Aircraft Engineers International – Målrettet innsats over mange år gir resultater
I Februar 2006 startet diskusjoner rundt forslag til nytt regelverk. Eksperter fra flyindustrien,
sammen med representanter fra EASA, vurderte mulighetene for å fjerne kravet om sertifiserte Flyteknikere.
Det ble utviklet en detaljert modell som ville tillatt hvert enkelt selskap å utstede
interne autorisasjoner til ikke-sertifiserte mekanikere. OG at disse skulle gis
rettigheter som lot de signere for vedlikehold innen sitt eget selskap, dvs uten
CRS slik som vi kjenner den i dag.
Forslaget ble til slutt ikke gjennomført, men diskusjonene demonstrerte en
stor grad av misforståelse innen flyindustrien (bekreftet av EASA i deres
”opinion 06/2010”) angående rettigheter og ansvaret til sertifisert Flyteknikere ved signering av flyvedlikehold.
AEI fikk mange innspill, fra tilknyttede nasjonale foreninger, om tilfeller der funksjonen til Flyteknikeren har blitt undergravd og i noen tilfeller regelrett forbigått! Ved hjelp av enorm faglig og økonomisk støtte fra de samme nasjonale foreninger, inkludert NFO, har AEI oppnådd positiv respons fra EASA. Etter at AEI dokumenterte alvorlige brudd på regelverket rundt CRS har EASA (vi skriver nå 2015) kommet med klare uttalelser som detaljert beskriver rettigheter og ansvaret til CRS og Support Staff når flyvedlikehold blir utført.
AEI har nå oppnådd en positiv samarbeidsprosess med EASA og vi håper å kunne publisere flere positive nyheter neste år(ene). For å oppnå dette er vi helt avhengig av NFO og andre nasjonale støttespillere!
Vi ber alle om å sette seg inn i disse uttalelsene og sjekke om deres selskap er innenfor kravene! Hvis dere har spørsmål så gå til deres lokale Teknisk Utvalg representant. TU er nå kurset og skal være i stand til å gi gode svar.
EASA`s utalelser kan leses under her.
På vegne av AEI og med vennlig hilsen
Geir Ove Eriksen
Technical Affairs Committee Chairman
EASA Statement for CRS
The certificate of release to service as described in EASA Part 145.A.50 is one of the fundamental principles in the European regulatory framework for airworthiness.
Several items of discussion and cases of difference in interpretation have been raised with the Agency in the past and are currently subject of two rulemaking tasks:
• RMT.0217 (M.029) “CAMO and Part-145 responsibilities”.
• RMT.0097 (145.024) “Functions and responsibilities of B1 and B2 support staff”.
The content of those NPAs cannot be used directly to answer today’s questions as we have to comply with the rules that are applicable today, however the following bullet points will address a number of issues currently experienced around the issuance of a certificate of release to service (CRS) and give guidance on EASA’s view/interpretation of those items:
“Appropriately authorised certifying staff”
In order to issue a CRS the certifying staff have to be formally authorised by the maintenance organisation to do so.
The word “appropriately” means that the person can only be authorised when the organisation has verified compliance with all the applicable qualification requirements, only for the scope of work applicable to that qualification (in the case of Part-145 organisations, please refer to 145.A.30, 145.A.35) and always within the privileges granted by the Part-66 licence held by the person (refer to 66.A.20)
This means that, for example, in the case of a line maintenance event which includes a daily check + some single running tasks + requested defect rectification entered in the Technical Log by the crew, if such event includes tasks within the scope of B1 and B2 privileges (mechanical tasks and avionic tasks), then a single release to service can only be issued if the person issuing it holds both the B1 and B2 licences. It is not possible for a B1 certifying staff (or for a B2 certifying staff) to issue a single release to service covering the full maintenance event. The other option is to have a B1 certifying staff issuing a release to service for the mechanical tasks and a B2 certifying staff issuing a release to service for the avionics tasks, which would become a multiple release system.
“when it has been verified that all maintenance ordered has been properly carried out”
This doesn’t necessarily mean that certifying staff have to perform or supervise the whole process of every task, but the necessity of assessing the complexity of each task, making sure that they have been assigned to personnel authorised to sign-off to the corresponding level, coordinating the different tasks, supporting that personnel in case of any mistakes or unexpected difficulties and verifying that the job has been completed and signed-off properly.
As a consequence, this is not just an administrative task which can be performed from a remote location or without having been involved at all. Certifying staff have the last call on the amount of involvement they would like to perform in order to be satisfied that the maintenance can be properly released, and this level of involvement cannot be predefined or limited by the organisation’s procedures.
In the case of base maintenance, what are the functions and responsibilities of “support staff”
The qualification criteria for certifying staff and support staff are identical as both:
• must have a Part-66 licence with the corresponding type ratings;
• must have the same recent experience and continuation training;
• must have training in human factors and company procedures; and
• are subject to the same competence assessment;
The only difference is that in the base maintenance environment there is an additional function, the category C certifying staff. However, this function is more administrative due to the more complex environment.
Regarding the level of involvement of the support staff, 145.A.30(h) states that “B1 and B2 support staff shall ensure that all relevant tasks or inspections have been carried out to the required standard before the category C certifying staff issues the certificate of release to service”.
This requirement is of a similar nature to the one contained in 145.A.50(a), where certifying staff are required to ensure that “it has been verified that all maintenance ordered has been properly carried out”. As a consequence, the level of involvement expected from the support staff follows the same principles as indicated above for certifying staff.
What is the function of personnel authorised to “sign-off”
AMC 145.A.65(B)(3)3 states that, in order to prevent omissions, every task or group of tasks should be signed-off by formally authorised personnel after its completion. It also states that a “sign-off” is different from a “release to service”.
Furthermore, this AMC states that work by “unauthorised personnel” (temporary staff, trainee..) should be checked by “authorised personnel” before they sign-off. “They” means “authorised personnel” (formally authorised to sign-off).
This concept of personnel authorised to sign-off is in line with the provisions related to the assessment of mechanics contained in AMC 145.A.30(e)(3). This assessment should guarantee that “mechanics shall be able to carry out tasks to any standard specified in the maintenance data, and will notify supervisors of mistakes requiring rectification to re-establish required maintenance standards”.
Nevertheless, holding a “sign off” authorisation doesn’t mean that the authorised person can sign-off all tasks. It means that he/she can sign-off tasks up to the authorised level, depending on the training and experience held, and in accordance with a procedure described in the MOE. Furthermore, even if this person is qualified and able to carry out the task to the required standard, this does not mean that certifying staff and support staff are not needed. The presence of certifying staff and support staff is an additional safety barrier and, as explained above, has the function of coordinating the different tasks, supporting those mechanics in case of any mistakes or unexpected difficulties and verifying that the job has been completed and signed-off properly.