New CAW regulatory framework What changes for us? - Your safety is our mission - Enac
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New CAW regulatory framework
What changes for us?
ENAC workshop 13 Nov 2019
Eugenia Diaz Alcazar
Airworthiness Standards & Implementation Section Manager
Your safety is our mission.
An Agency of the European UnionContent
→ General overview of recent changes to CAW regulation
→ 1st part – Changes due to SMS
→ Part-CAMO
→ Introduction of SMS in Part-145
→ 2nd part – Other changes
→ General Aviation
→ Maintenance Check lights and Mixed Operation
2Reg (EU) 1321/2014
Reg (EU) 2019/1383
→ GA Task Force Phase II (Opinion 05/2016)
→ Part-ML
→ Part-CAO (without SMS)
→ SMS Phase I (Opinion 06/2016)
→ Part-CAMO (with SMS)
→ Part-M
→ Technical Records (Opinion 13/2016)
Reg (EU) 2019/1384
→ Mixed Operations & Maintenance Check Flights
3Reg (EU) 1321/2014 – new structure
Background and general overview
→ Opinions voted 28 Feb 2019
→ Regulation (EU) 2019/1383
→ Adopted: 8 Jul 2019
→ Published in OJ: 4 Sep 2019
→ Entry into force: 24 Sep 2019
→ Applicable from: 24 Marc 2020 (cf. corrigendum)
→ Also Part-M/-145/-66/-147/-T affected
→ Transition period
4Reg (EU) 1321/2014 – new structure
5Part-CAMO (1/13)
Why SMS?
→Air Operators are required to implement a Management
System including safety management processes (Reg.
(EU) 965/2012)
→Licenced air carrier operators are required to be
approved as CAMO (Reg. (EU) 1321/2014)
→+ ICAO Annex 19 compliance
Management System required for CAMO
6Part-CAMO (2/13) General approach
→New Annex Vc – Part-CAMO
→New structure, new numbering based on ARX/ORX (Air
Operation and Air Crew Regulations) with content
adapted to CAMO
→Introduction of a «Management system», including SMS
and Compliance Monitoring (references to ‘quality
system’ are deleted)
→Keep Section A and Section B
Part-M Subpart G approvals no longer valid from 24 Sep 21
7Part-CAMO (3/13)
General approach
→CAMO required for continuing airworthiness
management of:
→ Complex motor-powered a/c (twin-turboprop < 5700 kg
MTOM ‘exempted’); and/or
→ Aircraft operated by licenced air carriers;
→May be used for all other a/c (optional)
8Part-CAMO (4/13)
SECTION A – ORGANISATION REQUIREMENTS
→ General requirements
CAMO.A.005 Scope ORX.GEN
to Section 1
CAMO.A.160 Occurrence reporting
→ Management
CAMO.A.200 Management system ORX.GEN
to Section 2
CAMO.A.220 Record keeping
→ CAMO specific requirements CAMO
CAMO.A.300 Continuing airworthiness managementspecific
exposition
to
CAMO.A.325 Continuing airworthiness management data 9Part-CAMO From ‘Quality system’ to ‘Management system’
M.A.712 Quality system CAMO.A.200 Management system
(CAMO.A.202/205)
Main focus: Main focus:
Compliance monitoring Safety risk management
Feedback system Effectiveness of mitigating actions
Compliance monitoring
In case of licensed air carriers In case of licensed air carriers the
the quality system shall be an management system shall be an
integral part of the operator’s integral part of the operator’s
quality system management system
Organisational review for small No organisational review – Compliance
CAMOs managing a/c not used Monitoring function required in all
by licenced air carrier cases
10Part-CAMO (6/13)
→ CAMO.A.200 focuses on what is essential for safety management,
by mandating the organisation to:
→ responsibilities
→ safety policy
→ safety reporting procedures (just culture principles)
→ identification of safety hazards and the management of associated risks
including actions to mitigate those risks and effectiveness of those actions
→ monitor compliance
→ competent personnel informed about significant safety issues
→ document
11Part-CAMO (7/13)
→SMS is simple for simple organisation/activity
→An effective SMS can be demonstrated by answering
4 simple questions:
1. What is most likely to be the cause of your next occurrence with the
potential to lead to an accident or serious incident?
2. How do you know that?
3. What are you doing about it?
4. Is it working?
12Part-CAMO (8/13)
CAMO oversight cycle by Competent Authority
→Harmonised oversight among the aviation domains and
risk based oversight approach
→Credit may be taken from the Management system
Effective risk management “Effective continuous reporting system to
Change management competent authority on safety performance and
Corrective actions implemented regulatory compliance”
24 months 36 months 48 months
Level 1 Reduced safety
finding performance 13Part-CAMO (9/13) AMC/GM
→ Unlike for aircrew and air operations, no distinction will be made
between complex and non-complex organisations
→ Flexibility and proportionality will be provided (e.g. for small
organisation) in a single set of AMC
→ Example: Establishment of a safety review board (SRB) except where not
justified by the size of the organisation and the nature and complexity of its
activities
→ References to ‘EASA Form 4’ to be deleted for all management
personnel. Acceptance process through oversight and exposition
approval
14Part-CAMO (10/13) Also new in Part-CAMO →Occurrence reporting iaw Reg. (EU) 376/2014 →Internal safety reporting scheme to enable the collection and evaluation of all occurrences, errors, hazards etc. →New Part-CAMO applicants shall perform a pre-audit →Possibility for the organisation to develop ‘Alternative Means of Compliance’ (AltMoC to the EASA AMC) →Concept of ‘Change not requiring prior approval’ replacing ‘Indirect approval’ (same intent) →System to plan the availability of staff 15
Part-CAMO (11/13) Transition
→Organisations holding Part-M Subpart G approval will be
deemed to have been approved in accordance with Part-
CAMO
→They will be given 2 years to adapt their procedures and
exposition to be compliant with Part-CAMO
→They will then receive a new EASA Form 14 (issue 5)
CAMO approval Certificate
→Until the organisation complies with Part-CAMO,
oversight in accordance with Subpart G of Part-M
16Part-CAMO (12/13) Transition
24 Sep 2019 24 March 2020 24 Sep 2021
Deemed to be approved by Part-CAMO (no NEW Subpart G certificate
certificate) revoked if transition
findings not closed !
Subpart G Subpart G Deemed Part-CAMO Compliant Part-CAMO
Surveillance iaw Part-
Surveillance i.a.w. Part-M Subpart G
CAMO
Closure “transition finding”
Issuance CAMO
CAME certificate
approved
17Part-CAMO
24 Sep 2019
(13/13)
24 March 2020 24 Sep 2021
Request Part-CAMO certificate
CAMO revoked if
not in compliance
Issuance new CAMO with Part-CAMO!
Subpart G Subpart G certificate
Surveillance i.a.w. Supart G Surveillance i.a.w. Part-CAMO
Closure “transition finding” Part-CAMO
Transition - Possible amendment to regulation! 18Part-145 with SMS (1/9)
→ Working method RMT.0251(b)
→ Content harmonised with Part-CAMO and
Part-ARX/ORX (Air Operation and Air Crew Regulations)
→ Introduction of a « Management system »
→ Aligned with Part-CAMO
→ includes Safety management and Compliance Monitoring (references to ‘quality system’ are
deleted)
→ for all Part-145 organisations
→ Streamlined approach to Part-145 amendments:
→ Section A (organisation requirements): any existing/amended paragraph keeps
the current numbering; any ‘new’ paragraph takes the Part-CAMO numbering
→ Section B (authority requirements): alignment with Part-CAMO
19Part-145 with SMS (2/9) – NPA 2019-05(C)
20Part-145 with SMS (3/9) – NPA 2019-05(C)
21Part-145 with SMS (4/9) – NPA 2019-05(C)
22Part-145 with SMS (5/9) – NPA 2019-05(C)
23Part-145 with SMS (6/9)
→ 145.A.200 focuses on what is essential for safety management, by mandating
the organisation to:
→ clearly define responsibilities and accountabilities
→ establish a safety policy and related safety objectives
→ implement safety reporting procedures in line with just culture principles
→ ensure the identification of aviation safety hazards entailed by its activities, ensure their
evaluation, and the management of associated risks including:
→ taking actions to mitigate the risks;
→ verifying the effectiveness of actions taken to mitigate risks;
→ monitor compliance, while considering any additional requirements that are applicable
to the organisation
→ maintain personnel trained, competent, and informed about significant safety issues
→ document all management system key processes.
24Part-145 with SMS (7/9)
AMC/GM
→ Unlike for aircrew and air operations no distinction between complex
and non-complex organisations
→ Flexibility and proportionality will be provided (e.g. for small organisation)
in a single set of AMC (same approach as CAMO)
→ Example: Establishment of a safety review board (SRB) except where not
justified by the size of the organisation and the nature and complexity of its
activities
→ References to personnel ‘human factor training’ replaced by ‘safety
training’
→ Management of change, continuous improvement, internal
investigation
25Part-145 with SMS (8/9)
Other changes not SMS related
→ References to Reg. (EC) No 216/2008 changed to Reg. (EU) 2018/1139
(New Basic Regulation)
→ Concept of ‘change not requiring prior approval’ replacing ‘indirect
approval’ (same intent) see 145.A.85
→ References to Flight Engineer (FE) licences deleted, as these are no
longer foreseen in EASA Part-FCL. Existing authorisations to be
‘grandfathered’
→ Pre-audit required for new Part-145 applicants
→ References to EASA Form 4 in AMC deleted for all management
positions (same approach as CAMO). Acceptance process through oversight
and exposition approval
26Part-145 with SMS (9/9)
Transition
→ Under discussion - Part-145 organisations may be given 2
years to adapt their procedures and exposition
→ With the management system requirement
→ With the other changes to Part-145
Conclusion
→ This proposal addresses the core elements of the ICAO
Annex 19 and promotes an integrated approach to the
management of an organisation
27Reg (EU) 1321/2014 – new structure
28Part-ML (1/19)
What is « Part-M light » (Part-ML)?
→ Part-ML objectives:
→ proportional to lower complexity and associated risks,
→ as clear and simple as possible.
Part-ML similar in its structure to Part-M
→ How? Alleviations in AMP, Airworthiness Review, defect
deferment by pilot …
29Part-ML (2/19)
→ Applicability to non-complex:
→ Aeroplanes up to 2 730 Kg MTOM
→ Helicopters up to 1 200 kg MTOM / max 4 occupants
→ Other ELA 2 aircraft
When they are not used by Licenced Air Carrier (LAC)
→ Part-ML is the only option for this category of aircraft.
→ All other aircraft must follow Part-M
Part-ML covers both private and commercial (non-LAC),
in particular all sailplanes and balloons
30Part-ML (3/19)
Continuing Airworthiness Management
* CAMO or CAO(-CAM) may be optionally contracted by the owner
31Part-ML (4/19)
Continuing Airworthiness Management
* CAMO or CAO(-CAM) may be optionally contracted by the owner
32Part-ML (5/19)
Continuing Airworthiness Management
Case of ATO/DTO
* CAMO or CAO(-CAM) may be optionally contracted by the owner
33Part-ML (6/19)
Continuing Airworthiness Management
When a CAMO or CAO(-CAM) is not contracted, the owner
shall manage the continuing airworthiness of the aircraft
under its own responsibility.
When the aircraft is leased, the responsibility is
transferred to the lessee.
34Part-ML (7/19)
Aircraft Maintenance Programme (AMP) New!
→ Not possible to have the AMP approved by NAA
→ For aircraft managed by a CAMO or CAO:
→ The CAMO or CAO approves the AMP with justifications to any
deviations from Design Approval Holder (DAH) data
→ For aircraft not managed by a CAMO or CAO:
→ The AMP is declared by the owner (no justification for
deviations needed)
Remark: the NAA may still require a copy of the AMP
35Part-ML (8/19)
AMP and MIP
→ Possibility to use the Minimum Inspection Programme (MIP) as an
alternative to the DAH data
→ Possibility to deviate from DAH data, but the deviating task
cannot be less than the extent of the corresponding MIP task in
terms of frequency and task type
Remark: no MIP for airships and rotorcraft to date
36Part-ML AMP and MIP examples in GM
ICA task AMP proposed MIP task Alternative
alternative acceptable
Inspection XX Inspection XX Inspection XX YES
6 months 12 months interval 12 months
interval interval
Inspection XX Inspection XX Inspection XX NO
12 months 24 months interval 12 months
interval interval
Functional test Operational test Functional test NO (functional
system XX system XX (same system XX test considered
interval) or general (same interval) more restrictive
visual inspection than operational
system XX (same test)
37
interval)Part-ML (10/19)
AMP review
→AMP shall be reviewed annually:
→ in conjunction with the Airworthiness Review (AR), by the person
performing the AR; or
→ by the CAMO or CAO(-CAM) (e.g. in case of ARC extension)
→In case of deficiency found, the AMP shall be amended
In case of deficiency, the Competent Authority shall be
informed by the person performing the review only if
he/she does not agree with the AMP corrections
38Part-ML (11/19)
Acceptable Means of Compliance for AMP
→Improved template for the AMP
→Guidance on TBO extensions
→Minimum Inspection Programme (MIP) compliant with
ML.A.302(d) for aeroplanes, sailplanes and balloons
The AMP template will be an “EASA Form AMP”
39Part-ML (12/19) AMP
→ New! no AMP declaration/approval and no AMP document
required when:
→The manufacturer data and all recommendations are
used
→No additional tasks resulting from repairs, modifications,
life-limited components, repetitive ADs, etc.
→Pilot-owner authorised for pilot-owner maintenance
Note: the AMP will consist of relevant ICA, ALS, AD,
service letters, operational requirements…
Applicable also when CAMO or CAO(-CAM) is contracted 40Part-ML (13/19) Aircraft defects
→New! Possibility for the pilot to defer:
→ defects affecting ‘non-required equipment’
→ defects affecting ‘required equipment’:
→without the intervention of certifying staff
→without using the MEL
→when agreed with aircraft owner or contracted CAMO or CAO
only for aircraft (other than balloon/sailplane) operated under Part-NCO
only for balloon not operated under Subpart-ADD of Part-BOP
only for sailplane not operated under Subpart-DEC of Part-SAO
41Part-ML (14/19) Component maintenance
→ Clarified/extended alleviation to release comp. maintenance
with aircraft CRS (without EASA Form 1)
iaw component maintenance data (e.g. CMM)
→ for:
→Component maintenance other than overhaul
→Overhaul of engine/propellers for CS-VLA, CS-22 and LSA
iaw aircraft maintenance data (e.g. AMM)
→ for:
→All component and all types of maintenance
42Part-ML (15/19) Pilot-owner maintenance
only for aircraft (other than balloon/sailplane) operated under Part-NCO
only for balloon not operated under Subpart-ADD of Part-BOP
only for sailplane not operated under Subpart-DEC of Part-SAO
→Appendix II (replacing Appendix VIII) for tasks excluded
→Possibility for the pilot-owner to release 100h/annual
inspection task(s) when
→ the 100h/annual inspection is not combined with the
Airworthiness Review
→ the task is not critical, complex, AD-related… 43Part-ML Airworthiness Review (AR) and ARC
→Only EASA Form 15c applicable to Part-ML (by
competent authority, organisation or independent CS)
→The Competent Authority may still perform the AR and
issue the ARC
→The AR shall include a review of the AMP by the person
performing the AR (extension: AMP reviewed by
organisations)
New! No more ARC recommendation to the Competent Authority
44Part-ML (17/19) AR and ARC (cont’d)
→Possibility for maintenance organisations to perform AR
and issue the ARC together with the 100h/annual
inspection (before only possible for ELA1)
→New! Possibility for independent certifying staff to
perform AR and issue the ARC together with the
100h/annual inspection
only for aircraft (other than balloon/sailplane) operated under Part-NCO
only for balloon not operated under Subpart-ADD of Part-BOP
only for sailplane not operated under Subpart-DEC of Part-SAO
45Part-ML (18/19)
ARC extension
→CAMO or CAO(-CAM) can extend max. 2 times the ARC
if:
→ The aircraft has been managed by that CAMO or CAO during
the last 12 months
→ Aircraft has been maintained during the last 12 months by:
→Approved maintenance organisation; and/or
→Pilot-owner iaw ML.A.803; and/or
→Independent certifying staff carrying out pilot-owner maintenance tasks
46Part-ML (19/19)
Part-ML -> Part-M
→If an aircraft moves from Part-ML to Part-M (e.g.
because it changes to LAC operations):
→ The AMP must be approved by the NAA
→ Additional maintenance may be required to comply with the
new AMP
→ An airworthiness review is performed and a new ARC is issued
47Part-CAO (1/12)
→ Combined Airworthiness Organisation
→ New simplified organisation approval for GA
→ Alleviated requirements
→ Reduced involvement of Competent Authority
→ Combined privileges for:
→ Maintenance
→ Continuing airworthiness management
→ Airworthiness review
→ Permit to fly
48Part-CAO (2/12)
49Part-CAO (3/12)
→ Part-CAO applicable to :
→ Non-complex motor-powered aircraft
→ When they are not operated by licenced air carriers
This covers Part-ML a/c and certain Part-M a/c
→ No SMS requirement (keeping ‘Quality System’)
→ Possibility to apply for a Part-CAO approval with partial privileges
→ Single exposition for all activities (CAE)
Part-M Subpart F approvals no longer valid 2 years after entry into force
50Part-CAO (4/12)
Simple requirements
→ The approval certificate has been simplified, with no indication of
aircraft types, just aircraft categories and associated privileges
→ No man-hour requirement
→ No requirement to record the recency of certifying staff
→ No minimum age for certifying staff
Small CAO can replace the quality system by regular organisational reviews
(subcontracting of CAM tasks not allowed)
51Part-CAO (5/12)
Simple requirements
→ More privileges for the organisation to introduce changes
→ For activity on light aircraft, NDT and/or component other than
complete turbine engine, the ‘scope of work’ can be changed
in accordance with an approved procedure
→ Changes to location, facilities, tooling, equipment, material can
be managed by the organisation
Reduced involvement of Competent Authority
→ The possibility to work outside approved location is not
limited to line maintenance
52Part-CAO (6/12)
Airworthiness Review and ARC
→More privileges to maintenance organisation for the AR
(before limited to ELA1)
53Part-CAO (7/12)
Permit to Fly
→A CAO with AR/ARC privileges, may be additionally
approved to issue a permit to fly
→ Limited to CAO registered in EU Member State
→ for those particular aircraft for which the CAO can issue the
ARC
Permit to fly is issued by the airworthiness review staff
authorised by the CAO
54Part-CAO (8/12)
Transition
→ CAMO, Part-145 or Subpart F Organisations will be issued a Part-
CAO approval upon application
→ Current scope of work will be maintained by introducing
limitations in CAO approval
→ Until 24 Sep 2021 to adapt the procedures and manuals to be
compliant with Part-CAO
→ Limitations can be removed (if desired) only after complying with
the corresponding elements and including the corresponding
procedures in the CAE
55Part-CAO (9/12)
Transition (cont’d)
→ “Controlled environment” is not affected by the transition period
→ The organisation can benefit from the new Part-CAO
alleviations/privileges only when the CAE is approved
→ Part-CAO approval will generate a new organisation Approval
reference (update of EASA Form 1 and ARC)
→ Else, organisations use CAME/MOE/MOM until CAE is approved
After CAE approval, maintenance organisations need CAM
privilege to continue developing AMP
56Part-CAO (10/12)
24 Sep 2019 24 March 2020 24 Sep 2021
Request CAO
CAO revoked if
Issuance CAO transition findings
not closed !
Part-145 org. Part-145 org.
Surveillance i.a.w. Part-145 (existing scope of work)
CAO approval (same privileges)
Closure “transition finding” Part-CAO Surveillance i.a.w. Part-CAO
CAE
approved
Example: Transition from Part-145 to Part-CAO 57Part-CAO (11/12)
24 Sep 2019 24 March 2020 24 Sep 2021
Request CAO
CAO revoked if
Issuance CAO transition findings
not closed !
Part-145 org. Part-145 org.
Surveillance i.a.w. Part-145 Surveillance i.a.w. Part-CAO
Closure “transition finding” Part-CAO
Possible amendment to regulation!
58Part-CAO (12/12)
→Part-CAO not just created to replace Subpart F, but to
offer a new type of organisation, adapted to GA, which
can address all the needs of this community in the
domain of continuing airworthiness
→Part-CAO was developed with GA associations for
GA community
→EASA recommend all CAMO, Subpart F and Part-145
organisation involved in GA to transition to CAO as soon
as the regulation allows
59Part-M (1/4)
→ Essentially amended to accommodate for the introduction of
Part-ML, Part-CAO, Part-CAMO and BR reference:
→ Remove most GA alleviations
→ Certain requirement applicable to Part-CAO
→ Part-M subparts F and G: may still be used for 2 years; then
approvals no longer valid
→ Opinion 13/2016 Technical Records (RMT.0276)
→ ‘Commercial DTO’ specifically mentioned
60Part-M (2/4)
→ Embodiment policy in M.A.301 is moved to Part-CAMO
[CAMO.A.315(b)(4)]
→ Mass and Balance statement added in M.A.301
→ Possibility to amend aircraft technical log system by exposition
amendment procedure
→ Clarification that the ARC cannot be issued until all findings have
been closed
61Part-M (3/4) Transition
→ New structure of M.A.305, clearer on what continuing
airworthiness records are and consistent record keeping period
→ “Service Life Limited Parts” (subject to a certified life limit or to a
service life limit) replaced by “Life Limited Parts” and “Time-
controlled Components”
→ “In-service history records” (used in ICAO) for life limited parts
which partially incorporates the concept of “back to birth”
traceability
This rulemaking task also applies to the amendment of Part-145
62Part-M (4/4) EASA Certificates
→ ARC: EASA Forms 15a and 15b amended
→ EASA Form 15c moved to Part-ML
→ AMO class ratings (Appendix IV) amended because no more ARC
recommendation
→ EASA Form 3-MF (Subpart F approval) amended
References to Basic Regulation (EU) 2018/1139
63Part-145 (1/2)
→ Essentially amended to accommodate for the introduction of
Part-ML and BR
→ Airworthiness Review and ARC
→Reference to Part-ML for the accomplishment method
→Applicable to full scope of Part-ML aircraft (ELA1 today)
→ EASA Form 3-145 amended (issue 4)
→ Amendment privileges
No privileges in developing AMP. AR for Part-ML aircraft
64Part-145 (2/2)
→ Essentially amended to accommodate for the introduction of
Part-ML and BR
→ Airworthiness Review and ARC
→Reference to Part-ML for the accomplishment method
→Applicable to full scope of Part-ML aircraft (ELA1 today)
→ EASA Form 3-145 amended (issue 4)
→ Amendment privileges
No privileges in developing AMP. AR for Part-ML aircraft
65Maintenance check flights (1/4)
“Maintenance check flight” means a flight carried out to provide reassurance of
the aircraft’s performance or to establish the correct functioning of a system or
equipment that cannot be fully established during ground checks:
→ (a) as required by the aircraft maintenance manual (AMM) or any other
maintenance data issued by a design approval holder being responsible for the
continuing airworthiness of the aircraft; or
→ (b) after maintenance, as required by the operator or proposed by the
continuing airworthiness management organisation; or
→ (c) as requested by the maintenance organisation for verification of a
successful defect rectification; or
→ (d) to assist with fault isolation or troubleshooting.
66Maintenance check flights (2/4)
→ A maintenance check flight is a continuing airworthiness tasks (M.A.301)
→ CAMO needs procedures
→ CAMO needs to ensure adequate coordination between operator and maintenance
organisation
→ The CAMO (in consultation with the maintenance organisation) needs to
→ identify the need for a maintenance check flight; and
→ decide if a PtF is required
→ The maintenance organisation may need input/data obtained during the MCF
and/or finish the maintenance after the MCF. A certificate of release the
maintenance is required then.
67Maintenance check flights (3/4)
→ A PtF is only needed when during the flight the airworthiness
requirements cannot be met
→ Other maintenance check flights can be conducted under the CofA, without
PtF, where
→ the need of the maintenance check flight is part of the maintenance instructions
produced by the design approval holder (within aircraft limitations). A release to
service with incomplete maintenance should be issued before the maintenance
check flight;
→ the operator wants to conduct a maintenance check flight for reliability purposes
(e.g. to assess adequate aircraft operation after have undergone complete heavy
maintenance);
→ confirmation (confidence gain) is necessary that maintenance (on ground) has fixed
a system, that could not be verified on ground, despite maintenance instructions
were followed. 68Maintenance check flights (4/4)
Regulatory changes timeline
Rule AMC/GM
Publication Applicability Publication/applicability
Air Ops (EU 965/2012): Part
NCO/SPO 4 Sept 2019/5 Sept
16 Sept 2019 / 17 Sept
(EU 2019/1384 + EU 2019 25 Sept 2019
2019
2019/1387)
+ ((EDD 2019/019/R))
Initial Airworthiness (EU
28 Aug 2019/29 Aug
748/2012): Part-21
03 Jun 2019 23 Mar 2020 2019
(EU 2019/897 +corrigendum)
+ ((EDD 2019/018/R))
Continuing Airworthiness N/A 1Q 2020
(EU 1321/2014): Part M/145
69Mixed Operations (1/4)
The same aircraft is used:
Early morning: by the AOC holder for a CAT flight
Late morning: by an SPO operator* for an aerial photography flight
*: It may be the same AOC holder, which is also a declared SPO
operator.
Noon: by another operator (Owner) for a private flight
(NCC/NCO)
Afternoon: by an ATO for a training flight
Next morning: by the same AOC holder for a CAT flight
70Mixed Operations (2/4)
Following a change of use of the aircraft from CAT
operations to non-commercial operations or to
specialised operations, the responsibility for the
continuing airworthiness of aircraft subject to that change
should be kept at the AOC holder level. Therefore
Annexes I (Part-M) and Vb (Part-ML)
71Mixed Operations (3/4)
→ Enable the use of aircraft included in an AOC by other
operators, non-AOC holders;
→ Identify the aircraft used by other operators in the AOC
holder’s documentation;
→ Require a procedure to identify which operator is responsible
for operational control for each flight outside AOC;
→ Describe how the shift of operational control is communicated
between operators.
72Mixed Operations (4/4)
The other operator’s responsibilities (NCC/NCO or SPO):
→Comply with the applicable requirements;
→Record every flight in the aircraft technical log system;
→Contact the AOC holder for any technical issue of the a/c while under
its operational control;
→Report any occurrence to the AOC holder in due time and before next
CAT flight.
Continuing airworthiness remains with the AOC holder.
73Thank you
easa.europa.eu/connect Your safety is our mission.
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