Part-CAMO: what the 2019 reform changed for continuing airworthiness management

From a subpart to an annex

For years, organisations responsible for managing aircraft continuing airworthiness were approved under Subpart G of Part-M, Annex I to Regulation (EU) No 1321/2014. Small maintenance shops working on non-complex aircraft fell under Subpart F. This arrangement, inherited from EASA's early years, mixed rules applicable to the aircraft and rules applicable to organisations in a single text.

Implementing Regulation (EU) 2019/1383 of 8 July 2019, published in the Official Journal on 4 September 2019, overhauled this architecture by adding three annexes to Regulation 1321/2014:

• Annex Vb (Part-ML), a lighter regime for low-mass, non-complex motor-powered aircraft, notably aeroplanes with a maximum take-off mass of 2,730 kg or less and rotorcraft of 1,200 kg or less certified for no more than four occupants;
• Annex Vc (Part-CAMO), dedicated to continuing airworthiness management organisations;
• Annex Vd (Part-CAO), for combined organisations bringing together airworthiness management and maintenance in general aviation.

Transitional provisions allowed existing approvals to be converted, with the transition period ending in 2021.

The management system at the heart of the scheme

The major novelty of Part-CAMO is the requirement for a management system that includes safety risk management. In practice, a CAMO must now:

• identify hazards associated with its activities and assess the related risks;
• define clear responsibilities, around an accountable manager and nominated personnel;
• carry out independent compliance monitoring;
• run an internal occurrence reporting system and learn from it;
• control contracted tasks, for which it remains responsible.

The regulation provides, on the other hand, that safety management principles do not apply to Part-CAO combined organisations, designed for a less demanding environment.

What a CAMO does day to day

Beyond the reform, the job remains the technical steering of the fleet. The CAMO develops and maintains the aircraft maintenance programme, tracks airworthiness directives and modifications, schedules checks, manages time limits and life-limited parts, and ensures that maintenance is carried out by a duly approved organisation. Where it holds the privilege, it can also perform airworthiness reviews and extend the related certificates under the conditions set by the regulation.

This conductor role makes the CAMO the convergence point for fleet technical data: maintenance reports, component reliability, shop findings and engine monitoring. This is precisely where the growth of predictive maintenance is playing out. Using such data to adjust intervals or anticipate removals does not waive any regulatory requirement: any change to the maintenance programme must be justified and approved through the established procedures.

Impacts on organisations

For airlines, business aviation operators and independent airworthiness management providers, Part-CAMO has had several consequences:

• a documentation overhaul of the organisation exposition and procedures;
• upskilling of teams in risk management and compliance monitoring;
• closer alignment with flight operations management systems where the CAMO sits within an air carrier;
• clearer contractual relationships with Part-145 shops and technical subcontractors.

For general aviation, by contrast, the introduction of Part-ML and Part-CAO eased constraints, giving owners more flexibility over the maintenance programme and the choice of providers.

A performance-based approach

The reform moved continuing airworthiness management from a mainly documentary approach to one based on safety performance. For organisations, the challenge is no longer only to prove compliance during audits, but to demonstrate that they identify and address their own risks. It is a cultural shift that brings CAMOs closer to the requirements already imposed on operators and training organisations.