Question: Should the Part M – Sub-Part G Continued Airworthiness Management Organisation (CAMO) have the ability to select responsible maintenance teams / personnel to work on their aircraft if they are to manage and maintain ‘continuing airworthiness’ to their acceptable standards?
When the CAMO receives a completed work package from a Maintenance Repair Organisation (MRO), the CAMO makes an informed decision on the standard of work carried out. This decision is really ascertained by the quality of the completed ‘work package’ i.e. correct entries, parts recorded, complex tasks, critical tasks carried out etc.
If the work package has all the relevant information and is completed to a standard the CAMO expects then it assumes the work has been completed fully.
However, if errors are found within the work package then, questions arise to determine the standard of workmanship, which has been carried out on the aircraft.
Therefore, the CAMO has a perception in balancing its judgement when reviewing various standards of completed work packages; i.e. such as ‘what was the actual standard of work carried out?’
From the reviewing the completed work package there are some ‘unknowns’ such as:
- Was the correct tooling used?
- Has the documentation or procedure been followed?
- Was there any Human Factors ‘Performance or Limitations’ that influenced or impacted on the work carried out?
- What is the ‘Attitude & Behaviour’ of the technician, engineer or mechanic?
- Have the correct components (parts, consumables, raw materials) been used?
However, what about the engineer? Which engineer carried out the work? What is their actual attitude & behaviour like? Integrity? They always make mistakes – same person!
As an example there could be 3 different types of technician, engineer or mechanic.
- Engineer A: hates completing paperwork but is very professional in their attitude / behaviour to approach each task (hands on skills). However, their ability to complete the task successfully is gauged on the entries made and the completed paperwork, not the task itself.
- Engineer B: not very good at completing tasks but exceptional at paperwork & documentation completion. However, focuses more on paperwork than task in-hand.
- Engineer C: has the ability to maintain an even balance between task completion example; fulfilling the requirements of the Certificate Release to Service (CRS) and completion of the paperwork / documentation. Ensuring above normal standards are achieved at all times. This is the EASA Part 145 Maintenance Organisation ‘IDEAL’ Engineer.
Therefore, when the CAMO reviews the completed work package they assume it should:
- Accurately reflect the scope of work and tasks completed
- Satisfactorily shows that the task has been completed to a high standard.
If the CAMO is satisfied that the work package has been satisfactorily completed, entries correct with no errors or mistakes then, it assumes the work specified has been completed to a standard. Thus, the CAMO measures the MRO’s standard and ability based on perception, the completed work package and not the actual standard of work accomplished.
CAMOs moving to the next level of compliance:
Should the CAMO responsible for the continuing airworthiness of the aircraft and its components have selected or have oversight of the individuals who carry out the maintenance instead of gauging the ‘maintenance standards’ by the paperwork only?
Example: CAMO oversees the maintenance organisation employees’ competencies, attitude & behaviours etc. They should determine the standard carried out on the aircraft and not just base it on the completed work package alone.
Should the CAMO’s be driving or setting the expected standards and not just rely on an organisation having a maintenance organisation approval as a form of compliance therefore, the CAMO does not need to influence the standards of workmanship?