GM1 145.A.205 Contracting and subcontracting

CAA ORS9 Decision No. 38

RESPONSIBILITY WHEN CONTRACTING OR SUBCONTRACTING MAINTENANCE

(a) Regardless of the approval status of the subcontracted organisations, a Part-145 organisation is responsible for ensuring that all subcontracted activities are subject to hazard identification and risk management, as required by point 145.A.200(a)(3), and to compliance monitoring, as required by point 145.A.200(a)(6).

(b) A Part-145 organisation is responsible for identifying hazards that may stem from the existence of complex maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included) with due regard to the organisations’ interfaces (see GM1 145.A.200(a)(3)). In addition, the compliance monitoring function should at least check that the approval of the contracted maintenance organisation(s) effectively covers the contracted activities, and that it is still valid.

(c) A Part-145 organisation is responsible for ensuring that interfaces and communication channels are established with the contracted maintenance organisation(s) for occurrence reporting. This does not replace the obligation of the contracted organisation(s) to report to the CAA in accordance with UK Regulation (EU) No 1321/2014.

For subcontracted activities, interfaces and communication channels are also needed for the purpose of the internal safety reporting scheme (145.A.202).

(d) Contracts, both for contracting and subcontracting should be retained for a period of 5 years.