Maintenance and Certification - The
by Traci K. Brittain, Superintendent, Aircraft Maintenance Engineer Licensing and Training, Operations, Aircraft Maintenance and Manufacturing, Civil Aviation, Transport Canada
“Privilege” [priv·i·lege] ... The American Heritage Dictionary identifies this as “a special advantage, permission, right, or benefit granted to or enjoyed by an individual.” Roget’s New Millennium Thesaurus defines a privilege as an “advantage, allowance, authority, authorization, benefit, entitlement, grant or license.”
Regardless of which definition you choose, its clear that being granted a “privilege,” be it regulatory or otherwise, is serious business.
The scope of privileges associated with an AME licence allow for certification (i.e. maintenance certification) of work performed either by the licence holder or by another person under supervision of the licence holder (primary privilege). However, there are several other privileges and responsibilities attached to the AME licence; one of them being the responsibility of confirming an AME applicant’s experience in the technician’s personal logbook.
Where the primary privilege is self-explanatory and clearly understood by licence holders, past and current practices indicate there is confusion regarding the scope of the secondary privileges; their associated legal responsibilities and to whom they apply.
AMEs must be conscious of what they are signing for when it comes to tasks performed by another person; AME applicants must be careful to ensure that they record the tasks correctly and get the right people to sign for them.
It is surprising how often task records (e.g. AME logbooks or other such documents) are presented to Transport Canada (TC) for licensing assessment purposes, and during the review it’s discovered that:
- The aircraft registration mark identified for the task being claimed does not, or did not, belong to that aircraft type at the time the task was completed (i.e. recorded as Bell206, registered as Airbus319);
- Due to non-applicability or non-existence of the system, the task being claimed is not one that could be performed on the aircraft type identified (i.e. changed floats on B737) ... [I kid you not]; or
- The person who signed for completion of a task didn’t hold the appropriate ratings, or in some cases even a licence, at the time the work was completed (i.e. task completed in 2001, signatory licensed in 2003).
“Technically,” are such entries regarded as an offence under the Aeronautics Act? You bet’cha!
In these types of situations, both the inaccurate entries made by the apprentice and the certifications made by the AME could be viewed as false entries and subject to regulatory enforcement action. Why? Because both the person who wrote the entry and the person who signed for it are liable for the accuracy of the statements made or claimed.
By recording the entry, the applicant is certifying that they have in fact performed the task on that date, aircraft type and registration - and that the person they got to sign for the task supervised them completing the work claimed.
By appending their signature and AME licence [or approved maintenance organization (AMO)] number to a task performed by another, the signatory is certifying that they have personally observed the work to the extent necessary to ensure that it is performed in accordance with the requirements of any applicable standards of airworthiness - and that the individual who completed the work was competent to meet the requirements of Canadian Aviation Regulations (CARs) Standard566.03(4)(e)(ii), which states:
- Proof of having completed aircraft maintenance tasks shall take the form of a certification by the AME, or equivalent person who supervised the work [...] and confirm that the applicant is able to:
- (A) identify the applicable standard for the task;
- (B) select the proper tools;
- (C) perform the work correctly without supervision; and
- (D) complete the necessary documentation.
- (A) identify the applicable standard for the task;
If the task was not completed under the current supervisor’s realm, they cannot be asked to sign for it.
If the AME was not suitably licensed, or deemed to be an equivalent person (i.e. having the same level of knowledge and experience as that of a licensed AME) at the time the task was performed, they are not qualified to sign for the task(s).
So when someone says, “Hey boss, I need you to sign off some tasks in my logbook, you know, engine and starting systems stuff I did,” as the applicant you need to make sure that you’ve filled out all of the information required in the logbook pertaining to that work, that it’s accurate and that you ask the right person to sign it off. As the AME, you need to check to see when that task was performed in order to ensure that it was in fact completed under your supervision, and that you are eligible to sign for it.
Remember - TC will check this information when submitted for review. Errors of this type will result in rejection of the task list or logbook; additional work and time for the apprentice to correct the entries; identification of the AME incorrectly signing for tasks; and the possibility of enforcement action.
The bottom line is, be conscious of what’s being recorded and what’s being signed. And remember, both the AME and the apprentice are legally responsible for the accuracy of the statements made or claimed.
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