April 25, 2016

sasadmin

The first comment to share is that in general EASA requirements and obligations are or should be considered as minimum compliance. There is a good chance that if you feel that you are falling short in respect of the qualifications, there may be additional issues in respect of managing competence.

As an example EASA CAR M Sub Part G, AMC M.A. 706 Para 4.5 for qualification of post holder’s- States the following
“A relevant engineering degree or an aircraft maintenance technician qualification with additional education acceptable to the competent authority.”

So we have 3 separate elements to consider:

Formal education / Aircraft Maintenance Technician (Licensed Aircraft Engineer – LAE) & Additional education acceptable to the competent authority

a) Formal Education

When we talk about ‘relevant engineering degree’ it is actually quite straight forward and means for example an engineering degree from aeronautical, mechanical, electrical, electronic, avionic or other studies relevant to the maintenance and continuing airworthiness of aircraft/aircraft components;”

b) Aircraft Maintenance Technician or (Licensed Aircraft Engineer – LAE)

When we talk about the Aircraft Maintenance Technician it does “NOT” in fact stipulate that the person must have a licence therefore it is possible not to have. The simple answer is when we look a little deeper in the structure of the regulation, often we find they (the regulations) are issued in a way that allows flexible interpretation – this is intentional and helps the organisation to manage in the best way.
However please remember that it is to the organisations absolute advantage to ensure the highest possible level of competence in Senior Managers Post Holders and Business areas owners.
In addition we need to build up confidence in the regulatory regarding our ability as an organisation to deliver an effect system with highly competent workers.

c) Additional education acceptable to the competent authority

The question is could the organisation therefore develop its own interpretation of additional training for the role and make it an organisational requirement? The answer is off course as it is the operator who is ultimately responsible to demonstrate an accept compliance. (but the regulator MUST also agree and accept)
‘What is the exact meaning of an aircraft maintenance technician qualification’ He should have completed aircraft maintenance course or should have cleared all Modules also?

Well first consider the new requirement which has been with us since sept 2010:

“For all large aircraft and for aircraft used for commercial air transport the organisation shall establish and control the competence of personnel involved in the continuing airworthiness management, airworthiness review and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority.”
And secondly the following:
AMC M.A.706 – Personnel Requirements CAMO MANAGER, Knowledge of quality systems,

Five years relevant work experience;

A relevant engineering degree or an aircraft maintenance technician qualification with additional education acceptable to the competent authority.
The above qualifications (For Post Holder) may be replaced by an additional 5 years relevant experience additional to (i.e. ten years in total) – So we may see there is a “Trade Off” between the need for formal qualification and the gaining of experience.

Means a person with less formal education but 10 years of relevant experience “could” meet the requirement. But note again the term “acceptable to the CAA”
We should recognise that ultimately the CAA will decide, So it is not as flexible as it could be, but it does permit a degree of variations which suits the different organisations and the specific need.

Conclusion

Taking into account the comment about EASA regulations and minimum compliance. It is reasonable to expect that a person who satisfies the organisation regarding competence should also satisfy the CAA. But off course we cannot speak for the CAA and they will make the decision regarding acceptance.
The bottom line is to consult the CAA before you commit to avoid misunderstanding and the possibility of disappointment.

Also to note there are many extremely competent Post Holders or nominated persons who are neither degree holding or who have obtained an aircraft maintenance Engineers Licence.

For details regarding SAS training courses please see website or email office@sassofia.com