How to Write a CAME: Structuring a Part-CAMO Exposition Under Regulation 1321/2014

Knowing how to write a CAME is one of the most important steps when establishing or restructuring a Continuing Airworthiness Management Organisation (CAMO).

If you are establishing a full CAMO from the ground up, our guide on how to build a CAMO from scratch explains the wider approval structure, management system requirements, and authority expectations beyond the CAME itself.

Under Regulation (EU) No 1321/2014, specifically Annex Vc (Part-CAMO), every approved CAMO must maintain a compliant Continuing Airworthiness Management Exposition (CAME) as required by CAMO.A.300.

The CAME is not simply a manual for authority approval—it is the operational backbone of the organisation. It defines how continuing airworthiness is managed, how responsibilities are assigned, how compliance is maintained, and how the organisation demonstrates control to the Competent Authority.

Many organisations approach the CAME as a paperwork exercise. This is usually where problems begin.

A poorly written CAME creates audit findings, operational confusion, authority distrust, and serious compliance exposure.

A strong CAME, however, becomes a management tool—not just an approval document.

This article explains how to write a CAME properly under Part-CAMO, with direct reference to Regulation (EU) No 1321/2014 and practical authority expectations.

1. Understand What CAMO.A.300 Actually Requires

Before writing the document, management must understand the legal requirement behind it.

Under CAMO.A.300, the organisation must provide a Continuing Airworthiness Management Exposition containing:

  • a statement signed by the Accountable Manager
  • the scope of work
  • the title(s) and name(s) of persons referred to in CAMO.A.305
  • an organisation chart
  • a description of the management system
  • procedures specifying how the organisation ensures compliance
  • amendment procedures for the exposition

This means the authority is not asking for a generic manual template.

They are asking for documented proof of how your CAMO actually functions.

The exposition must reflect reality—not aspiration.

Where referenced, official documents should be linked directly to the source, including:

2. Start with the Scope of Approval

The CAME should be built around the real approval scope—not the other way around.

This includes:

  • aircraft types and variants
  • fleet size
  • operational environment
  • airworthiness review privileges
  • permit to fly recommendation privileges
  • contracted maintenance arrangements
  • subcontracted continuing airworthiness tasks

Many organisations make the mistake of drafting a broad manual first and trying to fit operations into it later.

This creates immediate authority concerns.

Your CAME must reflect exactly what the organisation is approved to do under CAMO.A.125. The approval scope drives not only the CAME structure but also the wider organisational design discussed in our CAMO setup guide for new operators.

If the scope changes, the CAME must change.

3. Structure the CAME Around Operational Control

A good CAME is written around control, not around chapters.

Most authorities expect the exposition to clearly demonstrate control over:

  • aircraft status
  • AD and mandatory requirement compliance
  • AMP control
  • defect management
  • deferred defect monitoring
  • maintenance planning
  • technical records integrity
  • contracted maintenance oversight
  • subcontracted CAW task oversight
  • occurrence reporting
  • compliance monitoring

If these controls are not obvious, the authority will assume they do not exist.

The best CAMEs are operationally usable by staff—not just readable by auditors.

4. Clearly Define Responsibilities and Authorities

Under CAMO.A.305, nominated persons must be clearly identified.

This typically includes:

  • Accountable Manager
  • NPCA / Continuing Airworthiness Manager
  • Compliance Monitoring Manager
  • Safety Manager (where applicable)
  • Airworthiness Review Staff (if privileges are held)

The CAME must show:

  • reporting lines
  • authority boundaries
  • delegation rules
  • escalation paths
  • independence of compliance monitoring

Authorities are not interested in decorative organisation charts.

They want evidence that the people named actually control the function.

Ambiguity here creates immediate findings.

5. The Management System Must Be Real

Under CAMO.A.200, the management system is one of the most scrutinised sections.

Your CAME must describe how the organisation manages:

  • safety policy and objectives
  • compliance monitoring
  • occurrence reporting
  • risk assessment
  • corrective action management
  • internal audits
  • management review
  • human factors considerations
  • continuous improvement

The old “quality manual” mindset is no longer enough.

Part-CAMO expects a functioning management system, not a compliance department hidden in the back office.

This is especially relevant as operators integrate Part-IS requirements, where information security governance becomes part of authority expectations and organisational control. Our guide on Part-IS requirements for CAMOs explains how these requirements affect CAMO procedures and exposition content.

Many initial approvals fail here because the manual describes a system that does not exist in practice.

6. Contracted vs Subcontracted Activities Must Be Precise

One of the most common CAME weaknesses is confusion between contracted maintenance and subcontracted continuing airworthiness management tasks.

These are not the same.

The CAME must clearly distinguish:

Contracted Activities

Examples include:

  • Part-145 maintenance organisations
  • component repair organisations
  • engine repair vendors
  • external logistics providers

These organisations work under their own approvals.

Subcontracted CAW Tasks

Under CAMO.A.125(d)(3), only specific continuing airworthiness management tasks may be subcontracted under CAMO control.

Examples include:

  • maintenance planning support
  • technical records administration
  • engineering support
  • reliability programme administration
  • AD and SB assessment support

Not everything can be subcontracted.

Final airworthiness responsibility always remains with the approved CAMO.

This section must be especially strong because authorities review it very closely.

7. Avoid the Biggest CAME Mistake: Copy-Paste Compliance

The most common failure is using a template without operational ownership.

Authorities identify this immediately.

Typical signs include:

  • procedures that staff cannot explain
  • responsibilities assigned to roles that do not exist
  • workflows that contradict actual practice
  • generic references copied from another operator
  • approval privileges the organisation does not hold

A template may help with structure.

It should never define your operation.

The best CAME is written from real workflows upward—not from a purchased template downward.

8. Prepare the CAME for Authority Approval

The Competent Authority will assess whether the exposition proves control.

They will typically challenge:

  • management system effectiveness
  • competence of nominated personnel
  • subcontract control
  • technical records procedures
  • maintenance planning robustness
  • AMP governance
  • defect and deferred defect control
  • occurrence reporting pathways
  • compliance monitoring independence

The strongest approvals come from early authority engagement, not from last-minute manual polishing.

A CAME should be audit-ready from the beginning.

Conclusion

Knowing how to write a CAME properly is not about producing a longer manual—it is about building a controlled organisation.

Under Regulation (EU) No 1321/2014, the CAME is the formal demonstration of how the CAMO manages continuing airworthiness, maintains compliance, and satisfies authority oversight.

A strong CAME delivers three things:

  1. regulatory compliance
  2. operational clarity
  3. authority confidence

When those three exist together, approval becomes significantly easier.

The best CAME is not written for the auditor.

It is written for the organisation that must live with it every day.

FAQs

What is a CAME in Part-CAMO?

A CAME is the Continuing Airworthiness Management Exposition required under CAMO.A.300 of Regulation (EU) No 1321/2014. It defines how the CAMO is organised, managed, and controlled to ensure continuing airworthiness compliance.

Is the CAME mandatory for CAMO approval?

Yes. A CAMO cannot obtain approval without an accepted CAME. The Competent Authority uses the exposition to assess whether the organisation has the required structure, procedures, and management system.

What should be included in a CAME?

The CAME should include organisational structure, nominated personnel responsibilities, management system procedures, compliance monitoring, subcontracted activities, technical procedures, occurrence reporting, and record-keeping controls.

Who approves the CAME?

The Competent Authority responsible for the CAMO approval reviews and accepts the CAME before approval is granted. Any major revisions also require authority acceptance.

What is the most common mistake when writing a CAME?

The most common mistake is writing procedures that do not reflect actual operations. Authorities quickly identify manuals that are copied from templates but not implemented in practice.

Can a CAMO use a template CAME?

Templates can help structure the document, but the final CAME must reflect the organisation’s real procedures, responsibilities, systems, and approval scope. A generic template alone is never sufficient.

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