-Complex Aircraft: The minimum continuing airworthiness experience requirement is reduced to 3 years.

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Management System Integration: Safety Management (SMS) & Compliance Monitoring

Pursuant to CAMO.A.200, a Part-CAMO must establish, implement, and maintain an integrated management system encompassing two complementary pillars: the Safety Management System (SMS) and the Compliance Monitoring System.

The Safety Management System (SMS) in Continuing Airworthiness

Continuing airworthiness decisions directly impact flight safety margins. Part-CAMO applies structured safety risk management to maintenance planning:

1. Hazard Identification: Proactively identifying latent hazards within airworthiness operations. Examples include:
   • Maintenance scheduling pressures during peak commercial flight seasons;
   • Latent risks associated with repetitive defect deferrals under the MEL;
   • Supply chain disruptions resulting in long lead-times for critical components;
   • Human factors in technical records entry and maintenance coordination;
2. Safety Risk Assessment & Mitigation: Assessing the probability and severity of risks using a standard Risk Assessment Matrix, ensuring risks are mitigated to As Low As Reasonably Practicable (ALARP);
3. Safety Performance Indicators (SPIs): Tracking quantitative safety metrics, such as In-Flight Shut-Down (IFSD) rates, technical turn-around delays, maintenance error reports, and MEL deferral trends against defined Safety Performance Targets (SPTs);
4. Internal Safety Reporting Scheme (CAMO.A.202): Implementing a confidential internal safety reporting scheme complying with Regulation (EU) No 376/2014 and Just Culture principles, ensuring staff can report errors and hazards without fear of disciplinary retaliation.

Compliance Monitoring System

The Compliance Monitoring System acts as the organisation's internal regulatory policing mechanism:

• Implements an independent annual audit plan covering all continuing airworthiness management activities, CAME procedures, contracted Part-145 maintenance providers, and subcontracted entities within a 12-month cycle;
• Categorizes audit non-conformities into Level 1 findings (significant non-compliance lowering safety standards or posing serious flight hazard, requiring immediate corrective action and authority notification) and Level 2 findings (non-compliance that could lower safety standards if uncorrected within an agreed timeframe);
• Maintains an uninhibited, direct feedback loop to the Accountable Manager to ensure that audit findings are backed by executive authority and resolved through timely corrective action plans.

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Contracting vs Subcontracting: Legal Boundaries

Module 10 candidates frequently confuse the vital legal distinction between contracting maintenance and subcontracting CAMO tasks:

1. Contracting Maintenance to Approved Part-145 Organisations

A Part-CAMO manages airworthiness but typically does not perform physical spanner-work on aircraft. Under M.A.201(e)(3), a licensed air carrier must either be approved under Part-145 itself or conclude a written contract with an approved EASA Part-145 maintenance organisation.

• The relationship must be formalized through a written technical maintenance contract complying with Appendix I to Part-M;
• The contract establishes clear interfaces regarding work order transmission, technical data availability, defect communication, MEL deferral coordination, and technical record return.

2. Subcontracting CAMO Tasks: CAMO.A.125(d)(3) & CAMO.A.205

A Part-CAMO may choose to subcontract specific continuing airworthiness administrative or engineering tasks to an external third party that does not hold a Part-CAMO approval (e.g. contracting an engineering firm to track ADs, process reliability data, or run computerized maintenance planning software). However, strict legal conditions apply:

1. Retained Ultimate Responsibility: The Part-CAMO remains fully and solely responsible for all subcontracted activities. Any error or oversight committed by the subcontractor is treated under the law as an error of the CAMO itself;
2. Working Under the CAMO's Management System: The subcontracted entity must work strictly in accordance with the CAME procedures of the CAMO and be fully integrated into the CAMO's compliance monitoring and SMS audit programme;
3. CAME Specification & NAA Approval: The subcontracting arrangement, interface procedures, and subcontractor identity must be explicitly detailed in the CAME and approved by the Competent Authority;
4. Non-Subcontractable Core Tasks: European law strictly forbids the subcontracting of core airworthiness management functions. A CAMO can NEVER subcontract:
   • The conduct of airworthiness reviews;
   • The issuance of Airworthiness Review Certificates (Form 15b);
   • The submission of airworthiness review recommendations (Form 15a);
   • Final approval recommendations for the Aircraft Maintenance Programme;
   • Ultimate airworthiness decision-making.

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Practical Maintenance Scenario & Module 10 Exam Tips

Maintenance Practical Example: A Part-CAMO managing a fleet of 20 regional jet aircraft subcontracts its maintenance planning and engine health monitoring to an independent aviation software consultancy in Ireland that does not hold Part-CAMO approval. An analyst at the software firm misinterprets an Airworthiness Directive revision and enters an incorrect repeat inspection threshold in the maintenance database, causing two aircraft to overrun their mandatory inspection due dates. During an NAA standardisation audit, the Accountable Manager argues that "the software subcontractor is exclusively at fault." Under CAMO.A.125 and CAMO.A.205, the NAA rejects this defense. The CAMO is 100% legally responsible for all subcontracted tasks. The CAMO failed to exercise adequate compliance monitoring oversight over its subcontractor, resulting in a Level 1 regulatory finding against the CAMO itself.

Module 10 Exam Tips:

• Part-CAMO was introduced by Regulation (EU) 2019/1383 to replace Part-M Subpart G for CMPA and CAT, adding SMS.
• The CAME (CAMO.A.300) is signed by the Accountable Manager.
• Airworthiness review staff on complex aircraft need at least 5 years of continuing airworthiness experience plus a Part-66 licence or engineering degree.
• Subcontracting allows tasks (planning, AD tracking) to be done by non-approved entities under the CAMO's approval, but ARC issuance and final decisions can NEVER be subcontracted.
• The Compliance Monitoring Manager must have an independent reporting line directly to the Accountable Manager.