The Regulation permits some contracting of continuing airworthiness tasks by CAMOs to other approved or non-approved organisations, working under their quality system. However, it is considered that it does not reflect the practices which have existed within the industry for some years or the way the industry is developing.
In order to provide a regulatory framework for the new industry trend there is already an NPA under discussion. Even if you might think that the initial goal is derive the responsability from the AOC holder to the contracted CAMO organization your assumption is not totally correct. AOC holder for CAT operations will be forced to set up a Continuous Airworthiness Control Organzation (CACO) with a Continuous Airworthiness Control Exposition (CACE) manual detailing its surveillance procedures. More over CACO organizations might use the new SMS concept to prove means of control via a RAA (Risk Assesment Analysis) activity.
Is still not clear when this regulation will be fanally applicable, but this fresh approach will be for sure well received by start up airlines with a clear oursoutcing strategy.
From Aviation Island we will monitor this process as will definetively affect our contractual relations with our customers. Full text is available at EASA web: http://www.easa.europa.eu/rulemaking/docs/npa/2010/NPA%202010-09.pdf