Appendix II to AMC M.A.711(a)(3) — Subcontracting of continuing airworthiness management tasks

1.      Subcontracted continuing airworthiness management tasks

1.1.    To actively control the standards of the subcontracted organisation, the CAMO should employ a person or group of persons who are trained and competent in the disciplines associated with M.A. Subpart G. As such, they are responsible for determining what maintenance is required, when it has to be performed, by whom and to what standard in order to ensure the continuing airworthiness of the aircraft to be operated.

1.2.    The CAMO should conduct a pre-subcontract audit to establish that the organisation to be subcontracted can achieve the standards required by M.A. Subpart G in connection with those activities to be subcontracted.

1.3.    The CAMO should ensure that the organisation to be subcontracted has sufficient and qualified personnel who are trained and competent in the functions to be sub-contracted. In assessing the adequacy of personnel resources, the CAMO should consider the particular needs of those activities that are to be subcontracted, while taking into account the subcontracted organisations existing commitments.

1.4.    To be appropriately approved to subcontract continuing airworthiness management tasks, the CAMO should have procedures for the management control of these arrangements. The continuing airworthiness management exposition should contain relevant procedures to reflect its control of those arrangements made with the sub-contracted organisation.

1.5.    Subcontracted continuing airworthiness management tasks should be addressed in a contract between the CAMO and the subcontracted organisation. The contract should also specify that the subcontracted organisation is responsible for informing the CAMO, that is in turn responsible for notifying the respective competent authority, of any subsequent changes that affect their ability to fulfil the contract.

1.6.    The subcontracted organisation should use procedures which set out the manner of fulfilling its responsibilities with regard to the subcontracted activities. Such procedures may be developed by either the subcontracted organisation or the CAMO.

1.7.    Where the subcontracted organisation develops its own procedures, they should be compatible with the continuing airworthiness management exposition and the terms of the contract. These should be accepted by the competent authority as extended procedures of the CAMO and as such should be cross-referenced from the continuing airworthiness management exposition. One current copy of the subcontracted organisation’s relevant procedures should be kept by the CAMO and should be accessible to the competent authority when needed.

Note: Should any conflict arise between the subcontracted organisation’s procedures and those of the CAMO, then the policy and procedures of the continuing airworthiness management exposition will prevail.

1.8.    The contract should also specify that the subcontracted organisation’s procedures may only be amended with the agreement of the CAMO. The CAMO should ensure that these amendments are compatible with its continuing airworthiness management exposition and comply with M.A. Subpart G.

The CAMO should nominate the person responsible for continued monitoring and acceptance of the subcontracted organisation’s procedures and their amendments. The controls used to fulfil this function should be clearly set out in the amendment section of the continuing airworthiness management exposition detailing the level of CAMO involvement.

1.9.    Whenever any elements of the continuing airworthiness management tasks are subcontracted, the CAMO personnel should have access to all relevant data in order to fulfil their responsibilities.

Note: The CAMO retains the authority to override, whenever necessary for the continuing airworthiness of their aircraft, any recommendation of the subcontracted organisation.

1.10.  The CAMO should ensure that the subcontracted organisation continues to have qualified technical expertise and sufficient resources to perform the sub-contracted tasks while complying with the relevant procedures. Failure to do so may invalidate the CAMO approval.

1.11.  The contract should provide for competent authority monitoring.

1.12.  The contract should address the respective responsibilities to ensure that any findings arising from the competent authority monitoring will be closed to the satisfaction of the competent authority.

2.      Accomplishment

This paragraph describes the topics which may be applicable to such subcontracting arrangements.

2.1.    Scope of work

The type of aircraft and their registrations, engine types and/or components subject to the continuing airworthiness management tasks contract should be specified.

2.2.    Maintenance programme development and amendment

The CAMO may subcontract the preparation of the draft maintenance programme and any subsequent amendments. However, the CAMO remains responsible for assessing that the draft proposals meet its needs and for obtaining competent authority approval; the relevant procedures should specify these responsibilities. The contract should also stipulate that any data necessary to substantiate the approval of the initial programme or an amendment to this programme should be provided for CAMO agreement and/or competent authority upon request.

2.3.    Maintenance programme effectiveness and reliability

The CAMO should have a system in place to monitor and assess the effectiveness of the maintenance programme based on maintenance and operational experience. The collection of data and initial assessment may be made by the subcontracted organisation; the required actions are to be endorsed by the CAMO.

Where reliability monitoring is used to establish the effectiveness of the maintenance programme, this may be provided by the subcontracted organisation and should be specified in the relevant procedures. Reference should be made to the approved maintenance and reliability programme. Participation of the CAMO’s personnel in reliability meetings with the subcontracted organisation should also be specified.

When providing reliability data, the subcontracted organisation is limited to working with primary data/documents provided by the CAMO or data provided by the CAMO’s contracted maintenance organisation(s) from which the reports are derived. The pooling of reliability data is permitted if it is acceptable to the competent authority.

2.4.    Permitted variations to the maintenance programme

The reasons and justification for any proposed variation to scheduled maintenance may be prepared by the subcontracted organisation. Acceptance of the proposed variation should be granted by the CAMO. The means by which the CAMO acceptance is given should be specified in the relevant procedures. When outside the limits set out in the maintenance programme, the CAMO is required to obtain approval by the competent authority.

2.5.    Scheduled maintenance

Where the subcontracted organisation plans and defines maintenance checks or inspections in accordance with the approved maintenance programme, the required liaison with the CAMO, including feedback, should be defined.

The planning control and documentation should be specified in the appropriate supporting procedures. These procedures should typically set out the CAMO’s level of involvement in each type of check. This will normally involve the CAMO assessing and agreeing to a work specification on a case-by-case basis for base maintenance checks. For routine line maintenance checks, this may be controlled on a day-to-day basis by the subcontracted organisation subject to appropriate liaison and CAMO controls to ensure timely compliance. This may typically include but is not necessarily limited to:

-            applicable work package, including job cards;

-            scheduled component removal list;

-            ADs to be incorporated;

-            modifications to be incorporated.

The associated procedures should ensure that the CAMO is informed in a timely manner on the accomplishment of such tasks.

2.6.    Quality monitoring

The CAMO’s quality system should monitor the adequacy of the subcontracted continuing airworthiness management task performance for compliance with the contract and with M.A. Subpart G. The terms of the contract should therefore include a provision allowing the CAMO to perform a quality surveillance (including audits) of the subcontracted organisation. The aim of the surveillance is primarily to investigate and judge the effectiveness of those subcontracted activities and thereby to ensure compliance with M.A Subpart G and the contract. Audit reports may be subject to review when requested by the competent authority.

2.7.    Access to the competent authority

The contract should specify that the subcontracted organisation should always grant access to the competent authority.

2.8.    Maintenance data

The maintenance data used for the purpose of the contract should be specified, together with those responsible for providing such documentation and the competent authority responsible for the acceptance/approval of such data, when applicable. The CAMO should ensure that such data, including revisions, is readily available to the CAMO personnel and to those in the subcontracted organisation who may be required to assess such data. The CAMO should establish a ‘fast track’ means to ensure that urgent data is transmitted to the subcontractor in a timely manner. Maintenance data is defined in M.A.401(b) or ML.A.401(b).

2.9.    Airworthiness directives (ADs)

While the various aspects of AD assessment, planning and follow-up may be accomplished by the subcontracted organisation, AD embodiment is performed by a maintenance organisation. The CAMO is responsible for ensuring timely embodiment of the applicable ADs and is to be provided with notification of compliance. It, therefore, follows that the CAMO should have clear policies and procedures on AD embodiment supported by defined procedures which will ensure that the CAMO agrees to the proposed means of compliance.

The relevant procedures should specify:

-            what information (e.g. AD publications, continuing airworthiness records, flight hours/cycles, etc.) the subcontracted organisation needs from the CAMO;

-            what information (e.g. AD planning listing, detailed engineering order, etc.) the CAMO needs from the subcontracted organisation in order to ensure timely compliance with the ADs.

To fulfil the above responsibility, the CAMO should ensure that it receives current mandatory continued airworthiness information for the aircraft and equipment it is managing.

2.10.  Service bulletin (SB) modifications

The subcontracted organisation may be required to review and make recommendations on the embodiment of an SB and other associated non-mandatory material based on a clear policy established by the CAMO. This should be specified in the contract.

2.11.  Mandatory life limitation or scheduled maintenance controls and component control/removal forecast

Where the subcontracted organisation performs planning activities, it should be specified that the organisation should receive the current flight cycles, flight hours, landings and/or calendar controlled details, as applicable, at a frequency to be specified in the contract. The frequency should be such that it allows the organisation to properly perform the subcontracted planning functions. It, therefore, follows that there will need to be adequate liaison between the CAMO, the contracted maintenance organisation(s) and the subcontracted organisation. Additionally, the contract should specify how the CAMO will be in possession of all current flight cycles, flight hours, etc., so that it may assure the timely accomplishment of the required maintenance.

2.12.  Engine health monitoring

If the CAMO subcontracts the on-wing engine health monitoring, the subcontracted organisation should receive all the relevant information to perform this task, including any parameter reading deemed necessary to be supplied by the CAMO for this control. The contract should also specify what kind of feedback information (such as engine limitation, appropriate technical advice, etc.) the organisation should provide to the CAMO.

2.13.  Defect control

Where the CAMO has subcontracted the day-to-day control of technical log deferred defects, this should be specified in the contract and should be adequately described in the appropriate procedures. The operator’s MEL/CDL provides the basis for establishing which defects may be deferred and the associated limits. The procedures should also define the responsibilities and actions to be taken for defects such as AOG situations, repetitive defects, and damage beyond the type certificate holder’s limits.

For all other defects identified during maintenance, the information should be brought to the attention of the CAMO which, depending upon the procedural authority granted by the competent authority, may determine that some defects can be deferred. Therefore, adequate liaison between the CAMO, its subcontracted organisation and contracted maintenance organisation should be ensured.

The subcontracted organisation should make a positive assessment of potential deferred defects and consider the potential hazards arising from the cumulative effect of any combination of defects. The subcontracted organisations should liaise with the CAMO to get its agreement following this assessment.

Deferment of MEL/CDL allowable defects can be accomplished by a contracted maintenance organisation in compliance with the relevant technical log procedures, subject to the acceptance by the aircraft commander.

2.14.  Mandatory occurrence reporting

All incidents and occurrences that meet the reporting criteria defined in Part-M and Part-145 should be reported as required by the respective requirements. The CAMO should ensure that adequate liaison exists with the subcontracted organisation and the maintenance organisation.

2.15.  Continuing airworthiness records

They may be maintained and kept by the subcontracted organisation on behalf of the CAMO, which remains the owner of these documents. However, the CAMO should be provided with the current status of AD compliance and life-limited parts and time-controlled components in accordance with the agreed procedures. The CAMO should also be granted unrestricted and timely access to the original records as and when needed. Online access to the appropriate information systems is acceptable.

The record-keeping requirements of Part-M should be met. Access to the records by duly authorised members of the competent authority should be granted upon request.

2.16.  Maintenance check flight (MCF) procedures

MCFs are performed under the control of the operator in coordination with the CAMO. MCF requirements from the subcontracted organisation or contracted maintenance organisation should be agreed by the operator/CAMO.

2.17.  Communication between the CAMO and the subcontracted organisation

2.17.1. In order to fulfil its airworthiness responsibility, the CAMO needs to receive all the relevant reports and relevant maintenance data. The contract should specify what information should be provided and when.

2.17.2. Meetings provide one important cornerstone whereby the CAMO can fulfil part of its responsibility for ensuring the airworthiness of the operated aircraft. They should be used to establish good communication between the CAMO, the subcontracted organisation and the contracted maintenance organisation. The terms of the contract should include, whenever appropriate, the provision for a certain number of meetings to be held between the involved parties. Details of the types of liaison meetings and associated terms of reference of each meeting should be documented. The meetings may include but are not limited to all or a combination of:

(a)     Contract review

Before the contract is enforced, it is very important that the technical personnel of both parties, that are involved in the fulfilment of the contract, meet in order to be sure that every point leads to a common understanding of the duties of both parties.

(b)     Work scope planning meeting

Work scope planning meetings may be organised so that the tasks to be performed are commonly agreed.

(c)      Technical meeting

Scheduled meetings should be organised in order to review on a regular basis and agree on actions on technical matters such as ADs, SBs, future modifications, major defects found during shop visit, reliability, etc.

(d)     Quality meeting

Quality meetings should be organised in order to examine matters raised by the CAMO’s quality surveillance and the competent authority’s monitoring activity and to agree on necessary corrective actions.

(e)     Reliability meeting

When a reliability programme exists, the contract should specify the involvement of the CAMO and of the subcontracted organisation in that programme, including their participation in reliability meetings. Provision to enable competent authority participation in the periodical reliability meetings should also be made.