EASA Part-CAMO COMPLIANCE MONITORING — General Notes

Consider the key features of the Compliance Monitoring Program to ensure compliance within an EASA Part-CAMO Environment:

1) The primary objectives of compliance monitoring are to provide an independent monitoring function on how the organisation ensures compliance with the applicable requirements, policies and procedures, and to request action where non-compliances are identified.

2) The independence of the compliance monitoring should be established by always ensuring that audits and inspections are carried out by personnel who are not responsible for the functions, procedures or products that are audited or inspected.

3) The independent audit should be an objective process of routine sample checks of all aspects of the CAMO ability to carry out continuing airworthiness management to the standards required by this Regulation.

It should include some product sampling as this is the end result of the process.

4) The independent audit should provide an objective overview of the complete set of continuing airworthiness management-related activities.

5) The audit plan should ensure that all aspects of Part-CAMO compliance are verified every year, including all the subcontracted activities, and the auditing may be carried out as a complete single exercise or subdivided over the annual period.

6) The independent audit should not require each procedure to be verified against each product line when it can be shown that the particular procedure is common to more than one product line and the procedure has been verified every year without resultant findings.

7) Where findings have been identified, the particular procedure should be verified against other product lines until the findings have been closed, after which the independent audit procedure may revert to a yearly interval for the particular procedure.

8) Provided that there are no safety-related findings, the audit planning cycle specified in this AMC may be increased by up to 100%, subject to a risk assessment and/or mitigation actions, and agreement by the competent authority.

9) Where the organisation has more than one location approved, the audit plan should ensure that each location is audited every year or at an interval determined through a risk assessment agreed by the competent authority and not exceeding the applicable audit planning cycle.

10) A report should be issued each time an audit is carried out describing what was checked and the resulting non-compliance findings against applicable requirements and procedures.

CONTRACTING OF THE INDEPENDENT AUDIT

1) If external personnel is used to perform independent audits:

2) Any such audits are performed under the responsibility of the compliance monitoring manager; and

3) The organisation remains responsible for ensuring that the external personnel has the relevant knowledge, background, and experience that are appropriate to the activities being audited, including knowledge and experience in compliance monitoring.

Note - The organisation retains the ultimate responsibility for the effectiveness of the compliance monitoring function, in particular for the effective implementation and follow-up of all corrective actions.

COMPLIANCE MONITORING — Feedback System

1) An essential element of the compliance monitoring is the feedback system

2) The feedback system should not be contracted to external persons or organisations.

3) When a non-compliance is found, the compliance monitoring function should ensure that the root cause(s) and contributing factor(s) are identified (see GM1 CAMO.A.150), and that corrective actions are defined.

4) The feedback part of the compliance monitoring function should define who is required to address any non-compliance in each particular case, and the procedure to be followed if the corrective action is not completed within the defined time frame.

5) The principal functions of the feedback system are to ensure that all findings resulting from the independent audits of the organisation are properly investigated and corrected in a timely manner and to enable the accountable manager to be kept informed of any safety issues and the extent of compliance with Part-CAMO.

6) Unless the review of the results from compliance monitoring is the responsibility of the safety review board (AMC1 CAMO.A.200), the accountable manager should hold regular meetings with staff to check the progress of any corrective actions.

7) These meetings may be delegated to the compliance monitoring manager on a day-to-day basis, provided that the accountable manager:

(a) meets the senior staff involved at least twice per year to review the overall performance of the compliance monitoring function; and

(b) receives at least a half-yearly summary report on non-compliance findings.

(c) All records pertaining to the independent audit and the feedback system should be retained for the period specified in point CAMO.A.220(b) or for such periods as to support changes to the audit planning cycle in accordance with AMC2 CAMO.A.200(a)(6), whichever is the longer.

Compliance Monitoring Function Requires independent auditing

1) The compliance monitoring function is one of the elements that is required to be in compliance with the applicable requirements.

Note - This means that the compliance monitoring function itself should be subject to independent monitoring of compliance in accordance with point CAMO.A.200(a)(6).

RESPONSIBILITY FOR ENSURING COMPLIANCE (This is Quality Control)

1) The person(s) nominated with the responsibility of ensuring that the organisation always complies with the applicable continuing airworthiness management, airworthiness review and permit to fly requirements of this Annex (Part-CAMO), Annex I (Part-M) and Annex Vb (Part-ML) are responsible, in the day-to-day continuing airworthiness management activities, for ensuring that the organisation personnel works in accordance with the applicable procedures and regulatory requirements.

2) These nominated persons should demonstrate a complete understanding of the applicable regulatory requirements and ensure that the organisation’s processes and standards accurately reflect the applicable requirements. It is their role to ensure that compliance is proactively managed and that any early warning signs of non-compliance are documented and acted upon.

Next Steps

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