CAP2400S Airworthiness Code - Interactive

AIRWORTHINESS
A MAINTENANCE GUIDE FOR
Light Aircraft
CAA / October 2022
CHAPTER 1: INTRODUCTION
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Published by the Civil Aviation Authority, First Published, October 2022

2022 Version 1, October 2022
CHAPTER 2: RESPONSIBILITIES
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CHAPTER 3: PART-ML MAINTENANCE

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CHAPTER 4: CONTINUING AIRWORTHINESS
Airworthiness Code / Notes 02

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
Airworthiness Code / Contents 03

CAA / October 2022
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

Airworthiness Code / Contents 04

CAA / October 2022
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
Airworthiness Code / Intro 05

CAA / October 2022
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.
The publication primarily addresses:
> Part 21 aeroplanes and rotorcraft subject to the Part-ML regulation; and
> Part 21 aircraft operating on an enduring permit to fly.
The aim is:
BETTER INFORMED OWNERS SAFE AND INFORMED

AND OPERATORS AIRWORTHINESS DECISIONS
Readers should understand that the publication is a guide and not a

definitive statement of the law. In some places the legal text has been
paraphrased for the purpose of clarity and explanation.
References to source regulations are made throughout this guide

and include any associated acceptable means of compliance,
certification specifications and guidance material.
i Part-ML and Part-CAO information and

UK regulations can be found at caa.co.uk.
Airworthiness Code / Intro 06

CHAPTER 1: THE AIRWORTHINESS SYSTEM CHAPTER 2: RESPONSIBILITIES CHAPTER 3: PART-ML MAINTENANCE CHAPTER 4: CONTINUING AIRWORTHINESS
07
Airworthiness Code / Chapter 1
AIRWORTHINESS
SYSTEM
THE
01.
CAA / October 2022
CAA / October 2022
CHAPTER 1: 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 Subject Nature
Annex I – Part-M Continuing Airworthiness for Complex Airworthiness

Motor-Powered Aircraft and / or aircraft Requirements
used as part of a Licensed Air Carrier
Annex II – Part-145 Maintenance Organisation Requirements Organisation Approval
Annex III – Part-66 Aircraft Maintenance Licence Personal Qualification
Annex IV – Part-147 Aircraft Maintenance Training Organisations Organisation Approval

(Basic Training & Type Training)
Annex Va – Part-T Part T – Aircraft Registered in a Airworthiness

Third Country, short term leasing Requirements
– airworthiness requirements
Annex Vb – Part-ML Continuing Airworthiness Airworthiness
for Light Aircraft Requirements
Annex Vc – Part-CAMO Continuing Airworthiness Organisation Approval

Management Organisation
Annex Vd – Part-CAO Combined Airworthiness Organisation Organisational

Approval
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.
Airworthiness Code / Chapter 1 08

CAA / October 2022

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.

CAA / October 2022

Key Regulations
CONTINUING AIRWORTHINESS (CONTINUED)
Part-CAO (continued) Part-CAMO

The privileges of a Part-CAO organisation could Part-CAMO is the equivalent of Part-CAO for
include both Part-M (for example fixed wing non- organisations managing the airworthiness
complex motor-powered aircraft up to 5700kg) of aircraft that are not covered by Part-ML.
and Part-ML aircraft. Part-CAMO replaced the Part-M, subpart G
organisations. Unlike a Part-CAO approval,
In this case the organisation must have
the Part-CAMO does not have a maintenance
appropriate privileges included on the
privilege. Complex motor powered aircraft or
approval certificate (Form 3-CAO) and
aircraft on the AOC of a licensed air carrier
exposition procedures covering both
must be maintained by a Part-145 organisation.
Part-M & Part-ML aircraft.
Although aimed at the more complex aircraft
The organisation will be described in the and operators, a Part-CAMO organisation with
Combined Airworthiness Exposition (CAE), appropriate privileges can manage light aircraft in
including how it will operate in compliance with accordance with the Part-ML requirements.
the Part-ML / Part-M regulations.
A Part-CAO organisation may in some
circumstances authorise commercial Part-145
pilots for specific and limited maintenance
tasks away from the home base of the aircraft’s A Part-145 approval is a standalone maintenance

operator. This should not be confused with organisation approval. In some limited cases
pilot-owner maintenance, but is maintenance it can include the privilege to perform an
performed by a commercial pilot based on an airworthiness review and issue an airworthiness
authorisation issued by the organisation. review certificate (ARC) for Part-ML aircraft. A
Part-145 organisation without an appropriate Part-
CAMO or Part-CAO cannot perform continued
airworthiness management under contract.
Part-M
A Part-145 organisation may authorise
Part-M now effectively applies to all aircraft not commercial pilots for specific and limited
covered by Part-ML and is only discussed further maintenance tasks on aircraft away from the
to give context. Previously Part-M applied to all home base of the aircraft’s operator. This should
aircraft, with some alleviations for GA aircraft. not be confused with pilot-owner maintenance,
Part-ML is a standalone annex and Part-M but is maintenance performed by a commercial
requirements do not apply to aircraft that are pilot based on an authorisation issued by the
subject to Part-ML. organisation.

CAA / October 2022

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.

CAA / October 2022

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.
ACCEPTABLE MEANS OF COMPLIANCE

RETAINED EU LAW
Acceptable Means of Compliance (AMC) and
Part-ML and the other regulations detailed in this Guidance Material (GM) is designed to assist
guide originally applied in the UK via EU law. Under the reader in understanding and complying with
the terms of the European Union (Withdrawal) Act the regulations. AMC sets out the more detailed
2018, such regulations transfered into UK law at means by which compliance may be achieved.
the point at which the UK left the EU. GM typically assists in understanding the
meaning and interpretation of an implementing

Unless otherwise specified, references to rule.
regulations in this guide are to the version in force in
the UK. Readers should ensure that they refer to the AMC is sometimes referred to as ‘soft law’. To
UK version of any regulations or associated AMC or provide uniform implementation, the CAA has
GM, since it may differ from that of the EU. decided that AMC will constitute a means by
which the requirements in the applicable retained
EU legislation can be met. However, compliance
FINDING REGULATIONS may be demonstrated by other means.
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.

CAA / October 2022

Design and Manufacture

The design and certification of aircraft and related The state which has jurisdiction over the DAH is
products is referred to as Initial Airworthiness. known as the ‘state of design’.
Whilst the focus of this guide is on continued
airworthiness and maintenance, some When an individual aircraft is manufactured the
understanding of initial airworthiness concepts will new aircraft is issued with a ‘Form 52’ which
be useful for the owner or operator of an aircraft. certifies conformity to the type design. It also
confirms the aircraft is in a condition for safe
operation and has been satisfactorily flight
AIRCRAFT CERTIFICATION
tested.
The Certificate of Airworthiness (C of A) is an
internationally recognised standard and a legal ORPHAN AIRCRAFT
requirement for most aircraft to fly. To be eligible for
a C of A, an aircraft must normally be in conformity Type Certificates are sometimes surrendered by
with a certified aircraft type design. the DAH. The affected aircraft are often referred
to as ‘orphans’. Normally the loss of the DAH
The high-level framework for certified aircraft is would render the C of A invalid. However, a
established through ICAO and then implemented concept known as the ‘Specific Airworthiness
nationally by ICAO contracting states, or in Specification’ (SAS) was used in the EASA
the case of EASA member states, through the system to allow continued flight for aircraft
EASA Implementing Rules. Certified aircraft without a DAH. The SAS effectively replaces
are designed to regulatory requirements and the aircraft TCDS and the aircraft may be issued
Certification Specifications (CS). The CS are the with a Restricted C of A. Types such as the

more detailed airworthiness requirements that an Slingsby T67 or Beagle Pup now fly under this
aircraft design is assessed against. arrangement. As far as the owner or operator
are concerned, the continued airworthiness
When it has been established that an aircraft procedures are similar to those associated with
design and prototype complies with the a full C of A.
applicable requirements, a Type Certificate is
issued by the responsible aviation authority, such EASA and UK regulations no longer permit the
as the UK CAA or EASA. The Type Certificate issue of a new SAS. A SAS issued by EASA
confers type approval on the aircraft and permits prior to 1st January 2021 remains valid for
the production of individual airframes that UK registered aircraft. A list of existing SAS
conform to the Type Certificate. There is an documents is published on the CAA website.
associated Type Certificate Data Sheet (TCDS)
– this records the basis of the type approval
and gives information concerning the design,
ENDURING PERMITS
airworthiness, and operation of the aircraft.
Some factory-built Part 21 aircraft have not

demonstrated compliance with the requirements
The Type Certificate is issued to an organisation for issue of a C of A. Under EASA, an alternative
that becomes the Type Certificate Holder or to full certification was the ‘enduring’ permit
Design Approval Holder (DAH). Throughout to fly. Such aircraft were approved on the
this guide the term Design Approval Holder basis of ‘flight conditions’, including specific
(DAH) will be used. The DAH is normally airworthiness requirements that differ from those
the manufacturer of the aircraft, although under Part-ML. More detail is included on p.79.
the DAH may change, for example if the
original manufacturer is taken over by another Reference: UK Regulation (EU) 748/2012, Part 21,
organisation. Section A
CAA / October 2022

Continuing Airworthiness Management

Continuing airworthiness management can be MANDATORY ITEMS
defined as “the processes by which an aircraft
is kept in a condition where it remains airworthy During the initial design and certification of the
throughout its operational life”. To be considered aircraft, some airworthiness tasks are identified
airworthy, the aircraft must continue to meet by the DAH as mandatory and designated as
the build standard and requirements of the type Certification Maintenance Requirements or
design. Part-ML and Part-CAO apply a framework Airworthiness Limitation Items. These items
of requirements to support this process. must always be incorporated into the relevant
Aircraft Maintenance Programme (AMP).
Part-ML, ML.A.301 identifies various tasks to
ensure the ongoing airworthiness of the aircraft: Airworthiness Directives (ADs) may be issued
by the state of design or the state in which
> Pre-flight inspections;
an aircraft is registered. These are mandatory
> Rectification of defects and damage in airworthiness actions, normally issued in
accordance with approved data; response to a safety risk associated with
> Repairs and modifications in accordance with an aircraft or component. For example they
approved data; may require inspection or replacement of a
component that has suffered a high failure rate.
> Performing the maintenance required by the
aircraft maintenance programme;
The UK also has the airworthiness ‘Generic
> Applicable airworthiness directives or other
Requirements’ which are mandatory for a range
mandatory requirements; and
of light aircraft on the UK register. Some relate

> Maintenance check flights. to continuing airworthiness and can be found in
CAA CAP 747.
INSTRUCTIONS FOR CONTINUED
AIRWORTHINESS RESPONSIBILITIES
The DAH for the aircraft supplies the data to Part-ML, ML.A.201 states that the aircraft owner
carry out the airworthiness tasks for maintaining is responsible for the continued airworthiness of
the aircraft in an airworthy condition. This is the aircraft.
normally in the form of manuals and referred
to as the Instructions for Continued It is possible for the owner to delegate the
Airworthiness (ICA). continued airworthiness of the aircraft to an
organisation approved under Part-CAO or Part-
The ICA is normally updated throughout the CAMO. Such an arrangement is often known
life of the aircraft type. This will typically be in as a ‘CAMO contract’. If an aircraft is used for
response to operational experience, incidents or commercial operations, it is a requirement for the

accidents and additional considerations as the aircraft operator to enter into a CAMO contract.
average age of the type increases. Updates to
the ICA can be in the form of amended manuals If the aircraft is leased, the lessee takes on the
or via service bulletin, instruction or letter. management responsibilities of the owner, if so
identified in the lease contract or on the aircraft’s
registration certificate.
Reference: Part-ML, Section A; Part 21, 21.A.7,

21.A.3B
CAA / October 2022

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.
ML.A.401 and ML.A.402 set out the principles APPROVALS AND QUALIFICATIONS
for the performance of maintenance. It must be
in accordance with the applicable maintenance ICS must have the appropriate Part-66 maintenance
data, using the methods, techniques and practices licence and be rated for the relevant aircraft type.
defined by the DAH. Personnel and organisations Approved organisations must also use personnel
must have the appropriate qualifications, knowledge, qualified and rated under Part-66, as well as
tools and facilities for the task being performed. having the aircraft type within their organisational
exposition. The exposition of an approved
AIRCRAFT MAINTENANCE organisation is essentially the company manual
and sets out the nature, scope, procedures and
Depending on the aircraft or maintenance task, responsibilities for the organisation.
the work may be performed by an approved
organisation (for example under Part-CAO) or ML.A.801(d) does permit qualified certifying staff to
independent certifying staff (ICS). Certain tasks may be assisted by other personnel, provided they work
also be conducted by a pilot-owner who is familiar under direct and continuous control.
with the applicable requirements - see p.71 for more

details. In the case of aircraft operating on a Part 21
enduring permit to fly, there is a permit maintenance
On completion of the maintenance task, a Certificate release authorisation system defined in British
of Release to Service (CRS) is issued confirming that Civil Airworthiness Requirement (BCAR) Section
the work has been performed in accordance with A, Chapter A3-7 that allows holders of that
the applicable requirements (for example Part-ML or authorisation to perform and certify maintenance.
Part-145). The requirements applicable to the CRS See CAP 553 for more details.
are set out in ML.A.801.
RESPONSIBILITIES
COMPONENT MAINTENANCE
Although a CRS must not be issued when the
Maintenance of components is addressed at aircraft is known to be unairworthy, the personnel
ML.A.502. Maintenance to engines, propellors or organisation assigned to a maintenance task are
and other components must also be performed only responsible for correctly performing the work
in accordance with the techniques and practices ordered by the person or organisation managing
defined by the DAH or individual manufacturer. the airworthiness of the aircraft. Only the owner
or a contracted organisation can take overall
Major component maintenance such as overhaul of responsibility for the airworthiness of the aircraft.
engines and propellors must normally be conducted This is sometimes misunderstood but is a critical
by an approved organisation, other than the point in understanding the airworthiness system.
exceptions noted in ML.A.502. Components that
have been overhauled by an approved organisation Reference: Part-ML, Section A; Part-145; Part-CAO;
are issued with a CAA Form 1 or equivalent. CAP 553, BCAR Section A

CAA / October 2022

The Airworthiness Review

A key element of the Part-ML system is the > Modifications and repairs are
Airworthiness Review. The review process compliant (performed in accordance
examines the airworthiness status of the aircraft with approved data);
to ensure that the C of A remains valid.
> The aircraft complies with the latest
revision of the type design and TCDS; and
When an airworthiness review has been
completed and any associated compliance > The aircraft holds a valid Noise
findings closed, the aircraft is issued with an Certificate if required.
Airworthiness Review Certificate (Form 15c) –
referred to as the ARC. The ARC has a 12 month The above is the documented review.
validity period. Whilst the C of A document The second element of the review is the
for a UK registered aircraft does not expire, physical survey - this checks that:
the aircraft cannot fly without a valid ARC.
> All required placards and
In practical terms, the review is a safety health markings properly installed;
check of the aircrafts continuing airworthiness
management and to some extent, maintenance. > The aircraft complies with its
approved flight manual;
The process and requirements are set out in
Subpart I, ML.A.901-907. Although the review > No evidence of defect can be found
involves various documentation checks, it that has not been addressed; and
should never be considered a ‘paperwork

> No inconsistencies can be found between
exercise’. To refer to it as such would indicate a
the physical aircraft survey, the aircraft
misunderstanding of its conduct and purpose.
configuration and the documented review.
The airworthiness review process For aircraft not subject to a CAMO contract, the
verifies the following: AMP must be reviewed by the airworthiness
review staff as part of the review to ensure
> Airframe, engine, propeller flying hours
that it remains valid and effective.
and cycles have been properly recorded;
> Flight manual and weight & balance are In some cases, and only for aircraft subject
current and reflect the aircraft configuration; to a CAMO contract, the ARC may be issued
a first and second extension, extended
> Maintenance required by the
on each occasion for 12 months.
programme (AMP) has been
performed and correctly certified;
Depending on the operational use of the

> Known defects have been corrected aircraft, the airworthiness review can be
or appropriately deferred; performed by either an approved Part-
CAMO/CAO/145 organisation or an ICS with
> Airworthiness Directives and other
a specific Part-ML approval to perform an
mandatory requirements such as generic
airworthiness review, issued by the CAA.
requirements have been performed;
> Service life limited parts have not
exceeded their life limitation;

CAA / October 2022

The Airworthiness Review

In the case of ICS or a maintenance organisation, If circumstances reveal a potential
the review must be carried out alongside the safety threat, the CAA must perform the
aircraft’s 100 hour or annual inspection. If a airworthiness review and issue the ARC.
Part-CAO or Part-CAMO organisation is used,
the review can be conducted at a separate time. Reference: ML.A.901, ML.A.902, ML.A.904
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’.
Part-ML, Section B sets out the procedures

for the CAA overseeing aircraft, personnel and
organisations under the Part-ML system.

CAA / October 2022

The Mandatory Occurrence Reporting System

THE MOR SCHEME
A full list of reportable occurrences can be
The requirement for a mandatory occurrence
found in UK Regulation (EU) 2015/2018,
reporting (MOR) system stems from ICAO
note there are others relating to aircraft
Annex 13. UK Regulations (EU) 376/2014
operations that are not listed here.
and 2015/1018 implement this in the UK.
The list applicable to pilots flying on aircraft
The objective of the MOR system is: other than complex-motor powered aircraft
can be found in Annex V of the above
“To facilitate collection and exchange of regulation, only the technical occurrences
information on actual or potential safety have been picked out and listed above.
hazards and deficiencies and contribute
Reports are submitted using the aviation
to the prevention of aircraft accidents”
reporting portal. More information and guidance
is also available at caa.co.uk/cap382. CAP 1496
It is not to attribute blame or liability. Occurrence contains further details on using the portal. If
Reports are treated confidentially to maintain full difficulties are experienced with the submission
and free reporting from the aviation community of a report, the CAA Safety Data team would
and to protect the identity of the reporter. be pleased to hear from the aviation community
and can be contacted at sdd@caa.co.uk.
The MOR regulation asks pilots flying light
aircraft to play an active role in making aviation A key point to remember with reporting
safer by reporting certain safety occurrences. is that if the DAH and regulator are not

In the airworthiness context this includes: aware of an issue, that lack of reporting
may contribute to an incident or accident.
> Abnormal severe vibration;
If a responsible person is aware of a safety
> Fire, explosion, smoke, toxic gas occurrence and has reason to believe that
or fumes in the aircraft; it has not been reported as it should, the
CAA has a whistleblowing policy via which
> Any flight which has been performed with issues may be raised in confidence.
an aircraft which was not airworthy;
> Any flight control not functioning
correctly or disconnected;
> Any failure or substantial deterioration
of the aircraft structure;
> Any loss of a part of the aircraft in flight;

> A failure of an engine, rotor, propeller, fuel
system or other essential system; and
> Leakage of any fluid which resulted
in a fire hazard or possible hazardous
contamination or structure, systems
or equipment or risk to occupants.

CAA / October 2022

The Mandatory Occurrence Reporting System

PART-ML REQUIREMENTS REPORTING TO THE DAH
ML.A.202 also requires that any person It is also important to report relevant occurrences
identified as having responsibilities under to the DAH. Airworthiness Directives are
ML.A.201, shall report any condition of an aircraft normally issued when a DAH has reported
or component which endangers flight safety to: an unsafe condition to the state of design.
> The CAA; A key part of the DAH identifying an unsafe
> The organisation responsible for condition is the feedback given through reporting
the type design or supplemental schemes. This can allow safety interventions to
type design (DAH); and be made before accidents and incidents occur.
> 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.
Pilots and owners should always report Reference: UK Regulation (EU)

any occurrence that is considered relevant 2015/1018; ML.A.202; CAP 1496]

to safety. If an occurrence is related to
maintenance activity, ask the ICS or maintenance
organisation if they have reported the issue.

CAA / October 2022

Airworthiness System Summary

The DAH achieves type approval of the design In some circumstances pilot-owners are
and then produces aircraft in accordance permitted to perform maintenance.
with that approval, as reflected in the Type
The aircraft is maintained in accordance with
Certificate and associated data sheet.
the AMP. The data and processes provided
Changes (modifications and repairs) to the
by the DAH or manufacturer are used in all
aircraft post manufacture must be approved
maintenance activity. Approved organisations and
prior to embodiment on the aircraft.
ICS follow the procedures and requirements of
Feedback to the DAH throughout the life cycle the airworthiness regulations and organisational
of the type drives changes to the type design exposition, as applicable.
or the ICA. Mandatory occurrence reporting is
The aircraft records are kept complete and are
a key part of this feedback. Where an unsafe
regularly updated from detailed maintenance
condition applicable to the type is identified,
records and utilisation data such as hours,
an Airworthiness Directive may be issued
cycles and landings.
mandating inspection or modification activity.
Regular airworthiness reviews ensure that the
Throughout the life of an individual aircraft,
C of A remains valid.
continuing airworthiness management ensures
that the aircraft remains airworthy. Maintenance The aviation regulator performs rulemaking,
work orders are placed to ensure the required oversight, certification and investigation
work is performed by appropriately qualified ICS functions in support of the aviation system.
or approved organisations. Regulatory controls applied to the maintenance
and continuing airworthiness management are
proportionate to the complexity of the aircraft

and operational use.

CAA / October 2022

Airworthiness System Summary

Aircraft managed by an approved organisation
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

Aircraft managed by the owner
Design Organisation
Manufacturer
Occurrences
Owner
Work Order
Occurrences
/ Contract
Records
Maintenance
Organisation or
ADs / GRs Occurrences ICS as appropriate
Regulator
Occurrences

CAA / October 2022

Organisational Approvals and the Airworthiness Codes

Below is a pictorial representation of the codes / structure discussed in the previous pages.
Part-ML Aircraft Part-ML Aircraft

Part-NCO and Non Part-NCO and/or Operated
Non Commercial by a commercial ATO / DTO
Continuing Part-CAMO or Part-CAO
Airworthiness (organisation)
Owner
Airworthiness Part-CAMO or Part-CAO

Review (organisation)
*Part-145
with airworthiness review privileges
*Part-66
ICS with CAA issued Part ML authorisation
Maintenance Part-CAO or Part-145

(organisation)
Part-66
independent centifying staff
Pilot / Owner
*Only when concident with 100 hour inspection
Note: The above assumes appropriate certicate privileges are held.


23
RESPONSIBILITIES
AIRWORTHINESS
OF THE OWNER
OR OPERATOR
02.
CAA / October 2022
CAA / October 2022

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
Does a flying school aircraft need to be managed and

maintained by an approved organisation?
Under Part-ML, certain operational uses of the The contract is required to be between
aircraft require that the operator of the aircraft the operator (normally the ATO or DTO) and
enters into a CAMO contract with an organisation the Continuing Airworthiness Management
approved under Part-CAO or Part-CAMO or are Organisation.
themselves approved as a CAMO organisation:
Note that when the CAMO requirement applies,

> Use of the aircraft by a commercial Approved
it is also required that maintenance tasks on
Training Organisation (ATO);
the aircraft are performed by a maintenance
> Use of the aircraft by a commercial Declared organisation approved under Part-CAO, Part-M
Training Organisation (DTO); or or Part-145.
> Use of the aircraft outside of Part-NCO
(e.g. Part-SPO). ‘Commercial’ ATO or DTO in this context
means one run as a business, not necessarily
one that provides training for commercial pilot’s
licences.

CAA / October 2022

CHAPTER 2: AIRWORTHINESS RESPONSIBILITIES OF AN OWNER / OPERATOR
Does a flying school aircraft need to be managed and

NON-COMMERCIAL FLIGHT TRAINING
There are some circumstances in which flight Pilot-owner training
training can take place, without the need
for a CAMO contract covering the aircraft. Aircraft operated under Part-NCO by its owner
Guidance on this subject is provided in GM1 to together with an ATO or a DTO flight instructor
ML.A.201(e). for the purpose of training, where the contract
between the owner and the training organisation
Note that payment may still be exchanged for and the procedures of the training organisation
the flights, but the activity should normally fall allow it. The continuing airworthiness of such
within one of the scenarios below. aircraft remains under the responsibility of the
owner, or of the CAMO or CAO organisation
contracted by the owner.
Non-commercial ATO or DTO
Flights within an organisation that is an ATO or Limited and specific training

DTO, created with the aim of promoting aerial
sport or leisure aviation and on the conditions Aircraft used for very limited training flights due
that: to the specific configuration of the aircraft and
limited need for such flights.
> The aircraft is operated by the organisation

under ownership or dry lease;
> The ATO/DTO is a non-profit organisation;
and Reference: ML.A.201(e)
> Whenever non-members of the organisation
are involved, such flights represent only a
marginal activity of the organisation.
The criteria to be considered non-commercial

in this scenario are similar to that for an
‘organisation created with the aim of promoting
aerial sport or leisure aviation’, as set out in
article 6(4a) of the UK Air Operations Regulation
and associated GM. This includes further
guidance on ‘non-profit’ status and ‘marginal
activity’. Note that ‘non-profit’ relates to the

legal construct of the organisation, not the
financial health of a business.

CAA / October 2022

Does a private aircraft need to be managed and

PRIVATE AIRCRAFT UNDER PART-NCO
Private aircraft operated under Part-NCO do Continuing airworthiness management requires
not require a CAMO contract. An aircraft skill and attention to detail. This is reflected
could potentially be managed by the owner in the guidance material to ML.A.201(f):
and maintained by appropriately qualified
ICS. With the appropriate authorisation “If an owner decides not to make a contract
from the CAA, ICS can also perform the with a CAMO or CAO, the owner is fully
airworthiness review and issue the ARC. responsible for the proper accomplishment of
Certain elements of the maintenance the corresponding continuing airworthiness
could also be performed by the owner. management tasks. As a consequence, it
is expected that the owner properly and
Managing the airworthiness of your aircraft may realistically self-assesses his or her own
bring an interesting and rewarding dimension competence to accomplish those tasks or
to the ownership experience. However, for otherwise seek the necessary expertise”.
many aircraft owners the interest in aviation
begins and ends with the flying and entering Owners should be aware of their responsibility,
into a CAMO contract with an approved as it is sometimes a conscious decision
organisation will be the more appropriate option. of approved organisations to perform

maintenance tasks on an aircraft, but not to
Owners considering managing the airworthiness enter a contract that gives them responsibility
of their aircraft need to be realistic about their for the continuing airworthiness.
interest, capability and time to do so. There are
many tasks and considerations, for example: In the absence of a Part-ML continuing
> Producing and declaring the airworthiness management contract, the full
maintenance programme; responsibility for airworthiness rests with
the owner, even if the owner has paid an
> Organising the maintenance tasks;
organisation or engineer to perform some of
> Reviewing and actioning mandatory the continuing airworthiness management
requirements such as ADs and work. An aircraft is only managed by an
Generic Requirements; approved organisation if a CAMO contract in
> Ensuring modifications and repairs are accordance with Part-ML, Appendix I is in place.
performed using approved data; and
> Updating the aircraft records and logbooks.

CAA / October 2022

Does a private aircraft need to be managed and

PRIVATE HIRE AND NON-EQUITY GROUPS GROUP OWNERSHIP
Private owners hiring out their aircraft need Aircraft that are owned by a group of
to consider the airworthiness implications of shareholders are still considered private aircraft.
doing so and have a system for monitoring Provided the aircraft is operated under Part-
the use of the aircraft and ensuring NCO, the group may elect to manage the
defects and damage are reported. continuing airworthiness of the aircraft. As
with a sole owner, the group members need
Some aircraft owners establish what is referred to collectively consider the merits of doing
to as a ‘non-equity’ group, whereby they so and whether entering a CAMO contract
retain ownership of the aircraft but hire it out may be a safer and more realistic option.
to a specific group of individuals who may
pay a monthly subscription for the privilege If a group does decide to manage the aircraft,
of using the aircraft. Legally non-equity responsibilities for this need to be assigned
groups are no different from private hire. within the group. Particularly in larger groups,
one or several co-ordinated individuals need
Whilst private hire does not trigger the CAMO to be given the responsibility for ensuring
contract requirement, it will add complexity to all the necessary tasks are reviewed and
the airworthiness management task for the completed. Even with a CAMO contract in place,
owner. The CAA recommends aircraft owners all groups should have a robust mechanism

in this situation do consider entering a CAMO for monitoring the use of the aircraft and
contract, particularly if they are hiring out ensuring that any defects or damage are
multiple aircraft. Commercial ATOs or DTOs reported and attended to in a timely manner.
hiring out their aircraft will require a CAMO
contract if the aircraft is also used for training.
Pilots hiring an aircraft should also consider and

question the airworthiness management and
maintenance arrangements. Particularly with
owner managed aircraft, there will be variation in
the maintenance programmes and the standards
applied may not be the same, even if all meet
the minimum Part-ML requirements. Pilots may
wish to discuss with the owner whether the

AMP is appropriate for the aircraft’s utilisation
profile and whether any non-mandatory
maintenance tasks are being omitted.

CAA / October 2022

Why does it matter if there is a formal continuing

airworthiness management contract?
Part-ML is intended to be proportionate to the complexity of the aircraft and operational use.
For example, the owner of a privately operated aircraft is given more scope to manage the
airworthiness risks themselves compared to when an aircraft is used in a commercial environment.
The diagram below visualises how the requirements are scaled.
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

29
MAINTENANCE
PROGRAMME
THE PART-ML
03.
CAA / October 2022
CAA / October 2022

CHAPTER 3: THE PART-ML
MAINTENANCE PROGRAMME
The Part-ML Maintenance Programme (AMP)
INTRODUCTION
In the early days of aviation, engineers and aircraft operators realised that having a regime of
inspections and maintenance tasks, rather than simply repairing failures, would improve aircraft safety
and reliability. This concept is fundamental to continuing airworthiness and under Part-ML, the regime
is known as the ‘Aircraft Maintenance Programme’ (AMP).
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.

THE AMP TEMPLATE
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

CAA / October 2022

CHAPTER 3: THE PART-ML MAINTENANCE PROGRAMME

SECTION 1 - AIRCRAFT IDENTIFICATION
Aircraft identification
1 Registration(s): G-ABCD Type: Piper PA28-140 Serial No (s): 28-24504
Owner: Johanna Smith
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.


CAA / October 2022


SECTION 2 - BASIS FOR THE MAINTENANCE PROGRAMME
Basis for the Maintenance Programme
2 Design Approval Holder (DAH) Minimum Inspection Programme

instructions for continued (MIP) as detailed in the latest
airworthiness (ICA) x revision of AMC1 ML.A.302 (d)
Other MIP complying with ML.A.302 (d)
(List the tasks in Appendix A)
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.

CAA / October 2022


SECTION 3 – DAH INSTRUCTIONS FOR CONTINUED AIRWORTHINESS
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.
Design Approval Holder (DAH) Instructions for Continuing Airworthiness (ICA)
3 Equipment manufacturer and type Applicable ICA reference (revision/

date not required assuming the
latest revision will always be used)
For aircraft other than balloons
3a Aircraft (other Piper PA28-140 753-586 Service Manual

than balloons)
3b Engine Lycoming O-320-E3D 60297-30 Operators Manual

(if applicable) 60294-7 Overhaul Manual
3c Propeller Sensenich 74 DM6-0-58 Sensenich Service Bulletin R17

(if applicable)
[balloon section omitted]
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.

CAA / October 2022


SECTION 4 – ADDITIONAL MAINTENANCE REQUIREMENTS
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)
4 Indicate if any of the following types of repetitive Yes No

maintenance are included in the AMP (when replying
‘YES’, list the specific requirements in Appendix B)
Maintenance due to specific equipment and modifications Yes
Maintenance due to repairs No
Maintenance due to life-limited components (this should No

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.)
Maintenance due to mandatory continuing airworthiness information No

(airworthiness limitations (ALIs), certification maintenance
requirements (CMRs), specific requirements in the TCDS, etc.)
Maintenance recommendations, such as time between overhaul Yes

(TBO) intervals, issued through service bulletins, service
letter, and other non-mandatory service information
Maintenance due to repetitive ADs Yes
Maintenance due to specific operational/airspace directives/ No

requirements (altimeter, compass, transponder, etc.)
Maintenance due to type of operation or operational approvals No
Other No

CAA / October 2022


SECTION 4 – ADDITIONAL MAINTENANCE REQUIREMENTS (CONTINUED)
Maintenance due to specific equipment and modifications
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

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.

CAA / October 2022


Maintenance due to mandatory continuing airworthiness information (airworthiness limitations

(ALIs), certification maintenance requirements (CMRs), specific requirements in the TCDS, etc.)
More detail is included in the Managing Continuing Airworthiness section regarding

identification of these tasks, but generally they are included in the DAH data and
sometimes included as tasks on the type certificate data sheet, as illustrated below:
Life Limitations (see also AMM, chapter 4-00-00 (P/N 761-888)):

The bolt and stack-up that connect the upper drag link to the nose gear
trunnion are required to be replaced every 500 hours time
in-service. The part numbers are as follows:
1. Piper P/N 400 274 (AN7-35) bolt or Piper P/N 693 215 (NAS6207-50D) bolt;
2. Piper P/N 407 591 (AN960-716L) washer, as applicable;
3. Piper P/N 407 568 (AN 960-716) washer, as applicable;
4. Piper P/N 404 396 (AN 320-7) nut; and
5. Piper P/N 424 085 cotter pin.

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.

CAA / October 2022


Maintenance recommendations, such as time between overhaul (TBO) intervals, issued

through service bulletins, service letter, and other non-mandatory service information
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.
Maintenance due to repetitive ADs
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.
Maintenance due to specific operational/airspace directives/

requirements (altimeter, compass, transponder, etc.)
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.

CAA / October 2022


Maintenance due to type of operation or operational approvals
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.


CAA / October 2022


SECTION 5 – MAINTENANCE TASKS ALTERNATIVE TO THE DAH ICA
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)
5 Indicate if there is any maintenance task alternative Yes No
to the DAH’s ICA (when ‘YES’, list the specific
alternative maintenance tasks in Appendix C)
Key info ! Key info !

If a task is mandatory such as an AD or Before deciding to adopt an alternative or less
Airworthiness Limitation, it must always be frequent task to that of the DAH ICA, the owner
included in the AMP, without deviation. should consider their liability liable in the event
that an incident or accident occurs as a result.
Any deviation from a non-mandatory task or
interval must also comply with the MIP.
Whilst in the short term some alternatives

could save money, an escalation or deletion of
Part-ML allows for deviations from DAH ICA, a task may lead to a defect not being identified
but only when tasks are not classified as until a point where repair is no longer possible,
mandatory. Deviations could include escalation therefore increasing the long-term cost of
of a task (doing a task less often), increasing the ownership.
frequency of a task, changing the scope of a
task or disregarding a task completely. However,
the alternative task or frequency of task is
not permitted to be less restrictive than the
equivalent task in the MIP.
Whilst the potential savings of alternative tasks may

look tempting, an owner should consider if they
possess the knowledge and aircraft maintenance
experience to make decisions related to the

proposed alternative task. The DAH has included
the task, most likely based on significant
operational experience and analysis, which may
include knowledge of incidents and accidents.
For example a corrosion inspection task may not

be mandatory but in a climate such as the UK,
may be highly advisable.

CAA / October 2022


SECTION 5 – MAINTENANCE TASKS ALTERNATIVE TO THE DAH ICA (CONTINUED)
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.
It should be noted that manufacturers recommendations are based on adherence to servicing
schedules and task frequencies and may be compromised if these schedules are not followed.
The table below gives some examples of when deviations from ICA task intervals are permitted.
AMP proposed Alternative acceptable

ICA task MIP task
alternative Yes / No
Inspection XX Inspection XX Inspection XX Yes

6 months interval 12 months interval 12 months interval
Inspection XX Inspection XX Inspection XX No

12 months interval 24 months interval 12 months interval

Inspection XX Inspection XX Inspection XX No
24 months interval 36 months interval 12 months interval (24 months to be used)
Functional test Operational test system Functional test system No*

system XX XX (same interval) or XX (same interval)
general visual inspection
system XX (same interval)
Operational test Functional test system Operational test system Yes*

system XX XX (same interval) XX (same interval)
Inspection XX Inspection XX None relevant Yes

24 months interval 36 months
Functional test General visual inspection None relevant Yes
*A functional test is more restrictive (more detailed) than an operational test
If the MIP permits a deviation from the DAH ICA recommended task or interval, the owner or CAMO
must consider the possible safety impact.

CAA / October 2022


The table below lists some factors to consider and indicates scenarios in which deviations from the
DAH ICA may represent a higher risk.
Consideration Possible risk level
OPS approval Higher Risk: commerical operation, commercial flight training
Medium Risk: flight training by an association, non-
commercial specialised operations (SPO)
Lower Risk: private
Flight rules Higher Risk: instrument flight rules (IFR)

Medium Risk: visual flight rules (VFR) at night
Lower Risk: VFR by day
Aircraft weights Higher Risk: Other than ELA1*

Medium Risk: ELA1 aircraft other than light sport aeroplanes (LSA),
very light aircraft (VLA), sailplanes and powered sailplanes
Lower Risk: LSA, VLA, sailplanes and powered sailplanes

Who manages Higher Risk: owner
the airwothiness
Lower Risk: CAMO / CAO
of the aircraft?
Who maintains Higher Risk: pilot-owners

the aircraft?
Medium Risk: independent certifying staff
Lower Risk: maintenance organisation
Time in service Higher Risk: very high number of hours or years

(flight hours, years)
Medium Risk: medium number of hours or years
Lower Risk: low number of hours or years
Aircraft utilisation Higher Risk: less than 50 h per year

Medium Risk: around 200 h per year
Lower Risk: more than 400 h per year
ACAM findings* Higher Risk: numerous findings in ACAM or ramp inspections

Medium Risk: few findings in ACAM inspections
Lower Risk: rare findings in ACAM inspections

CAA / October 2022


Consideration Possible risk level
System redundancy Higher Risk: single-engined aircraft

(for components such
Lower Risk: multi-engined aircraft
as engine/propeller)
Supplementary Higher Risk: no supplementary measures
maintenance measures
Lower Risk: supplementary measures (such as oil analysis, engine
data monitoring, boroscope inspections, corrosion inspections, etc.)
Risk factor of Higher Risk: engine failure on a helicopter

component failure
Medium Risk: engine failure on an aeroplane
Lower Risk: sailplane, or powered sailplane
*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.

CAA / October 2022


SECTION 6 – PILOT-OWNER MAINTENANCE
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.
Pilot-owner maintenance (only for balloons not operated under Subpart-ADD, or
sailplanes not operated under Subpart-DEC, or other aircraft operated under Part-NCO)
Remark: pilot-owner maintenance is not allowed for aircraft operated by commercial ATO/DTO
6 Does the Pilot-owner perform Pilot-owner Yes No

maintenance (ref. Part-ML, ML.A.803)?
If yes, enter the name of the pilot-owner(s) authorised to perform such maintenance:
Pilot-owner name: Johanna Smith Licence Number: GBR.FCL.CP.444205J
Signature: Date: 12/08/2022
Note: It is possible to refer to a list in the case of jointly owned aircraft.

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.

CAA / October 2022


SECTION 7 – APPROVAL / DECLARATION OF THE AMP
Approval/Declaration of the Maintenance Programme (select the appropriate option)
7 Declaration by owner: x Approval by contracted CAMO/CAO:
‘I hereby declare that this is the Approval Reference No of the CAMO/CAO:
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.’
Pilot-owner name: Johanna Smith Name
Signature: Signature:
Date: 12/08/2022 Date:
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. CHAPTER 4: CONTINUING AIRWORTHINESS

CAA / October 2022


SECTION 8 – THE CERTIFICATION STATEMENT
Certification statement
8 ‘I will ensure that the aircraft is maintained in accordance

with this maintenance programme and that the maintenance
programme will be reviewed and updated as required’
Signed by the person/organisation responsible for the continuing
airworthiness of the aircraft according to ML.A.201:
Owner/Lessee/operator: x CAMO/CAO:
Name of owner/lessee or CAMO/CAO approval number: Johanna Smith
Address: 6 Privet Drive, Crawley, RH10 1AR
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.

CAA / October 2022


SECTION 9 – APPENDICES
9 Appendices attached: Yes No
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.

CAA / October 2022


SECTION 9 – APPENDICES (CONTINUED)
Appendix A — Minimum inspection programme (MIP)

(only applicable if a MIP different from the one described in AMC1 ML.A.302(d) is used
— see Section 2 above)
Detail the tasks and inspections contained in the MIP being used.
Appendix B — Additional maintenance requirements
(include only if necessary — see Section 4 above)
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).
Task Description: References: Interval:

(tick box if the selected interval
differs from that required in
the referenced document)
Maintenance due to specific equipment and modifications
AA211CC Vacuum Tempest SL-003 (note 800H

Pump Life Limit – unit has no WIP)
Maintenance due to repairs

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 due to Mandatory Continuing Airworthiness Instructions

(ALIs, CMRs, specific requirements in the TCDS, etc.)

CAA / October 2022


Appendix B — Additional maintenance requirements (continued)
Maintenance recommendations, such as time between overhaul (TBO) intervals, issued through
service bulletins, service letter, and other non-mandatory service information
Engine Overhaul Lycoming SI 1009 (Notes 11, 2400H
15 & 16 apply)
Propeller Overhaul Sensenich SB R17 (Metal Prop 2000H

TBO)
Emergency locator EASA SIB 2019-09 1 Year

transmitters and personal
locator beacon — annual
testing
(if not using MIP or equivalent EASA SIB 2011-15 2 Years

ICA task) Transponder test
Maintenance due to repetitive ADs

Wing Spar Corrosion EASA AD 2005-0032 7Y
Oil Cooler Hoses (TSO-C53a FAA AD 2017-14-04 8Y / 1000H

Type C fitted)
Control Cable Failures FAA AD 2013-02-13 7Y / 2000H
Stabilator Balance Tube EASA AD 2005-0034 200H

Cracking
Maintenance due to specific operational/airspace directives/requirements

(altimeter, compass, transponder, etc.)
Maintenance due to type of operation or operational approvals
Other

CAA / October 2022


Appendix C — Maintenance tasks alternative to the DAH’s ICA (not less restrictive than MIP)
(include only if necessary — see Sections 5 above)
Task Description Recommended Alternative Amended interval

interval inspection/task
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)
Engine Overhaul 12Y (FH limitation Addition of conditional 15Y Overhaul

has been adopted, inspections at 100H
unchanged) intervals, as detailed 100H Conditional
in justification form Inspections.
attached.

Appendix D — Additional information (optional)
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.

CAA / October 2022

Review of the AMP

The AMP is required to be reviewed annually. In addition, the review checks the following:
This review cannot be performed by the owner.
> Revisions to the documents that
If the owner manages the aircraft, the review
form the basis of the programme
should be considered as an independent check
(e.g., MIP or DAH data);
of the content of the AMP. The review is critical
for identifying conditions that might adversely > Changes in the aircraft configuration,
impact the airworthiness of the aircraft. and type and specificity of operation;
> Changes in the list of pilot-owners; and
If an aircraft is managed by a Part-CAMO or > Applicable mandatory requirements such
Part-CAO organisation, the review of the as Airworthiness Directives, Airworthiness
AMP does not necessarily need to be conducted Limitations, Certification Maintenance
at the same time as the Airworthiness Review Requirements and specific maintenance
of the aircraft. requirements included in the TCDS.
If an aircraft is not managed by an approved Even maintenance requirements for older

organisation but rather declared by the owner, aircraft evolve as type experience is gained,
the review of the AMP must be performed at so it is important to consider the above points
each Airworthiness Review by the approved at each review.
organisation or Part-ML authorised ICS who
issues the ARC. If deficiencies are identified, the Part-CAMO,
Part-CAO or owner as applicable must amend
The purpose of the review is to assess the AMP. The ARC (Form 15c) cannot be issued

the effectiveness of the AMP. This is done until the amendment is made and the aircraft is
mainly by looking at issues identified during in compliance with the amended AMP.
maintenance for the last 12 months and also
reported throughout the year by pilots(s) and
assessing if these are related to a deficiency in
the maintenance programme. This is generally
where a defect has occurred, related to where
the owner has elected to disregard a DAH task
recommendation (e.g. significant corrosion that
would have been detected earlier had the owner
performed the specific corrosion inspections
recommended by the DAH).

CAA / October 2022

When an AMP is not required

ML.A.302 (e) states that declaration by the Following all maintenance recommendations
owner or approval by the Part-CAMO or Part- would also require applying and evidencing every
CAO is not required and an AMP document will service bulletin or letter issued for the aircraft.
not need to be produced when: For a common GA type that is perhaps 25 years
old or more, this may not be realistic from a time
> All ICA from the DAH are being followed
and cost point of view.
without deviation;
> All maintenance recommendations such The ‘no AMP document’ option is more likely to
as TBO intervals, issued through Service be applicable when an aircraft is new or relatively
Bulletins, service letters and other non- simple. The inclusion of the option was intended
mandatory service information are being primarily for balloons, although it may be used for
followed without any deviations; and other aircraft if appropriate.
> All pilot-owners are authorised to perform
pilot-owner maintenance.
Since the AMP must reflect any tasks required

due to modifications, repairs or operating
considerations, it is unlikely that this option will
be applicable for most GA aircraft.


CAA / October 2022

Notes on the MIP

AMC1 ML.A.302 (d) includes an acceptable Given the requirement to use DAH data for
MIP for the different categories of aircraft, the actual tasks and inspections, a reasonable
noting that there is no MIP for rotorcraft or question might be “what benefit do we get
airships, therefore the DAH data must be when using the MIP as opposed to the DAH
used as the AMP basis. ICA, most of which will also be on a 100 hour
major check cycle?”. This is a valid question but
When using a MIP, the customisation of the remains the responsibility of the Part-CAMO,
programme, as detailed in the previous sections, Part-CAO or owner to answer.
is still required. The MIP gives only core tasks
which then must be tailored to the specific The MIP includes a tolerance of 1 month or
aircraft and operation. 10 hours (to the 10 hour inspection). The next
interval is calculated from the time the inspection
When using the MIP, it is still a requirement to takes place.
use the manufacturers maintenance manual
to accomplish each task / inspection. As an When performing a MIP task, proper operation of
example, the MIP task for the wheels includes backup or secondary systems and components
an inspection for cracks, defects, and condition should be performed, whenever a check for
of the bearings. The work would need to be improper installation / operation is carried out.
performed in accordance with the procedure
included in the manufacturer’s manual. This is
logical when considering that the manufacturers
may have specified areas of interest from service

experience and in some cases wear limits
beyond which operation is unsafe.

CAA / October 2022

Summary of AMP responsibilities

AMP element Owner managed CAMO/CAO managed
Customisation for Required Required

the aircraft
Development & approval AMP declared by the owner. AMP approved by the
status CAMO / CAO.
Performance of the AMP At airworthiness review by By CAMO / CAO at least
review airworthiness review staff. every 12 months.
Owner must resolve issues CAMO / CAO resolves issues

raised by amending and raised by amending
declaring the AMP. and approving the AMP.
Management & Shall not be less restrictive Shall not be less restrictive
responsibility for deviations/ then the MIP. then the MIP.
alternate tasks
No justifications is requred Assessment and justification
and the owner takes copy to be sent to owner
responsibility for the alternate and held on file.
task deviation inclusing any
consequences. CAMO / CAO takes

responsibility for the alternate
task deviation including any
consequences.

54
AIRWORTHINESS
CONTINUING
PRACTICAL
04.
CAA / October 2022
CAA / October 2022

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.

CAA / October 2022

CHAPTER 4: PRACTICAL CONTINUING AIRWORTHINESS
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

CAA / October 2022

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.
If the aircraft is managed by the owner, the owner

RECTIFICATION

must agree to the deferral of a defect. If managed
by a Part-CAMO or Part-CAO organisation, that In most cases the desired outcome is to rectify
organisation must agree the deferral. An entry the defect and restore the serviceability of the
must be made in the aircraft records of any aircraft. It is essential that the work is performed
deferred defect. as detailed by the DAH data. In practical terms
this means following the aircraft maintenance
Another consideration is the deferral of defects manual, using the appropriate tools and using the
that might impact the performance of the aircraft parts specified in the relevant illustrated parts
or its equipment. It should always be apparent to catalogue.
the pilot what the serviceability status is of the
aircraft they are flying, including any performance Defect deferrals cannot be indefinite in their
limitations. duration. Part-ML requires that any defect that
does not seriously hazard flight safety is rectified
Part-NCO Subpart D, Instruments, Data and as soon as practicable from the date on which the
Equipment (NCO-IDE) should also be considered defect was first identified and within the limits
as it specifies equipment required for flight specified in the maintenance data. This is logical
including instruments, aircraft equipment, when considering that any defect is an erosion of
safety equipment. Even if the pilot considers the type design standard.
it safe, it may not be legal to operate an aircraft
with deficiencies in required instruments, data, Reference: Part-ML, ML.A.301, ML.A.401,
and equipment. ML.A.403; UK Regulation (EU) 965/2012,
Part-NCO

CAA / October 2022

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.
Reference: Part-ML, ML.A.301, ML.A.304,

ML.A.401; Part 21, Subpart M

CAA / October 2022

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.

Period of original STC
Approval Basis
approval or validation
Pre-EASA (before 28th FAA STCs validated by an EU Member State prior to EASA are
Sept 2003) considered to hold a “Grandfathered” approval. “Grandfathering” is
a term used by the EU Regulations and allows EASA acceptance of
approvals granted under the pre-EASA certification regimes of EASA
Member States.
Prior to EASA, the CAA would have validated foreign STCs via the issue
of an Airworthiness Approval Notice (AAN).
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)

CAA / October 2022

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.
Reference: Part 21, Subpart D, Subpart E

CAA / October 2022

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

CAA / October 2022

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
Some manufacturers, particularly in the avionics

discipline provide specific CS-STAN installation
guides for certain equipment.

CAA / October 2022

Accomplishment of Maintenance in Accordance

with the AMP
MONITORING UTILISATION WORK ORDERS
Once the AMP has been established, the For the owner managing their own aircraft, it is
next challenge is to manage the associated important that maintenance task requirements
maintenance tasks and ensure they are are clearly communicated to the organisation or
performed at the correct time. This is dependent ICS who will conduct the work.
on the pilots(s) of the aircraft properly recording
and the owner / Part-CAMO or Part-CAO A Part-CAO or Part-145 organisation is required
summing the flight time / landings / cycles, as to receive a written work order for any work
applicable. If this is not correct, neither will be the undertaken. An example of a clear work order is
timing of maintenance tasks. below may be stated in an email:
When considering tasks defined by a utilisation

To ABCD engineering,
time, the definition used by the DAH in the ICA
must be understood. For example, the DAH As discussed, please perform the following
assumption for maintenance, particularly for tasks on G-ABCD as detailed in the attached
engines, may be based on the engine running AMP.
time, not flight time. This should be checked
throughout the aircraft and engine DAH data 100H Inspection
and reflected when compiling the AMP and EASA AD 2005-0032 Wing Spar Corrosion

managing the maintenance.
FAA AD 2017-10-04 Oil Cooler Hoses
When considering what needs to be monitored (Inspection)
and managed, it will essentially consist of Kind regards,
scheduled checks, components and a collection
of what can be referred to as single running
Note also that a maintainer is not required to
tasks. The CAA logbook system “CAP 543
hold the current applicable maintenance data,
Time Limited Task, Additional Inspections and
apart from when the maintenance is being
Component Change Record” can be used to
performed. Most maintainers have a subscription
control these tasks, and the logbook pink pages
service to the DAH data but for rare types,
can be used (CAP 398, 399 & 400) to control the
the owner may need to provide the current
repeat Airworthiness Directives.
applicable data to enable the maintenance to be
performed. This should be discussed with the
Other solutions include spreadsheet use selected organisation or ICS.
or where multiple aircraft are managed,

commercially available software. It is important
Reference: ML.A.301, ML.A.302
that the system used is consistently updated,
well understood, reliable and ensures the timely
highlighting of maintenance tasks before they
become overdue.
Rotorcraft typically include more life limited parts

therefore the volume of items to be tracked
should be considered where selecting a system.

CAA / October 2022

Managing Mandatory Requirements

Mandatory requirements include: It is important that the owner is aware of
mandatory airworthiness information. This is
> Airworthiness Directives (ADs)
by subscription to the relevant airworthiness
> Operational directives with a continuing authorities safety information. The most
airworthiness impact common links are as follows, but there may be
> Continuing Airworthiness requirement others depending on the state of design for the
established by the CAA (e.g., Generic aircraft, engine, propeller and equipment:
Requirements)
> Measures required by the CAA as an UK CAA: Subscriptions | UK Civil Aviation
immediate reaction to a safety problem Authority (caa.co.uk)
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.
Other continuing airworthiness requirements Airworthiness Directives may be issued at any

established by the CAA are contained within CAP time, so monitoring needs to be continuous.
747, Mandatory Requirements for Airworthiness. This is usually by using email subscriptions
Section 2, Part 4 of CAP 747 contains Generic available from the CAA and the applicable state
Requirements, some of which are applicable to of design for the aircraft, engine, components
Part 21 aircraft. and equipment.
Emergency ADs are sometimes issued and

these could require immediate action.
Some ADs and if this is the case it will be
stated in the AD. If an aircraft is managed by
a Part-CAMO or Part-CAO organisation, the
organisation should be consulted, and should

have identified the requirement as part of their
own approved processes.

CAA / October 2022


Depending on the urgency or nature of the AD, different actions may be required:
AD Action Required Action
AD – Immediate or very short notice AD planned and accomplished according to

compliance required, or the AD will be due AD requirements.
before the next maintenance opportunity.
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.
AD with a repeat requirement. AMP amended with appropriate details to

ensure capture of the repeat requirements.
A similar process would need to be followed in the event of an applicable Generic Requirement or
Operational Directive being issued.
Reference: Part-ML, ML.A.301, ML.A.303; Part 21, 21.A.3B


CAA / October 2022


GENERIC REQUIREMENTS
Although only rarely amended, Generic Requirements (GRs) are also contained within CAP 747
and should be reviewed for applicability to Part 21 aircraft. The current GRs are included below for
information only and reference should be made to CAP 747 for more detail.
Applicability
GR *Basis of
Title
No. Part 21 Non-Part Applicability
Aircraft 21 Aircraft
4 Electrical Generation Systems – Yes Yes 1 and 2
Aircraft Not Exceeding 5,700 kg
Maximum Authorised Weight
6 Electrical Generation Systems – Bus-Bar Yes Yes 1 and 2

Low Voltage Warning Single-Engined Aircraft
With a UK Certificate of Airworthiness
8 Cotton, Linen and Synthetic Yes Yes 3

Fabric-Covered Aircraft
9 Helicopter Emergency Escape Facilities Yes Yes 3

10 Painting of Aircraft Yes Yes 3
11 Maintenance of Cockpit and Cabin Combustion Yes Yes 3

Heaters and their associated Exhaust Systems
15 Light Aircraft Maintenance Schedule No Yes 2

(Non-EASA Aircraft – Annex I)
16 Tyre Bursts In Flight – Inflation Media Yes Yes 3
17 Maintenance Requirements for Variable No Yes 2

Pitch Propellers Installed on Aircraft Holding
a UK Certificate of Airworthiness
18 Electrical Power Supplies for No Yes 2

Aircraft Radio Systems
19 Emergency Power Supply for Electrically No Yes 2

Operated Gyroscopic Bank and Pitch
Indicators (Artificial Horizons)
23 Maintenance Personnel Certification Yes Yes 3

for Non-Destructive Testing of Aircraft,
Engines, Components and Materials
24 Light Aircraft Piston Engine Overhaul Periods No Yes 2
25 Aerobatic Smoke Systems No Yes 3

CAA / October 2022

Managing Maintenance Check Flights (MCFs)

The definition and requirements for MCFs are data reference and maintenance actions to be
set out in UK Regulation (EU) 965/2012 - the performed after the flight. After a successful
UK Air Operations Regulation. MCFs are carried MCF, the maintenance records should be
out under the control and responsibility of the completed, the remaining maintenance actions
aircraft operator. For MCFs conducted under finalised and a certificate of release to service
Part-NCO, please see NCO.SPEC, Section 6. (CRS) issued.
The CAA has also issued CAP 1038, the Check
Flight Handbook which gives detailed and Example 2: For reliability considerations and/
practical information about the need, planning or quality assurance, an operator, owner, CAO
and conduct of these flights, including a section or CAMO organisation may wish to perform
dedicated to light aircraft. an MCF after the aircraft has undergone
maintenance, even if not required by the
For certain MCFs, the performance information applicable maintenance data. In this case the
obtained or verified in flight by the crew will CRS should be issued before the flight and the
be necessary for assessment or consideration flight is conducted under the aircraft’s C of A.
after the flight by the maintenance personnel or
Example 3: After troubleshooting of a system
organisation, prior to issuing the maintenance
on the ground, an MCF is proposed by the
release. The maintenance staff should appoint
maintenance personnel or organisation as
and brief the crew to ensure that the scope of
confirmation that the solution applied has
the check flight and any process or information
restored the normal system operation. During
required is understood.
the maintenance performed, the maintenance
instructions are followed for the complete

Some different scenarios follow that indicate
restoration of the system and therefore a CRS
if the aircraft can fly under its C of A or if a
is issued before the flight. The airworthiness
temporary permit to fly is required:
certificate is valid for the flight. An open entry
requesting this flight may be recorded in the
Example 1: The aircraft maintenance manual aircraft logbook.
(AMM), or any other maintenance data issued
by the DAH, requires that an MCF be performed Example 4: An aircraft system has failed and
before completion of the maintenance ordered. flight without the system is not permitted by
In this scenario, a certificate after incomplete operational or maintenance data. However,
maintenance, when in compliance with maintenance data does not provide for
ML.A.801(f) or 145.A.50(e), should be issued and troubleshooting or diagnosis on the ground.
the aircraft can be flown for this purpose under Since the failure would normally prohibit flight,
its C of A. Due to incomplete maintenance, it the aircraft may not fly under its C of A and a
is advisable to open a new entry in the aircraft temporary permit to fly is required. After the
logbook, that identifies the need for an MCF. flight and the corresponding maintenance work,
This new entry should contain or refer to, as the aircraft can be released to service and
necessary, data relevant to perform the MCF, continue to operate under its C of A.
such as aircraft limitations and any potential
effect on operational and emergency equipment Reference: Part-ML, ML.A.301; Part-NCO, NCO.
due to incomplete maintenance, maintenance SPEC

CAA / October 2022

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.

CAA / October 2022

Records when changing Part-CAMO

or Part-CAO Organisation
For various reasons owners and operators When a CAMO contract with a Part-CAO
may wish to change their contracted CAMO. organisation is terminated, CAO.A.090 requires
Part-ML acknowledges this and there exists that the organisation transfer the records
a requirement in ML.A.307 that relates to the required by Part-ML to the new organisation
transfer of records. or person. This is a regulatory requirement and
owners may wish to add this to the continuing
The transition of airworthiness records between airworthiness management contract if applicable.
owners and organisations will be is significantly
easier if relations remain cordial. To prevent Reference: ML.A.305, ML.A.307
unpleasant negotiations or litigation, the CAA
recommends that every effort is made to
maintain good terms in all relationships.
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.
In order to maintain an aircraft, independent

certifying staff must be appropriately licensed,
and type rated for the aircraft, and approved
organisations such as a Part 145 or Part-CAO
must have the aircraft type or group listed on

the approval certificate and in the company
exposition.

CAA / October 2022

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;

CAA / October 2022

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.
A pilot-owner can only release work that the

pilot-owner has performed themselves and must
have access and use the DAH maintenance data
when performing the task. They are not able to

supervise and release work performed by others
and there are limits to what can be performed.

CAA / October 2022

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.
CERTIFICATE OF RELEASE TO SERVICE

Reference: Part-ML, ML.A.402, ML.A.801,
Once complete, the work needs to be released ML.A.803, Appendix II & III
with a Certificate of Release to Service. The CRS
should be written or fixed in the logbook and

CAA / October 2022

Aircraft Exterior Repainting and Interior Trim Work

Aircraft painting and interior refurbishment are PAINTING
maintenance tasks. Most organisations that offer
these services are not themselves approved or Painting is subject to a mandatory requirement in
licensed to release maintenance tasks on an the UK, Generic Requirement (GR) 10, and can
aircraft. Work by such organisations therefore be found in CAP 747. There are also standard
needs to be supervised and released by either changes relating to paint and decorative finishes
an authorised ICS or approved maintenance in CS-STAN.
organisation.
In general terms, GR10 requires consideration /
INTERIOR WORK action relating to:
> Manufacturer’s requirements, impact on
Interior work would normally is outside of the airworthiness of the paint task;
scope of pilot-owner maintenance discussed
in Part-ML Appendix II. Interior work should be > Issue of a CRS on completion; and
discussed with an ICS or approved organisation > Responsibility and control by ICS or an
before any disassembly of the aircraft is approved organisation as appropriate.
undertaken. If an owner removes the interior Note that for painting, the ICS involvement
and sends it to an unapproved organisation, is limited to ELA1 aircraft. In all other cases
without prior consultation, it may not be possible the work must be overseen by an approved
to certify the reinstallation. If a new interior is organisation.
installed without approval, the ARC may be
refused at the next Airworthiness Review. For aeroplanes, ELA1 includes an aircraft

with a Maximum Take-off Mass (MTOM)
For interior work on GA aircraft, the ICS or of 1200 kg or less that is not classified as
approved organisation will need to supervise the a “complex motor-powered aircraft”.
work to the extent necessary to ensure it has
been performed correctly and can be released Many aircraft under Part-ML will fall outside
on completion. This may need to be under a of the ELA1 definition so would require an
sub-contract arrangement between the approved approved organisation to oversee the work.
organisation and the organisation doing the
interior work. Some work, especially when not a
like for like change, may need to use CS-STAN or
have a bespoke modification created.
While interior trim work may appear to be

largely cosmetic, it does raise issues around
flammability and the functioning of seat

adjustment mechanisms, both of which can be
safety critical. For this reason it is considered a
maintenance task requiring supervision by ICS or
approved organisations.

CAA / October 2022

Aircraft Exterior Repainting and Interior Trim Work

PAINTING (CONTINUED) Note that a complete paint job on an aircraft will
normally require the aircraft to be reweighed
Painting is considered to be major work and if and an updated weight and balance schedule
not carried out correctly will compromise the produced.
airworthiness of the aircraft. Some potential
issues include: Critical tasks and the need to perform
independent inspections should be considered
> Reduction in fastener heads caused by
where tasks which may affect the aircraft flight
uncontrolled use of power tools;
path and attitude have been performed, such as
> Surface scratching; the balancing, installation, rigging and adjustment
> Use of incorrect tools to remove paint and of flight controls.
aerodynamic sealant;
> Degrading of plastics and transparencies; Full details relating to the painting of aircraft
can be found in Generic Requirement (GR)
> Aluminium surface contamination by
10, as contained in CAP 747
steel wool;
Mandatory Requirements for Airworthiness.
> Use of incorrect paint stripper, or poor Reference should also be made to CS-STAN
application control leading to airframe where applicable.
contamination (sometimes observed after
paint has been applied by the stripper
Reference: Part-ML, ML.A.301, ML.A.801;
leaching from between skin joints);
CAP 747; UK CS-STAN
> Blockage of probes, vents, and other

openings or failing to remove masking
material from them;
> Failure to replace mandatory markings or
registration marks;
> Water ingress through the use of power
washing (e.g., fuel contamination);
> Uncontrolled variation of the aircraft
basic weight;
> Loss of correct mass balance moments on
flight control surfaces;
> Variation to the surface profile and
smoothness by uncontrolled use of
aerodynamic fillers;
> Aggressive removal of paint applied to

fabric. Not considering the aircraft and fabric
system manufacturers instructions;
> Jamming of flight control and / or landing
gear mechanisms; and
> Impact of paint coatings on non-destructive
testing (NDT) methods.

CAA / October 2022

Purchasing a used aircraft

Key info !
The aircraft has some recorded defects for
The applicable airworthiness regulations rectification when it goes in for the next 100H
represent a minimum standard only. check, none of which are adversely impacting
safety but will be expensive to rectify.
The scope Part-ML allows for deviations from
DAH recommendations and the delegation of In both scenarios 1 & 2, the aircraft are compliant
airworthiness decisions to owners, will inevitably with Part-ML and have a valid C of A and ARC,
lead to different levels of maintenance being but they are two very different aircraft.
applied to individual aircraft. A large proportion of
the UK GA fleet are also considered to be aging It will often be cost effective to spend more
aircraft; bringing additional considerations for money on an aircraft in better condition than buy
their ongoing airworthiness. a cheaper one that will have significant defect
rectification costs.
BUYER BEWARE Potential buyers need to approach aircraft

ownership with caution and not be overcome by
To give an example, owner 1 maintains the the excitement of the purchase. Unfortunately
aircraft to the manufacturers data, with no aircraft are often sold with undisclosed faults
exceptions. Every service bulletin, service that render them unairworthy - missing such
letter, or optional modification is performed. The issues will be very costly when they inevitably
manufacturers corrosion inspection programme emerge later.
is complied with. The engine is factory

overhauled and never exceeds TBO. The aircraft Whilst the CAA has an interest in these issues,
is kept in a heated hangar. Replacement parts they are often raised with the CAA a significant
are new. The aircraft operates on a well-kept period after the sale which makes proving an
airfield with a hard runway and is generally used unairworthy condition existed at the point of sale
for flights of one hour or more. very difficult or impossible.
Owner 2 has the same aircraft type, maintains

the aircraft to the MIP, deviates from multiple
DAH recommendations, including the
manufacturers corrosion inspection programme,
and is running the engine and propeller beyond
the recommended TBO.The aircraft is kept
outside, not covered and rarely flown. Most
flights are for local sightseeing and last for
around thirty minutes.

CAA / October 2022

Purchasing a used aircraft

PRE-PURCHASE INSPECTION
The best way to establish the status of the The status of the documentation that
aircraft is to have a type experienced and accompanies the aircraft should be carefully
independent engineer or organisation perform a scrutinised. Without complete and accurate
thorough pre-purchase survey of the aircraft and records an aircraft is not complete, and the value
its records. The type experience is important, will be diminished. If you are having a survey
especially on niche aircraft that are less common. conducted on the aircraft, include a review of the
documentation and records.
An ICS or organisation familiar with the type
should be able to advise on the availability and Time, effort and money spent at pre-purchase
cost of spare parts and maintenance. Not all survey could prevent an expensive and often
aircraft are well supported so ongoing costs unpleasant negotiation or litigation after the
between types can vary significantly. Some purchase. Identification of a defect does not
individuals and organisations specialise in aircraft necessarily mean a purchase should not proceed,
of specific construction such as wood, fabric and but the prospective buyer should consider how
metal tube or composite. it affects any offer they plan to make on the
aircraft. It may also be possible to negotiate the
It is preferable for the individual or organisation rectification of defects prior to the sale.
conducting the inspection to be a disinterested
party who is not involved in the maintenance
or continuing airworthiness of the aircraft. The

inspection should take the form of an aircraft
survey and go beyond a general walk around.
Performing a flight in the aircraft is also advisable.
Even an aircraft advertised with a “fresh annual”

should be approached with caution and be
appropriately surveyed prior to purchase. There
will likely be a reason for an unusually low
price, and sometimes that reason will mean the
purchase is not advisable.

CAA / October 2022

Certificate of Airworthiness Applications

(including aircraft import)
All Part 21 aircraft types that qualify for a CAA Type Certificate Data Sheets can be found
Certificate of Airworthiness (C of A) are issued on the UK CAA website. For used aircraft
with a non-expiring C of A, validated annually where the exporting organisation are unable
with an Airworthiness Review Certificate (ARC, to declare compliance with the CAA approved
Form 15c). This annual validation will be either Type Certificate Data Sheet, the CAA should be
the issue of a new ARC or an extension of the contacted for further guidance.
validity of the current ARC.
Key info !
All applications for a C of A are made using the
online form which can be found on the CAA Part Note that transfer documentation for used
21 Aircraft, C of A Webpage. aircraft must have been issued within the
60 days preceding receipt of the application
The CAA has determined that some aircraft types by the CAA.
are required to meet Additional Requirements for
Importation before a C of A can be issued. These
additional requirements are defined in CAP 747 Noise certificates are required for some GA
and may include UK Airworthiness Directives and aircraft and this element should be researched
applicable Generic Requirements. As part of the prior to making the application for the C of A.
application, the supporting Part-ML authorised No separate application is required. In practice
person or approved organisation should check for this means providing the noise record number

compliance with the latest version of CAP 747. applicable to the aircraft configuration from
the CAA approved noise certification levels
Transfer documentation is normally one of the database. There are often multiple noise record
following documents: numbers for the same aircraft type, since noise
characteristics will vary depending on the exact
> Form 52 Statement of Conformity to Type
engine, propeller and exhaust configuration. Care
Design (new aircraft manufactured in the
is needed to select the correct record.
UK or the EASA Member states). The
aircraft must be declared as being compliant
Applications must be supported by an approved
with the UK approved version of the Type
person (ICS with a Part-ML authorisation) or
Certificate Data Sheet;
organisation (e.g., Part-CAO or Part-CAMO). An
> Export Certificate of Airworthiness (new airworthiness review will need to be performed
aircraft from outside of the UK or EU). The and an ARC (Form 15c) issued by the supporting
aircraft must be declared as being compliant person or organisation as part of the process.
with the UK approved version of the Type

Certificate Data Sheet; or
> Export Certificate of Airworthiness (used
aircraft). The aircraft must be declared as
being compliant with the UK approved
version of the Type Certificate Data Sheet.

CAA / October 2022

Certificate of Airworthiness Applications

(including aircraft import)
AIRCRAFT SURVEY
A newly manufactured aircraft does not Good preparation is key for the surveyor visit.
necessarily need a physical survey by the CAA If there are no adverse findings, the certificates
before the issue of a UK C of A, unless it is a will usually be issued on site before the surveyor
type new to the UK register. The CAA may chose leaves or by email shortly thereafter.
to survey any aircraft as part of the application,
but often for a new aircraft, the C of A is issued For used aircraft, a check flight is required to
after a desktop review by the CAA’s Shared support the C of A issue. See CAP 1038 for more
Services Centre (SSC) Technical Team in Gatwick. detail. Permit to fly applications can be made
as part of the C of A application process and if
Used aircraft requiring a C of A will be subject to required should be made at the point of initial C
a physical survey by the CAA. of A application, so as to avoid any unnecessary
delay in the process. Owners should also
If a survey is required, the CAA will allocate an consider performing an airworthiness check flight
airworthiness surveyor to attend the aircraft. To while the aircraft is still on the register of the
prepare for this: existing state, immediately prior to deregistration.
This potentially avoids needing a permit to fly for
> Collate all relevant aircraft records in a
the check flight prior to acceptance on the UK
logical order, ensure they are up to date and
register.
available at the location of the survey;

> Ensure that the current status of Other items for the owner to consider includes,
modifications, repairs, mandatory but is not limited to:
requirements, maintenance and components
is up to date and available at point of survey, > VHF Radio with 8.33Khz spacing
along with any supporting documents; > Transponder Mode S Code & Verification
> Ensure that any original documents from > Aircraft Registration Markings (and
the exporting state are available (e.g., Export exemption for military markings if applicable)
C of A), or if communicated digitally, the
> Fireproof registration plate
supporting email dialogue;
> ELT
> Ensure that the aircraft is in a condition
for survey and any maintenance has been
completed and released to service; and Reference: Part 21, Subpart H; Part-ML,
> Ensure that the location for the survey ML.A.906
allows for good access to the aircraft and

records and ideally protected from inclement
weather.

CAA / October 2022

Ownership of Aircraft operating on an enduring

Part 21 Permit to Fly
A permit of fly is issued when an aircraft cannot > Any modification, repair or configuration
meet the requirements for the issue of a C of change that affects the datasheet
A. A permit to fly can either be temporary, for must be appropriately approved
example when maintenance is not up to date, or (either by the manufacturer, another
permanent (enduring) where the aircraft has not design organisation or the CAA).
been shown to meet certification requirements.
Where an enduring permit to fly is issued, the The Form 18b is specific to each aircraft and
use of the aircraft is limited to non-commercial owner because the owner is taking responsibility
flying activity and additional permissions may be for the airworthiness of the aircraft including the
needed when flying outside of the UK. datasheet, manuals, maintenance programme
and any modifications. Importantly the owner is
The permit to fly is issued to an individual aircraft responsible for ensuring any published continued
serial number and is supported by a CAA Form airworthiness information (such as Airworthiness
18b (known as “Flight Conditions”). The Form Directives) is followed.
18b references an Aircraft Data Sheet (similar to
a TCDS), AFM and Aircraft Maintenance Manual The maintenance of these aircraft in the UK is not
(AMM). The Form 18b also lists any conditions usually performed and certified by an approved
and limitations essential for safe operation and organisation (e.g., Part-CAO), but by a Permit
specifies how maintenance must be certified. Maintenance Release (PMR) which is signed
The Form 18b is signed by the owner and by an individual authorised by the CAA. The

approved by the CAA. certification is made in accordance with UK national
requirements for permit to fly aircraft contained in
Although each Form 18b is individual to the BCAR A3-7 – see CAP 553 for more details.
specified aircraft, examples of conditions and
restrictions contained in Section 8 of the form Owners should ensure prior to permit renewal
are as follows: that the aircraft is compliant with the Form 18b
Flight Conditions and that all supporting records
> The use of the aircraft is limited to are available. Where the flight conditions need
non-commercial flying activity; amendment, the owner should correspond with
> The aircraft must be maintained in the DAH, as the responsibility to present those
accordance with the AMM defined conditions to the CAA for approval is with the
in the aircraft data sheet. This owner, in most cases supported by the DAH.
includes safe component lives and
other airworthiness limitations; Potential owners of enduring permit to fly aircraft
> The Airworthiness Review must be should consider the relative complexity of this
performed as detailed in ML.A.903 but type of aircraft management. As with any task,
an ARC / Form 15c is not issued. An familiarity with the process of management and
entry must be made in the logbook permit application and survey makes that task
describing the review and its outcome easier, but it should be recognised as different to
and supplied on request to the CAA; the Part-ML aircraft.
> New parts are required to have a CAA Form
1 or equivalent; and Reference: Part 21, Subpart P; CAP 553, BCAR
Section A

CAA / October 2022
THE AIRWORTHINESS CODE
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
THE AIRWORTHINESS CODE
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

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AIRWORTHINESS

A MAINTENANCE GUIDE FOR

Published by the Civil Aviation Authority, First Published, October 2022

CHAPTER 3: PART-ML MAINTENANCE

CHAPTER 4: CONTINUING AIRWORTHINESS

Airworthiness Code / Notes 02

CHAPTER 3: PART-ML MAINTENANCE

Section 6 – Pilot-owner Maintenance 43

Airworthiness Code / Contents 03

CHAPTER 3: PART-ML MAINTENANCE

Airworthiness Code / Contents 04

CHAPTER 3: PART-ML MAINTENANCE

Airworthiness Code / Intro 05

The publication primarily addresses:

> Part 21 aircraft operating on an enduring permit to fly.

The aim is:

BETTER INFORMED OWNERS SAFE AND INFORMED

CHAPTER 3: PART-ML MAINTENANCE

Readers should understand that the publication is a guide and not a

References to source regulations are made throughout this guide

certification specifications and guidance material.

i Part-ML and Part-CAO information and

Airworthiness Code / Intro 06

CHAPTER 1: THE AIRWORTHINESS SYSTEM

Annex Subject Nature

Annex I – Part-M Continuing Airworthiness for Complex Airworthiness

Annex III – Part-66 Aircraft Maintenance Licence Personal Qualification

Annex IV – Part-147 Aircraft Maintenance Training Organisations Organisation Approval

CHAPTER 3: PART-ML MAINTENANCE

Annex Va – Part-T Part T – Aircraft Registered in a Airworthiness

Annex Vc – Part-CAMO Continuing Airworthiness Organisation Approval

Annex Vd – Part-CAO Combined Airworthiness Organisation Organisational

Airworthiness Code / Chapter 1 08

CHAPTER 1: THE AIRWORTHINESS SYSTEM

CHAPTER 3: PART-ML MAINTENANCE

> for operation with a minimum crew of

Airworthiness Code / Chapter 1 09

CHAPTER 1: THE AIRWORTHINESS SYSTEM

Part-CAO (continued) Part-CAMO

CHAPTER 3: PART-ML MAINTENANCE

subject to Part-ML. organisation.

Airworthiness Code / Chapter 1 10

CHAPTER 1: THE AIRWORTHINESS SYSTEM

CHAPTER 3: PART-ML MAINTENANCE

Airworthiness Code / Chapter 1 11

CHAPTER 1: THE AIRWORTHINESS SYSTEM

ACCEPTABLE MEANS OF COMPLIANCE

CHAPTER 3: PART-ML MAINTENANCE

Continuing Airworthiness – AMC GM.

Airworthiness Code / Chapter 1 12

CHAPTER 1: THE AIRWORTHINESS SYSTEM

Design and Manufacture

CHAPTER 3: PART-ML MAINTENANCE

Some factory-built Part 21 aircraft have not

CHAPTER 1: THE AIRWORTHINESS SYSTEM

Continuing Airworthiness Management

CHAPTER 3: PART-ML MAINTENANCE

response to operational experience, incidents or commercial operations, it is a requirement for the

Reference: Part-ML, Section A; Part 21, 21.A.7,