Contracted & Sub-Contracted Relationships in the EASA Context

Rustom D. Sutaria – Avia Intelligence, Dhaka, Bangladesh, 2018


SCENARIO: The organisation that has been awarded the contract is responsible for complying with all requirements that are associated with the contracted activity.

Example:
The operator awards a contract to an Approved Maintenance Organisation including the responsibility of certification of aircraft and components.

 There is a serious limitation to a contracted Relationship:  For example, it is not allowable for an operator to transfer its responsibility for mandatory oversight.  The operator must remain responsible for continuing Airworthiness under the regulations.


SCENARIO:
The organisation has awarded a contract to a supplier, but has retained the responsibility for complying with all requirements that are associated with the contracted activity.

Example – OPERATOR TO MAINTAINER RELATIONSHIP:
An AMO awards the contract for the fabrication of aircraft seat covers to a cabin interiors organisation without a Part 145 Approval.

Certification of the Seat Cover under EASA Form 1 remains with the Awarding Part 145 Organisation under the remit of their Capability Listing which is approved under the awarding organisation’s Part 145 approval.

Another Example – OPERATOR TO OPERATOR OR OPERATOR TO STAND ALONE CAMO RELATIONSHIP:
The operator has sub-contracted the Aircraft Maintenance Planning Function (usually under the operator’s CAMO’ to a Stand-alone Part M Subpart G organisation or to another operator with the relevant approvals.  CONTRACT CANNOT APPLY HERE!!  CAMO Tasks are regarded as under sub-contract because oversight of the CAMO tasks must strictly remain with the Operator per regulations.