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In the words of ICAO, Continuing Airworthiness is:
- “All of the processes ensuring that, at any time in its life, an aeroplane complies with the technical conditions fixed to the issue of the Certificate of Airworthiness and is in a condition for safe operation" - source: ICAO Airworthiness Manual [ICAO, 2014]
It is useful to compare Continuing and Continued as they are sometimes used interchangeably. Continued Airworthiness is also known as Initial Airworthiness or by the UK Ministry of Defence as “Type Airworthiness” [MAA, 2021]
- Initial Airworthiness - Those activities that demonstrate compliance with the technical conditions, (certification basis) to the satisfaction of the competent authorities, it is the culmination of the design and certification stages.
- Type Airworthiness - “All the actions associated with the upkeep of a Type Design and the associated Approved Data through life.” “Note: Previously known as Continued Airworthiness.” - Source MAA02 glossary [MAA, 2021]
The key difference being that continuing airworthiness is about sustaining an aeroplane, ie actions relevant to each registered air vehicle whereas continued or type airworthiness is about activities to control, assess and change/repair the type design to sustain airworthiness for the whole fleet.
Management of Continuing Airworthiness
It follows therefore that Continuing Airworthiness Management is the process by which an aircraft is kept in a condition where it remains airworthy throughout its life - or in other words is technically fit for flight. Although the ultimate responsibility for continued airworthiness is assigned in ICAO Annex 8 to the State of Design the programme to achieve continuing airworthiness is a matter for the State of Registry. And although the owner bears the legal responsibility for continuing airworthiness, there is very much a shared responsibility between:
- The aircraft Type Certificate Holder (TCH) - Designer / Manufacturer
- Commercial Air Transport (CAT) Operators
- Aircraft Owner
- Maintenance Organisation
- Authorised Persons e.g. Licensed Aircraft Engineers
- Regulators i.e. Airworthiness Authorities
This obligation for CAT operators is stated within EU 2018/1139 Annex V Section 6, Essential Requirements for Air Operations [EU, 2018] an aircraft must not be operated unless:
- The aircraft is airworthy and in a condition for safe and environmentally compatible operation, and;
- The operational and emergency equipment necessary for the intended flight is serviceable and;
- The airworthiness document and if applicable the noise certificate is valid, and;
- The maintenance of the aircraft is performed in accordance with the applicable requirements.
These obligations are reiterated within M.A 201 (Technical Requirements - Responsibilities) in EASA Part M [EC, 2014], which gives more detail concerning the responsibilities for continuing airworthiness.
Inspection methods and intervals, repair actions, modifications and timescales are all part of Continuing Airworthiness, as are feedback to design/production and formal airworthiness review (or Airworthiness Review Certificate, ARC). Although these are drawn from EASA Part M, Sub Part G M.A.708 [EC, 2014], the activities would be similar to those required of any operator
For operators based in EU nations, and others who choose to follow EASA regulations, a Continuing Airworthiness Management Organisation (CAMO) must be in place to assure that maintenance is performed correctly. This is an (approved) organisation responsible for implementation of continuing airworthiness management tasks. For operators based outside the EU, for whom EASA regulations do not apply, continuing airworthiness is still managed in a controlled manner but the regulations are within the rules for the operator.
For each of the aircraft the approved CAMO manages, they are required to carry out the following functions:
- Develop and control a maintenance programme for the aircraft managed including any applicable reliability programme
- Present the aircraft maintenance programme and its amendments to the competent authority for approval
- Manage the approval of modification and repairs,
- Ensure that all maintenance is carried out in accordance with the approved maintenance programme and released in accordance with M.A. Subpart H [Certificate of Release to Service (CRS)]
- Ensure that all applicable Airworthiness Directives (ADs) and operational directives with a continuing airworthiness impact, are applied.
- Ensure that all defects discovered during scheduled maintenance or reported are corrected by an appropriately approved maintenance organisation,
- Ensure that the aircraft is taken to an appropriately approved maintenance organisation whenever necessary,
- Coordinate scheduled maintenance, the application of ADs, the replacement of service LLP, and component inspection to ensure the work is carried out properly
- Manage and archive all continuing airworthiness records and/or operator's technical log.
- Ensure that the mass and balance statement reflects the current status of the aircraft.
Continuing Airworthiness is therefore not just the maintenance of aircraft and associated products and parts, but also involves monitoring performance of those items in service. This will include recording in-service difficulties experienced against each item to assess significance with respect to safety and airworthiness for the specific aircraft/product type and for impact across similar aircraft/products. Timely response is required where airworthiness is affected, which means devising and provisioning rectification action, and promulgating the necessary information to restore safety levels.
- For more on concept of Continuing Airworthiness, see the Continuing Airworthiness leaflet prepared by the International Federation of Airworthiness (IFA) to assist the understanding of the basic Continuing Airworthiness requirements and control functions.
- EC (2018), Regulation (EU) 2018/1139 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency.
- EC (2014), Commission Regulation (EU) No 1321/2014 of 26 Nov 2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks. (external link)
- AC 43.13-1B: Acceptable Methods, Techniques, and Practices - Aircraft Inspection and Repair, FAA, September 1998
- AC 43.13-2B: Acceptable Methods, Techniques, and Practices - Aircraft Alterations, FAA, March 2008
- ICAO (2014), Doc 9760 Airworthiness Manual, 3rd Edition, ICAO.
- MAA (2021), MAA02 Military Aviation Authority Master Glossary, Issue 9.
- Maintenance Briefing Notes: Maintenance Documentation by Airbus
- Maintenance Briefing Notes: Maintenance during aircraft storage by Airbus