CAMO Contracting and Subcontracting: CAMO.A.205 and Maintenance Contracts

Define which work is being placed outside the CAMO

A CAMO can arrange for another organisation to perform management tasks or contract a maintenance organisation to carry out maintenance. The agreement needs to say which work is involved. The CAMO, CAO and Part-145 roles guide explains the wider division of responsibilities; this guide follows the two different arrangements through evaluation and service preparation.

Neither record is a separate organisational approval. They make the evidence and arrangements easier to review.

CAMO.A.205 applies to both arrangements

Paragraph (a) requires conformity with applicable requirements and consideration of associated aviation safety hazards for both contracted maintenance and subcontracted management activities. Paragraph (b) then addresses subcontracted management specifically: work under the managing CAMO's approval and access for its competent authority.

That distinction matters when reviewing an external organisation. A positive evaluation cannot remove the CAMO's duties or give the subcontractor a separate approval. Record how authority access will be provided. Also examine the hazards created by the arrangement, including handovers, delayed information and unclear decision responsibilities. An absence of reported occurrences alone does not demonstrate that those hazards have been considered.

Evaluate the management tasks and the people doing them

Use the subcontractor evaluation when considering an assignment or reviewing its delivery. Start with the actual scope and contract reference, then sample evidence that the work can be performed as agreed. A generic description such as “engineering support” leaves too much unanswered: identify the outputs, interfaces and decisions included in the assignment.

CAMO.A.305(d) requires a system to plan sufficient appropriately qualified staff, and CAMO.A.305(g) requires competence to be established and controlled. AMC1 CAMO.A.305(g)(e) gives useful role objectives: programme engineers interpret source data to develop the AMP, engineering staff interpret and use technical data, and planners organise maintenance effectively and on time. Apply the relevant objectives to the subcontracted scope. The staff competence and manpower guide explains how to assess that evidence without treating every criterion as universal.

Practical evidence can include a sample completed task, the data revision used, a demonstration of the agreed software and a traceable handover. Check consistency with the managing CAMO's continuing airworthiness management exposition (CAME) and the contract. Record deviations and their effect on the proposed scope, rather than relying on a favourable overall impression.

Define the maintenance contract and its interfaces

Read the condition at the start of paragraph (c) with its references to M.A.201 and ML.A.201. It addresses the required written contracts where the CAMO lacks the appropriate maintenance approval. Its objectives include maintenance ultimately being performed by an appropriately approved maintenance organisation and clear specification of the referenced continuing-airworthiness functions.

Appendix IV provides the technical subjects to work through with the maintenance organisation:

The following groups cover its topics. Apply the relevant ones to the aircraft, engine or line-maintenance arrangement; they are not a complete standard contract or a prescribed customer questionnaire.

Appendix IV point 1 also explains that a contract normally does not provide detailed work instructions. Roles, procedures and routines in both organisations should reflect the contract so that people understand their responsibilities. Where several maintenance organisations are involved, check that the agreements are consistent with one another.

Keep the established technical workflows alongside the agreement: AMP control, AD evaluation and compliance, and maintenance release and records. The contract explains the interfaces between those activities; this guide does not repeat their procedures.

Keep individual work orders within CAMO.A.315(d)

The aircraft case is unscheduled line maintenance. Selecting a transit, daily or weekly check in the intake form does not establish that this exception applies. The second case covers component maintenance, including engines and propellers as applicable. Preserve these limits when deciding how to document the maintenance arrangement.

Gather customer details before the service starts

The new maintenance customer details form helps an internal maintenance-control or commercial member record information received from the customer. Confirm missing details with the relevant contact and use the record to prepare the agreed scope, resources and communications. Customers outside the workspace do not fill in the form.

Fictional example: ExampleAir asks ExampleMRO to provide recurring daily checks at a new station for MSN-EXAMPLE-014. The maintenance manager confirms the requested scope and location, the continuing airworthiness manager identifies the work instructions, and the flight operations post holder supplies the flying schedule and operational contacts. They clarify fluid specifications and supply arrangements before the service begins. A recurring scheduled service does not become the unscheduled-line-maintenance case simply because the intake form calls it line maintenance.

Why the forms ask what they ask

Subcontractor evaluation

Identity, scope, manuals, contract and evaluation date establish the assignment and evidence being reviewed. This is important because CAMO.A.205(b) places the management work under the managing CAMO's approval. Authority access records how the separate access condition in the same paragraph will be met; a favourable score is not an access arrangement.

Staff, training, resources and role capability test whether the proposed team can deliver the agreed tasks. CAMO.A.305(d) and (g) provide the staffing and competence context; AMC1 CAMO.A.305(g)(e) helps select relevant role objectives. An organisation may be well equipped for planning support but lack the competence needed to develop a maintenance programme. The conclusion needs to follow the actual scope.

Procedures, software, current documents, communication and deviations provide practical evidence of performance against the contract. They support the conformity duty in CAMO.A.205(a)(1). Identify what was sampled and the consequence of any gap; a software name or a manual reference alone does not demonstrate effective use.

Hazards and risk controls address CAMO.A.205(a)(2). Consider the arrangement actively, even when no occurrence has been reported. For example, an ambiguous handover could allow both parties to assume the other is checking a due task. Record the risk assessment and controls in the comments rather than treating silence as evidence of acceptable risk.

Comments, conclusion and actions connect each judgement to evidence. Explain negative or not-applicable answers, identify outstanding work and state any limits on the assignment. These are practical ways to make the evaluation reviewable; the form's outcome is not a separate regulatory approval.

New maintenance customer details

Customer identity, representative and date received show who supplied the information and where to clarify it. The administrative details establish the service request; they do not prove maintenance capability.

Aircraft, locations and requested scope support the contract topics in Appendix IV points 2.1–2.2. They let the maintenance organisation compare the request with the work and locations covered by its certificate. Record enough detail to distinguish an on-call request from a defined scheduled service.

Fluid specifications, data references and supply arrangements help prevent uncertainty over what to use and who supplies it. Point 2.12 addresses the allocation of material and component supply; the form's specific fluid prompts are practical preparation details, not separately prescribed questionnaire fields.

Communication, procedure familiarisation and contacts help the people delivering the service understand the agreed responsibilities and reach the right person. They support point 1's procedures and routines and point 2.22's information-exchange arrangements. Selecting a briefing method alone does not establish a person's competence.

Schedules and work instructions received support preparation of the planned work. Points 2.7 and 2.14 address maintenance data and scheduled-work support documents. Reference the relevant instructions and schedule so the information can be checked. CAMO.A.315(c)–(d) still determine the maintenance contract or individual-work-order arrangement; an intake record does not replace it.

Record the review and confirm the follow-through

The continuing airworthiness manager or nominated person prepares the subcontractor evaluation as a workspace member. Its written compliance-review section goes to a workspace member acting as compliance monitoring manager, who reviews the scope, evidence, risks, authority access and relevant findings. Record the decision, any limits, and the actions and evidence needed before an outstanding point can be treated as resolved.

Avioverse follow-up sections are assigned only to workspace members. The assignee records Approve or Request changes with a comment, or Not required with a reason. Accepting the evaluation outcome does not remove unresolved deficiencies or the duties in CAMO.A.205. The maintenance customer details form has no built-in follow-up section; its information supports the separate contract and service-preparation work.