Contracting CAM - Revolution or Evolution ir. Erik MOYSON Director - - PowerPoint PPT Presentation

Contracting CAM - Revolution or Evolution

• ir. Erik MOYSON

Director Safety & Operations erik.moyson@iaca.be Workshop Contracting Continuing Airworthiness Management EASA, 28 June 2012, Cologne, Germany

IACA member airlines

• are CAT AOC holder
• Commercial Air Transport
• Air Operator Certificate
• 32 airlines, 800+ aircraft
• are CAMO approved (Part-M.G )
• may (sub)contract some CAM tasks
• no CAM contracted to organisations not established

as CAT technical organisations (i.e. no subcontract)

• do contract CAM tasks to organisations that are

established CAT technical organisations

• CAMO of CAT AOC provides CAM services to

subsidiary operators as well as external operators

• decision / follow-up and general oversight

remains responsibility of contracting operator

IACA member airlines

• Real (dynamic) vs ideal (steady state) world
• small operators
• start-up operations
• introduction new aircraft / engine type
• Synergy (financial & quality)
• subsidiary operators
• group of operators with separate AOC but under the

same ownership structure

• Continuity
• lease organisations to maintain expensive assets

compliant with standards and regulations

• lessee contracts CAM to CAMO of CAT AOC lessor

Reasons for contracting CAM

• Small operators and Start-up operations

typically contract all CAM tasks

• Medium size operators

typically contract specific CAM tasks:

• AD/SB evaluations
• maintenance program development & upkeep
• reliability control
• engine condition monitoring
• Large operators
• share/pool CAM activities per aircraft / engine type
• contract each other or

affiliated engineering organisations

Extent of CAM contracts

• Organisational
• keep the organisation small
• no need to invest in specialised / scarse knowledge
• Financial
• economy of scale
• small operators can hardly afford specialised staff
• Operational and technical quality
• 24/7 available specialised staff
• benefit using a/c and engine type experienced CAMO
• larger sample allows for better statistics
• Leasing
• CAM contracted to lessor (continuity CAM)

by lessee (no Part-M.G required)

Advantages contracting - operator

• Quality and monitoring
• extend quality system to unapproved organisation
• Oversight
• perators’ oversight limited to tasks subcontracted
• ‘‘dedicated’’ staff, per audit to another CAT AOC
• Organisational
• required level of capability, contradicting reason for

subcontracting

• Complexity
• subcontracting to non-approved organisation is more

complex than contracting to approved organisation

Disadvantages subcontracting - operator

• Financial
• economy of scale, similar to increasing own fleet
• contracted CAMO can work more efficiently
• Expertise
• center of excellence
• pooling of technical and reliability data makes for better

statistics

• No duplication
• does not experience additional oversight when

contracted by more CAT AOC operators

Advantages contracting – contracted CAMO

• Duplication
• multiple audits by different contracting operators
• Complexity
• unapproved organisations have no established

(approved) procedures of their own

• but have to work under the procedures of the

(different) contracting operators

Disadvantages subcontracting – “camo”

• Oversight
• rganisations are subject to oversight related to their

Part-M.G approval

• Quality
• center of excellence aircraft / engine type
• better quality CAM tasks by contracted CAMO than by

smaller operator

• pooling of technical and reliability data makes for better

statistics

• Lease out
• continuity CAM when contracted by lessee to lessor
• aircraft stays in same controlled environment

Advantages contracting - authority

• Number of subcontracted organisations
• not limited, approve / accept each set-up
• Authority control and Oversight
• unapproved organisation not subject to oversight
• versight by subcontracting operator is less effective
• Duplication
• multiple audits per subcontracting operator
• Responsibilities
• perators (without proper resources) subcontract CAM

to unapproved organisations (who are not accountable)

• Complexity
• subcontracting to unapproved organisation is

more complex than contracting to approved

Disadvantages subcontracting - authority

• Operators
• ften subcontract all CAM tasks without extending

quality system due to lack of technical expertise

• Oversight of unapproved organisations
• efficacy quality audits alone as oversight questionable
• perators may rely on others for oversight
• Contracting to Part-M.G
• has not created safety issues, as CAMO is approved

and has technical infrastructure and staff

• Management Continuing Airworthiness must be robust
• hence, should stay with approved organisations and
• versight by their competent authorities

Shortcomings of subcontracting CAM

Summary contracting CAM

contracting

• perator

contracted CAMO competent authority to unapproved

• rganisations

Quality and monitoring Oversight Complexity Duplication Complexity Oversight Duplication Responsibility Complexity to approved

• rganisations

Organisational Financial Operational and technical quality Leasing Expertise Financial No duplication Quality Continuity reason Start-up New type Group Synergy Expertise

1. Commercial Air Transport 2. support contracting CAM, but NPA was too complex 3. CAM shall only be performed by approved organisations 4. disconnect Part-M.G CAMO from AOC 5. rewrite Part-M to change default position

• where ‘‘CAMO is integral part of AOC’’
• to ‘‘minimum organisational requirements to manage

contract with a CAMO’’ 6. flexibility

• Option A : manage contract with CAMO
• Option B : in-house CAMO
• Option C : combination, per fleet (*)

(*) considering continuity CAM for short-term leases

IACA view

• Revolution ?
• fundamental change in a relatively short period ?
• CAT AOC holders have been contracting all/some

CAM tasks for some time

• Evolution ?
• gradual change over a longer period ?
• Contracting CAM is not new
• early 70s, introduction of wide boy aircraft
• AF/AZ/IB/LH/SN pooled engineering & maintenance

A300, A310, B747, DC10 (ATLAS)

• KL/SK/SR/UT pooled DC10 (KSSU)
• Evolution of regulatory environment
• from national to harmonisation at EU level

Contracting CAM: Revolution or Evolution

Thank you for your attention