AMC2 M.A.708(c) Continuing airworthiness management    

CAA ORS9 Decision No. 1

MAINTENANCE CONTRACT WITH ANOTHER CAMO/OPERATOR

1. The purpose of M.A.708(c) is to ensure that all maintenance is carried out by an appropriately approved maintenance organisation. It is possible to contract another operator/CAMO (secondary operator/CAMO) that does not hold a maintenance organisation approval when it proves that such a contract is in the interest of the CAMO by simplifying the management of its maintenance, and the CAMO keeps an appropriate control of it. In this case the continuing airworthiness management exposition should include appropriate procedures to ensure that all maintenance is ultimately carried out on time by approved maintenance organisations in accordance with the CAMO’s data. In particular, the quality system procedures should place great emphasis on monitoring compliance with the above. The list of approved maintenance organisations, or a reference to this list, should be included in the CAMO’s continuing airworthiness management exposition.

2. This contract should not preclude the CAMO from ensuring that all maintenance is performed by appropriately approved organisations which comply with the M.A.201 continuing airworthiness responsibility requirements. Typical examples of such arrangements are the following:

— Component maintenance:

The CAMO may find it more appropriate to have a primary contractor (the secondary operator/CAMO) dispatching the components to appropriately approved organisations rather than sending themselves different types of components to various maintenance organisations approved under Part-145. The benefit for the CAMO is that the management of maintenance is simplified by having a single point of contact for component maintenance. The CAMO remains responsible for ensuring that all maintenance is performed by maintenance organisations approved under Part-145 and in accordance with the approved standards.

— Aircraft, engine and component maintenance:

The CAMO may wish to have a maintenance contract with a secondary operator/CAMO not approved under Part-145 for the same type of aircraft. A typical case is that of a dry- leased aeroplane between operators where the parties, for consistency or continuity reasons (especially for short-term lease agreements), find it appropriate to keep the aeroplane under the current maintenance arrangement. Where this arrangement involves various Part-145 approved contractors, it might be more manageable for the lessee CAMO to have a single maintenance contract with the lessor operator/CAMO. Whatever type of acceptable maintenance contract is concluded, the CAMO is required to exercise the same level of control on contracted maintenance, particularly through the M.A.706(c) continuing airworthiness management group of persons and quality system as referred to in M.A.712.