PART M - M.A. 201 - Aircraft Airworthiness Responsibility

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skydiveireland
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PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by skydiveireland » Thu Feb 23, 2012 2:18 am

PART M - (which is Annex 1 to EC No 2042/2003).

It refers to the Continuing Airworthiness Management of an aircraft and the responsibilities associated with it.

M.A. 201 - Responsibility:
Section (a) States:

"The owner is responsible for the continuing airworthiness of an aircraft and shall ensure that no flight takes place unless:
1. the aircraft is maintained in an airworthy condition, and;
2. any operational and emergency equipment fitted is correctly installed and serviceable or clearly identified as
unserviceable, and;
3. the airworthiness certificate remains valid, and;
4. the maintenance of the aircraft is performed in accordance with the approved maintenance programme as specified in M.A.302."

It then states in section (e): Owner may Contract an Approved Subpart G - Continuing Airworthiness Management Organisation - who "Assumes Responsibility" for the tasks in part (a).

"In order to satisfy the responsibilities of paragraph (a) the owner of an aircraft may contract the tasks associated with continuing airworthiness to an approved continuing airworthiness management organisation as specified in M.A. Subpart G (continuing airworthiness management organisation hereinafter) in accordance with Appendix I. In this case, the continuing airworthiness management organisation assumes responsibility for the proper accomplishment of these tasks."

I would be very interested to hear individuals interpretation of the part in (e) which states:
"In this case, the continuing airworthiness management organisation [u]assumes responsibility[/u] for the proper accomplishment of these tasks."

Particular reference to the bit that says "assumes responsibility".

Question: If the aircraft owner has contracted an approved Subpart G - CAMO company (which the owner is entitled to do in accordance with section (e); Who is responsible for the aircraft airworthiness?

A - The owner is responsible for the airworthiness of the aircraft?
or
B - The Subpart G - Approved CAMO company who the owner contracted is responsible for the aircraft airworthiness?

Thanks in advance for the feedback....

Blue Skies....

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by stovepipe » Thu Feb 23, 2012 9:30 am

You've answered yourself. It's always the owner. The CAMO is only responsible for "proper accomplishment of these tasks". Ultimately, it's the owner's job to check that the CAMO have done it right. Naturally, there's an element of trust involved, as the owner has the right to assume that the CAMO will do it right, from Day 1 and the CAMO has a duty to live up to that expectation.

regards
Stovepipe

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by skydiveireland » Thu Feb 23, 2012 10:04 am

Thanks for the input Stovepipe.

Your interpretation of it is helpful but rather confusing to me in another sense though. I would appreciate if you could develop a bit more on it.

You say the owner is "Ultimately" responsible but the CAMO is responsible for the "proper accomplishment of these tasks" but "ultimately it's the owners job to check the CAMO will do it right".

How can the Owner "check that the CAMO have done it right"? - when the owner is not trained, skilled, or equipped to check anything to do with aircraft airworthiness? (doesn't it take something like 6-7 years to become a certified aircraft engineer?)

Can you provide more feedback about "The CAMO is only responsible for the "proper accomplishment of these tasks"?

Blue Skies...

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by stovepipe » Thu Feb 23, 2012 2:08 pm

For example, in the Commercial world, an airline will send it's aircraft to an CAMO for, say, a C-Check and will send along a rep to make sure that nothing is done outside of the maintenance programme unless the national authority or the manufacturer approves it and that all overhaulable items are dealt with correctly, say, for example, a flap motor, goes to a reputable shop for proper overhaul and the rep also tracks work cards and work records to ensure compliance. They would agree prices and manhours and so on. the rep would also be consulted about anything that crops up unexpectedly, that needs to be repaired.Now, on a smaller scale, GA aircraft owners don't tend to send a rep into a small CAMO and are effectively taking them on trust. Again, the CAMO boss should contact the owner if he finds something out of kilter, before going ahead and fixing it. Needless to say, trust works both ways. The CAMO has to turn out a good job and the owner has to be an honest broker at his end. They would have to sit down and come to a suitable agreement before tools are turned, otherwise there could be grief about the scope of work undertaken. Even though the owner may know nothing about maintenance, it's still his ultimate responsibility/duty of care for the airworthiness of the aircraft. Rather like in the Commercial world, Christoph Mueller or Michael O'Leary bear the ultimate corporate responsibility for their airlines and would take the fall if something goes wrong.

regards
Stovepipe

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by Earhart » Thu Feb 23, 2012 2:54 pm

Hi Stovepipe,

I think you may have inadvertantly confused a CAMO with a Maintenance Organisation. Per M.A.201(h) In the case of Commercial Air Transport, the operator must be approved as a CAMO for the aircraft it operates. The airline is the CAMO e.g. they decide what maintenance to do and when. The airline may send a rep to the Maintenance Organisation, but not to the CAMO.

The owner is responsible for the continuing airworthiness of the aircraft (don't confuse this with maintenance). This responsibility extends to ensuring that the aircraft is presented for maintenance, when required, to an appropriate person or organisation. It includes ensuring operational and emergency equipment required is fitted and functional. It includes having a maintenance programme (and knowing what the manufacturer's recommendations are) and ensuring the ARC is valid. No flight may take place without these.

The owner may contract a CAMO to do certain tasks on behalf of the owner. In this case, a contract is agreed between them. This contract should detail what the CAMO is responsible for e.g. drawing up a maintenance programme, planning for maintenance, sending details of what is to be done to the Maintenance Organisation (may all be in the same organisation). This should be crystal clear and not based on 'trust.' The CAMO is ultimately responsible for whatever tasks they are contracted to do, if the contract valid (e.g. not terminated).
The owner may be responsible for sending in the hours and cycles used on the aircraft to the CAMO. The CAMO then notifies the owner when a check is due e.g. "you have 10 hours remaining to your next check, please contact us to arrange a date for the input"

Continuing Airworthiness Tasks (as defined in M.A.301) may be contracted to a CAMO, but some of them may be the responsiblity of the owner e.g. pre-flight inspection. This is an 'abridged' listing.

1. Accomplisment of Pre-flight inspections
2. the rectification of defects and damage
3. the accomplishment of all mainteannce required
4. For large aircraft - analysis of effectiveness of the maint. programme
5. The accomplishment of ADs, Operational Directives etc
6. All mods and repairs are accomplished correctly
7. Non-mandatory mods and inspections - for large aircraft the establishment of an embodiment policy
8. Maintenance check flights.

The IAA have a Memorandum which may help
http://www.iaa.ie/index.jsp?p=93&n=97&a ... 20&lID=895" onclick="window.open(this.href);return false;

These opinions are my own and may not reflect the opinions of anyone else. However, I hope they may help.

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by Earhart » Thu Feb 23, 2012 3:01 pm

As an addendum:

M.A.201 (c) states that 'Any person or organisation performing maintenance shall be responsible for the task performed.

This includes pilot-owner maintenance, Part 66 Licenced Engineers, M.F. Organisations and Part 145 organisations. I understand that the Blue Skies' comment was made following the mixup with CAMO and Maintenance Organisation - but for clarity, the pilot is not expected to second guess the engineer and verify what s/he has done.

These opinions are my own and may not represent anyone elses opinions

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by stovepipe » Thu Feb 23, 2012 9:14 pm

Very good replies and you're dead right, Earhart.What I've found with small aircraft is that the average owner does not know or understand the full extent of his responsibility as the owner and, in effect, depends on his maintenance organisation to do it for him. A lot of owners believe that the responsibility lies with the engineers, but it clearly doesn't.

regards
Stovepipe

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Re: PART M - M.A. 201 - Aircraft Airworthiness Responsibility

Post by skydiveireland » Thu Feb 23, 2012 11:45 pm

@Stovepipe

Your State:
"A lot of owners believe that the responsibility lies with the engineers, but it clearly doesn't."

This matter is not so "clear". We have established the owner of light aircraft (weighing less then 5700 kgs) have the right to contract a Subpart G Continuing Airworthiness Management Organisation to do what the PART M.A. 201 (e) law states as "Assume the Owners Responsibility" for Airworthiness.

Ironically a person does not have to be an Aircraft Engineer to hold the position of a Subpart G - Airworthiness Manager in an approved CAMO. In fact there is no formal qualification required to hold the Subpart G Manager position.This is a bit scary in my opinion....

@ Earhart
Well written and very factual. Thank you for the input.

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