Continuing Airworthiness
Keeping the aircraft airworthy
Part-M and Part-ML (Regulation 1321/2014) allocate responsibility. The owner/operator is responsible for continuing airworthiness; a Part-CAMO manages it under contract. Core tasks: the approved maintenance programme (AMP); compliance with airworthiness directives, which are mandatory; assessment of service bulletins, which are not mandatory unless an AD, the AMP or the operator requires them; control of modifications and repairs; defect trend analysis; mass and balance; and the airworthiness review.
The airworthiness review certificate (ARC) is valid for one year. It is issued by the competent authority or by a CAMO holding the privilege, after a review of records and a physical survey of the aircraft. The ARC cannot be extended - a new review is needed. Where the aircraft changes register, a new ARC or review is required.
Traps: assuming service bulletins are automatically mandatory; assuming a Part-145 release to service demonstrates continuing airworthiness (it covers only the work performed); mixing record-retention periods - Part-145 keeps maintenance records three years, while CAMO/owner records for the aircraft must be kept for the periods Part-M states. Also, a CRS is not an ARC.
Rule of thumb: three questions in order - what must be done (AMP, ADs), who signs the work (Part-145/Part-66), and is the aircraft still airworthy overall (ARC).
Worked example: an ARC expires on 30 June. The review must be completed before expiry, with records showing AD compliance, weight report and maintenance accomplished; otherwise the aircraft cannot fly until a new ARC is issued.