15 Sep Part-M to Part-CAMO
From Part M to Part-CAMO:
A closer look at the transition.
The transition from Part M, Subpart G to Part-CAMO was implemented by EASA on March 24th in 2020. Roughly one and a half years later the transition is ongoing with an official deadline on March 24th in 2022. What does it mean for aircraft owners regarding their aircraft management and what are the main changes?
For most operators, aircraft owners, and even CAMOs and national authorities, the transition process is hard to manage and often connected to a lot of question marks.
The good news first: For aircraft which are noncomplex hardly anything will change unless they are not operated under an AOC. A non-complex aircraft is defined by the Maximum Take-Off Weight (MTOW) which must be lower than 5,700 kg, the configuration/capacity of passengers, which must be lower than 19 persons. Additionally, if the aircraft is certified for a crew of at least two pilots or equipped with a turbojet or more than one turboprop engine it is also regarded as a complex aircraft and therefore the management has to follow Part-CAMO. Your aircraft is not affected by any of the restrictions above and you are operating NCO? Then you are on the safe side. If not, there are a lot of requirements to show attention to. But what is new about Part-CAMO compared to Part M?
Safety Management System
The first point to mention is that with Part-CAMO a Safety Management System (SMS) must be implemented. Besides that there is a new key role named “Safety Manager” was created. With some exceptions due to the amount of requirements, the Compliance Manager and Safety Manager could be the same person.
Both, the CM and SM must have the same qualification (eg. Gen Fam Type training) as the organization’s PCA under the new Part-CAMO.
In general, this system and the position of a Safety Manager was created to enhance safety and minimize risks.
We at PRIMUS AERO manage safety by ensuring that, through our safety management process, the safety risks of the consequences of hazards in critical activities related to the provision of services are controlled to a level as low as reasonably practicable (ALARP). This safety risk management encompasses two distinct activities: hazard identification and safety risk assessment and mitigation.
Safety Risk Management & Safety Assurance
The Safety Risk Management (SRM) process provides for initial identification of hazards and assessment of risk. Safety risk controls are developed, and once they are determined to be capable of bringing the safety risk to ALARP – these controls are employed in daily operations. It is at this point that the Safety Assurance (SA) function takes over. Safety Assurance assures that organizational controls are being practiced and that all types of controls continue to achieve their intended objectives.
Management of Change
Management of Change (MoC) represents the next point on the list of reforms of Part M and represents a part of the Safety Management System. More precisely, it is part of the Assurance Program. MoC is a process to identify external and internal triggers that may affect the appropriateness or effectiveness of existing safety risk mitigation strategies and to eliminate or modify safety risk controls that are no longer needed or effective due to changes in the operational environment. Therefore, before any change in the organization is planned, such as e.g. the implementation and deployment of new technologies, changes to the organizational structure, etc. the potential risks that might occur are evaluated.
Again, these innovations in Part-CAMO should and will enhance safety and make procedures more tangible and in the end more feasible. All in all, there are a lot more new aspects when having a closer look at Part-CAMO. These three to four points above were just an excerpt of the more important ones and a good example of how significant the changes are. That is why it is crucial to have a service provider, which started early to make to new system work for them.
DI(FH) Isabell Gasteiger, Quality Manager
Wolgang Büttner , Customer Care Manager
This article was originally published in Aviation Heaven Magazine in November 2021.