4.
An operator should therefore have adequate knowledge of the design status (type specification, customer options, airworthiness directives (AD), airworthiness limitations contained in CS-25 Book 1, Appendix H, paragraph H25.1, fuel tank system airworthiness limitations including Critical Design Configuration Control Limitations (CDCCL), modifications, major repairs, operational equipment) and required and performed maintenance. The status of aircraft design and maintenance should be adequately documented to support the performance of the quality system.
5.
An operator should establish adequate co-ordination between flight operations and maintenance to ensure that both will receive all information on the condition of the aircraft necessary to enable both to perform their tasks.
6.
The requirement does not mean that an operator himself performs the maintenance (this is to be done by a maintenance organisation approved under MCAR-145) but that the operator carries the responsibility for the airworthy condition of aircraft it operates and thus should be satisfied before the intended flight that all required maintenance has been properly carried out.
7.
When an operator is not appropriately approved in accordance with MCAR-145, the operator should provide a clear work order to the maintenance contractor. The fact that an operator has contracted a maintenance organisation approved under MCAR-145 should not prevent it from checking at the maintenance facilities on any aspect of the contracted work if he wishes to do so to satisfy his responsibility for the airworthiness of the aircraft.
AMC M.201 (h) 1- Responsibilities
1.
An operator only needs to be approved for the management of the continuing airworthiness of the aircraft listed on its AOC. The approval to carry out airworthiness reviews is optional.
2.
This approval does not prevent the operator subcontracting certain continuing airworthiness management tasks to competent persons or organisations. This activity is considered as an integral element of the operator’s MCAR-M Subpart G approval. The regulatory monitoring is exercised through the operator’s MCAR-M Subpart G. approval. The contracts should be acceptable to CAD.
3.
The accomplishment of continuing airworthiness activities forms an important part of the operator’s responsibility with the operator remaining accountable for satisfactory completion irrespective of any contract that may be established.
4.
MCAR-M does not provide for organisations to be independently approved to perform continuing airworthiness management tasks on behalf of commercial air transport operators. The approval of such activity is vested in the operator’s air operator’s certificate (AOC). The sub-contracted organisation is considered to perform the continuing airworthiness management tasks as an integral part of the operator's continuing airworthiness management system, irrespective of any other approval held by the subcontractor including a MCAR-M Subpart G approval.
5.
The operator is ultimately responsible and therefore accountable for the airworthiness of its aircraft. To exercise this responsibility the operator should be satisfied that the actions taken by sub-contracted organisations meet the standards required by MCAR-M Subpart G. The operator's management of such activities should therefore be accomplished
(a)
by active control through direct involvement and/or
(b)
by endorsing the recommendations made by the sub-contracted organisation.
6. In order to retain ultimate responsibility the operator should limit sub-contracted tasks to the activities specified below:
(a)
airworthiness directive analysis and planning
(b)
service bulletin analysis
(c)
planning of maintenance
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