Regulation (EU) 1321/2014 and further subsequent amendments, specifically Part M paragraph M.B.303 and Part ML in paragraph ML.B.303, requires each Authority to draw up a programme of inspection activities to monitor the airworthiness status of the aircraft fleet recorded in the State “National’ register, according to a sample inspection scheme. The inspection activities define the ACAM Programme and are configured as “Product verifications” on a sample of “National Fleet” aircraft selected according to a “Risk Based” approach reviewed annually.

On an annual basis ENAC, an ENAC working group, named “ACAM Committee”, identifies the list of aircraft (in terms of number and type of inspections) that will be subject to ACAM Inspection. The list is drawn up according to a “Risk Based” approach that takes into account:

  • the findings raised of previous surveillance activities (not only coming from previous ACAM programme),
  • the knowledge and number of Aeronautical operators distributed throughout the territory, with particular reference to commercial transport operators and SPOs,
  • the “Occurrences” notified through the various channels, reports from EASA or other Authorities, as well as from the analyses resulting from SANA/SACA inspections, contingent conditions of unavailability.

The results of technical/maintenance events received by ENAC through the monitoring of certified/declared organizations, appropriately evaluated for homogeneous areas of interest (e.g. aircraft types, type of operations, etc.), may contribute to
complementing the results for the determination of the sample of aircraft/operators that will constitute the annual programme.

On the basis of the selected criteria, the Committee shall assess the number, territorial distribution and type of aircraft categories to be inspected. These inputs allow to export, from the fleet data recorded by ENAC, the list of potential “registration marks” (among those which have a known airworthiness status and/or active). The total number of aircraft chosen for guidance covers approximately 10% of the “national fleet”, not necessarily distributed in equal percentages across the categories. The intended estimated aim, where possible and not exhaustively, is to cover the entire national fleet over a time interval of 10 years.
As a rule, when selecting the sample, the priority will fall on aircraft that have never been inspected or that have been inspected later than 8/10 years, where there are no potential safety threads, except those where major issues are already known to ENAC.
Aircraft for which operational, continuous airworthiness and maintenance oversight has been delegated to another EASA Authority (in case of agreement to transfer responsibility for airworthiness oversight and use (Art. 83 bis of the Chicago Convention) are excluded. Ad hoc assessments will be carried out on a case-by-case basis.

In no way should ACAM inspections be understood as a deresponsibility of owner/operator or of the CAMO/CAO that manages the airworthiness or of the ARS who performs the last complete airworthiness review, nor replace the monitoring activities carried out by the entities in a limited time.

All maintenance and obligations defined by applicable regulations must always be carried out by the owner/operator.

The ACAM monitoring programme may be adapted during the year to take into account the current airworthiness status of aircraft (for instance in case of mandatory notices according to paragraph M.A.901 (p)/ML.A.903(f)) have been omitted) and the related periodic reviews carried out directly by ENAC pursuant to M.A.710 and M. B.902, as well as due to changes of the aircraft categories to be observed.

The “national fleet” subject to ACAM inspections is defined among all aircraft registered in Italy and those registered abroad for which ENAC carries out oversight of operations, continuous airworthiness and maintenance, when specifically provided for delegation of oversight according to the agreement to transfer responsibility for airworthiness oversight and use (Art. 83 bis of the Chicago Convention).
Aircraft within Annex II to Regulation (EU) 2018/1139 and as amended may also be included, except for aircraft with time limited flight title (e.g. Three-year Flight Permits), amateur construction aircraft, State Aircraft/Conventions with National Institutions.

Owner/operator means person or organisation as defined in M.A.201(a)/ML.A.201(a). The Owner/operator shall attend the ACAM inspection or delegate a person or an organisation.

The owner/operator or who has formal delegation of responsibility for continuing airworthiness in accordance with Regulation EU 1321/2014 Annex.Part M or Part ML (M.A.201(j)/ML.A.201(g)), remains responsible for the closure of the ACAM inspection.



No. If the applicability requirements for the ACAM programme are applicable to the aircraft, it will be counted among the aircraftselectable for inspection.

ENAC, once informed the owner/operator about the ACAM Inspection, can ask the cooperation of other EASA Authorities in order to carry out the inspection.

The same applies when oversight of operations, continuous airworthiness and maintenance is carried out by another EASA Authority, when specifically provided for in the agreement to transfer responsibility for airworthiness oversight and use (Article 83 bis of the Chicago Convention).

The ACAM inspection costs shall be fully covered by the Entity, except for the ones of a possible flight and the associated airport charges during the inspection.





Physical inspection of the aircraft is required at each ACAM Inspection, therefore the verifications are exclusively on-site. If a consistent, detailed and precise documentation is already available at ENAC, can be evaluate in advance by the inspector, in order to facilitate the activities with the owner/operator during the inspection.
Indicatively, except for preparation and post-inspection time frame (assessment of approval and effectiveness of corrective actions in relation to the identified root cause), or special cases, an in-depth ACAM verification of a complex aircraft should be performed in two days, while for other simple aircraft should be sufficient one day.
In-flight verifications may be associated with each of these inspections when necessary; when it is not possible to complete airworthiness inspections in flight (flight inspection) on the ground are performed.

The aircraft covered by the programme are identified under five categories related to the type:

CMA – Complex motor aircraft (as defined in Article 3 of Regulation (EU) No 2018/1139 and as amended);
CMH – complex motor helicopter – (as defined in Article 3 of Regulation (EU) 2018/1139 and as amended);
NCMA – Non-complex motorized aircraft;
NCMH – non-complex motor helicopter;
OTH – Other aircraft types, ELA1 and ELA2, gliders and motor sailplanes, balloons etc. and in three categories related to the main operational use (ref. Regulation (U E) 965/2012): Commercial (CAT, SPO), Non-Commercial (NCC/NCO), Pilot Licence Training (ATO/DTO).

During the inspection ACAM the responsible for continuing airworthiness in accordance with Regulation EU 1321/2014 Annex.Part M or Part ML (M.A.201(j)/ML.A.201(g)), or entity delegated by it shall be present.

The Inspector appointed by ENAC, on the basis of the contacts of the owner/operator available in the Entity’s database, will inform the owner/operator that the aircraft has been selected for an ACAM inspection.
Based on the needs of both parties, the date and place of the inspection will be agreed, and subsequently formally notified via ENAC protocol.
The communication shall normally specify the following:

a) aircraft model and brands;
b) type of ACAM Inspection envisaged;
c) Place and date of the ACAM inspection;
d) any undertaking with which to carry out the inspection;
e) name(s) of ENAC personnel responsible for carrying out the inspection.

Depending on the type of operation of the aircraft or operator (certified or not) and the contingencies (e.g. making available of the aircraft is temporarily almost immediate to contacts between the parties), communication can be conveyed through the most effective and streamlined tool currently assessed, i.e. PEC or email.
Where the aircraft is operated in activities already subject to ENAC oversight to an organisation, formal notification can also take place only by email.
Communication is not foreseen in the case of aircraft subject to ramp inspection without prior notice.

In cases the owner/operator does not respond to requests for contact (untraceable user or lack of feedback to formal
communications), see what it defined in the FAQ “refusal case”.

In these cases, see what is defined in the FAQ “refusal case”.

In-flight verifications will be carried out as part of ramp and/or in-depth inspections, when deemed necessary; when it is not possible to complete airworthiness checks on the ground are performed (e.g. for operation of alarm systems, defect reporting).

For each of the aircraft identified in the annual ACAM programme, the inspector in charge shall contact its owner/operator and in co-ordination with it, any CAMO or maintenance undertakings potentially involved, in order to verify, in relation to the operation and the planning of the planned maintenance, the date and place where the specific type of ACAM Inspection can be carried out Physical inspection of the aircraft is required at each ACAM Inspection.
For each aircraft selected, at least one of the types of in-depth Inspection and ramp inspection will be performed.The majority consists of in-depth inspections, uniformly divided into the use groups provided for in the ACAM sample; when deemed necessary, the flight inspection is associated with the “ramp inspection”.

Part of the inspections of the selected sample may be carried out without notice (AMC1 M.B.303(a));
It is possible to carry out the ACAM inspection in combination with inspections of aircraft conducted for other purposes (export, permit to fly, SANA, etc.)

At the end of the inspection, the relevant Inspection Report will be drawn up by the Inspector(s), recorded in the ENAC database. The report, including any non-compliance (reliefs).

In the case of Inspection without findings, the standard does not oblige ENAC to send the Registered Inspection Report.
In the case of Inspection with findings, these will be classified by the inspector and notified to the owner/operator, as well as to any involved organization. The findings actionee has to provide formal answers to the inspector, identifying the Root Cause Analysis, as well as the follow-up and closure of corrective actions.

See FAQ “What happens in the event of non-compliance following an ACAM inspection”.

The owner/operator may not oppose the conduct of an ACAM inspection, except for reasons of force majeure duly documented.
Under M.A.201(j)/ML.A.201 (g) the person or organisation responsible for continuing airworthiness of the aircraft (as defined in M.A.201(a)/ML.A.201(a)) shall ensure that the planned and notified ACAM inspection can take place in the form and manner required by ENAC, considering margins of agreement in the definition of the place and date of the inspection.

Otherwise, it applies as defined in the FAQ “refusal case”.

The refusal by the owner/operator of the aircraft, without justified reason or as a result of a manifest attitude to prevent inspection and/or make the aircraft available for ACAM inspection, shall be considered as level 1 non-compliance with actions limiting on the validity of aircraft airworthiness certifications.

Indicatively, except for preparation and post-inspection time frame (assessment of approval and effectiveness of corrective actions in relation to the identified root cause), or special cases, an in-depth ACAM verification of a complex aircraft should be performed in two days, while for other simple aircraft should be sufficient one day.

The person or organisation responsible for continuing airworthiness of the aircraft, as defined in M.A.201(a)/ML.A.201(a), shall provide assistance to the inspector(s) in charge of accessing the aircraft and associated documentation, including maintenance records.
Therefore, it shall ensure that the selected aircraft is presented clean and that adequate maintenance personnel support for the ACAM inspection is provided to the ENAC inspector/team.
The owner/operator must ensure that:
a) the appropriate information to ENAC to identify, based on the operational-maintenance planning of the aircraft forming part of the annual ACAM sample, date, place and type of inspection to be carried out;
b) The aircraft is made available to ENAC for the execution of the specific type of ACAM Inspection identified therein at the agreed place and date;
c) the appropriate resources are put in place and made available to allow, within the prescribed time limits, the identification of the final cases relating to the findings that emerged during the request for ACAM Inspection;
d) in relation to the above, appropriate corrective/preventive and proactive actions are identified and implemented within the time limit set to avoid the recurrence of the evidence highlighted.
Because the conduct of ACAM inspections may require the use of technical documentation and/or the carrying out of operations and inspections that may require the performance of maintenance activities with the consequent need for a CRS release, the owner/operator will ensure that a level of support to ENAC is provided comparable to that envisaged M.A.901 (j).
By virtue of the above, where the verification activities carried out on the aircraft selected within the programme are deemed to be linked to the requirements and intents of paragraph M.B.704(c) of paragraph M.B.704(c) for the continuous oversight of the CAMO undertakings that manage the continuing airworthiness of those aircraft.
However, it should be pointed out that, apart from the obligations deriving from the regulatory requirements mentioned above, adequate support to ENAC’s activities for the efficient and effective implementation of the ACAM programme contributes to ensuring that all actors in the aviation sector can operate in an “industrial” context in which the reference legislation is implemented consistently in all the sectors involved ▼ The above and especially to operators in the private sports-recreation sector engaged in first-person management of the continuing airworthiness of their aircraft, as it addresses a high level of safety that is proportionate to the complexity and non-finality of the above-mentioned evidence, also capable of responding to the risk.

Worst case of selected aircraft not reachable (as per samples) can be:
a) occurred in an accident and is not assumed to be put back into efficiency with timeframes compatible with the ACAM plan;

b) due to unforeseen operational needs, the subject of a rescheduling of the relevant operational deployment plan (e.g. case of ramp survey) or slots of the related scheduled maintenance intervention (e.g. in-depth case);
c) subjected to the hypothetical maintenance work due to unexpected reprogramming of the maintenance slots by the originally planned maintenance company;
d) is removed from fleet due to deletion of activity by the owner/operator;
e) be transferred to another register.
In such cases, the Inspector ENAC in charge may assess in conjunction with the owner/operator of the aircraft whether to reschedule the intervention by keeping the selected registration mark or replace with another aircraft falling within the same characteristics (same operator, same type, same operating environment), notifying (internal) the ACAM Committee.

In the event of significant non-compliance for safety, Inspector ENAC shall:
report to the Director of the territorial competence structure the non-compliances and the cases identified for appropriate treatment also by any personnel responsible for other structures of the body or other authorities involved;
propose to the Director of the structure the appropriate corrective actions necessary to ensure safety, each based on the structures ENAC or competent authorities.
propose to the Director of the structure the issuing of the denying flight departure pursuant to Article 802 of the Civil Code

Each finding resulting from an inspection shall be categorised by reference to a KRE and the applicable regulatory requirements. Part M and Part ML shall require the Authority that the non-compliances identified with the ACAM inspection shall be analysed in terms of safety significance and, if any, the ultimate cause and the necessary actions to remove them.
Therefore, the ACAM Inspector shall communicate in writing (on the basis of the existing models provided by ENAC) any non- compliances, with the relevant classification (level 1 or 2), to the subject concerned by the inspection, in order to initiate in a reasonable time frame the Root Cause Analysis and the appropriate corrective actions, the adequacy and effectiveness of which in removing the final cause identified in the previous analysis and thus avoiding the recurrence of non-compliance, must have been ascertained, as applicable, with appropriate follow-up VERIFICATIONS.
In case of significant non-compliance for safety : see “What happens in case of significant non-compliance for safety?”.
The communication identifies for each finding, in a manner appropriate to the nature, scope, severity and extent of the same, the deadline for identifying the root causes, the need to receive appropriate corrective/preventive/proactive actions and the verification of their effectiveness and adequacy in the terms described above.
In relation to the importance and classification of the survey, the actions required may also include in the most serious cases measures in relation to the validity of the ARC of the aircraft or the approvals of the undertakings involved (e.g. M.B.705 and its AMC M.B.705(a)(1).
The same ACAM inspector, in relation to a survey or a group of findings, will carry out an analysis of the safety significance and in case of significant non-compliance for safety will proceed to the identification of the causes and the actions necessary to eliminate them. In the event such actions also affect entities or organisations other than the specific Directorate responsible for the oversight of the aircraft, the latter, through the Central Technical Supervision Directorate, will transmit the information on the non-compliances identified to the ENAC Directorates or competent authorities abroad, in order to ensure appropriate enforcement actions.
Replies from the inspected entity must be formally sent to ENAC, at protocollo@pec.ENAC.gov.it,while ensuring that the ACAM Inspector is included in a copy. If the subject does not have a PEC, he or she may send as necessary by email to the contact details that the inspector will communicate to the data subject.
The team will ensure that the Submitted material is recorded in the ENAC protocol.

If, in conducting the root cause analysis, the person responsible for airworthiness Identifies or assumes among the possible causes of non-compliance against other entities, such as e.g. I love 145 or CAMO, it is desirable that those who carry out the RCA involve them in advance in the analysis.
If the ultimate cause of a finding, as agreed with ENAC, identifies a non-compliance with any chapter of Part M/ML or other part of EASA legislation, ENAC, to the extent of the various internal competences, will take the actions envisaged in relation to this situation (e.g. M.B.705 and related AMC, M.B.605 and related AMC, etc.).
In the event that aircraft registered in other EU States or undertakings approved by other EU authorities are involved, ENAC shall also forward appropriate communications (ref. M.B.1 05 and M.B.303(i)) to the competent authority of the Member State concerned in such a way as to make it possible to take the relevant measures and conduct appropriate analyses in accordance with the
legislation in force.
If deficiencies are detected during inspections requiring one or more corrective actions to be taken on the aircraft before the next flight, the inspector in charge of the inspection shall immediately notify the owner/operator and/or the CAMO/CAO undertaking which contractually manages its continuing airworthiness in accordance with Part M/ML (or their formally delegated representative) with
the most effective instrument for the purpose (hand delivered report, annotation in the technical logbook or aircraft booklet, etc.).
Particularly critical situations (e.g. in the case of Level 1 findings contested by the owner/operator/company) are immediately brought to the attention, including through the short routes, of the ENAC Director responsible for the subsequent actions. Pursuant to Article 10 of Regulation 2018/1139 et seq., the ENAC Office shall take, directly or through the airport or public security authorities, any measure, including the detainment of an aircraft, capable of preventing the continuation of an infringement.
In other cases, the inspector in charge shall, at the end of the inspection, carry out an appropriate de-briefing with the owner/operator and/or the CAMO undertaking which contractually manages its continuing airworthiness in accordance with Part M
(or their formally delegated representative) on the results of the inspection pending the formalisation of the inspection by the Directorate/Operations Office.
In the event that aircraft registered in other EU States or undertakings approved by other EU authorities are involved, the Directorate/Operations Office shall subsequently forward appropriate communications (ref. M.B.105 and M.B.303(g) or as applicable ML.B.105 and ML.B.303(g)) also to the competent authority of the Member State concerned so as to make it possible to take the relevant measures and conduct appropriate analyses in accordance with the legislation in force.

The ACAM inspection of each aircraft provided for in the annual ACAM plan may be considered as closed only when the results of the root analysis for each non-conformity found are agreed and, against them, Inspector ENAC has notified the owner/operator that the evidence on the effective closure of the proposed corrective, preventive and proactive actions is satisfactory.
Note that in the case of aircraft inspection not “I” the findings must/may be notified to the country of registration as appropriate.

The AMCs associated with M.B.303 and ML.B.303 provide guidance on the types of Inspection to be performed under the Program and its contents and purposes (this represents a basic structure acceptable also under Part ML), which may include a documentary analysis phase and, in all cases, physical inspection of the aircraft within the limits of the scope and purpose of the inspection, shall be identified as:
in-depth inspections (in-depth inspection);
ramp inspections (Ramp inspection);
In-flight verifications may be associated with each of these inspections when necessary, i.e. when it is not possible to complete airworthiness inspections in flight (flight inspection), it is performed on the ground.
The airworthiness verification activities of aircraft and in the surveillance programmes of aircraft operators (ref. AMC M.B.303 and point 4 of AMC M.B.303(d)) include:

a) In-depth inspections: inspections during major maintenance, inspection at the main base of a CAMO operator/organisation for a single aircraft;
b) In ramp inspections: ramp inspections of the surveillance programme of certified aircraft operators; In order to improve the efficiency of the activities, combined VERIFICATIONS may be carried out during surveillance audits (both
ongoing audits and changes), which may cover, for example, but not only:
The In-depth ACAM inspection; the airworthiness review;

Physical inspection for permission to fly;
The inspection for the certificate of airworthiness for export;
The product audit in accordance with M.B.704(c);
The product audit in accordance with Part 145 or Part M, Chapter F;
the supervised review for the authorisation of ARS, provided that it covers the full scope of the physical inspection in accordance with M.A.710(c) and notes related to notifications of deficiencies in the PdM declared pursuant to M.A.302(h)4 by the owner/operator of ELA1 aircraft not engaged

Each ACAM Inspection requires verification on a sample of a number of key airworthiness risk elements (key airworthiness elements), defined in AMC M.B. 303 (b. A detailed definition of individual KREs is contained in Appendix III to GM1 to M.B.303(b) which also provides supporting information, lists typical items and regulatory references.
For each KRE, the verification sample shall be significant and representative of the areas of greatest attention.
Therefore, the VERIFICATIONS do not necessarily concern “all” elements relating to a particular KRE (e.g. “all” parts with limited life, or “all” airworthiness requirements) but a significant sample of them, taking into account the time and resources actually budgeted.
The identification of this sample falls within the competence of the professional(s) in charge of the ACAM inspection and is selected by it in such a way as to be significant and representative within the population and in the specific reference context and appropriate in terms of the need in any case to ensure the achievement of the objectives of the ACAM programme itself (ref. AMC/GM relating to point M.B.303(b)).

Root cause analysis (RCA) is a class of problem solving methods aimed at identifying the ultimate causes of problems or events.
The practice of RCA is based on the belief that problems solved better by trying to address, correct, or eliminate underlying causes, compared to just addressing the immediately obvious symptoms. If corrective measures are directed to the latest causes, it is more likely that the recurrence of the problem will be prevented. However, it is recognised that it is not always possible to prevent the recurrence of non-compliance with the adoption of a single corrective action.
Conversely, there may be more effective measures (methods) that can solve the root cause of a problem. Thus, RCA is often considered as an ITERATIVE process, and is often seen as a continuous improvement tool.
RCA is typically used as a Reactive method for resolving a non-conformity: The analysis is done after an event has occurred.
Personnel experience in the use of Methodologies for RCA, test useful as a pro-active method. In this case, RCA can be used to predict or predict likely events, even before they occur. RCA is not a single well-defined methodology: there are many different tools, processes, and philosophies for performing RCA analysis.
The general principles that I must always keep in mind for the effective conduct of the CAR are:
I. The primary objective of the CAR is to identify the main cause(s) of a problem in order to it determines effective corrective actions to prevent the specific problem from recurring in the future, i.e. to address the problem with
virtual certainty of success. (The term “Next” is meant as almost certain prevention of recurrence of the problem.)
II. To be effective the RCA must be carried out systematically, usually as part of a investigation whose findings and causes must be supported by documented evidence. This usually requires effective teamwork
among the skills involved.
III. There may be more than one ultimate cause for an event or problem, the difficult part is to demonstrate by analysis their Persistence in the phenomenology under examination and support the effort needed to prove it.
The purpose of identifying all solutions to a problem is to prevent the recurrence of non-compliance at the lowest cost in the simplest way. If there are alternatives that are equally effective, then the simpler or lowest cost approach will be preferred.
Identification of the ultimate cause depends heavily on how the problem or event is defined.
An effective reporting on the problem and description of events (such as failures, for example) are useful, if not necessary.
To be effective, the analysis should establish a sequence of events or timelines to understand the relationships between contributing factors (causal), ultimate cause, and the problem or event defined to avoid it in the future.

RCA can help a reactive culture (which reacts to problems) into a forward-looking culture that solves problems before they occur or intensify. More importantly, it reduces the frequency of problems that occur over time within the environment in which the RCA process is used. Φ
In order to achieve the effectiveness and success of the RCA, forms of support from management are often necessary, such as a non-punitive policy towards those who are ready to IDENTIFICATE problems within a system.
Note that RCA is the most critical part of the success of corrective action as Eastern corrective action towards the real cause of the problem.
The determination of the main cause of non-compliance is secondary in relation to the objective of prevention, but without knowing the main cause, it cannot be determined what an effective corrective action is for the specific problem.

The purpose of the analysis of the ultimate cause or root cause analysis RCA) is the examination of errors, and their causes, which have been identified as findings within the scope of the inspection. It is therefore necessary to:
I. define the problem or describe the event in a factual way;
II. collect data and evidence, categorising them along a timeline of events up to the final failure or crisis in the process;
III. ask the “reason” and identify the causes associated with each phase in the sequence that led to the specific problem of the event;
IV. identify the main reasons that in case they have been applied, they have interrupted the wrong sequence phases;
V. if there are multiple causes, which is often the case, they are revealed clearly for subsequent optimal selection;
VI. Identify corrective actions that with certainty prevent the recurrence of the problem or event;
VII. Implement solutions that are effective, prevent recurrence with reasonable certainty with agreement by consensus of the involved parties, that are in full control, meet the aims and objectives pursued and do not cause the introduction of further new and unexpected problems;
VIII. Implement recommended corrective actions for the ultimate cause;
IX. Ensure effectiveness by observing the implementation of recommended solutions.
There are various techniques for conducting the RCA that can be freely used by the person responsible for continuous airworthiness
such as:
• Causal factor tree analysis – a technique based on reporting all causal factors in a “tree structure” in such a way that the
cause-effect relationship is clearly identified
• Fault mode and effects analysis — FMEA
• Fault trees analysis
• “5 Why” method
• Ishikawa diagram, also known as a herringbone diagram or causes effect diagram.
Ultimately, an effective analysis of root causes allows not only the identification of the cause of the “defectology” actually found during the inspection and the appropriate actions that prevent its recurrence, but also the identification of possible precursors of other potential non-conformities and preventive and proactive actions that prevent their occurrence. That contributes to the continuous airworthiness management system of the national fleet is implemented effectively and consistently with the expected standards and at a level deemed acceptable to ensure the validity of aircraft airworthiness certifications and the overall safety of operations.