Under the European regulatory requirements for non-commercial operations of complex motor-powered aircraft (NCC), operators with their principal place of business in an EASA member state are required to have the continuing airworthiness of aircraft managed by a continuing airworthiness management organization (CAMO). In practical terms, the options are that either the NCC operators get a CAMO approval and manage the continuing airworthiness themselves or that they contract aircraft management tasks to another CAMO. As NCC operators are often very small organizations, outsourcing is often the most effective option.

Outsourcing continuing airworthiness management provides technical supervision by a third party, eliminating internal bias, and overcomes the limited resources and technical and legal expertise within the NCC operators, according to Giuseppe Renga, business development manager at continuing airworthiness management organization Amros-Global.

“Opting for CAMO outsourcing provides an economic advantage to NCC operators, as it does not force the operator to have permanent personnel but rather to look into a wide choice of service providers,” said Sara Zerbini, technical director at continuing airworthiness management organization Dasaero. “NCC operators may not be able to hire five people to manage one airplane." She explained that an external CAMO provides expertise in numerous subjects and aircraft types.  "When contracting a third-party CAMO with diverse staff, an NCC operator can be reasonably certain that if an airplane has, for example, an avionics problem, the CAMO will have experts with subject matter knowledge readily available," she noted.

Selecting a CAMO

Parameters that NCC operators should consider when selecting a CAMO primarily concern the fleet technical management capabilities and expertise of the organization under consideration. Renga advised, “Consideration should be given to the depth of the know-how available in the company and the extent to which it makes use of professional IT systems. Moreover, the CAMO should be able to ensure the full handling of aircraft with regard to airworthiness,” Renga added. Additional benefits are supporting the phase-in and phase-out of aircraft and customizing maintenance solutions.

It is also important that the CAMO has a familiarity with the applicable regulatory authority and knows how to manage the relationship with the authority as well as the documentation based on what the local authority requires. Relationship management includes the ability of key people in the CAMO to speak the language of both the operator and the authority. “A CAMO may be very well organized, but it may not have the possibility to fully interface with the authority due to language barriers, and it may need the support of external parties in the discussion with the authority or in the acceptance of documentation such as the aircraft maintenance program,” said Zerbini.

Operator Responsibilities

Even when a contract with a CAMO exists, NCC operators continue to have responsibilities with regard to aircraft continuing airworthiness. The operators must have a general understanding of EASA Part-M and of the approved maintenance program as well as communicate the aircraft status and every status change to the CAMO, according to Renga.

At a more detailed level, the obligations of the operators are to provide technical logbooks and records to the CAMO to register and update the aircraft operative activity, or use the ones provided by the CAMO. “The operators must also present the aircraft to the approved maintenance organization, agreed with the CAMO, at the due time and not modify the aircraft without first consulting the CAMO,” said Zerbini. “The operators must also inform the CAMO of any scheduled maintenance and unscheduled maintenance carried out without the knowledge and control of the CAMO, report through the logbook all defects found during operations, and transmit to the CAMO a copy of the registered technical logbook every time a flight is completed or as soon as practical.”

The operators must guarantee that no flight is performed if maintenance items to be carried out by an approved maintenance organization in accordance with the approved maintenance program are overdue; if the aircraft is not in airworthy condition and/or the airworthiness review certificate (ARC) is expired; if the documentation requested on board is not present and/or not updated; and if the aircraft is not operated in accordance with the approved flight manual or other approved documentation.

“NCC operators are also required to inform the competent authority whenever the contract with the CAMO is denounced by either the CAMO or the operator and to inform the CAMO and the competent authority whenever the aircraft is sold. Operator responsibilities also include carrying out all occurrence reporting mandated by the applicable regulations and to inform the CAMO on a regular basis about the aircraft flying hours and any other utilization data, as agreed with the CAMO, ideally via IT systems,” said Renga.

Information Exchange

Software technology is playing an increasingly important role in the domain of aircraft continuing airworthiness management. It is becoming established more in general to the interface between the operator and the CAMO but also to communicate the likes of equipment unserviceability. “Continuing airworthiness management should be planned, controlled, and executed on a professional IT system, such as Camp or Amros, because other less sophisticated means do not provide for the same level of accuracy and planning possibilities,” said Renga.

Airworthiness management requires significant closed-loop communication in addition to the software solutions to manage the planning tasks. “Every communication between the CAMO and all the other stakeholders requires a feedback to complete a task either via email or other established means of communication. Closed-loop communication is a defining trait of a professional CAMO, as it sets the ground for accuracy and the professional management of the aircraft,” said Renga.

After an initial meeting, which is perhaps more useful to conduct in person to know each other and understand what the expectations of both parties are, the two fundamental controlled communication systems are via email for all that must have traceability and by telephone when it comes to information that must be exchanged on an urgent basis. “Communication software that is readily available in the consumer market—such as messaging, emails, and WhatsApp—are all suitable. Usually if one does not work, another one does. The problem arises in those areas of the world where there is not the availability of an internet connection. For example, some operators in Africa may not be able to send copies of the technical logbook page. In such cases, what you have to do is postpone or make a phone call,” said Zerbini. “Obviously when it comes to something that needs to be traced, such as an item of a minimum equipment list that has been opened remotely by a commander, the call must immediately or as soon as possible be followed by something written, even in an email format which is commonly accepted everywhere.”