Discussions about Part 42 of CASR highlighted the increasing responsibilities and pressure in managing continuing airworthiness.
Operators found workforce capability as a key risk area, particularly around training, competency and clear career pathways for CAMO staff.
They noted that the following issues may affect continuing airworthiness:
- limited understanding of Part 42 responsibilities
- challenges in attracting and retaining experienced staff.
What can operators do?
Approved Maintenance Organisations (AMOs) operating under Part 42 of CASR should recognise the link between:
- maintenance work
- continuing airworthiness management (CAMO) functions.
Key factors for effective Part 42 outcomes include:
- workforce capability
- clear roles
- decision-making.
AMOs should:
- develop CAMO competency frameworks with industry, including knowledge of airworthiness requirements, maintenance planning, and operational impacts
- ensure staff clearly understand CAMO roles, responsibilities and decision-making authority
- address workforce gaps by improving attraction and retention, including career pathways, pay, and role design
- ensure maintenance control roles have the right mix of technical skills and operational understanding
- use practical, proportionate solutions that suit the size and complexity of the organisation
- treat workforce issues such as skill gaps, shortages and unclear roles as safety risks in the SMS.
Smaller operators, including those under CASR Part 135, should take a practical approach to meeting Part 42 requirements while still ensuring CAMO functions are effective for the size and complexity of the operation.
What are we doing and what have we already delivered?
We recognise the challenges around workforce capability and role clarity under Part 42 of CASR, especially for CAMO functions and maintenance control activities.
We have:
- provided guidance on Part 42 responsibilities, including the use of qualified entities for CAMO functions while confirming accountability remains with the certificate holder
- set expectations that CAMO staff hold suitable qualifications and show competence, and we continue to review competency guidance for consistency
- engaged with industry through forums and workshops to understand workforce challenges and inform policy and guidance
- included CAMO functions in surveillance activities, focusing on effectiveness, decision-making and staff competency
- recognised that smaller operators, including Part 135 operators, may need flexible and practical approaches while still meeting requirements
- continued to update guidance and policy to better support implementation, including workforce capability, training and CAMO arrangements.