Program compliance
Maintenance program status review against its approved basis in the CAMO file
This review confirms that a maintenance program status still corresponds to the program the authority approved. It is run for CAMO managers when the due list must be shown to rest on the current approved basis: at program transitions, after repeated revisions, or while preparing an airworthiness status baseline. The task due list is read against the approved program revision, its source documents, and the escalations, deviations, and bridging decisions recorded in the file. Tasks scheduled on intervals the approved basis no longer supports are reported with the revision history that explains the drift.
When this review is needed
- The program has been revised repeatedly and nobody has proven the due list caught every change.
- A fleet is bridging from one program basis to another, or from a previous operator's program.
- An authority audit or airworthiness review will sample due-list tasks against the approved program.
- Escalations and short-term deviations have accumulated without a consolidated record.
The problem
The approved maintenance program and the operational due list are maintained by different people on different rhythms. Program revisions land as documents; the due list changes task by task in the scheduling system, and each translation is a chance for an interval, threshold, or applicability note to be dropped or misread. After a few revision cycles the due list reflects a program that exists nowhere on paper.
What gets reviewed
- The task due list against the currently approved program revision and its approval record
- Interval, threshold, and applicability agreement for sampled and high-consequence tasks
- Escalations, deviations, and tolerances applied, against the approvals that permitted them
- Bridging records where the aircraft moved between programs or operators
- Program source references: MRB report, MPD revisions, and ALS or CMR items where applicable
- Open-item logs for program changes accepted but not yet implemented in the due list
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What gets validated
- Sampled due-list tasks carry the interval and threshold stated in the approved revision, not an earlier one
- ALS and CMR items are tracked at their mandatory intervals with no unapproved escalation applied
- Every escalation or deviation in use has its approval in the file and has not lapsed
- Bridging calculations at program transitions preserved each task's position rather than resetting it
- The approved-program revision in the file matches what the authority's approval letter actually covers
Evidence normally required
- The current task due list export from the scheduling system
- The approved program document set with revision and approval records
- Escalation, deviation, and tolerance approvals in force
- Bridging documentation from any program or operator transition
- CAMO open-item logs and airworthiness-review notes touching the program
Common discrepancies
- Tasks still scheduled at an escalated interval after the escalation approval expired
- A program revision that tightened an interval, implemented for new tasks but never applied to instances already scheduled
- ALS items handled in the system as ordinary program tasks, exposed to tolerances they must not receive
- Bridging from a prior operator that restarted task positions the approved method required to be carried over
What is at stake
A task running on a stale interval is either being over-maintained at real cost or under-maintained against the approved basis, and the second case is a compliance finding with retroactive reach: every accomplishment since the drift began can be questioned. Unwinding that during an audit consumes exactly the engineering attention the audit already demands.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Establish the approved basis
Confirm which program revision the approval record actually covers and assemble its source documents.
Compare the due list
Read sampled task intervals, thresholds, and applicability against the approved revision, prioritizing ALS and CMR items.
Audit escalations and bridges
Verify every escalation, deviation, and bridging decision in use against its approval and validity period.
Specify the corrections
Deliver the divergence list with approved values and the revision history, ready for the scheduling team to implement.
What the buyer receives
- A task-level exception list showing the due-list value, the approved value, and the revision where they diverged
- A consolidated register of escalations and deviations with approval status
- A corrected due-list specification the scheduling team can implement and evidence
Who uses the output
- CAMO managers evidencing program compliance to auditors and reviewers
- Maintenance planning teams correcting the scheduling system
- Fleet engineers managing escalations and program transitions
How the work fits into the transaction or program
Program status is the scaffolding under the rest of the CAMO file: task cards close against program tasks, non-routines arise from them, and the airworthiness review samples them. Proving the due list against the approved basis first keeps the task-card and non-routine reviews from validating work against the wrong requirement.
Jurisdiction-specific considerations
For US operators, 14 CFR 121.380 and 135.439 set recordkeeping duties around the maintenance program, with 91.417 covering the aircraft records themselves. EASA operators maintain the AMP under Regulation (EU) 1321/2014 with CAMO approval and audit obligations, and ICAO Annex 6 frames the program requirement for states that build on it. The review adapts to whichever approval chain governs the aircraft, since due-list drift from the approved basis is a failure mode common to all of them.
Regulatory limits
The review compares the due list to the approved program and its recorded approvals. It does not approve programs, escalations, or deviations, does not perform the airworthiness review, and makes no determination that the aircraft is airworthy.
What this review does not cover
- Reliability analysis or optimization of program intervals
- Authoring program revisions or escalation justifications
- Auditing the scheduling software itself beyond the values it holds
Specific to this review
- Due-list drift is usually invisible from inside the CAMO because both the list and the program look internally consistent; only reading one against the other exposes it.
- Interval tightenings get dropped more often than relaxations, because relaxations save money and are implemented with enthusiasm.
- ALS and CMR items are the highest-stakes lines on the due list: they carry no tolerance authority, so a drifted interval there is immediately reportable.
- Bridging events dominate the exception population; a fleet that changed programs twice will typically owe most of its findings to those two moments.
Sources
U.S. Government (eCFR). Air carrier maintenance recordkeeping and retention requirements under Part 121.
U.S. Government (eCFR). Maintenance recordkeeping and retention requirements for Part 135 operators.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
International Civil Aviation Organization. International standards for aircraft operation, including maintenance program and recordkeeping expectations.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
Frequently asked questions
How is this different from the authority's program audit?
It runs to the same comparison, due list versus approved basis, but earlier, at your instigation, and with a remediation output rather than findings. Operators typically use it to enter the authority audit with the drift already found and corrected.
Relevant glossary terms
Related pages
Where this fits
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