A Continuous Airworthiness Maintenance Program has a defined set of requirements under FAA regulations: a written maintenance manual covering specific topics, designated required inspection items with independent inspectors, tracking of every applicable Airworthiness Directive, a continuing analysis and surveillance system, formal oversight of contract maintenance providers, mandatory record retention, and FAA authorization through Operations Specification D072. The rules live in 14 CFR Parts 121 and 135, and they apply before the first flight and every day after.
Who Has to Operate Under a CAMP
Every certificate holder under 14 CFR Part 121, covering scheduled air carriers and flag operations, must maintain a CAMP.1eCFR. 14 CFR 121.367 – Maintenance, Preventive Maintenance, and Alterations Programs Fleet size is irrelevant; there is no opt-out.
For Part 135 commuter and on-demand operators, the line is drawn at seats. Aircraft type-certificated for ten or more passenger seats (excluding pilot seats) fall under the full CAMP framework in 14 CFR 135.423 through 135.443. Operators using aircraft with nine seats or fewer follow a lighter maintenance structure under Parts 91 and 43, though they may voluntarily adopt the CAMP standard.2eCFR. 14 CFR 135.411 – Applicability
Owners of large airplanes and turbine-powered rotorcraft flying under Part 91 must select a formal inspection program, and one available option is a continuous airworthiness inspection program that mirrors CAMP.3eCFR. 14 CFR 91.409 – Inspections Fractional ownership programs under Part 91 Subpart K are not required to use a CAMP, but a program manager who elects to must then follow 14 CFR 91.1413 through 91.1443 in full.4eCFR. 14 CFR Part 91 Subpart K – Fractional Ownership Operations
What the Maintenance Manual Must Contain
The manual is the foundation. Federal rules require it to describe the maintenance organization, name every entity arranged to perform inspections or maintenance, and lay out methods for both routine and nonroutine work.5eCFR. 14 CFR 121.369 – Manual Requirements The Part 135 parallel is nearly identical.6eCFR. 14 CFR 135.427 – Manual Requirements
The manual must also cover:
- Procedures for calibrating precision tools and test equipment.
- Standards for accepting or rejecting inspected items.
- Instructions for handling work interrupted by shift changes, so that unfinished tasks are properly completed before anyone releases the airplane.
- Buy-back procedures for reinspecting work that failed a previous required inspection.
- Instructions preventing anyone from overruling an inspector’s decision except inspection-unit supervisors or an administrator with responsibility for both inspection and maintenance.
The regulations also require structural separation between inspection and maintenance functions. When the same organization does both, inspection authority must remain independent below the administrative level where overall responsibility sits.7eCFR. 14 CFR 121.365 – Maintenance, Preventive Maintenance, and Alteration Organization The mechanic’s boss cannot also be the inspector’s boss until you climb high enough on the org chart.
Required Inspection Items and Independent Inspectors
The manual must designate certain maintenance and alteration tasks as “required inspection items”: tasks where a mistake or a wrong part could endanger safe flight. For each such item, the manual has to describe the inspection method and identify by job title the personnel authorized to perform it.5eCFR. 14 CFR 121.369 – Manual Requirements
The core rule is independence. A mechanic cannot perform a required inspection on their own work.8eCFR. 14 CFR 121.371 – Required Inspection Personnel The same prohibition applies to Part 135 operators, with a narrow exception letting pilots perform required inspections on rotorcraft in remote areas when no qualified mechanic is available.9eCFR. 14 CFR 135.429 – Required Inspection Personnel
Airworthiness Directive Tracking
A CAMP must track every Airworthiness Directive that applies to each airframe, engine, propeller, and appliance. The records must document current AD status, the date and method of compliance, and, for recurring ADs, when the next action is due.10eCFR. 14 CFR 121.380 – Maintenance Recording Requirements Miss a deadline and the aircraft is no longer airworthy the moment compliance lapses.
Continuing Analysis and Surveillance System
Approval is not the finish line. Every Part 121 and Part 135 operator must establish and maintain a Continuing Analysis and Surveillance System (CASS) that monitors how well the maintenance and inspection programs are working and corrects any deficiencies.11eCFR. 14 CFR 121.373 – Continuing Analysis and Surveillance12eCFR. 14 CFR 135.431 – Continuing Analysis and Surveillance
In practice, CASS collects data on mechanical delays, unscheduled component removals, and inspection findings. When a component fails more often than expected, or when inspections reveal a pattern, the system triggers corrective action. Operators who want to use a reliability program to set and adjust their own maintenance intervals, rather than submitting each change to the FAA, must obtain separate authorization through their Operations Specifications (typically D074 or D075).13Federal Aviation Administration. AC 120-17B – Reliability Program Methods – Standards for Determining Time Limitations
If the FAA finds that an operator’s programs lack adequate procedures or standards, it can require changes, and the certificate holder must implement them.11eCFR. 14 CFR 121.373 – Continuing Analysis and Surveillance
Oversight of Contract Maintenance
Outsourcing is allowed, but the certificate holder stays fully responsible for “covered work” a contractor performs. Covered work includes any essential maintenance that could endanger safe flight if done improperly, all regularly scheduled maintenance, and any required inspection item.14eCFR. 14 CFR 121.368 – Contract Maintenance
The certificate holder must be “directly in charge” of all covered work, meaning a representative must be available for consultation even when not physically watching every task. No maintenance provider may perform covered work unless it is done under the certificate holder’s supervision and control and in accordance with the certificate holder’s own maintenance manual.15eCFR. 14 CFR 135.426 – Contract Maintenance
Beyond supervision, the operator must:
- Develop written policies and procedures for all contracted work, include them in the maintenance manual, and obtain FAA acceptance.
- Build specific procedures into the CASS for overseeing contracted covered work.
- Send the responsible Flight Standards office a monthly list of every maintenance provider, including the physical address where work is done and a description of the work type.14eCFR. 14 CFR 121.368 – Contract Maintenance
Record Retention
Federal regulations set minimum retention periods for CAMP records. For Part 121 operators, the categories break down like this:
- Records showing that all requirements for issuing an airworthiness release were met must be kept until the work is repeated or superseded, or for one year after the work is performed, whichever comes first. Records of the last complete overhaul are excluded from the one-year option.
- Records of the most recent complete overhaul of each airframe, engine, propeller, and appliance must be kept until superseded by work of equivalent scope and detail.
- Records showing total time in service, life-limited part status, time since last overhaul, current inspection status, AD compliance status, and current major alterations must be retained and transferred with the aircraft when it is sold.
These rules appear in 14 CFR 121.380 for Part 121 operators and 14 CFR 135.439 for Part 135 operators, with substantively the same requirements.10eCFR. 14 CFR 121.380 – Maintenance Recording Requirements16eCFR. 14 CFR 135.439 – Maintenance Recording Requirements Lost records can make an aircraft unsaleable, because the buyer has no verified history to rely on.
FAA Approval and Operations Specification D072
A CAMP has to be reviewed and approved by the FAA before the operator can fly under it. The operator develops a General Maintenance Manual covering internal policies and procedures for the entire fleet, catalogs technical specifications for every aircraft (including specific tail numbers and engine models), and sets inspection intervals and time-between-overhaul limits that reflect current manufacturer data and engineering standards. The package goes to the local Flight Standards District Office or the designated Certificate Management Office.
Once satisfied, the FAA issues Operations Specification D072, formally authorizing the operator to maintain its aircraft under a CAMP. D072 identifies each authorized aircraft by make, model, and series and references the specific CAMP documents the operator must follow.17Federal Aviation Administration. N 8900.725 – CAMP, Reliability Program, and Time Limitations Authorization Time limitations for overhauls, replacements, and periodic inspections must be contained in the OpSpecs or in a separately approved document. Items designated “on condition” rather than on a fixed time limit have to be maintained through periodic inspections described in the certificate holder’s manual.18Regulations.gov. D072 – Aircraft Maintenance – Continuous Airworthiness Maintenance Program (CAMP) Authorization
Extra Requirements for ETOPS
Two-engine airplanes flying Extended Operations carry an added layer. Each certificate holder must develop a separate ETOPS continuous airworthiness maintenance program for every airplane-engine combination used, authorized through the operator’s OpSpecs. This ETOPS CAMP supplements either the manufacturer’s maintenance program or the operator’s existing approved CAMP.19eCFR. 14 CFR 121.374 – Continuous Airworthiness Maintenance Program (CAMP) for Two-Engine ETOPS Systems whose failure over open ocean would leave a crew with fewer options draw particular attention.
Penalties for Non-Compliance
The stakes are real. A company that violates FAA regulations faces civil penalties of up to $75,000 per violation. An individual, including a mechanic or inspector, can face up to $17,062 per violation under the current inflation-adjusted schedule. The figures adjust annually for inflation. For maintenance violations that involve knowingly presenting a nonconforming aircraft, the maximum penalty jumps to over $1.2 million.20Federal Register. Revisions to Civil Penalty Amounts, 2025
Beyond money, the FAA can suspend or revoke an operator’s certificate, which shuts down all flight operations until the problems are resolved.21Federal Aviation Administration. FAA Compliance and Enforcement Program (Order 2150.3C)