Lessons learnt from the introduction of CAMOs › docs › default-source › events › 13... · Lessons learnt from the introduction of CAMOs in FR 19 CAMO obligations A Part-145

Lessons learnt from the

introduction of CAMOs

MAWA Conference 2014

ICETA Richard DURIEZ

Initial airworthiness advisor

Sep 2014 Lessons learnt from the introduction

of CAMOs in FR 2

Overview

• Airworthiness stakeholders within the FR organisation

• FR airworthiness regulation

• Regulation applicable to CAMOs

• State organisations structure

• CAMO approval

• CAMO tasks

• Maintenance documents

• MOs oversight by CAMOs

• CAMO obligations

• Transitional provisions

• CoA issuance and validity / ARC extension and ARC renewal

• Specific issues relating to continuing airworthiness management

• Guidebooks

• Conclusion


of CAMOs in FR 3

Airworthiness stakeholders

DSAÉ

Minister of Defence Minister of the Interior Minister of Budget

Support

DGA SGA

Functional

Regulation Oversight

Coordination in the airworthiness domain

CHOD

Defence Staff

Defence Staff responsibility DGA

MoB MoI MoD

Aviation Operating Authorities

DGA Flight Testing

Regulation

Oversight

DGA Technical Authority

State Aviation Safety Authority

Villacoublay Air Base 107


of CAMOs in FR 4

DSAÉ pillars & missions

CONTINUING

AIRWORTHINESS

MISSIONS:

•REGULATION

•OVERSIGHT

ATM/ASM

AIRPORTS

CNS

MISSIONS:

• REGULATION

• AIRSPACE

MANAGEMENT

• OVERSIGHT

AIRCREW

TRAINING

&

OPERATIONS

MISSIONS:

• REGULATION

WATCH &

HARMONIZATION

7 AVIATION OPERATING AUTHORITIES (AOAs)

INITIAL

CERTIFICATION

& CONTINUED

AIRWORTHINESS

MISSIONS:

•REGULATION

•OVERSIGHT

Technical Authority

DGA Flight Testing


of CAMOs in FR 5

French airworthiness regulation structure

Decree 2013-367 (superseding the decree 2006-1551)

Order

« Duties »

Order

« Conditions »

Order

« Registration »

Order

« Continuing airworthiness »

Order

« RPAS »

Interdepartmental level

Authorities level

Instruction

« Initial airworthiness »

Instruction

« Continuing airworthiness »

- Essential airworthiness requirements

- Regulations considered as acceptable

means of compliance

- FRA 21

- FRA Forms

- FRA M - EMAR(FR) M (provision)

- FRA 145 - EMAR(FR) 145

- FRA 147 - EMAR(FR) 147

- FRA 66 - EMAR(FR) 66 (provision)

- FRA Forms - EMAR Forms

AMC & GM for all FRA

Mementos and procedures

Internal documents

documents : - applicable to State organisations and personnel

- applicable to industry through contracts

DGA Technical Authority DSAÉ State Aviation Safety Authority

Instruction

« Report of

technical occurrences »

Instruction

« Civil ADs and TCH

technical directives »

Instruction

« Stores and equipment

excluded from continuing

airworthiness »


of CAMOs in FR 6

Regulation applicable to CAMOs

• Art. 4 of Order « Continuing airworthiness »:

• An organisation approved according to the conditions of the present order is under the responsibility of an Accountable Manager (AM) appointed by the Aviation Operating Authority (AOA) or the organisation.

• A single person can be appointed AM of several approved organisations (e.g. CAMO, MO, MTO)

• The AM makes sure that the activities can be funded and that they are carried out in compliance with the applicable rules for continuing airworthiness. For each organisation, he shall appoint one or several Post Holders (PH), responsible for managing and supervising the activities of the organisation.

• FRA M.A.706 : the AM has corporate authority for ensuring that all continuing airworthiness management activities can be financed and carried out in accordance with this Part

The AM shall have the appropriate levers for human and financial resources


of CAMOs in FR 7


• The Aviation Operating Authorities (i.e. Chiefs of Staff & directors) designate the CAMOs for the aircraft they operate.

As such, the AOA designates an Accountable Manager (AM):

• Generally within the AOA

or, provided maintenance is fully carried out by an industrial MO, within industry by outsourcing the CAMO, e.g.:

• CATS for:

• Xingu (FAF & FN),

• Cap 10 (FN),

• Epsilon & D140 (FAF)

• Airbus Helicopters for:

• EC225 (FN)



of CAMOs in FR 8

• M.A.712 Quality system

• (a) To ensure that the approved CAMO continues to meet the requirements of this Subpart, it shall establish a quality system and designate a Quality Manager (QM) to monitor compliance with, and the adequacy of, procedures required to ensure airworthy aircraft. Compliance monitoring shall include a feedback system to the AM to ensure corrective action as necessary.

Quality means:

• procedures listed in the CAME to enforce the airworthiness regulation

• independent monitoring to guarantee the enforcement of the procedures to the AM

• identifying deviations through internal audits

• airworthiness regulation watch

≠ ISO 9001 quality system


• Where a Post Holder (PH) carries out the management and supervision of activities relating to both continuing airworthiness (CAMO) and aircraft maintenance (MO), he shall guarantee the functional separation between these activities.



of CAMOs in FR 9

Aviation Operating Authority CoS & directors

FRA 147

approved MTO

FRA M

approved CAMO

FRA 145

approved MO

AM AM AM

PH

QM

PH

QM

PH

QM

State organisations structure

Production

Quality monitoring

Production Production

Quality monitoring Quality monitoring

• Organisation adopted within FR State aviation • One MTO, one CAMO, one MO per AOA

ARS

Airworthiness Review Staff

Designate


of CAMOs in FR 10

Aviation Operating Authority CoS & directors

FRA 147

approved MTO

FRA M

approved CAMO

FRA 145

approved MO

AM AM

PH

QM

PH

QM


Production

Quality monitoring

Production

Quality monitoring

• Case of a single AM responsible of a CAMO and an MO Functional separation between Continuing Airworthiness Management

and Maintenance shall be guaranteed

ARS

Airworthiness Review Staff

Designate

Continuing Airworthiness

Management Responsible Maintenance Responsible


of CAMOs in FR 11

• In order for the AM to have the appropriate levers for human and financial resources, the AM is at the CoS or director level

• His PH and his QM are at the same level

• The CAMO AM is responsible for all the fleets and all the bases

• In order for the CAMO AM, PH and QM to properly carry out the continuing airworthiness management, delegated AM, PH and QM can be designated on each base for each fleet

• CAME : common provisions applicable to the head office and the fleets + one chapter or annex per fleet to address their specificities and differentiate the local chains of responsibilities

• Thanks to the transitional provisions of the FR airworthiness regulation, the Continuing Airworthiness Management Exposition (CAME) can be drafted in an incremental way

• starting with the head office and one fleet on one base,

• then adding other fleets and other bases

• in a timely manner to meet the calendar objective set in the regulation for a controlled environment.

Smooth implementation within the AOAs



of CAMOs in FR 12

CAMO approval

The AM shall be fully aware of his responsibilities and shall carry out his duties accordingly:

Importance of the meeting with the AM carried out by the Airworthiness Director

• M.A.715 Continued validity of approval

• (a) An approval shall be issued for an unlimited duration. It shall remain valid subject to compliance with FRA M and continuing oversight by DSAÉ

• Principle adopted by DSAÉ to issue initial approval:

• Incremental approval process by perimeter

• Perimeter = one fleet on one air base

• Each perimeter shall be audited

• Initial organisation approval of head office (Staff or directorate level) + one perimeter

• Then gradual extensions to other perimeters Exhaustive audits

Optimization of DSAÉ auditors workload


of CAMOs in FR 13

CAMO approval

Challenges:

• Continuing oversight:

• M.B.704 (b) Each organisation shall be completely audited at periods not exceeding 24 months

• Partial audit every 6 months

To adapt its workload, DSAÉ took late 2013 the following decision :

• First audit : fundamental requirements

• Following audits : secondary requirements + sample audit of fundamental requirements

• Meeting with the AM every 2 years

• Number of on-site audits (initial audits and continuing oversight)

Decrease the audit duration

• Initial audit : from an average 36 days to 24 in 2014

• Continuing oversight : from an average 25 days/year to 20 in 2018

• All MOs working for a CAMO should in theory be FRA 145 approved before the CAMO is FRA M approved

Transitional provisions : pending their FRA 145 approval, MOs are authorized to issue release to service documents, provided they are signed by a Maintenance Staff whose competences are recognized by DSAÉ pending their FRA 66 licence

CAMO

DSAÉ head office Findings

management

Rejection Form

12

Mandate

Audit responsible

CAMO Approval process

Application

Form 2

Application

form

Form 4

Details of

management

personnel

CAME

Acceptability

Form

10b

Report

Documented review

Form

10a

notification

Confirmation

of audit date

Form

10b

Report

On site audit

Management of

Level 1 findings

Management of

Level 2 findings

Form

12

Continuing

oversight

mandate

Continuing

oversight

2-year cycle

Approval

continuation

Approval

suspended


of CAMOs in FR 14


of CAMOs in FR 15

CAMO tasks


• For the aircraft under their responsibility, the CAMOs:

1. define the aircraft maintenance programmes

2. have the Airworthiness Directives (ADs) implemented

3. initiate the work orders

As such, they establish the maintenance work orders from the applicable Instructions for Continuing Airworthiness (ICAs) and notify them to the Maintenance Organisations (MOs);

4. make sure of the proper execution of the work ordered and their record tracking

5. develop a Continuing Airworthiness Management Exposition (CAME)

which describes all the procedures relating to continuing airworthiness management used by the CAMO and, if appropriate, list the contracts or the protocols between this organisation and:

• the organisations subcontracted for continuing airworthiness management tasks

• the Maintenance Organisations (MOs)


of CAMOs in FR 16

Maintenance documents

• Aircraft maintenance programme

• The Type Certificate Holder defines a Recommended Maintenance Programme

• approved by the Technical Authority ( )

• On this basis, the CAMO defines an Maintenance Programme, tailored to the actual flight activity, which is

• validated by the Aviation Operating Authority (AOA) and

• approved by the State Aviation Safety Authority ( )

It is then called Approved Maintenance Programme

The applicable Approved Maintenance Programme is mandatory to obtain a FRA M approval extension on a perimeter relating to a fleet

• Applicable instructions for continuing airworthiness (ICAs)

Sometimes difficult to identify

A WG was set up between DGA, DSAÉ and CAMOs to define:

• what the applicable ICAs are actually

• who approves the ICAs (DGA, TCH…) from case to case

DSAÉ issued a guide for the approval of ICAs


of CAMOs in FR 17

MOs’ oversight by the CAMO


• The CAMOs monitor the organisations, which carry out the maintenance of aircraft and aircraft elements.

• This monitoring shall be carried out in accordance with the terms and conditions of the expositions established by the CAMOs and accepted by the State Aviation Safety Authority ( )

Even though DSAÉ carries out the oversight of all approved MOs, each CAMO shall monitor the MOs working for it

• CAMO monitoring of the MOs :

• Formalized selection process of industrial MOs

Visibility on subcontractors

• Quality assurance audits of its MOs

Through GQA (Government Quality Assurance) process in case of industrial MOs under MoD contract


of CAMOs in FR 18

CAMO obligations


• The CAMOs make sure the following obligations are met:

1. the aircraft is maintained in accordance with the applicable maintenance data and in particular with the approved aircraft maintenance programme;

2. all aircraft items are correctly installed and serviceable or clearly identified as unserviceable;

3. the aircraft has an acceptance document;

4. all the documents stating the airworthiness of the aircraft are recorded in accordance with the terms and conditions specified in the CAME and accepted by the State Aviation Safety Authority ( ).

The CAMO should have an efficient and updated information system for record keeping, accessible any time

If not, high workload and difficulty or impossibility to get the approval


of CAMOs in FR 19

CAMO obligations

A Part-145 release only certifies that the maintenance actions described in the release have been carried out in accordance with Part-145.

• e.g. Form 1 Block 14a. Certification Statement

• Certifies that unless otherwise specified in Block 12, the work identified in Block 11 and described in Block 12, was accomplished in accordance with EMAR 145 and in respect to that work the items are considered ready for release to service.

However it does not certify that the component is in an airworthy condition since it does not attest whether the component was initially produced to the required production standards or which was the standard of the maintenance performed in the past.

It is the responsibility of the CAMO to collect all the information related to the airworthiness status of the component (e.g. implementation of applicable ADs)

in order to make sure it is eligible for installation


of CAMOs in FR 20

Transitional provisions


• The CAMOs, which carry out services in the airworthiness environment at the date of entry into force of the present order, have

• until 31 December 2014 ( to be extended to 31 December 2015)

• or at the latest at the end of the contracts binding them to the State and notified before the entry into force of the present order (case of outsourced CAMOs)

• to comply with the all set of provisions relating to continuing airworthiness.


• The CAMOs have until 31 December 2016 to have the maintenance programmes, approved by the AOAs at the date of entry into force of the present order, comply with the recommended maintenance programmes approved by the Technical Authority ( ) and to submit their approval to the State Aviation Safety Authority ( )

Transitional provisions are essential for the smooth implementation of an airworthiness regulation


of CAMOs in FR 21

CoA : Issuance (FRA 21 subpart H)

and validity (FRA M subparts G and I)

CoA

T0 T0 + 1 yr T0 + 2 yr T0 + 3 yr T0 + 4 yr

ARC n°1 1st extension

of ARC n°1

2nd extension

of ARC n°1

Renewal

ARC n°2

CAMO Request

for AR

Recommendation

for AR

Recommendation

for AR

Request

for AR

CNMAA

(DSAÉ)

- carry out the AR

- issues the ARC

Extend

the ARC(1)

Extend

the ARC(1)

carry out the AR,

issues the ARC(2)

CAMO

CNMAA

(DSAÉ)

issues the CoA

& the CoR

(1) FRA M subpart G approved CAMO with privilege to carry out the AR and extend the ARC

(2) FRA M subpart G + I approved CAMO with privilege to carry out the AR and issue the ARC

3 year cycle

The CAMO shall maintain the

applicable aircraft configuration in compliance with

the approved type definition


of CAMOs in FR 22

ARC extension and ARC renewal

• FRA M subpart G privilege :

• The approved CAMO has the privilege to carry out the AR and extend the ARC

Transitional provisions : pending the first CAMO approvals, the first ARC issued by DSAÉ had a maximum 3-year validity

• FRA M subpart G + I privilege

• The approved CAMO has the privilege to carry out the AR and issue the ARC

• Currently no CAMO has the G + I privilege

• Some AOAs are considering this privilege, some are not interested

G + I privilege means less Airworthiness Reviews for DSAÉ, but also means that the CAMO Airworthiness Review Staff

shall be evaluated by DSAÉ


of CAMOs in FR 23

Specific issues relating to

continuing airworthiness management

• Operational deployment :

Continuing airworthiness management shall be carried out,

but there could be cases where the conditions for the CoA validity are no longer met

• In that case, the AOA may issue a Permit to Fly as per Art. 51 of Order conditions

1. to allow flights in order to restore the validity of a suspended CoA;

2. to allow ferry flights of aircraft for which the conditions of the CoA are not met any longer;

3. to allow any other flight, upon assent:

• of the Technical Authority ( ) for any deviation from the conditions of the Type Certificate;

• of the State Aviation Safety Authority ( ) for any deviation from the continuing airworthiness regulation.

DSAÉ issued a guide “PtFs issued by AOAs”


of CAMOs in FR 24

Specific issues relating to

continuing airworthiness management

• ARC validity expires during aircraft maintenance:

• ARC extension by the CAMO is possible

• ARC renewal by DSAÉ to be carried out after check flight under PtF

• Aircraft transfer to DGA Flight Testing:

• No CAMO transfer except for long-term lending, even if maintenance is carried out by DGA Flight Testing FRA 145 approved MO

• MRO contracts:

• to support CAMO work orders to industrial MOs

• placed by:

• DGA as Procurement Agency for initial MRO together with aircraft procurement

• SIMMAD (Joint Structure for the MRO of Aeronautical Products) for the next MRO contracts

Complex structure where a CAMO is split between an AOA and SIMMAD


of CAMOs in FR 25

Guidebooks

• DSAÉ issued the following Guidebooks:

• Organisation Approval application

• Drafting the CAME (Continuing Airworthiness

Management Exposition)

• Accountable Manager interview

• Approved Maintenance Programme

• Airworthiness Review

• CAMO Airworthiness Review Staff

• Applicable instructions for continuing airworthiness (ICAs)

• Aircraft registration

• PtFs issued by AOAs


of CAMOs in FR 26

Conclusion

• Implementation of the airworthiness regulation

• Airworthiness regulation issued in Dec 2006

• FRA M issued in Jun 2010

• DSAÉ put in place in Sep 2010 but officially created in Apr 2013

• 4 FRA M approvals issued so far (FAF, FN, FAA, Customs)

• Perimeter achieved so far by these CAMOs: 20 to 100%

• Transitional provisions for CAMOs until Dec 2015

Importance of transitional provisions with an adequate duration

• CAMO

• Place of the CAMO within the operator’s structure

• The AM shall have appropriate levers for human and financial resources

The AM shall be fully aware of his responsibilities and shall carry out his duties accordingly

• MRO contracts to support work orders for MOs

To be carefully considered

• Approved maintenance documentation

• The CAMO shall maintain the applicable aircraft configuration in compliance with the approved type definition

• Efficient information system for record keeping

27

Thank you for your attention! Any questions? Sep 2014

Lessons learnt from the introduction of CAMOs in FR

Documents

Lessons learnt from the introduction of CAMOs › docs › default-source › events › 13... · Lessons learnt from the introduction of CAMOs in FR 19 CAMO obligations A Part-145