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(3) Under § 121.369 and § 135.427, the air carrier’s manual must cover the administration of its CAMP, as written in its manual. The manual must include specific methods for complying with the applicable sections of parts 121 and 135 when maintenance providers perform maintenance, preventative maintenance and alterations on behalf of the air carrier.  These sections also require the air carriers list in its manual the persons with whom it contracts for maintenance and to include a description of the contracted work.

(4)  The following specific areas must be addressed in the air carrier's CAMP

(a)  Adequate Organization. Under §§ 121.365, 135.423, and 135.425, the air carrier must ensure that the person with whom it arranges to perform maintenance has an organization capable of handling the work. The carrier must evaluate the minimum organizational requirements a maintenance provider must meet for a particular job. The air carrier must ensure the outsource maintenance provider is capable of performing its CAMP requirements as provided by or as authorized by the carrier for the type of work being outsourced. Further, if required inspection items (RII) will be maintained or altered by the maintenance provider, the inspection functions must be separated within the outsourcing organization. If the carrier's maintenance program or procedures require specific compliance aspects, the carrier must be able to show that the maintenance provider is equally capable of following the manual and procedures.

(b)  Required Inspection Personnel.

i.  Under §§ 121.371 and 135.429, the air carrier must ensure the maintenance provider performing the work knows its specified RIIs. The carrier must also ensure that the maintenance provider RII authorized personnel are trained IAW the requirements of carrier’s CAMP.

ii.  Each air carrier shall maintain, or determine that each person with whom it arranges to perform its required inspections maintains, a current listing of persons who have been trained, qualified, and authorized by the carrier to conduct required inspections. The persons must be identified by name, occupational title, and the inspection that they are authorized to perform. The air carrier shall give written information to each person so authorized by the carrier, describing the extent of the person's responsibilities, authorities, and inspection limitations. The air carrier must provide this list for inspection upon FAA request.

(c)  Continuing Analysis and Surveillance.

i. Under §§ 121.373 and 135.431, the air carrier must continually survey its CAMP and all persons acting under that program to ensure continuous compliance with its CAMP and the regulations. The air carrier must have a system in place that detects, identifies, and provides timely corrective action, on a continuing basis, for all deficiencies or deviations in those portions of the CAMP accomplished by the substantial maintenance provider, including maintenance recordkeeping. This generally requires the air carrier to perform audits of all its maintenance providers.


The air carrier must have a system in place that tracks and evaluates, on a continuing basis, the standards of performance (quality) of the substantial maintenance work accomplished by the individual maintenance provider.  This must include provisions for timely corrective action if the quality of work becomes unsatisfactory and deficiencies are noted.


Air carriers audits for their outsource maintenance provider need to ensure they are auditing for compliance to their program.  Audits performed by air carriers that just ensure the outsource provider is in compliance with part 145 may be contrary to regulations.  The air carriers should have an “in-process” type audit to follow the maintenance through its cycle to ensure the provider is in compliance with the air carriers program.  


Air carriers will not normally perform audits of third party organizations that certificated repair facilities sub-contract with. The air carrier must however, have a process that determines if the third party outsource maintenance provider has the organizational structure, competent and trained personnel, adequate facilities and equipment to perform the intended functions.  This process must ensure that the air carrier maintains its responsibility by being in control of their maintenance regardless of whom performs it.

Vol. 269-7

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