ED Decision 2020/002/R
SUBCONTRACTING OF CONTINUING AIRWORTHINESS TASKS
(a) The CAMO 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 CAMO’s management system, irrespective of any other approval held by the subcontracted organisation (including CAMO or Part-145 approval).
(b) The CAMO 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 CAMO should be satisfied that the actions taken by the subcontracted organisation meet the standards required by Part-CAMO. Therefore, the CAMO management of such activities should be accomplished:
(1) by active control through direct involvement; and/or
(2) by endorsing the recommendations made by the subcontracted organisation.
(d) In order to retain ultimate responsibility, the CAMO 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;
(6) any other activities, which do not limit the CAMO responsibilities, as agreed by the competent authority.
(e) The CAMO’s controls associated with subcontracted continuing airworthiness management tasks should be reflected in the associated contract and be in accordance with the CAMO policy and procedures defined in the CAME. When such tasks are subcontracted, the management 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 activities described in Appendix II. Where contracts are made with more than one organisation, the CAMO 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 to other organisations elements of the continuing airworthiness management tasks.
(h) The competent authority should exercise oversight of the subcontracted activities through the CAMO approval. The contracts should be acceptable to the competent authority. The CAMO should only subcontract to organisations which are specified by the competent authority on EASA Form 14.
(i) The subcontracted organisation should agree to notify the CAMO of any changes affecting the contract as soon as practical. The CAMO should then inform its competent authority. Failure to do so may invalidate the competent authority’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.
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