Continuing Airworthiness management is the process by which an aircraft is kept in a condition where it remains airworthy throughout its life – or in other wordsi.e. technically fit for flight. In the words of ICAO:
- “All of the processes ensuring that, at any time in its life, an aeroplane complies with the technical conditions fixed to the issue of the Certificate of Airworthiness and is in a condition for safe operation” – source: ICAO Airworthiness Manual [ICAO, 2014]
The ultimate responsibility for continued airworthiness is assigned in ICAO Annex 8 to the State of Design but the programme to achieve continuing airworthiness is a matter for the State of Registry. It is useful to compare Continued and Continuing as they are sometimes used interchangeably. Continued Airworthiness is also known as Type Airworthiness [MAA, 2016] or Initial Airworthiness [EC, 2014]
Continued Airworthiness = “All the actions associated with the upkeep of a type design and the associated approved data through life.” – Source MAA02 glossary [MAA, 2016]
Continuing Airworthiness = “All of the processes ensuring that, at any time in its operating life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation” – Source EC1321/2014 Article 2 [EC, 2014]
Management of Continuing Airworthiness
For operators based in EU nations, and others who choose to follow EASA regulations, a Continuing Airworthiness Management Organisation (CAMO) must be in place. This is an (approved) organisation responsible for implementation of continuing airworthiness management tasks.
According to EU 2018/1139 Annex V Section 6 [EU, 2018], the owner or – if designated by contract – the lessee is responsible for the continuing airworthiness of an aircraft and shall ensure that no flight takes place unless:
- The aircraft is maintained in an airworthy condition, and;
- Any operational and emergency equipment fitted is correctly installed and serviceable or clearly identified as unserviceable, and;
- The airworthiness certificate remains valid, and;
- The maintenance of the aircraft is performed in accordance with the approved maintenance programme as specified in Part M.A.302.
Reference should also be made to M.A 201 in EASA Part M [EC, 2014], which gives more detail concerning the responsibilities for continuing airworthiness. For operators based outside the EU, for whom EASA regulations do not apply, continuing airworthiness is still managed in a controlled manner but the regulations are within the rules for the operator. Although the owner bears the legal responsibility for continuing airworthiness, there is very much a shared responsibility between:
- The aircraft Type Certificate Holder (TCH) – Designer / Manufacturer
- Commercial Air Transport (CAT) Operators
- Aircraft Owner
- Maintenance Organisation
- Authorised Persons e.g. Licensed Aircraft Engineers
- Regulators i.e. Airworthiness Authorities
For each of its aircraft, the approved CAMO is required to carry out the following functions. Although these are drawn from EASA Part M, Sub Part G M.A.708 [EC, 2014], the activities would be similar to those required of any operator:
- Develop and control a maintenance programme for the aircraft managed including any applicable reliability programme
- Present the aircraft maintenance programme and its amendments to the competent authority for approval
- Manage the approval of modification and repairs,
- Ensure that all maintenance is carried out in accordance with the approved maintenance programme and released in accordance with M.A. Subpart H [Certificate of Release to Service (CRS)]
- Ensure that all applicable ADs and operational directives with a continuing airworthiness impact, are applied
- Ensure that all defects discovered during scheduled maintenance or reported are corrected by an appropriately approved maintenance organisation,
- Ensure that the aircraft is taken to an appropriately approved maintenance organisation whenever necessary,
- Coordinate scheduled maintenance, the application of ADs, the replacement of service LLP, and component inspection to ensure the work is carried out properly
- Manage and archive all continuing airworthiness records and/or operator’s technical log.
- Ensure that the mass and balance statement reflects the current status of the aircraft.
Continuing Airworthiness is therefore not just the maintenance of aircraft and equipment, but also involves monitoring performance of products in service. This will include recording service difficulties to assess significance with respect to safety and airworthiness for the specific aircraft/product involved and for similar aircraft/products. Timely response is required where airworthiness is affected, which means devising and provisioning rectification action, and promulgating the necessary information to restore safety levels.
Inspection methods and intervals, repair actions, modifications and timescales are all part of Continuing Airworthiness, as are feedback to design/production and formal airworthiness review (or Airworthiness Review Certificate, ARC).