AMC1 CAO.A.095(b)(3) Privileges of the organisation    

CAA ORS9 Decision No. 1

SUBCONTRACTING OF CONTINUING AIRWORTHINESS TASKS

(a) The CAO may subcontract certain continuing airworthiness management tasks to qualified organisations. The subcontracted organisation performs the continuing airworthiness management tasks as an integral part of the CAO quality system, irrespective of any other approval held by the subcontracted organisation (including CAMO, CAO or Part-145 approval).

(b) The CAO remains accountable for the satisfactory completion of the continuing airworthiness management tasks irrespective of any contract that may be established.

(c) In order to fulfil this responsibility, the CAO should be satisfied that the actions taken by the subcontracted organisation meet the standards required by Part-CAO. Therefore, the CAO management of such activities should be accomplished by:

(1) active control through direct involvement; and/or

(2) endorsing the recommendations made by the subcontracted organisation.

(d) In order to retain ultimate responsibility, the CAO should limit subcontracted tasks to the activities specified below:

(1) airworthiness directive analysis and planning;

(2) service bulletin analysis;

(3) planning of maintenance;

(4) reliability monitoring, engine health monitoring;

(5) maintenance programme development and amendments; and

(6) any other activities, which do not limit the CAO responsibilities, as agreed by the CAA.

(e) The CAO’s controls associated with subcontracted continuing airworthiness management tasks should be reflected in the associated contract and be in accordance with the CAO policy and procedures defined in the CAE. When such tasks are subcontracted, the quality system is considered to be extended to the subcontracted organisations.

(f) With the exception of engines and auxiliary power units, contracts would normally be limited to one organisation per aircraft type for any combination of the subcontracted activities. Where contracts are made with more than one organisation, the CAO should demonstrate that adequate coordination controls are in place and that the individuals’ responsibilities are clearly defined in the related contracts.

(g) Contracts should not authorise the subcontracted organisation to subcontract elements of the continuing airworthiness management tasks to other organisations.

(h) The CAA should exercise oversight of the subcontracted activities through the CAO approval. The contracts should be acceptable to the CAA. The CAO should only subcontract to organisations which are specified by the CAA on CAA Form 3-CAO (page 2, block titled ‘List of organisation(s) working under a quality system’).

(i) The subcontracted organisation should agree to notify the CAO of any changes affecting the contract as soon as practical. The CAO should then inform its CAA. Failure to do so may invalidate the CAA’s acceptance of the contract.

(j) Appendix II to AMC1 CAMO.A.125(d)(3) provides information on the subcontracting of continuing airworthiness management tasks by the CAMO. The same principles may be applied to the CAO.