FAQ
About C release and B1/B2 Support Staff
1) I hold an A320 (CFM 56) B2 type rating and my company would like me to certify a non-related engine defect (VHF 1 INOP) on an A320 (IAE V2500) aircraft. The VHF system installed is exactly the same as on my own fleet and the aircraft is AOG. Is this acceptable?
No it is not. Type ratings are issued following training on a specific type to meet EASA requirements. A licence holder may only certify for maintenance performed on an aircraft type listed on their licence and whilst holding a valid company authorisation. Valid aircraft type ratings are listed in Appendix 1 of the Part 66 acceptable means of compliance (AMC) material.
2) My company authorisation document includes the Airbus A320 (IAE V2500) aircraft although I only have the A320 (CFM56) variant on my licence. Is this acceptable?
No this is unacceptable. EASA regulations are quite specific and therefore a company can only authorise a licence holder to certify for maintenance performed on the exact engine/airframe combination listed on the licence.
3) During a progressive maintenance check (tasks taken from a c-check and performed on the line) I discovered corrosion on an aircraft which was outside of manufacturer’s specified limits. In order to avoid an AOG situation my engineering department issued an internal work order for the corrosion to be dealt with at a more convenient time. I closed the open tech log entry by cross referring to the internal work order. Is this acceptable?
No, there is no technical justification for deviations, however minor, from the Aircraft Maintenance Manual (AMM) except by an engineering organisation with appropriate design authority or in conjunction with the manufacturer as the Design Authority. Any Licensed Engineer asked to certify “outside of the limits specified in the aircraft maintenance manual” should ensure the design authority or manufacturers approval has been obtained.
4) My company has informed me that because I am authorised by them to certifying on their behalf, I am no longer liable or accountable for any mistakes as the authorisation in effect hands the accountability over to the company. This statement has been used to convince licence holders to certify for work outside of the AMM set limits. Is this correct?
No it is not. The licence holder has a very specific safety critical function which is further embedded and described in national laws. The CRS signatory is fully responsible for ensuring that all maintenance is correctly and completely carried out, in accordance with published procedures. The signature on the CRS is intended to be the evidence that the aircraft has been correctly maintained and therefore the Licensed Aircraft Engineer is required to do everything necessary in order to ensure that the performed maintenance has been carried out to the required standard. The Licenced Aircraft Engineer cannot avoid this responsibility and it is not mitigated or reduced by any circumstances or difficulties. Worst case scenario remains as before; you can lose everything you have, house and savings etc. if found guilty in a court of law.
5) Since the introduction of EASA Part M maintenance responsibilities appear to have become blurred. Who ultimately decides when an aircraft is serviceable or what troubleshooting is required, the Licensed Aircraft Engineer or the airline?
We would describe the relationship in this way. Commercial operators are required to follow the approved maintenance schedule at all times. Furthermore they are required to seek out a Part 145 approved maintenance organisation to perform such maintenance. Therefore Part M is about the management and not the performance of maintenance. For example, if a couple of brake units are discovered close to their wear limits and they do not actually need to be replaced immediately, the airlines Part M would be contacted and asked to decide whether it wishes the brakes to be replaced now rather than in the near future as it may be more convenient as far as the operation is concerned. This is perfectly acceptable. If however the brakes are worn beyond limits, then it is the Licensed Aircraft Engineer’s responsibility not to release the aircraft back into service until the brakes have been replaced. Nobody can override that decision as long as the decision is firmly based upon the manufacturers approved data. Troubleshooting defects follows the same principle. Only authorised certifying staff can decide, using approved maintenance data, whether an aircraft defect seriously hazards flight safety. Therefore only authorised certifying staff can decide what defect rectification action shall be taken before further flight and what defect rectification can be deferred.
However, this does not apply when:
- the approved minimum equipment list as mandated by the competent authority is used by the pilot; or,
- aircraft defects are defined as being acceptable by the competent authority.
Any aircraft defect that would not hazard seriously the flight safety shall be rectified as soon as practicable, after the date the defect was first identified and within any limits specified in the maintenance data.
Again the Licensed Aircraft Maintenance Engineer is responsible for ensuring the aircraft is fit for flight. In summary, all maintenance is based on total compliance with the Maintenance Manual (AMM) or other approved data and no deviation is permissible, on either legal or technical grounds, without design authority approval. Should that not be the case a certificate of release to service must not be issued.
6) Whilst performing a service bulletin detailing an inspection of the aft engine mount retainers for corrosion and cracking we discovered that the aft engine mount bolts were not installed as per the AMM. The AMM itself was confusing as the diagrams and graphics kept changing the viewing direction. However it appeared that the mount itself had been installed correctly but all attachments and bolts had been installed back to front. With the mount being supplied as part of the engine (delivered from overhaul already attached to the engine and therefore installed on aircraft as one unit) and as the engine had been on wing for over 3 years, we decided to issue the release to service and inform engineering. In addition the SB allowed a 50 cycle grace period in which any retainers requiring attention should be replaced. A re-inspection was required after 25 cycles to ensure no cracking. We considered this was an appropriate period in order for clarification to be obtained, perform corrective action if necessary and avoid an AOG situation. We supplied engineering with the relevant information. Engineering then contacted the manufacturer.
Later that day the manufacturer of the mounting assembly suggested contacting the aircraft manufacturer as in their view the aircraft should not continue in operation.
Next shift we read the view of the mounting assembly manufacturer and immediately refused to issue any further release to service statements for the aircraft until continued operation had been approved by the aircraft manufacturer. The manufacturer refused to issue an approval for continued operation. The engine bolt situation needed to be corrected immediately. Do you have a view on this situation?
First of all the behaviour (or lack of) from engineering upon receipt of the mounting bracket manufacturer’s opinion is not defendable. This amplifies our position and that of accident investigators of “only as per the AMM and approved documentation”. In a previous response we quoted from an accident investigation report in relation to situations being outside of the AMM:
“There is no technical justification for deviations, however minor, from the Maintenance Manual except by an engineering organisation with appropriate design authority or in conjunction with the manufacturer as the Design Authority. Any Licensed Engineer asked to certify outside of specified limits should ensure the design authority or manufacturers approval has been obtained”.
The statement applies equally to engineering departments. No design approval means, there is no authority to deviate from the maintenance manual. In the circumstances given here and particularly after receipt of the mount assembly manufacturer’s opinion, engineering should have immediately confirmed that the aircraft was grounded (AOG) and sought the aircraft manufacturer’s approval for continued operation.
That said the Licensed Engineers involved should learn from this event and in future, regardless of company pressures to quickly return the aircraft to service, ground the aircraft immediately.
7) My company have informed me that base maintenance support staff do not need to be B1 or B2 qualified as staff approved in accordance with our MOE can perform certain tasks without supervision even though they have no licence. This has resulted in my company reducing B1/B2 manning levels within base and most tasks are performed without any B1/B2 involvement. Is this acceptable?
No, this is unacceptable. The regulations are quite specific that Support Staff must be B1/B2 qualified. In addition B1/B2 qualified Support Staff must ensure that all tasks have been performed to the correct standard. The following statement applies:
B1/B2 Support Staff must be satisfied with the competence of the persons performing the work prior to the work commencing. B1/B2 Support Staff must also have inspected a sufficiently representative sample of the work and associated documentation prior to completing the task paperwork. All persons involved in aircraft maintenance must also document their involvement. Therefore signatures from both licensed/unlicensed personnel are required.
Furthermore it is also one of the functions of the Category C licence holder to ensure that there are sufficient Support Staff available on duty to ensure the above has taken place.
Base maintenance organisations should ensure that there are clearly defined tiers of responsibility in place in order to ensure safe and proper maintenance. Unlicensed mechanics are responsible for the quality of the work they perform. Support Staff are responsible for ensuring the mechanic is competent to perform the task, that the work was performed in accordance with approved data and that the work has been properly completed. This will require an element of supervision.
The Category C Certifying Engineer is responsible for ensuring that all of the above takes place before issuing the release to service.
8) I came on shift on Saturday to work on the delayed C check. I am confronted with a pile of maintenance documents to be signed for while the tasks have been completed by mechanics.
The tasks are finished, the test are performed by mechanics but I need to make the final signature on the task card since the night shift did not have a B1 on duty. The aircraft is ready to leave the hanger, all closed up and the tow truck in front of the aircraft connected. My boss want me to sign and I did because he stated that there is no need to check. it this correct, I am not feeling confident about it?
Answer: no, you are not! By doing this you take on a huge responsibility if something goes wrong by signing for work on which you were not able to “verify” if the work is done by the right competent persons following the proper maintenance procedures.
The Regulation clearly states that you have to “ensure” that the work is done by the right persons, following the correct procedures, using the right materials etc. Ensuring is not the same as believing what others wants to tell you to believe because they have an aircraft to deliver to the company. “Ensuring” is a personal “activity” and you should have had the possibility to decided that during some parts of the work, inspection, or test you would want to be present. Depending on the experiences you may have with some of the mechanics, it should be up to “you” to decided or not to decided, what you want to check or not. Are you signing off in this pile of documents for work that fall under your own scope of privileges stated on your license, or are their parts to sign for that do not fall under your scope of the authorization?
Accepting a pile of documents for rubber stamping takes away this very important possibility for you. It is your responsibility, and yours only. Being put under pressure by your boss is wrong. If something fails in future you might end up in jail for involuntary manslaughter, etc, losing your job and livelihood and al your assets. You will have to live with the burden that some persons died or injured because of your reluctance to say NO I don’t sign until I have had to chance to inspect some of the tasks. You will be the one prosecuted after an accident or incident with victims, the company walks away free, blaming you for not following the regulation and procedures, failing company procedures, and nobody else. Beware what you sign for.