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CAMO.A.135 requires the organisation to establish an independent compliance monitoring function that continuously verifies the organisation is meeting all applicable requirements of Part-CAMO and its own approved procedures.
What it means in practice
The compliance monitoring function is an internal audit capability that systematically reviews all areas of the organisation's activities to verify compliance with Part-CAMO requirements and the procedures described in the CAME. The function must be independent of the areas being monitored, meaning that compliance monitoring staff should not audit their own work. An annual compliance monitoring programme must be established, covering all areas of the organisation at least once per year.
The compliance monitoring function must report findings directly to the accountable manager or a nominated person with the authority to ensure corrective actions are implemented. The function is not just about identifying non-compliances but also about driving continuous improvement through the identification of trends and systemic issues.
Key requirements
The compliance monitoring programme must cover all Part-CAMO requirements and the organisation's own procedures. Monitoring must be carried out by trained and independent personnel. Findings must be recorded, root causes identified, and corrective actions tracked to closure. The accountable manager must review the results of the compliance monitoring programme to ensure its effectiveness.
Common compliance gaps
Lack of independence in the compliance monitoring function is a frequently raised finding, particularly in smaller organisations. Other common gaps include an incomplete monitoring programme that does not cover all required areas, insufficient follow-up on identified findings, and a failure to analyse trends across multiple audit cycles to identify systemic issues.
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