CAP2400P Airworthiness Code - Print
CAP2400P Airworthiness Code - Print
CAP2400P Airworthiness Code - Print
Light Aircraft
CAA / October 2022
CONTENTS
Contents 03
Foreword 05
Introduction 06
Chapter 1: The Airworthiness System 07
Key Regulations 08
Part 21 08
Part-ML 09
Part-CAO 09
Part-CAO (continued) 10
Part-CAMO 10
Part-M 10
Part 145 10
Part-66 Independent Certifying Staff 11
Design and Manufacture 13
Continuing Airworthiness Management 14
Maintenance 15
The Airworthiness Review 16
The Regulator 17
The Mandatory Occurrence Reporting System 18
The Airworthiness System Summary 20
Organisational Approvals and Airworthiness Codes 22
Chapter 2: Airworthiness Responsibilities of the owner/operator 23
Airworthiness Responsibilities of the owner / operator 24
Does a flying school aircraft need to be managed
and maintained by an approved organisation? 24
Does a private aircraft need to be managed
and maintained by an approved organisation? 26
Why does it matter if there is a formal continuing airworthiness management contract? 28
Chapter 3: The Part-ML Maintenance Programme 29
The Part-ML Maintenance Programme (AMP) 30
Section 1 – Aircraft Identification 31
Section 2 – Basis for the Maintenance Programme 32
Section 3 – DAH Instructions for Continued Airworthiness 33
Section 4 – Additional Maintenance Requirements 34
Section 5 – Maintenance Tasks Alternative to the DAH ICA 39
Section 6 – Pilot-owner Maintenance 43
Section 7 – Approval / Declaration of the AMP 44
Section 8 – The Certification Statement 45
Section 9 – Appendices 46
Review of the AMP 50
When an AMP is not required 51
A few words about the MIP 52
Summary of AMP responsibilities 53
CONTENTS
Chapter 4: Practical Continuing Airworthiness 54
Introduction 55
Pre-flight Check 56
Managing Defects 57
Managing Repairs 58
Managing Modifications 59
Use of CS-STAN 61
Accomplishment of Maintenance in Accordance with the AMP 63
Managing Mandatory Requirements 64
Managing Maintenance Check Flights (MCFs) 67
Aircraft Records 68
Records when changing Part-CAMO or Part-CAO Organisation 69
Selecting a maintainer 69
Pilot-owner Maintenance 71
Aircraft Exterior Repainting and Interior Trim Work 73
Purchasing a used aircraft 75
Pre-Purchase Inspection 77
Certificate of Airworthiness Applications (including aircraft import) 78
Ownership of Aircraft operating on an enduring Part 21 Permit to Fly 79
Abbreviations 80
FOREWORD
Communication is one of the key pillars of our relationship with the General Aviation community.
With around 18,000 GA aircraft and 30,000 pilots, it is important that key messages around safety and
risk management are clear and concise. Feedback from the community indicated that in the realm
of maintenance and continuing airworthiness management, there has sometimes been room for
improvement.
Since the first edition of the ‘Part-M’ maintenance regulations nearly 20 years ago, the requirements
in continuing airworthiness have evolved several times. While this evolution has been with the aim
of improvement, change has also brought the necessity to familiarise and understand – not always
welcome alongside the practical challenges of keeping aircraft airworthy. The CAA recognises this
reality and the frustration sometimes experienced in the past.
The 2019 Part-ML and Part-CAO regulations provide a proportionate framework for the maintenance
and continuing airworthiness management of light aircraft. The regulations also provide more
privileges for pilots, owners, independent certifying staff and small maintenance organisations.
However, devolving these responsibilities to the GA community has inevitably prompted debate
around standards and best practice. To that end, we encourage owners and airworthiness
professionals to educate and appraise themselves of the relevant considerations before making
airworthiness decisions.
Even though Part-ML was specifically written for the GA environment, there can still be a gap
between theory and practice. An owner may have an excellent understanding of the regulations,
but that needs to be married to a knowledge of their aircraft and the practicalities of airworthiness
management. The Airworthiness Code aims to bridge this gap and given owners not only a better
understanding of Part-ML itself, but how to apply it to their aircraft.
We would like to thank in particular the AOPA Maintenance Working Group and other members of the
GA community who contributed to the Airworthiness Code and hope that you will find it useful.
Rob Bishton
Group Director, Safety and Airspace
UK Civil Aviation Authority
INTRODUCTION
The Airworthiness Code for Maintenance is intended to provide practical
guidance on the key airworthiness topics for owners and operators of
general aviation aircraft.
> Part 21 aeroplanes and rotorcraft subject to the Part-ML regulation; and
THE
AIRWORTHINESS
SYSTEM
CHAPTER 1:
THE AIRWORTHINESS SYSTEM
Key Regulations
CONTINUING AIRWORTHINESS
Continuing Airworthiness requirements for Part 21 aircraft are set out in UK Regulation (EU)
1321/2014. This consists of a ‘cover regulation’ setting out the high level structure, followed by a
series of annexes containing the detailed technical requirements:
Annex Vb (Part-ML) and Annex Vd (Part-CAO) are the focus of this guide. They contain the continuing
airworthiness and organisational approval requirements applicable to light aeroplanes and helicopters,
when not operated by a licensed air carrier*.
Part-66 is also addressed when explaining the qualifications necessary to perform or certify
airworthiness tasks. The detailed requirements for obtaining Part-66 qualifications are beyond the
scope of the guide.
*‘Licensed air carrier’ refers to an air transport undertaking that is required to hold an operating licence issued by the CAA. An operating
licence relates to the nature, ownership and financial health of an airline business. It is separate from an air operator certificate (AOC),
although most commercial air transport operators are required to hold both.
Key Regulations
CONTINUING AIRWORTHINESS (CONTINUED)
Part-ML Part-CAO
Part-ML (or ‘M-Light’ as it is sometimes referred Part-CAO contains the requirements for
to) is essentially the regulatory code for the obtaining approval as a ‘Combined Airworthiness
continuing airworthiness management and Organisation’. This can consist of one or more of
maintenance of light aircraft. It was specifically the following privileges:
developed for GA and is applicable to:
1. Maintenance
> Aeroplanes of 2730 kg MTOM or less;
2. Continuing Airworthiness Management
> Rotorcraft of 1200 kg MTOM or less, certified
3. Airworthiness Review
for a maximum of four occupants; and
> Other ‘ELA2’ aircraft. 4. Permit to Fly
The approval is GA specific and applies to
Although not the subject of this guide, ‘other non-complex motor-powered aircraft not listed
ELA2’ aircraft includes manned balloons, on the AOC of a licensed air carrier. Complex
sailplanes, hot airships and gas airships. Part- motor-powered aircraft is defined as*:
ML is not applicable to aircraft listed on the air
operator certificate (AOC) of a licensed air carrier. (i) an aeroplane:
> with a maximum certificated take-off mass
Part-ML is broken down into Section A (Technical exceeding 5700 kg, or
Requirements) and Section B (Procedures for
> certificated for a maximum passenger
the CAA). It is Section A that applies to owners,
seating configuration of more than
operators and airworthiness staff.
nineteen, or
Section A includes: > certificated for operation with a minimum
crew of at least two pilots, or
> Subpart A - General
> equipped with (a) turbojet engine(s) or more
> Subpart B – Accountability (responsibilities)
than one turboprop engine, or
> Subpart C – Continuing Airworthiness
(ii) a helicopter certificated:
> Subpart D – Maintenance Standards
> for a maximum take-off mass exceeding
> Subpart E – Components
3175 kg, or
> Subpart H – Certificate of Release to Service
> for a maximum passenger seating
> Subpart I – Airworthiness Review Certificate configuration of more than nine, or
> for operation with a minimum crew of
The absence of a Subpart F or G from the above
at least two pilots, or
list is to keep the indexing consistent with the
equivalent Part-M structure, where Subparts F and (iii) a tilt rotor aircraft;
G have been replaced with the Part-CAO and Part-
CAMO approvals.
*Note that the definition “complex” for airworthiness may differ from that used in flight crew licensing and aircraft operations.
Key Regulations
CONTINUING AIRWORTHINESS (CONTINUED)
Key Regulations
CONTINUING AIRWORTHINESS (CONTINUED) INITIAL AIRWORTHINESS
Initial Airworthiness for Part 21 aircraft in the UK
Part-66 (Independent Certifying Staff)
is governed by UK Regulation (EU) 748/2012. The
Part-66 contains the requirements for the substantive technical requirements are contained
licensing of airworthiness personnel, including in Annex I - Part 21.
Independent Certifying Staff (ICS).
Part 21 covers numerous subjects, including type
Often referred to as a Licensed Engineer certificates, supplemental type certificates (STC),
or LAE, ICS may work independently of an European Technical Standards Order (ETSO),
organisational approval. Under Part-ML, aircraft production organisations, design organisations,
may be maintained and released by ICS, but certificates of airworthiness (C of A), noise
only if operated non-commercially. An ICS is still certificates, new parts and appliances, repairs,
bound by the requirements of Part-ML which technical standard orders and permits to fly.
define how the maintenance must be controlled,
performed, documented and released. This guide will not cover Part 21 in detail, however
will explain some common topics such as
The person performing the maintenance must
modifications and repairs.
be qualified, have access to and use the correct
manuals, use the correct tools (including
calibration if required) ensure proper facilities
PART 21 VS NON-PART 21 AIRCRAFT
in the case of inclement weather or lengthy
Part 21 aircraft are regulated in accordance with
maintenance, and ensure error capturing after
UK Regulation (EU) 2018/1139 (known as the
critical tasks (e.g., independent inspections).
‘UK Basic Regulation’) and the implementing
The work must be performed in a clean and well
regulations made under it. The UK Basic
organised area with no dirt or contamination.
Regulation derives from the UK’s retained EU
law. Part 21 aircraft would have been ‘EASA
Where an ICS is assisted in performing the
aircraft’ while the UK was still a member of
work, the persons assisting must be under
EASA. Most factory-built aircraft (other than
direct and continuous control, as is the case
microlights and gyroplanes) are Part 21.
for an approved organisation employing
non-certifying staff. Non-Part 21 aircraft are outside the scope of
When specifically authorised by the CAA, the ICS the UK Basic Regulation. Non-Part 21 aircraft
may hold a Part-ML authorisation allowing the were never subject to EASA regulation and are
holder to perform an Airworthiness Review and covered by the UK Air Navigation Order (ANO)
issue an ARC (Form 15c). This is limited to the 2016. Vintage and ex-military aircraft, amateur
Part-ML types held on the ICS Part-66 Aircraft built aircraft, microlights, gyroplanes are normally
Maintenance License and excludes aircraft that non-Part 21. Such aircraft will have a certificate
are used commercially (e.g., Commercial ATO of airworthiness or permit to fly issued under the
or DTO). More detail on this subject is provided ANO 2016, unless exempt from airworthiness
later on. regulation. Small foot-launched aircraft such
as hang gliders, paragliders and self-propelled
A Part-66 Aircraft Maintenance License with
hang or paragliders are also non-Part 21. A full
appropriate ratings is also a pre-requisite for the
description of the non-Part 21 criteria can be
authorisation to release aircraft maintenance
found in the UK CAA’s GA webpages.
under an approved organisation.
Key Regulations
PART-NCO ‘Part-ML’ is Annex Vb within the Continuing
Airworthiness Regulation – UK Reg (EU)
Part-NCO refers to the regulations for non- 1321/2014, which can be found via
commercial operations with other than complex- Basic Regulation, the Implementing Rules
motor-powered aircraft. It forms part of the UK and UK CAA AMC GM CS > Continuing
Regulation (EU) 965/2012 - the UK Air Operations Airworthiness.
Regulation. Part-NCO will apply to the operation
of most aircraft maintained under Part-ML. Flight Individual provisons within a regulation follow a
training operations provided on a commercial lettering and number system. For example, the
basis normally comply with Part-NCO, even if first entry in Part-ML is ‘ML.1’ and subsequently
they are considered commercial for the purpose within ML, Section A, the provisions are
numbered ML.A.101, ML.A.201 and so on.
of Part-ML.
UK regulations can be found at caa.co.uk/uk- AMC and GM are published separately alongside
regulations – those relevant to Part 21 aircraft each regulation – for Continuing Airworthiness
will be under Aviation Safety > Basic Regulation, see Aviation Safety > Basic Regulation, the
the Implementing Rules and UK CAA AMC Implementing Rules and UK CAA AMC GM CS
GM CS. > Continuing Airworthiness > CAA 1321/2014
Continuing Airworthiness – AMC GM.
Within the Basic Regulation and Implementing
Rules section, the regulations are separated
into functional area such as Initial Airworthiness, CAPS AND FORMS
Continuing Airworthiness, Air Operations or
Aircrew. The regulations made under the UK Throughout this guide reference is made to
Basic Regulation are often referred to collectively various CAA publications (CAPs) and Forms.
as ‘the Implementing Rules’. CAPs can be found online via caa.co.uk/
[capnumber] - for example caa.co.uk/cap747.
CAA online forms can be found here.
Maintenance
Whilst continuing airworthiness management is This signifies that the work has been performed
the process of managing the various tasks that in accordance with the applicable requirements.
are required to keep the aircraft in an airworthy Note that the use of the Form 1 is for component
condition, maintenance is the actual performance of release, not the release of the entire aircraft,
those tasks. which must be via a CRS.
The Regulator
Both the state in which an aircraft is registered COMMUNICATIONS
and the state of design have an important role to
play in overseeing the airworthiness system. For safety critical information, the CAA
uses a separate subscription service.
All ICAO contracting states will have an aviation This can be found using the following link:
regulator appointed for this purpose. The UK CAA Subscriptions - New Registration.
Civil Aviation Authority (UK CAA) is the aviation
regulator in the UK. The CAA also uses the ‘Skywise’ system to
notify aviation stakeholders of information or
The activities undertaken by aviation regulators guidance relevant to their activities. It is available
include: via App, website and as an email notification
service. It can be configured by subject,
> Approval and oversight of approved depending on individual preference. More
organisations; information can be found at skywise.caa.co.uk.
> Licensing of engineers;
The regulator in the state of design will also issue
> Certification of new aircraft types and communications regarding the airworthiness
design changes; of aircraft or components for which they have
responsibility. For example this could be the FAA
> Survey and issue of aircraft certificates.
in the USA or EASA in the case of DAHs residing
> Investigating Mandatory Occurrence and in an EASA member state.
whistle blowing reports;
It is important to identify and subscribe to the
> Issue of Airworthiness / Operational
relevant airworthiness communication channels
Directives and other mandatory instructions;
from the state of design.
and
> Review and development of policy and
regulations - also known as ‘rulemaking’.
> To the owner or CAMO / CAO, as applicable. DAHs are required to have a system to collect,
investigate and analyse failures, malfunctions
Persons identified in ML.A.201 and required to
and defects related to designs for which
report the include the owner, operator, lessee,
they have responsibility. This extends to the
maintenance personnel or pilot in command.
different types of DAH, such as Type Certificate
Holders, STC holders, Design Organisation
Key info ! Approval holders and ETSO holders.
Contract
Owner Operator Design Organisation
Utilisation
Manufacturer
Instructions
Occurrences
Occurrences
Part-CAO
or
Part-CAMO
Work Order
Occurrences
/ Contract
Records
Maintenance
Organisation or
ADs / GRs Occurrences ICS as appropriate
Regulator
Occurrences
Design Organisation
Manufacturer
Occurrences
Owner
Work Order
Occurrences
/ Contract
Records
Maintenance
Organisation or
ADs / GRs Occurrences ICS as appropriate
Regulator
Occurrences
Owner
*Part-66
ICS with CAA issued Part ML authorisation
Pilot / Owner
AIRWORTHINESS
RESPONSIBILITIES
OF THE OWNER
OR OPERATOR
CHAPTER 2: AIRWORTHINESS
RESPONSIBILITIES OF THE
OWNER OR OPERATOR
Responsibilities
ML.A.201(a) states that the owner is responsible ML.A.201(f) allows the owner to sign a
for the continuing airworthiness of the aircraft continuing airworthiness management contract
and shall ensure that no flight takes place unless (often known as a ‘CAMO’ contract) with an
the aircraft is: organisation approved under Part-CAO or
Part-CAMO. Doing so essentially delegates the
> maintained in an airworthy condition;
responsibility for the airworthiness of the aircraft
> any operational and emergency equipment to the organisation.
fitted is correctly installed and serviceable or
marked as unserviceable; The full requirements and outline of a continuing
> the airworthiness certificate is valid ; and airworthiness management contract are set out
in Appendix I of Part-ML. Note that even when
> maintenance is performed in accordance
the airworthiness management is contracted,
with the Part-ML AMP (Maintenance
the owner still has obligations such as having a
Programme).
general understanding of the aircraft’s AMP and
Not all aircraft owners will have sufficient presenting the aircraft for maintenance when
knowledge or being willing to manage the directed by the contracted organisation.
airworthiness of the aircraft themselves.
Reference: ML.A.201; Part-ML, Appendix I
Part-M
Complex motor-powered aircraft and/or on
the AOC of a licensed air carrier.
Part-M is out
of scope
Part-M
Non complex motor powered A/C, but outside
the scope of Part-ML due to weight or size
Part-M is out
of scope
Aircraft use
Part-ML
Non Part-NCO or used by a > Managed and maintained
commercial ATO/DTO by an approved organisation
> AMP developed and approved by
an approved organisation, including
justification of any deviations from
the DAH recommendations
Part-ML
> Owner managed
Part-NCO non
> Subject to some pilot owner maintenance
commercial
use > Maintained by independent certifying staff
> Owner developed and declared maintenance programme
> Owner determined deviations from design approval holders
recommendations, without justification
Level of regulation
THE PART-ML
MAINTENANCE
PROGRAMME
Part-ML also lists the minimum tasks that an AMP must contain and this is known as the ‘Minimum
Inspection Programme’ (MIP). The AMP and MIP requirements are set out in ML.A.302 and the
associated AMC and GM.
The Part-ML AMP and MIP concept replace previous arrangements for Part 21 aircraft maintained
under the CAA Light Aircraft Maintenance Programme (LAMP). The use of LAMP is no longer
permitted. This includes programmes based on LAMP where compliance with either the DAH data or
the MIP (as applicable) cannot be demonstrated.
There is a standard template for the AMP, available in MS Word format from the
UK CAA’s Part-ML webpage.
This chapter will guide the reader through each section of the AMP template, giving advice on
what issues to consider. Text in italics indicates sample entries as a worked example.
Although compiling the AMP requires a review of certain documents, it should never be
considered a paperwork exercise. The identification, inclusion and performance of maintenance
requirements is what keeps an aircraft airworthy.
Reference: ML.A.302
Aircraft identification
The AMP includes details of the owner and the aircraft that are on the programme. It can cover more
than one aircraft if any differences in the maintenance requirements are made clear. Logically the
boundary for this will be other aircraft of the same type using the same data. The reason for this will
become clear as the content of other sections is considered.
There are three options for the basis of the If the programme is to be approved by a Part-
maintenance programme: CAMO or Part-CAO organisation, any deviations
from the DAH recommendations need to be
> Design Approval Holder (DAH) instructions
identified and justified with a copy of that
for continued airworthiness;
justification sent to the owner or operator.
> Minimum Inspection Programme (MIP) from This is the case even when the MIP is used
AMC1 ML.A.302 (d); or as the basis of the programme.
> Other MIP complying with ML.A.302 (d).
The ‘other MIP’ option allows the development
When considering which option to select, of an alternative MIP compliant with the
bear in mind that the MIP is exactly that, it is requirements of ML.A.302 (d). This would need
a regulatory minimum, generic in nature with detailed work to achieve and is not covered
no consideration of the specific aircraft being further in this publication.
operated (customisation of the MIP is covered
later on). There is no MIP for rotorcraft or airships
therefore the AMP basis must always be the
A DAH programme is specific to the type, even DAH data.
down to the sub-model and most likely has
incorporated numerous service difficulties that
have occurred on that type, therefore may carry
safety benefits over using the MIP. A useful way
of looking at the difference is to compare the
MIP against the DAH recommendations, paying
particular attention to the aircraft specific tasks
that the DAH has included.
If the programme is based on the MIP, Section 3 can be left empty, as the AMP assumes that the
latest MIP will be used from AMC1 ML.A.302 (d) or if the ‘other MIP’ option is used, it will be included
in Appendix A. Where based on the MIP, but individual DAH tasks are going to be added as desired,
these can be added as detailed in Section 4.
If the AMP is to be based on DAH ICA, the relevant data is listed in this section. It is important to list
all the data that is being used to schedule the maintenance. As an example, the TBO for an engine
is generally not listed as part of the maintenance documentation, but as part of a Service Instruction,
Letter or Bulletin.
It is important to capture all relevant DAH ICA data – this could include data from the DAH of
individual parts or appliances (such as avionics or revised safety harness designs) on that aircraft that
are subject to STC and/or European Technical Standards Order (ETSO). Individual DAH data should not
be assumed to take account of that from other manufactures unless specific cross reference is made.
Section 4 considers and includes additional maintenance requirements. It is this section that is used
to customise the programme to reflect the specific aircraft, configuration, operation etc.
Where tasks are applicable, the section is annotated “yes”, and the specific tasks are included
in Appendix B. In the following example, entries that might be typical of a GA aircraft have been made:
Additional maintenance requirements to DAH’s ICA or to the MIP (applicable to all AMPs)
Other No
Maintenance due to specific modifications are those tasks due to a change from the original type
design of the aircraft. ICA may have been issued by the organisation approving or embodying the
modification (e.g., CS-STAN), and these should be considered and included as appropriate. Some
Avionics manufacturers provide guides for installation in accordance with CS-STAN, which includes a
section on ICA. Modern avionics can include items such as back up batteries and routine navigation
database software updates therefore the specifics of these systems should be carefully considered.
A good example of maintenance due to specific modifications is vacuum pumps. The original
pumps were largely replaced with more modern units in the 80s and 90s. Many of these pumps
have inspection ports, inspection schedules and a recommendation to replace on the basis of
indicated wear. Given that loss of control is a common cause of accidents in GA, this example
illustrates the importance of properly identifying and considering maintenance recommendations.
Maintenance due to repairs could be a life limited repair or, repeat inspections that
are required by the manufacturers repair scheme when a particular repair has been performed.
Maintenance due to life-limited components (this should be only if the MIP is used.
Otherwise, this data is already part of the DAH’s data used as a basis for the AMP.)
This entry is generally only needed if the MIP is used because if the AMP is based on the
DAH data, the life limited components should already be included in the DAH data. Whether
using the MIP or DAH data, check that you have captured any life limited components in
products, parts or appliances on the aircraft, particularly if related to modifications.
On aircraft of a relatively new design, airworthiness limitations are well distinguished, reflecting
their mandatory nature. Depending on the original certification date of the aircraft or product, it
may not be obvious which airworthiness items should be considered mandatory for the purposes
of the AMP. A variety of terms have been used historically to indicate mandatory requirements:
> Airworthiness limitations or airworthiness limitation items (ALI)
> Certification maintenance requirements (CMR)
> Safe life items or safe life limits or safe life limitations
> Life-limited parts (LLP)
> Time limits
> Retirement life
> Mandatory inspections or mandatory airworthiness inspections
> Fuel airworthiness limitations or fuel tank safety limitations
It may not be possible to ascertain whether the original DAH intended a task to be mandatory or
what the consequence of discarding or reducing the frequency of a task may be. Particularly with
older aircraft, the absence of a mandatory designation in the ICA is not necessarily an indication that
disregarding a task is safe. Aircraft owners compiling their AMP should consult the DAH, a Part-CAO
or Part-CAMO organisation knowledgeable of the type or the CAA when making determinations in
this area.
An example of this may be the engine TBO. Service bulletins are often used to identify
an area that needs specific attention, and this information may not always be in the
DAH inspection schedule. Service bulletins should therefore be considered an essential
source of important airworthiness related type specific information. Although they
may not all be mandated by the issue of an AD, they should be considered.
Owners should also consider the economics of decision making. Disregarding a recommended
task or performing it less often might eventually lead to the replacement of an expensive part
that otherwise might have been subject only to a relatively inexpensive repair. It may also reduce
the value of the aircraft.
ADs for GA aircraft are often produced by the regulator in response to an accident or incident but will
always be in response to an identified unsafe condition. Often the AD will mandate compliance with
a manufacturers service bulletin, be that an inspection or modification. Where a task has already been
performed and is a single occurrence with no repeat requirement, it should be listed in the aircraft’s
records as having been complied with, but does not need to be included in the AMP. Only work that
has not been performed and repeat requirements need to be included in the AMP.
As an example, there may be special maintenance requirements related to IFR flight. If the
TCDS shows the aircraft capable of IFR flight, the DAH data should be consulted for more detail
(e.g., AFM, service information or maintenance manual). Part-NCO, NCO.IDE (Instruments,
Data & Equipment) should be consulted for equipment requirements relevant to the operation
or airspace. For example, if an ELT is required to be fitted, the AMP should include the battery
life or replacement schedule. For repeat tasks such as updating avionics navigation data,
these should be included in the AMP if not already within the DAH ICA being used.
This entry may not be relevant for normal Part-NCO operations, but for activities
such as glider towing or other specialised operations (NCO.SPEC or Part-SPO),
these may bring additional airworthiness considerations not covered elsewhere.
The impact of any specific operational approvals should also be included.
Other
This section can be used for any other task the owner or approved organisation wishes to add,
that is not covered by the above. Even if the MIP is used as a basis for the AMP, the owner could
still elect to add desired DAH tasks using this section. For example, the owner may wish to
add more frequent tail wheel maintenance when operating from a bumpy strip or include more
corrosion inspections due to the the UK’s damp and often saline environment. This section is for
the owner to consider what else may be needed to keep the aircraft in an airworthy condition.
If there are any tasks in the AMP that are alternative to the DAH ICA, “yes” must be annotated in
Section 5. The individual alternative tasks must then be listed in Appendix C.
Maintenance tasks alternative to the DAH’s ICA (not less restrictive than MIP)
An example of a possible ‘false economy’ may be operating beyond engine TBO. If the engine is
overhauled having exceeded TBO by a considerable margin, you may find that additional parts of the
engine have worn beyond specification and need replacement. Whereas an overhaul at TBO may
require less replacement of parts. Timely interventions may be economically more efficient over the
long term.
The table below gives some examples of when deviations from ICA task intervals are permitted.
If the MIP permits a deviation from the DAH ICA recommended task or interval, the owner or CAMO
must consider the possible safety impact.
The table below lists some factors to consider and indicates scenarios in which deviations from the
DAH ICA may represent a higher risk.
*ACAM refers to Aircraft Continuing Airworthiness Monitoring inspections - these are carried out by the UK CAA or
other national aviation authorities. A 'finding' refers to a non-compliance identified during the inspection.
*For aeroplanes, ELA1 includes an aircraft with a Maximum Take-off Mass (MTOM) of 1200 kg or less that is not
classified as a “complex motor-powered aircraft”.
Where a Part-CAO or Part-CAMO organisation is contracted, in approving the AMP they must identify
and justify any deviations from the DAH data (including if they use the MIP). A copy of the deviations
and associated justifications must be provided to the owner.
Where the owner is managing the aircraft and declares the AMP, they are not required to justify the
deviations, however it may be useful for future reference to document any research and justifications
for deviations that have been included.
CAP 747 Generic Requirement 17 (Propellers) and Generic Requirement 24 (Engines) no longer
apply to Part 21 aircraft under Part-ML. Deviations from recommended overhaul periods must be
considered in accordance with the AMP and MIP framework.
Where it is intended for pilot-owner maintenance to be performed, the details of the pilot-owner(s)
performing the work should be entered into this section. In the event of multiple pilot-owners,
the names may be listed separately. See the separate section in this guidance covering
pilot-owner maintenance.
Remark: pilot-owner maintenance is not allowed for aircraft operated by commercial ATO/DTO
If yes, enter the name of the pilot-owner(s) authorised to perform such maintenance:
Pilot-owner maintenance is only permitted for aircraft not used commercially. A way to think of
it is that pilot-owner maintenance cannot be performed on an aircraft where Part-ML requires a
CAMO contract.
Signature: Signature:
The Part-ML AMP can be either approved or declared and the distinction is simple. If the aircraft is
managed by a Part-CAMO or Part-CAO organisation, that organisation must approve the AMP. If the
aircraft is not formally managed by a Part-CAMO or Part-CAO organisation, the owner must declare
the AMP. The AMP is not valid until it has been declared or approved.
“I hereby declare that this is the maintenance programme applicable to the aircraft referred to in
block 1, and I am fully responsible for its content and, in particular, for any alternatives tasks to
the DAH’s data.”
The organisation or person approving or declaring the AMP must keep it updated.
Certification statement
Owner/Lessee/operator: x CAMO/CAO:
Telephone/fax:
E-mail:
Signature:
Date: 12/08/2022
The certification statement is confirming that the person or organisation responsible will maintain the
aircraft in accordance with the AMP and that it will be reviewed and updated as required.
Appendix A x
Appendix B x
Appendix C x
Appendix D x
This section indicates the appendices that form part of the AMP. For the example given, there will
be no appendix A because the AMP is based on the DAH data. Appendix A would only be used if
the “other MIP” option was to be used, then the tasks from the “other MIP” would need to be listed.
There will be an Appendix B because additional maintenance requirements have been identified. An
appendix C is included because there is at least one task alternative to the DAH recommendations.
It is important to remember that the AMP is not a live status report, it is a document that sets out the
maintenance to be performed and the frequency it is to be performed at. The frequency or interval for
GA aircraft is normally expressed in hours or calendar time. Some tasks may be tracked by landings
or airframe cycles, so it is important to know what needs to be tracked. This information should be
found in the document used as the basis for the programme. Examples of completed appendices
B & C are below.
Appendix D can be used to provide additional information and there are no specific requirements for
its content. It could be used to provide a complete list of AMP tasks, or it could be used to list all of
the documents reviewed to create the programme. Use of Appendix D is optional.
Detail the tasks and inspections contained in the MIP being used.
This appendix is supposed to include only the tasks which are included in the AMP, either at the
recommended interval or at a different one.
(All repetitive maintenance tasks not included here, or the interval differences should be kept by the
CAMO/CAO (when contracted) in their files with their corresponding justifications. Appendix D may
optionally be used. Nevertheless, the owner/CAMO/CAO is responsible for taking into account all
instructions, even if they are not adopted and listed here. The person performing the AR, if reviewing
the AMP, is not responsible for the completeness of this appendix, but may do some sampling as
part of the investigations and the findings discovered during the physical review).
Maintenance due to life-limited components (This should be only if the MIP is used.
Otherwise, this data is already part of the DAH’s data used as the basis for the AMP.)
Maintenance recommendations, such as time between overhaul (TBO) intervals, issued through
service bulletins, service letter, and other non-mandatory service information
Other
Appendix C — Maintenance tasks alternative to the DAH’s ICA (not less restrictive than MIP)
(include only if necessary — see Sections 5 above)
When the DAH’s ICA are used as the basis for the AMP, this appendix is supposed to include only
the task’s alternatives to the DAH’s ICA, which are included in the AMP.
(When a CAMO/CAO is contracted, all elements justifying the deviations to the DAH’s ICA should
be kept by the CAMO/CAO and the organisation should provide a copy of these justifications to
the owner)
This appendix may optionally be used to provide additional information, such as the complete list
of AMP tasks or the list of documents (e.g. service bulletins) considered during the development
of the AMP.
PRACTICAL
CONTINUING
AIRWORTHINESS
CHAPTER 4: PRACTICAL
CONTINUING AIRWORTHINESS
Introduction
Chapter 1 established that the key to continuing For group owned aircraft, best practice is to
airworthiness management was the effective appoint a willing coordinator in the group to
management of the following items: manage the aircraft and serve as the single
point of contact between the group and the
> Accomplishment of pre-flight inspections;
maintainer and/or CAMO organisation. It is
> Rectification of defects and damage in important to set group rules for responsibilities
accordance with approved data; and agreement on financial decisions, this will
> Accomplishment of repairs and modifications avoid misunderstandings within the group or
in accordance with approved data; with the maintainer. It is important that the
nominated person within the group has the time
> Performing the maintenance as required by
and competence to effectively manage the tasks.
the maintenance programme;
> Accomplishment of any applicable mandatory Whilst this document is predominantly technical
requirement; and in its nature, financial planning for ongoing
> Performing maintenance check flights. maintenance and major costs should also be
considered. Good practice could include an
This chapter explores in more detail how this is engine fund, noting that the engine overhaul or
achieved, explains some of the key points and replacement is usually the biggest cost of GA
terms used and links to other resources that aircraft ownership.
may be helpful to owners when either managing
their own aircraft or entering into a continuing Reference: ML.A.301
airworthiness management contract with a Part-
CAMO or Part-CAO organisation.
Pre-flight Check
Foremost in the pre-flight checklist is making
sure that the aircraft is airworthy and fit for
Key info !
the intended flight. The pre-flight check is not The pre-flight check can become very routine,
considered a maintenance check therefore no but it must not be overlooked - it is the last
certificate of release to service is required. opportunity to identify an unsafe condition that
could result in an inflight emergency.
This section deals with the aircraft element of
the pre-flight check, it does not address pre-flight
planning or operational elements. The pre-flight check should never be rushed.
Many people involved in GA will recall incidents
The pre-flight check should include a walk around and accidents involving tow bars, pitot covers,
inspection of the aircraft and its equipment for control locks, incorrect weight and balance or
general condition. Guidance for this activity will insufficient fuel for the flight.
be found in the AFM, and normally includes
checking the following:
WEIGHT & BALANCE
> External surfaces are free of ice, snow, sand,
dust, and any other surface contaminant; The accuracy of weight and balance calculations
highlights an important relationship between the
> Tie downs have been removed and secured;
airworthiness and operation of the aircraft.
> Surface locks, tow bars, sensor covers,
and aperture blanks have been removed It is important that pilots conduct weight and
and stowed; balance calculations before flight, to ensure
> Engine oil / hydraulic oil content; that the aircraft remains within its certified
> Correct tyre inflation and oleo extension; weight and balance envelope. In order for those
calculations to be correct, the basic weight and
> Fuel content, free from contamination and
centre of gravity of the empty aircraft must also
sufficient for the intended flight and any
be accurate.
foreseeable diversion;
> Obvious signs of wear, damage, or leakage; If an aircraft has been subject to multiple
> The correct emergency equipment is present modifications or paint work, without updates to
and serviceable; the weight and balance schedule, there is a risk
> Weight and balance calculations, including that the aircraft may fly outside of the certified
performance of the aircraft, taking into envelope, even if the calculations may appear
account the aerodrome(s) being used; correct to the pilot.
> Any documents required are present and
valid; and “How confident are you in the basic weight
and centre of gravity figures for your aircraft?”
> Deferred defects and the impact on the
aircraft and its equipment.
Reference: ML.A.301
Managing Defects
If an aircraft is damaged or has a technical defect, The Minimum Equipment List (MEL) provides
it is important to ascertain how it might impact for the operation of an aircraft with specified
its operation. ML.A.403 states that “any aircraft equipment inoperative. It also specifies any
defect that seriously endangers the flight safety conditions that must be met when operating
shall be rectified before further flight”. in that condition. Normally an MEL is produced
by an aircraft operator and based on the Master
The following defects are permitted to be Minimum Equipment List provided by the DAH.
deferred, if the pilot has determined they do not
hazard flight safety: The Configuration Deviation List (CDL) is a list
established by the DAH which identifies external
> Defects affecting non-required
parts of an aircraft that may be missing at
aircraft equipment;
commencement of a flight (e.g., missing doors
> Defects when using the minimum equipment or panels). It also specifies any conditions (e.g.,
list or configuration deviation list (MEL / CDL); performance reductions) that must be considered
and when operating. A CDL is produced by an aircraft
> Any other defect where the aircraft is operator based on the CDL provided by the DAH.
operated under Part-NCO.
Most aircraft subject to Part-ML will not have
“All other defects may only be deferred by an an MEL or CDL provided by the DAH, although
approved organisation or ICS.” where they do exist, they must be used.
Managing Repairs
The initial damage assessment performed by Although repairs restore the aircraft to a
the repairer must establish the approved repair safe condition, unless they are repaired by
data to be used. The purpose of the repair is replacement of all affected components with
to restore the aircraft to an airworthy condition. those equivalent to original manufacture, the
Repair data will be either approved by the CAA, aircraft may not fully meet its original production
a design organisation approved under Part 21 or standard. Some repairs, particularly major repairs
via Standard Change or Repair (CS-STAN). The may include an ongoing repeat inspection to
following are common examples of repair data: assess the condition of the repair throughout the
remaining life of the aircraft.
> Maintenance Manual, Repair Manual or other
repair data approved and issued by the DAH;
Any previous repairs that may require repeat
> Part 21 Approved Data (Design Organisation); inspection should be considered in the context of
or the AMP customisation. Some major repairs may
> Standard Repair (CS-STAN). This may also require the aircraft to be reweighed to establish
allow the use of FAA Advisory Circular AC the new basic weight.
43.13 – 1B, although this should be checked
in CS-STAN before use. Good records of repairs are essential as without
them, it may not be possible to issue an
An owner managing their own aircraft is Airworthiness Review Certificate. Loss of
responsible for ensuring that the repair is these records may also devalue the aircraft,
performed in accordance with approved data. make it difficult to sell and in some cases
require the repair to be removed and a new
approved repair performed.
Managing Modifications
Modifications can increase the value and Some modifications introduce new ICA.
change the reliability, performance or aesthetics This may well require an update to the AMP
of an aircraft. Some modifications may be and relevant data will need to be shared
mandatory for particular airspace or operations with whoever is undertaking the applicable
(e.g., transponder or 8.33khz radio installations). maintenance tasks. Some modifications
Modifications to the aircraft must always introduce new operational equipment or impact
be approved. The approval signifies that the the performance of the aircraft, often requiring
modification meets the applicable design a flight manual supplement to be included in the
standards or certification specifications. AFM. Some modifications may require a new
calculation of the basic aircraft weight, including
Modification data will be either approved by a new weight and centre of gravity schedule or
the CAA, a design organisation approved under may require a physical reweigh of the aircraft.
Part 21 or be a Standard Change in accordance
with CS-STAN. The following are more common
STCS
examples of modification data:
> Service Bulletin Issued by the DAH FAA STCs are not automatically approved for
UK Part 21 aircraft, however many existing
> Part 21 Approved Modification
FAA STCs have been approved or validated
> Standard Change (CS-STAN) by the CAA or EASA. Depending on when the
> CAA Supplemental Type Certificate (STC) original validation was issued, it may or may
not be necessary for the FAA STC to be further
> FAA/EASA STC – see notes in the table
validated by the CAA before use.
During UK membership Validation of the FAA STC by EASA, and EASA STC issued.
of EASA
Post UK membership STC validation required by the CAA. This includes any changes made
of EASA (since 1st after 31st December 2020 to previously validated FAA STCs.
January 2021)
Managing Modifications
EASA STCs are not all automatically approved for UK Part 21 aircraft. In general, an applicable EASA
STC may be considered as accepted under the following circumstances:
Period of STC
Approval Basis
approval or validation
During UK membership STC approved by EASA with the issue of an EASA STC. STC continues
of EASA to be accepted by the CAA.
Post UK membership A new EASA STC has to be validated by the CAA, if it is classified as
of EASA (since 1st “significant” (Part 21,21.A.101).
January 2021)
For all “non-significant” STCs and changes to STCs that do not require
a CAA STC certificate change, these are accepted based on the EASA
approval.
The table relates to when the version of the EASA STC being embodied was approved. For example,
an STC approved during the UK membership of EASA remains approved and can be used for new
installations, as long as it has not changed since the UK ceased its EASA membership. In the case of
a new STC or change to an existing STC after the 31st December 2020, a direct CAA validation of that
change may be needed.
Complete records of modifications, including the approved data (e.g., STC) are essential as without
them, it may not be possible to issue an Airworthiness Review Certificate. Loss of these records may
also devalue the aircraft or make it difficult to sell.
Use of CS-STAN
Normally a modification or repair to an aircraft > Installation of carbon monoxide detectors
needs specific approval by either the DAH or > Camera installation
another approved design organisation. This is not
> Exchange of interior material
the case for a modification or repair contained in
CS-STAN. The latest UK version of CS-STAN is > Temporary repair of canopy cracks
available via the CAA website. > Aircraft repair in accordance with FAA AC
43.13-1B
The term ‘CS-STAN’ is essentially an abbreviation
for ‘Certification Specification - Standard’ and The individual Changes or Repairs are set out in a
covers both ‘Standard Changes’ (SC) and standard format:
‘Standard Repairs’ (SR).
Purpose – High level description of what the SC
When conducting a standard change or repair, or SR can or cannot be used for.
the ICS or approved organisation must follow
the applicable scope and procedure set out in Aircraft eligibility – Covers the aircraft that
CS-STAN. The ICS or organisation takes full the SC or SR can be embodied on, with any
responsibility for the change or repair being associated limitations (e.g., airspeed), class (e.g.,
compliant. rotorcraft / balloons / fixed wing) or complexity.
In some limited cases a pilot-owner may conduct Acceptable methods, techniques and
a standard change or repair. The individual practices – The technical detail of the SC or SR
change or repair procedures will state whether (e.g., equipment specification, conditions for the
pilot-owner release to service is acceptable. use of the SC or SR, testing, other applicable
airworthiness standards).
A Standard Change or Repair cannot be
embodied when that change or repair conflicts Limitations – Any limitations that are applied to
with the applicable DAH data. the SC or SR (e.g., technical and or operational
limitations).
Standard Repairs cannot normally be used if
an appropriate DAH repair already exists. The Manuals – Details relating to the aircraft
conditions of use for a Standard Change or manuals (e.g., requirement to update to flight
Repair should be carefully reviewed. manual, requirement to update the ICA).
CS-STAN has been developed over several Release to Service – Defines the level of the
years and now contains over fifty changes release to service, usually indicating if the SC or
and repairs including: SR is suitable for pilot-owner release or not.
> Exchange of conventional lights for
LED lights
Reference: Part 21, 21.A.90B, 21.A.431B; UK
> Battery Exchanges CS-STAN; Part-ML, ML.A.304
> Installation of FLARM equipment
> Exchange of avionics equipment
Use of CS-STAN
RESPONSIBILITIES RECORD KEEPING
In a normal repair or modification, the designer The CAA Form 123 should be used to record the
is responsible for compliance of the design with SC/SR embodied, including any data used. The
applicable CS and the installer is responsible for aircraft logbook should contain an entry referring
the embodiment of the modification or repair. In to the Form 123. Both the Form 123 and the
the case of CS-STAN, the installer is responsible release to service required after the embodiment
for full compliance with the CS-STAN SC or SR of the SC/SR should be signed by the same
as well as physical embodiment of the repair or person. It should also be signed in the final block
modification, including identifying any conflict by the owner, signifying that they have received
with the existing aircraft configuration and all relevant documentation and most importantly
modification status. any additional ICA or updates to the AFM.
The normal requirements under Part-ML for Complete records of modifications are essential
acceptance of parts used in changes and repairs as without them, it may not be possible to issue
still apply to those made under CS-STAN. an Airworthiness Review Certificate. Loss of
these records may also devalue the aircraft or
The person responsible for the embodiment of a make it difficult to sell.
change or a repair should compile details of the
work accomplished. In the case of SCs/SRs, this Reference: ML.A.305, ML.A.801
would typically include items such as:
> Parts list and documents (e.g., CAA Form 1)
> Drawings
> Test reports / results
> Instructions for continued airworthiness (ICA)
and flight manual supplements
> Any other relevant documentation
> Work record
ADs for GA aircraft are often produced by US FAA: U.S. Federal Aviation Administration
the regulator in response to an accident or Regulatory and Guidance Library
incident but will always be in response to (govdelivery.com)
an identified unsafe condition. Most often
the AD will mandate compliance with a EASA: EASA information hub (europa.eu)
manufacturer’s service bulletin, be that an
inspection or modification. Reference will need to be made to CAP 747 to
establish the applicable ADs for the particular
An Operational Directive or measure required aircraft, engine, propeller and equipment.
by the CAA as an immediate reaction to a safety There are some tables that identify
problem will most likely be issued as a Safety the applicable ADs dependent on status of
Directive. the aircraft.
AD – Due date after the next maintenance AD added to the work order for the next
opportunity. maintenance opportunity. AD planned and
accomplished according to AD requirements.
A similar process would need to be followed in the event of an applicable Generic Requirement or
Operational Directive being issued.
Applicability
GR *Basis of
Title Part 21 Non-Part
No. Applicability
Aircraft 21 Aircraft
4 Electrical Generation Systems – Yes Yes 1 and 2
Aircraft Not Exceeding 5,700 kg
Maximum Authorised Weight
Aircraft Records
Correct records demonstrate where the Where an AD has been previously complied with,
aircraft is in the maintenance cycle, repairs, the AD status should give the details, not simply
modifications, component replacements, state ‘PCW’ (Previously Complied With).
mandatory requirements etc and assist
> Current status of service life
maintainers or management organisations.
limited components:
If the aircraft passes from one maintainer or
management organisation to another, it is vital
This should include the CAA Form 1 or
that complete records are transferred with the
equivalent and a logbook / log card containing
aircraft. Missing or incomplete records can
the component identification, aircraft / engine /
have a significant impact on the value of the
propeller details to which the component is fitted,
aircraft may require that maintenance or repairs
installation and removal details, accumulated
are repeated.
flight time, landings, cycles and calendar
time as applicable to the component and the
All entries are required to be clear and accurate, current status of compliance with mandatory
with any corrections made in a manner that requirements (e.g., ADs).
clearly shows the original entry. The person
or organisation managing the aircraft are > Current status of modifications and repair
responsible for maintaining the required records. > Current status of compliance with the AMP
> Current list of deferred maintenance
PART-ML REQUIREMENTS
ML.A.305 specifies retention periods for the
ML.A.303 details the records to be kept: above records. When records are only kept
electronically, the IT system used should have
> Aircraft, Engine & Propeller Logbook, at least one backup system and should contain
containing the aircraft type, registration, safeguards against unauthorised altering of the
date, total flight time, cycles and landings. information.
Any maintenance CRS must be entered
into the records system as soon as
If an aircraft is managed by an approved
possible but not later than 30 days
organisation, a good question for the owner
after completion of the maintenance.
to ask that organisation is “how, and in what
> Current status of mandatory items conditions will the logbooks and aircraft records
(ADs, GRs, Operational Directives): be stored?”. The insurance status of the
organisation may be another consideration.
This is sometimes referred to as an AD status list.
It may be permissible to split the completed ADs
Reference: ML.A.305
from the repeat ADs, but the person reviewing
the records should be able to determine the AD
status from the information available, therefore
individual and separate AD logbook entries
would not constitute a “current status”. ADs
applicable to an aircraft type or component may
not always be applicable to a specific airframe of
that type. In this case the AD status should still
be recorded in the AD status list, accompanied
by the reason the AD does not apply.
Selecting a maintainer
When selecting a maintenance organisation, As with placing any business, discussing options
or authorised ICS, several factors need to be and experience with other owners might be
considered. There are the usual things such as useful, as would asking the maintainer about
location, convenience, reputation, quality of work their specific experience with the aircraft type
and price but from the perspective of managing concerned, especially where the aircraft is niche
the airworthiness of the aircraft, there are other or has different construction methods such as
things to consider. wood, fabric or composite.
Selecting a maintainer
The extent of the work required may also > Agree a work scope in writing, ensuring any
determine the options for where it is carried out. additional work is accurately defined and
Part-ML removed the restriction on ICS carrying quotation for performing the work is clear,
out complex tasks, however in the absence of with method and time of payment defined
a dedicated maintenance hangar, it may not be and agreed;
possible to perform the depth of work required > Agree the workshop where major parts are
and an approved organisation may be more being sent (e.g., factory overhaul, overhaul),
appropriate. These are all judgments to be made Consider reputation of workshop for the
and sensible areas to investigate and question. specific component;
> Agree cost limits for additional work, so
Another consideration is the way the work is
where desired, authorisation is granted
approached. Whilst all organisations should
by the customer before the work is
meet the minimum standards required by the
commenced or parts ordered;
regulations, there may be different approaches
between maintainers. A visit to the organisation > Agree if used parts need to be retained for
would be beneficial prior to placing the work, the owner to view or can be disposed of;
to meet the staff that will be working on the > Confirm arrangements for insurance of the
aircraft and get a sense of how they operate. aircraft during maintenance and liability for
When delivering the aircraft for maintenance, it the work performed;
is a good idea to conduct a walk around of the > Agree where the supplied records (e.g.,
aircraft with one of the maintenance personnel. logbooks) are going to be kept while the
This will ensure a better common understanding aircraft is with them;
of the work required.
> Agree the level of maintenance record
that will be provided to the owner. Whilst
When placing work with a Maintenance
the CRS, log statement and a copy of
Organisation or ICS, consider the following:
component Form 1s could be considered as
> Ensure their ethos is compatible with yours. normal, it is not unusual for a maintainer to
Are you comfortable with the organisation retain the detailed work pack and not provide
and people performing the work, experience a copy to the owner. The record to be
on type and general knowledge of the provided should be agreed when negotiating
aircraft. Consider recommendations from the work; and
other owners; > Consider and record how disputes and
> Confirm who provides the maintenance disagreements might need to be resolved.
manuals, to ensure that work is correctly
completed;
> Ensure that the organisation is approved to
perform the work (or ICS is appropriately
licensed to perform the work);
> Agree a date for the work to be performed,
a time frame for the work and deliver
the aircraft in person to the maintainer’s
premises. Walk around the aircraft with the
ICS or organisation staff after arriving;
Pilot-owner Maintenance
Key info ! INSPECTION FOR DEFECTS
The pilot-owner must hold the appropriate level Whilst performing pilot-owner maintenance,
of competence to perform the task and be good practice is to identify defects (such as
familiar with both the maintenance procedures corrosion patches) for rectification at the next
and the aircraft’s AMP. maintenance visit and make a record of them
so that they don’t get missed. If unsure about
a possible defect, a qualified ICS or approved
The pilot-owner can only perform simple visual organisation should be consulted before further
inspections or operations to check the airframe, operation.
engines, systems and component for general
condition, obvious damage and normal operation.
CORROSION
Appendix II of Part-ML contains a full list of
possible pilot-owner tasks for the different types It is worth noting that corrosion is a defect
of aircraft, including more detailed guidance on and is never an acceptable ongoing condition.
the requirements and limitations. Identification and treatment of corrosion on
metal aircraft needs constant vigilance. Even
The pilot-owner is responsible for any apparently superficial surface corrosion must not
maintenance that they perform and must be ignored since it may progress to structural
limit themselves to those tasks for which implications and put the aircraft beyond
they are competent. economic repair. Corrosion on the aircraft
skin may already have progressed to hidden
A pilot-owner can only perform and release extensive (and expensive) damage behind that
maintenance if they hold a pilot licence issued or skin on other parts of the aircraft structure.
validated by the CAA which includes the relevant The CAA have produced CAP 1570, Corrosion
type or class rating for the aircraft. They must and Inspection of General Aviation Aircraft, a
own the aircraft as a sole or joint owner and document that contains extensive information on
be named on the aircraft registration (for group the subject.
ownership this could be the trustee grid form
CA04). The pilot-owner performing and releasing
the work must be named in the AMP.
Pilot-owner Maintenance
PROHIBITED TASKS include details of the work performed and the
maintenance data used. The requirement is that
Tasks involving any of the following cannot be at the end of the work, the owner should have a
performed by a pilot-owner: clear and legible record of the work performed.
The release should include the name of the
> A critical maintenance task;
pilot-owner and be signed with the pilot-owners
> Requires the removal of major components normal signature, including the pilot’s licence
or a major assembly; number. The wording is slightly different from a
> Is carried out in compliance with an AD or standard CRS:
an airworthiness limitation item (ALI) unless
specifically allowed in the AD or the ALI; “certifies that the limited pilot-owner
> Requires the use of special tools or maintenance specified, except as otherwise
calibrated tools (except for torque wrench specified, was carried out in accordance
and crimping tool); with Part-ML, and in respect to that work,
the aircraft is considered ready for release
> Requires the use of test equipment or
to service.”
special testing (e.g., non-destructive testing,
system tests or operational checks for
It should be remembered that this release to
avionics equipment);
service is stating that the work was carried out in
> Is composed of any unscheduled special accordance with Part-ML. The release must be
inspections (e.g., heavy-landing check); issued prior to further operation of the aircraft.
> It affects systems essential for the
instrumental flight rules (IFR) operations; If the aircraft is managed by a Part-CAMO
> A complex maintenance task in accordance or Part-CAO organisation, a copy of the
with Appendix III of Part-ML, or it is a documentation and the CRS must be forwarded
component maintenance task in accordance to that organisation within 30 days of the pilot-
with point (a) or (b) of point ML.A.502; and owner maintenance task being performed.
> Is part of the 100-h/annual check.
Key info !
Aircraft not operated in accordance with
Part-NCO or aircraft operated by a commercial Appendix III of Part-ML gives a list of
ATO/DTO are not eligible for pilot-owner complex tasks that can only be certified by
maintenance. Any pilot performing maintenance independent certifying staff or approved
of commercially operated aircraft must be organisations. It may be possible for the
appropriately authorised by a Part-145 or Part- pilot / owner to work under the supervision
CAO maintenance organisation. of a suitably qualified person or organisation.
Abbreviations
AC CAMO EASA ICAO
FAA Advisory Circular Continuing European Aviation International Civil
Airworthiness Safety Agency Aviation Organisation
AD Management
Airworthiness Organisation ELA ICS
Directive European Light Aircraft Independent
CAO Certifying Staff
AFM Combined ELT
Aircraft Flight Manual Airworthiness Emergency Locator IFR
Organisation Transmitter Instrument
ALI Flight Rules
Airworthiness C of A ETSO
Limitation Item Certificate of European Technical LAE
Airworthiness Standard Order Licensed Aircraft
AMC Engineer (See
Acceptable Means CDL EU also ICS)
of Compliance Configuration European Union
Deviation List LAMP
AMP FAA Light Aircraft
Aircraft Maintenance CS Federal Aviation Maintenance
Programme Certification Administration Programme
Specification (CAA LAMP –
AOC FLARM now withdrawn)
Air Operators CMR Traffic Awareness and
Certificate Certification Collision Avoidance LED
Maintenance technology Light Emitting Diode
ARC Requirement
Airworthiness GA LLP
Review Certificate CRS General Aviation Life Limited Part
Certificate of
ATO Release to Service GAU MCF
Approved Training UK CAA General Maintenance
Organisation CS-STAN Aviation Unit Check Flight
Certification
BCAR Specification for GM MEL
British Civil standard changes Guidance Material Minimum
Airworthiness and repairs Equipment List
Requirement GR
DAH Generic Requirement MMEL
CAA Design Approval Master Minimum
UK Civil Aviation ICA Equipment List
Holder
Authority Instructions
DTO for Continued MIP
CAE Declared Training Airworthiness Minimum Inspection
Combined Organisation Programme
Airworthiness
Exposition
80
CAA / October 2022
Abbreviations
MOR SPO
Mandatory Specialised Operations
Occurrence Report
SR
MTOM Standard Repair
Maximum (CS-STAN)
Takeoff Mass
SSC
MTOW UK CAA Shared
Maximum Service Centre
Takeoff Weight
STC
NCO Supplemental
Non-commercial Type Certificate
operations with other
than complex motor- TBO
powered aircraft Time Between
Overhauls
NCO-IDE
Part-NCO – TCDS
Instruments, Data Type Certificate
& Equipment Data Sheet
NDT TSO
Non-Destructive Technical Standard
Test (e.g., Ultrasonic Order
/ Eddy Current)
VFR
POH Visual Flight Rules
Pilots Operating
Handbook
SAS
Specific Airworthiness
Specification
SB
Service Bulletin
SC
Standard Change
(CS-STAN)
SI
Service Instruction
SL
Service Letter
81