As far as CASA is concerned:
AC-66-5 v1.2
15.7 Certification of Australian aircraft outside of Australian Territory.
In accordance with regulation 42ZN, the Certificate of Registration holder of the aircraft is responsible for ensuring that all maintenance performed on the aircraft outside of Australian Territory is certified in accordance with the system for certification of the maintenance organisation performing the maintenance or; alternatively, in accordance with Schedule 6 of the CAR’s by:
• the pilot-in-command, for maintenance they have been authorised to perform;
• the holder of a valid appropriate Australian aircraft engineer licence;
• the holder of a valid appropriate Australian maintenance or welding authority;
• the holder of a valid appropriate aircraft maintenance licence issued by the appropriate authority in the Contracting State in which the maintenance is being performed; or
• an employee appropriately authorised by an organisation to perform maintenance on the aircraft, engine or system type as approved by the appropriate authority in the Contracting State in which the maintenance is being performed; and that the maintenance has been performed in accordance with the Certificate of Registration holder's System of Maintenance.
15.8 The Certificate of Registration holder or the pilot-in-command is responsible for ensuring that certification for the completion of maintenance has been correctly made in the appropriate log book, maintenance release or alternative document prior to flight.
The C of R holder is Australian, employing Australian or local LAMEs under an Australian System of Maintenance, so the CASR's apply. Under the System of Maintenance and the CASRs the B1 or B2 LAME is required to supervise the work of AMEs.
And the definition of "supervision" is given in CASR 1998 Vol 5 as:
30 Meaning of supervising
A person (the supervisor) is supervising the carrying out of maintenance done by another person if the supervisor:
(a) is physically present at the place that the maintenance is being carried out; and
(b) is observing the maintenance being carried out to the extent necessary to enable the supervisor to form an opinion as to whether the maintenance is being carried out properly; and
(c) is available to give advice to, and answer questions about the maintenance from, the person carrying it out.
The Part 66 AMC/GM provides additional guidance on the meaning of supervision. It makes for an interesting read. In particular:
Actual physical observation of the maintenance by the supervisor is required “to the extent necessary to enable the supervisor to form an opinion as to whether the maintenance is being carried out properly”. This means that the level of observation, and the resulting opportunity for the supervisor to intervene, is variable and can take into account the current competence, knowledge, skill sets and maturity of the aircraft maintainer being supervised.
An apprentice/new AME will necessarily work under direct/close supervision and the supervisor would be expected to attentively watch the work being performed. The supervisor would be expected to make sure the apprentice is aware of and is conducting themselves such that they are safe from hazards, undertaking the maintenance correctly, using the correct tools, following the appropriate instructions for continued airworthiness.
As Fed Sec has described, many of these AMEs are green, very green. With the LAME:AME ratio in LAX, can someone please tell me how the LAME can in good conscience and in accordance with his statutory obligation, "supervise" as defined above and certify for the work of such a large workforce of AMEs of a skill and experience level that he/she knows is woefully inadequate compared to Australian AMEs?
Now in LAX the C of R holder employs inexperienced AMEs, knowingly allows a LAME:AME ratio such that not all work can be adequately supervised, and bears no responsibility for the quality of the maintenance performed, only the quality of the certification.
The LAMEs in LAX walk a particularly fine line - as anyone who has worked under the LA regime knows, and I think they know in their heart of hearts it is a matter of not if but when the lack of adequate supervision comes back to bite him/her on the ar$e. Anyone who's done a bit of contract work in Asia can tell you it's the same in some facilities there too. But just because everyone else is turning a blind eye to air safety doesn't mean we should.
We have air safety and maintenance regulations for a reason. Over the course of decades, they have been written in the blood of the victims of countless air accidents. We as LAMEs can choose to pay lip service to them like some in our management do, or we can choose to obey them.
For the record, the LAME:AME ratio in QF company-wide is 55:45. The reason given for not training up AMEs to be LAMEs is that they don't want to exceed the ratio. That's what the company wants, and that's what they've got. It's a ratio I'm somewhat comfortable with, as it allows the company the flexibility to put AMEs where the manpower, the level of supervision, the system of maintenance and the company procedures manual allows, and it provides me a level of assistance from AMEs I require to get my job done, while meeting my obligation to my employer and to the law to adequately supervise the AME.
We will only get the level of safety we demonstrate we want. So please, for the sake of your LAME colleagues upline in the unenviable position of being unable to adequately supervise and unable to raise their concerns out of fear for their jobs: if you find poor quality work, report it.