1. Part-M Continuing Airworthiness Juan Anton Continuing Airworthiness Manager Rulemaking Directorate EASA
FBA introduction : insist on Standardisation rather than on inspections
A more proactive role
To reach a common understanding on the means of compliance
Achieve a even playing field
Cooperate between states

2. 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

3. 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).
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).

4. 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)).

5. 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):
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.

6. 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)
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.

7. 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.

8. 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.

9. 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

10. 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).

11. M.A.303 Airworthiness Directives
Airworthiness Directives are mandatory.

12. M.A.304 Modifications and Repairs
Data for modifications and repairs must be approved by EASA or by Part-21 design organisations.

13. 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 Part-145, 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.

14. 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.

15. M.A.501 Installation of components
Documentation needed for components:
New components: EASA Form 1 or FAA or TCCA (replaced by Form One).
Maintained components: EASA Form 1 or FAA (dual release) or TCCA /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.

16. 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

17. 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 CS-VLA, CS-22, LSA.
Release must be performed in Technical Log (no EASA Form 1)

18. 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.

19. 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).

20. 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).

21. 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).

22. 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.

23. 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)).

24. 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.

25. 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.

26. 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 maintenance is performed in accordance with the maintenance programme and released.
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 the mass and balance statement is up to date.

27. 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)

28. 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.

29. 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.

30. 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.

31. 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.

32. 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.