Qualifications of Airworthiness Review and Extension Staff under Part-CAMO

1. Five years experience in continuing airworthiness

The experience gained should include a broad range of appropriate continuing airworthiness related activities as required in Part-M Subpart C, Part-ML Subpart C and Part-CAMO, point CAMO.A.315, as applicable.

Compliance Monitoring staff may gain experience through carrying out relevant audits & product samples.

For aircraft under Part-ML, experience in continuing airworthiness can be gained full or part-time, either in a professional, or a voluntary capacity.

Acquired an appropriate Licence in compliance with Annex III, Part-66, or an aeronautical degree, or equivalent

2. An appropriate Part 66 licence:

Is a licence in the sub-category applicable to the aircraft under review, that is, Category B1-1, B1-2, B1-3 or B1-4 Licence. For B2 and C Licences where there are no sub-categories, the holder should have endorsed a type rating on an aircraft in the same group, that is, aeroplanes turbine, aeroplanes piston, helicopters turbine or helicopters piston.

For personnel holding Part-66 B2L, B3 and L licences, the following limitations apply:

B2L: Limited to aircraft not listed in Group 1 of the UK Part 66 Type Rating List.
B3: Limited to piston-engine non-pressurised aeroplanes of 2000 kg Maximum Take-off Mass (MTOM) and below.
L: Limited to aircraft within the subcategories listed on the licence.

In the case of a B1 / B2 licence with limitations, the licence must be at least dual trade. For example, a B1 Licence with a limitation on electrical power but includes airframe and engine privileges is acceptable. However, a B1 Licence that only includes engines or airframe or electrical power is not acceptable. Similarly, a B2 licence that only includes Radio or Instruments or Electrical Power or Autopilots, is not acceptable.

In the case of a B2L licence, the licence must cover more than one system rating, for example, Instruments and Autoflight.

In practical terms the following qualifications can be accepted as being equivalent to an aeronautical degree:

An aeronautical engineering apprenticeship, which includes associated formal technical college training equivalent to City & Guilds, HNC, ONC, TEC or BTEC (with a merit or distinction in all applicable modules). If another qualification is proposed, the applicant must be able to demonstrate equivalence. An expired Civil Aviation Authority (CAA) BCAR Section L licence in the appropriate sub-categories is also considered to be acceptable.

3. Formal aeronautical maintenance training

Knowledge of a relevant sample of the type(s) of aircraft gained through a formalised training course, means aircraft types of similar technology, construction and systems within the appropriate subcategory (aeroplanes turbine, aeroplanes piston, helicopters turbine or helicopters piston) and/or aircraft within the same group(s) listed on the organisations Terms of Approval.

For example, Airworthiness Review Staff in an organisation with aircraft of metal construction and aircraft of composite construction within the same sub-category would need to have received training on both aircraft types. If the organisation holds approval for multiple aircraft types of similar construction and systems within the same sub-category, the formal maintenance training should cover at least two types.

4. A position within the organisation with appropriate responsibilities

AMC1 CAMO.A.310(e) provides examples of how independence from the airworthiness management processes may be achieved. With respect to maintenance personnel, this does not mean the person has never been involved in the release to service of that particular aircraft, however, they should not have been involved in the release to service of that aircraft since the last airworthiness review was carried out.

In the absence of formal qualifications, the Civil Aviation Authority (CAA) may accept an additional 5 years’ experience in continuing airworthiness, meaning a total of 10 years’ experience in a combination of maintenance, continuing airworthiness and/or surveillance of such tasks.

The experience should cover a broad range of subjects relating to continuing airworthiness management and not isolated to a single process, such as planning or maintenance programme development.

In addition, 10 years’ experience means a minimum of ten years. If an organisation nominates a person with anything less than ten years of relevant experience, it will be rejected.

As part of the approval process, the Civil Aviation Authority (CAA) must formally accept the person nominated to be an Airworthiness Review Staff. This process will involve performing an airworthiness review under supervision to ensure both the procedure and process meet the requirements of CAMO.A.320. The approved organisation is required to nominate airworthiness review staff by submitting the UK CAA - Details of Nominated Personnel in an Airworthiness Organisation Form (SRG1769) to the CAA with details of relevant qualifications and experience together with a draft Continuing Airworthiness Management Exposition (CAME) amendment. The CAME will be approved when all the relevant requirements have been satisfied.

The airworthiness review performed under supervision does not require the CAA Surveyor to be closely supervising or instructing the nominated person when carrying out the review. It can be based on a review of the process with the person by going over a compliance statement that addresses all the required elements of Part-M, M.A.901 / Part-ML, ML.A.903, as applicable, and sampling accordingly. Wherever possible the CAA Surveyor will need to be present during the aircraft survey element to ensure it is covering all necessary requirements and sampling as and where appropriate.

Once the first airworthiness review staff has been accepted by CAA, the organisation may nominate further personnel for authorisation as airworthiness review staff subject to a procedure being approved in the exposition which allows cross-assessment. In such cases, evidence of an airworthiness review being carried out under the supervision of another airworthiness review staff, together with a suitable record of training should be provided to the CAA together with the UK CAA - Details of Nominated Personnel in an Airworthiness Organisation (SRG1769) and CAME amendment. Formal approval by the CAA of such personnel is through approval of the CAME.

The organisational procedure contained in the exposition should not allow the approved organisation to qualify personnel using the provisions of CAMO.A.310(a)2, national equivalent qualifications to a Part 66 licence or aeronautical degree, or the provisions CAMO.A.310(b) without the prior agreement or approval of the CAA. If the organisation intends to authorise a person using the equivalent qualification or additional experience route, approval by the assigned CAA Surveyor will be required in each case.

All airworthiness review staff nominated on an SRG1769 should also be named in the exposition. Refer to AMC1 M.A.310(c).

The organisations will need to develop procedures that include the assessment requirements of such personnel. The qualification / experience requirements to extend the Airworthiness Review Certificate (ARC) are not specified in the regulation, however, the Civil Aviation Authority (CAA) considers the following to be the minimum:

The nominated person(s) should be working in an environment where they are involved with the continuing airworthiness management process. An ideal person, particularly for the smaller organisation, would be the nominated Continuing airworthiness (CAW) Manager who has overall responsibility.

Other person(s) may be nominated where it can be demonstrated that they are actively involved in CAW management and have a sound understanding of Part-M and/or Part-ML, as applicable. This should include in particular a knowledge of M.A.901(b) and/or ML.A.901(c), that is, a full understanding of the principles and processes of the 'Controlled Environment'.

Familiarity with the organisation’s Continuing Airworthiness Management Exposition (CAME) procedure for extending an ARC and the subsequent notification procedure to CAA. Such a person would therefore be able to demonstrate that they are in a position to fully establish whether an individual aircraft satisfies the 'Controlled Environment' criteria.

The criteria for acceptance of these persons may be broader than is definable here and may vary depending on the size, structure or complexity of the organisation.