Part-M Continuing
Airworthiness
Juan Anton
Continuing Airworthiness Manager
Rulemaking Directorate
EASA
30/31 January 2013
EASA/Estonian CAA Rulemaking Workshop
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Entry into Force
 For commercial air transport (CAT):
28 September 2005 (opt-out for ARC until 28 September
2008)
 For other than commercial air transport:
28 September 2009
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M.1 Competent Authority
 Oversight of the continuing airworthiness of aircraft and issue ARC:
 Authority of Member State of Registry.
 Oversight of Subpart F maintenance organisations (similar to Part-145
and Part-147):
 Authority of Member State of Principle Place of Business.
 EASA for organisations located outside the EU.
 Oversight of CAMOs:
 Authority of Member State of Principle Place of Business if
independent CAMO (no AOC).
 Authority of Member State of operator (if part of AOC).
 EASA for organisations located outside the EU.
 Approval of maintenance programmes:
 In commercial air transport, the authority agreed by Member State
of Registry and Member State of operator (if different).
 For other than commercial air transport, the authority of the
Member State of Registry (or the authority of the CAMO if agreed
with the State of Registry).
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M.A.201 Responsibilities
 Pre-flight inspection:
Responsibility of Pilot-in-command (or operator in case of
CAT: Commercial Air Transport).
Performed by the pilot or another qualified person.
No need to be done by approved maintenance
organisations or Part-66 certifying staff.
 Maintenance of large aircraft and aircraft used in CAT:
Must be performed in Part-145 organisations.
 Maintenance of other aircraft:
By Subpart F organisations, by independent Part-66
certifying staff and by the pilot-owner (depending on the
type of tasks and as required by M.A.502 and
M.A.801(b)).
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M.A.201 Responsibilities
 Aircraft used in Commercial Air Transport (CAT):
Operator is responsible for continuing airworthiness.
Shall be approved as a CAMO (part of the AOC).
Shall be approved as Part-145 or contract a Part-145.
 Aircraft used in commercial operations other than CAT (if
Member State requires a certificate for the operational
activities):
Operator is responsible for continuing airworthiness.
Shall be approved as CAMO or contract a CAMO.
Shall be approved as Subpart F or Part-145 (as applicable
for the size of aircraft) or contract such organisations.
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M.A.201 Responsibilities
 Private aircraft* (large):
Owner is responsible for continuing airworthiness.
Shall contract a CAMO.
Maintenance has to be performed in Part-145 (no need
for contract).
 Private aircraft* (other than large)
Owner is responsible for continuing airworthiness.
It is not mandatory to contract a CAMO.
Maintenance by Subpart F, independent certifying staff
and pilot-owner (depending on the type of tasks and as
required by M.A.502 and M.A.801(b)).
* Private aircraft also include aircraft used for commercial
operations other than CAT when the Member State does
not require a certificate for the operational activities.
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M.A.201 Responsibilities
 When contracting a CAMO:
The contract must comply with Appendix I to Part-M.
Appendix I describes the responsibilities of the owner and
the responsibilities of the CAMO.
 For CAT it is not possible to contract a CAMO. The operator
must be approved as a CAMO:
The operator may sub-contract, under its Quality System,
some tasks as per AMC to M.A.201(h)1 and its Appendix
II.
The subcontracted organisation does not need to be a
CAMO.
The responsibility for the tasks is always of the operator
CAMO.
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M.A.202 Ocurrence Reporting
 Report any identified condition of an aircraft or component
which endangers flight safety.
 Must be done by all persons responsible under M.A.201.
 Reported to State of Registry, State of operator (if
applicable) and TC/STC holders.
 Maintenance organisations and independent certifying staff
shall report to the owner / operator.
 Reports shall be done before 72 hours.
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M.A.301 Cont. Airworth. Tasks
 This article shows the list of continuing airworthiness tasks:
 Preflight-inspections
 Rectification of defects to a recognised standard
 Accomplishment of maintenance per the maintenance
programme
 Analysis of effectiveness of maintenance programme (for
CAT and large aircraft)
 Accomplishment of ADs, operational ADs and other
requirements established by EASA or the authority
 Accomplishment of repairs and modifications
 Policy for embodiment of non-mandatory modifications
and inspections (for CAT and large aircraft)
 Flight checks when necessary
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M.A.302 Maintenance Programme
 A maintenance programme approved by the Competent
Authority is always required.

Provisions for indirect approval may be introduced
through approved procedures in the exposition (CAME).
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M.A.303 Airworthiness Directives
 Airworthiness Directives are mandatory.
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M.A.304 Modifications and Repairs
 Data for modifications and repairs must be approved by
EASA or by Part-21 design organisations.
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M.A.305 Record System
 Contains the records that must be kept by the owner /
operator and the conditions of storage and control. This is
additional to the record keeping requirements for Part145, Subpart-F and CAMO organisations.
 Contains the period of time during which they have to be
maintained.
 M.A.306 requires, for Commercial Air Transport, an
additional Operator´s Technical Log System.
 M.A.307 covers the transfer of those records to a new
owner / operator.
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Maintenance Standards

M.A.401: Maintenance data.

M.A.402: Performance of Maintenance.






All maintenance must be performed by qualified personnel
and following M.A.401 maintenance data.
Independent duplicate inspection required for flight sensitive
maintenance tasks.
Use of M.A.401 tools, equipment and materials.
Appropriate facilities.
Final check that no tools or other parts and material are left
in the aircraft / component.
M.A.403: Aircraft defects.
Note: These requirements are additional to Part-145 and Subpart F in order
to cover also independent certifying staff, pilot owner maintenance and
maintenance performed in AOG situations.
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M.A.501 Installation of components

Documentation needed for components:


New components: EASA Form 1 or FAA 8130-3 or TCCA240078 (replaced by Form One).
Maintained components: EASA Form 1 or FAA 8130-3 (dual
release) or TCCA24-0078/Form One (dual release)

Standard parts and materials (raw / consumable) do not need a
Form 1 or equivalent. Certificate of Conformance is enough.

Installer must check eligibility of component:

Particular attention to modifications and configuration of
aircraft, engines, etc.
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M.A.502 Component maintenance

Maintenance of components has to be done in approved
organisations (no independent certifying staff), except:

Maintenance of aircraft components iaw aircraft maintenance
data (or if agreed by the competent authority for simple
maintenance iaw component maintenance data), may be
performed by A rated organisations or independent certifying
staff when the component is:
 maintained on the aircraft, or
 temporarily removed to facilitate access
Release must be performed in Technical Log (no EASA Form 1)

Maintenance of engine/APU components iaw engine/APU
maintenance data (or if agreed by the competent authority for
simple maintenance iaw component maintenance data), may be
performed by B rated organisations when the component is:
 maintained on the engine/APU, or
 temporarily removed to facilitate access
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M.A.502 Component maintenance
(Continuation)

Maintenance of components for an ELA1 aircraft not used in
commercial air transport ,iaw component maintenance data, may
be performed by independent certifying staff except:
 Overhaul of components other than engines and propellers,
and
 Overhaul of engines and propellers for aircraft other than CSVLA, CS-22, LSA.
Release must be performed in Technical Log (no EASA Form 1)
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M.A.504 Unserviceable components

Unserviceable components shall be identified and stored in a
secure location under the control of a maintenance organisation,
until it is decided the action to be taken (repair or scrap), except


For aircraft not used in CAT other than large, where the
person who identified it as unserviceable can transfer it to
the owner after identifying it as unserviceable and
registration in the Log Book.
Components that reached their life limit or that can not be
repaired, shall be classified unsalvageable:



Not permitted to re-enter the supply chain.
Kept in a secure location or have it mutilated.
Responsibility can be transferred without mutilating the
component to a training organisation.
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Subpart F: Maintenance Orgs.

Subpart F maintenance organisations can only maintain aircraft
and components when not used in commercial air transport and
not used in large aircraft. Other aircraft have to be released by a
Part-145 organisation.

Main differences with Part-145:






No need for independent quality system (organisational
reviews required).
Limited privileges for sub-contracting.
There is no concept of line stations.
No base maintenance and no category C Part-66 personnel
required.
No category A personnel.
Some organisations may prefer to move-up to a Part-145
approval (includes the privileges of Subpart F organisations).
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Subpart H: CRS outside Part-145
Aircraft release (M.A.801)
The CRS can be issued by:

Subpart F maintenance organisations (certifying staff).

Independent certifying staff complying with Part-66 (except for
complex maintenance tasks listed in Appendix VII to Part-M and
performed on aircraft other than ELA1).

Pilot owner for private non-complex motor-powered aircraft
<2730Kg MTOM, sailplanes, powered sailplanes and balloons
(only for tasks listed in Appendix VIII to Part-M).
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Subpart H: CRS outside Part-145
Component release (M.A.802)
The CRS shall be issued in accordance with M.A.502.
The CRS shall be made on an EASA Form 1, except when the
maintenance is released in the Technical Log for those
exceptions listed in M.A.502(b) and (d).
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Subpart G: CAMO - Privileges
M.A.711

A CAMO may:





Manage aircraft not involved in CAT as listed in the certificate
Manage CAT aircraft when listed in its AOC.
Subcontract tasks to an organisation that works under its quality
system (this organisation does not need to be a CAMO)
Extend, under certain conditions, an ARC which has been issued by
the competent authority or another CAMO
A CAMO may additionally (optional) be approved to:
Issue ARCs (following M.A.901)
Make recommendations for an ARC to the Member State of Registry
(even if different to the State of the CAMO)
 Issue a Permit to Fly when the CAMO is attesting compliance with
the flight conditions (issued by EASA, DOA or competent authority,
depending on whether they affect safety of design or not))
THESE ADDITIONAL PRIVILEGES CAN ONLY BE GRANTED TO CAMOs
REGISTERED IN A MEMBER STATE.


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Subpart G: CAMO - Personnel
M.A.706:

1 Accountable Manager: corporate financial authority.

A person or group of persons responsible for ensuring that the
organisation is always in compliance with Part-M.

1 Nominated Postholder (only for CAT): responsible for the
management and supervision of the continuing airworthiness
activities of the paragraph above.
M.A.712(a):

1 Quality Manager (except for small organisations not involved
in CAT, per M.A.712(e) and (f)).
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Subpart G: CAMO - Personnel
M.A.707 Airworthiness Review Staff

Qualifications required *:




5 years experience in continuing airworthiness.
An appropriate Part-66 licence or aeronautical degree or
equivalent.
Formal aeronautical maintenance training.
A position in the organisation with the appropriate
responsibilities
 Independent from the continuing airworthiness
management process, or
 Overall authority.
* Some alleviations introduced for aircraft <2730 Kg MTOM not used
in CAT and for balloons.
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Subpart G: CAMO - Personnel
M.A.707 Airworthiness Review Staff

Must be formally accepted by the competent authority after
performing an airworthiness review under supervision.

The CAMO must issue them an authorisation.

They must be identified in the exposition.

The CAMO must retain the corresponding records (qualification,
experience, training, authorisation) until 2 years after they leave
the CAMO.
NOTE: Airworthiness Review Staff are also responsible for issuing the
Permit to Fly.
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Subpart G: CAMO - Tasks
M.A.708 Continuing Airworthiness Management

Develop and control a maintenance programme, presenting it and its
amendments to the competent authority for approval and, for non-CAT,
providing a copy to the owner.


Manage the approval of modifications and repairs.

Ensure that all ADs are applied.

Ensure that all defects are corrected by approved maintenance
organisations.

Ensure that the aircraft is taken to an appropriately approved
maintenance organisation when necessary.

Coordinate all maintenance activities.


Manage and archive the records and the operator’s technical log.
Ensure that all maintenance is performed in accordance with the
maintenance programme and released.
Ensure that the mass and balance statement is up to date.
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M.A.901 Aircraft airworthiness review

An ARC has to be issued with a validity of 1 year in order to
ensure the validity of the airworthiness certificate of the aircraft.

May be issued by a CAMO (with privileges), by independent
certifying staff (approved by the authority) or by the Competent
Authority, depending on the situation.

“Controlled environment” means:


Aircraft managed by CAMO during the previous 12 months,
and
Maintained only by approved organisations (except for pilot
owner maintenance, when performed by the pilot or by
independent certifying staff)
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M.A.901 Issuance of the ARC

For aircraft used in CAT and aircraft >2730 Kg MTOM
(except balloons):

If the aircraft is in a controlled environment:
 The CAMO managing the aircraft (if it has airworthiness
review privileges) can issue the ARC after performing a
full airworthiness review in accordance with M.A.710.

If the aircraft is NOT in a controlled environment or managed
by a CAMO without Subpart I privileges:
 The ARC will be issued by the Competent Authority based
on a recommendation issued by a CAMO with appropriate
privileges. The recommendation shall be issued after the
CAMO performs a full airworthiness review in accordance
with M.A.710.
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M.A.901 Issuance of the ARC

For aircraft <2730 Kg MTOM not used in CAT and for
balloons:


Any CAMO (if it has airworthiness review privileges) can issue
the ARC after performing a full airworthiness review in
accordance with M.A.710 (regardless of whether the aircraft
is in a controlled environment or not and regardless of
whether the CAMO manages the aircraft or not).
For ELA1 aircraft (privately used):

The ARC may also be issued by the Competent Authority
based on a recommendation issued by independent certifying
staff (approved by the authority). The recommendation shall
be issued after the certifying staff performs a full
airworthiness review in accordance with M.A.710.
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M.A.901 Issuance of the ARC

If there is a potential safety threat, the authority shall perform
the airworthiness review and issue the ARC themselves.

The authority may also perform the airworthiness review and
issue the ARC themselves in the following cases:


When the aircraft is managed by a CAMO located outside the
EU (since they cannot have privileges for airworthiness
review).
When the owner requests it for balloons and aircraft
<2730Kg MTOM.
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M.A.901 Extension of the ARC
Extension of the ARC

The CAMO managing the aircraft may, if the aircraft is in a
controlled environment, extend twice (1 year each time) an ARC
which has been issued by a CAMO or by the Competent
Authority.

There is no need for the CAMO to have airworthiness review
privileges since the ARC is extended without performing an
airworthiness review.
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Subpart G: Airworthiness Review
M.A.710 Airworthiness Review

It is applicable to airworthiness reviews performed by a CAMO,
by independent certifying staff and by the Competent Authority.

It includes a documental review of the aircraft records and a
physical survey of the aircraft.

The CAMO may advance it up to 90 days (without losing the
continuity pattern) to allow the physical survey to take place
during a maintenance check.

Airworthiness reviews cannot be sub-contracted.

A copy of any ARC issued or extended by the CAMO shall be sent
to the Member State of Registry within 10 days.
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