Component replacement by flight crew and JAR 66

[Bus429]

Here is one that may annoy those of you required to hold JAR 66 Cat "A" licences prior to obtaining JAR 145 limited authorisations.
JAR Temporary Guidance Leaflet (TGL) 38 will allow flight crew to issue a CRS for the replacement of internal lights, filaments, wheels, boilers, ovens, static wicks, batteries, simple emergency equipment, pax and crew seats, seat belts. They can certify for closing cowlings and refitting quick access panels (why can't they open them?). They can also issue a CRS for de-activation of sub-systems and components, as permitted by the MEL, where agreed with the NAA that any may constitute a simple task. They may also carry out any check involving simple techniques. Other tasks may be agreed with the respective NAA. What engineering qualifications must they obtain?

None!

They must hold a valid JAA FCL ATPL or F/E licence and undergo some JAR 145 procedural and task training. They will also have to attend "adequate maintenance airworthiness regulation training". They will only be able to carry out these tasks whilst acting in their professional capacity.
So, how does that sit with those jumping through hoops to obtain their JAR 66 Cat A?
Hardly seems fair to me.
Sources of info : TGL 38 and UK CAA Flt Ops Department Communications 7/2001
<img src="confused.gif" border="0"> <img src="mad.gif" border="0">

[ 15 January 2002: Message edited by: Bus429 ]</p>

[Genghis the Engineer]

The obvious question is what is the coverage of each of these items in their ATPL or CPL syllabus. If it's there clearly, and they've been examined in it, I see no problem - it doesn't need to be called an Engineering qualification.

Is it there? I don't know. Anybody?

G

[rightstuff]

Let them have all the approval they want,and then sit back and enjoy the delays and AOG's down route after some pilot has tried to change a filament for the L/G indication or similar.
You know what I'm talking about Bus,how many times were you called out to an acft on the line because some ham fisted aviator has tried to replace a filament and then claimed the light assy carriage came apart in his hand.
Personally I don't think the fly boys will be too happy about carrying out limited and simple tasks,especially if it means getting their hands dirty.
<img src="tongue.gif" border="0">

[HiSpeedTape]

This is a joke right?
I'd better get my overnight kit and passport and keep them handy for the first instance when a jockey pulls out a landing gear indication Kory switch and it comes apart in his mitts. This, as we all know, is a common occurrance when the jockeys get the urge to replace one of the two filaments in an otherwise perfectly serviceable unit.
HST

[Bus429]

Genghis - I disagree. The requirements for a JAR 66-A are more stringent (I'd imagine) than those within the ATPL syllabus. JAR 145.30, para (f) (1) stipulates that an organisation involved in, for example, line maintenance, must have staff appropriately qualified under JAR 66 A, B1 & B2.
So how can pilots be exempt from this requirement? Rhetorical question, because I'll tell you why. The Air Navigation Order allows the CAA (NAA in this case) to waive certain requirements. In my opinion, this is as a result of commercial expediency. I am afraid the UK CAA is pandering to the industry. This, again in my opinion, is partly due to the fact that industry funds the CAA by way of exhorbitant charges. This may generate a mindset dictating that the industry must be able to get something for their money. If the CAA were part of the DTLR (as the FAA is part of the DOT), and the taxpayer were to fund their operations, this situation may not arise. Just a thought.

[Genghis the Engineer]

Bus - my only point was that if the aircrew have been trained and examined to the same level as groundcrew on a particular task, I can't see a problem. The question I think is whether they have or not? If they haven't, they shouldn't.

G

[spannersatcx]

Captain writes in log - no1 main wheel worn to limits- you inspect it and he is wrong it is within limits as laid down - you sign it off as ok for further service. He insists that it is replaced - you say if you want it changed then you change the @$^&*"! thing yourself. Assuming of course he can find the MM and get the correct torque loadings etc. Yeah I see this working, not!

Of course with all the redundancies and things happening around the world, don't you think we should be fighting to protect OUR jobs, wouldn't you agree Genghis? <img src="confused.gif" border="0">

[Bus429]

Genghis - the whole thrust of this argument is that those with JAR 66 Cat A have had to go through the hassle of obtaining a licence to hold the same privileges as the pilot having no engineering licence whatsoever. Makes the stipulations of the above referenced JAR a bit of a farce. Do I think pilots should hold CRS certification (assuming they do not hold JAR 66 A, B1 & B2)? No, I do not, for the reasons stated by other LAES (two of whom I have known for years) on this topic.

[morroccomole]

Perhaps we should ask our industry / trade reps ALAE to get involved and voice concerns?

[Genghis the Engineer]

I think you should be demonstrating why a Licensed Tech has skills and experience that give far greater safety and efficiency benefits. I'm not a fan of trade-union style demarcation rules and don't support arguments on that basis alone - if job protection is a benefit of doing things the safest way, great.

I can recall a time and place where you had to be a qualified pilot to do an engine run - which was nonsensical - most times and places Techs are properly trained and specifically qualified to perform this task. Comparison?

Anyway, the winged master race are paid so much more than those of us who design, build or fix aeroplanes, that no airline is going to routinely use this permission except in dire need - most likely getting a slightly poorly jet home that's stuck in Umbongoland.

Sorry to sound a note of discord, but I think proven competence is what matters. JAR-66 is the main way to prove competence, but not necessarily the only. There are plenty of perfectly competent techs working under JAR-145 (such as at BA) without personal licenses, by some of the arguments here they shouldn't be allowed near an a/c either ?

G

[ 16 January 2002: Message edited by: Genghis the Engineer ]</p>

[ShyTorque]

In my last job I held an auth for changing any light bulbs or fitting and removing certain role equipment on the aircraft, a police helicopter. This isn't uncommon. We were NOT allowed to do any rectification.

Yes, it was commercial expediency. The contract allowed for no resident engineering support on site and it meant a call-out of the dedicated engineer from his bed if the aircraft went tech in the small hours of the morning; he could well have been workng until late at one of the other units he supported. By giving us the auths it meant the engineer had more chance of undisturbed sleep which suited me as chief pilot because I knew he was going to be in good shape to do that 200 hour for us the next morning.

I never objected to doing an engineer's job because it was part of my contract. I received proper training to do it and let's be honest, changing most light bulbs or wire locking doesn't require an engineering qualification, just a modicum of common sense and the proper tools. We also did our own daily Check A and refuelling. My hands were dirty more often than not and I usually stank of Jet A-1 by the end of any shift. Not a large problem but no doubt there are some cack-handed pilots who didn't ought to be given a sharp knife for dinner or would object to getting stuck in... <img src="smile.gif" border="0">

[Bus429]

Genghis - to be quite petulant, it is a matter of fairness. I don't know if you hold a licence but if you have monitored this forum over the last couple of years, you would have realised that engineer licencing has gone through a great deal of turmoil. Those tasks referred to in this post have been done in the past by mechanics aithorised by a company approved under A8-13. JAR 66 changed all that. All mechanics required to do these tasks now have to qualify under JAR 66 A. There are some rights for those holding authorisations issued by their employers before implementation. I personally feel that the JAR 66 route, equitably implemented, is the right way to go. However, there have been some glaring anomalies perpetrated by the CAA and the current topic is an example of just one. The JAA/NAA should apply the same rules for mechanics and pilots.

[Blacksheep]

I think that Professional Pilots won't be too keen on doing these things either. As Bus429 says, if engineering people have to get JAR66 licences to be able to sign for these things - at considerable personal expense and effort - why are pilots to be extended the privileges of the licence without the same rules being applied? Either the licence (and the fees that go with it) is necessary or it isn't. The practicality of the situation is that the work will be done by a mechanic, or an LAE that doesn't have the required company approval, at some outstation. The pilot will then certify the work. That certificate says that the work has been carried out using only approved materials and in accordance with the approved procedures, documents and manuals. I'd expect the person issuing the certificate to be competent in all these areas, including any relevant current airworthiness directives. As long as they are, it doesn't matter who signs the certificate, but an ATPL doesn't cover all these areas in the necessary depth. The tasks may seem superficially simple, but some have already used the Korry light example to point out one risk. How about wheel spacers for another? Some simple jobs aren't as simple as they seem.

Finally, I'll just point out that despite being a current LAE with type rated multi-category licences on several large airliners from two different airworthiness authorities, I am not qualified to certify any of these tasks on any aircraft. But the pilot would be? How distinctly odd!

**********************************
Through difficulties to the cinema

[Bus429]

...but don't forget the fact that engineers with limited authorisations cannot sign for anyone else's work. Therefore, if this all comes to pass, pilots should be doing the job in order to legally certify!

[Genghis the Engineer]

No I don't hold a CAA/JAA personal license, all the work I've done has been in environments where it wasn't needeed and work was done within a company / organisation approval. I regularly sign off work in that environment.

Frankly, I'm convinced by the arguments above. I wasn't necessarily convinced initially and would caution, one Engineer to others, in this or other issues USE THE SAFETY ARGUMENT. If you start with arguments about rights, how hard you've worked to get your license, or job protection, then any Engineering manager (including me) will consider that good evidence against your viewpoint. Argue safety, back it up with clear evidence, as Blacksheep has done, and your argument is unassailable.

G

[Bus429]

Genghis,
Rest assured my prime concern, as with most engineers, is safety. The thrust of this thread was to complain about the less than equitable treatment meted out by the CAA.

[PinPusher]

Emmm, ... anybody read the ANO or JAR 145 or JAR OPS lately.......?

Pilots have had the capability to hold authorisation to do a hell of a lot more than we give them credibility for and for a lot longer than we seem to remember up to and including duplicate inspections ......

And I'm sure somebody is about to quote words of wisdom picking up some small technicality about what I have said above but that's the way it has been for ages! JAR OPS has brought in a requirement for formal training before they can sign off Daily Inspections but under BCAR they had this privilege already.

[Bus429]

Pin,

I agree, CAP 360 part 2 has allowed it for years. However, goalposts have moved. Mechanics have now to have a Cat A licence to carry out these tasks, pilots do not. 145 stipulates a certifier has to be licensed under JAR 66 A, B1 or B2 to issue a CRS so why shouldn't pilots? I think the idea of a basic qualification for limited/simple tasks is a good idea - it should be applied in all cases.

[ShyTorque]

Bus 429,

The idea of requiring a pilot to be licensed for engineering tasks is an interesting one but it should be borne in mind that the more engineering quals a pilot is given, the more an employer will use them.

Even seemingly simple or basic tasks tend to be type specific, as Blacksheep has said, requiring one to one training so it is likely that the employer will be paying for it, at least in the short term. That might just give employers an opportunity to do without another engineer or two.

In what areas do you engineers feel that a pilot's knowledge is lacking? Serious question.

[Bus429]

Didn't say that pilots are incapable in any way. For a given task, a mechanic has to hold a JAR 66-A ticket, but the pilot doesn't. So, 1) Why bother having JAR 66-A or 2) make the whole system equitable?

I can see that I'm having trouble putting this point across. Check out <a href="http://www.caa.co.uk" target="_blank">http://www.caa.co.uk</a> and navigate to engineer licencing and JAR 66. See what the qualification path is for a JAR 66-A and then read TGL 38 and JAR 145.30.
Why bother mentioning this at all? The CAA will do whatever the operators want.

[ 20 January 2002: Message edited by: Bus429 ]</p>

[Genghis the Engineer]

Torque,

A surgeon once said to me that he could teach me to take somebody's kidney stones out in a couple of hours. But it would then take him another 5 years to teach me how to deal with everything else that might go wrong whilst you were doing so.

I think this principle probably applies to Engineering and it's various licenses, or to flying and an ATPL. I certainly find regularly, particularly in tracking down problems, I'm using all sorts of apparently unrelated Engineering theory.

G

[ 19 January 2002: Message edited by: Genghis the Engineer ]</p>

[ShyTorque]

Bus,

I understand what you are saying, or at least I think I do. You see it as unfair that a pilot can be allowed to carry out any engineering task without jumping through all the hoops that are required of an engineer. Please correct me if I am wrong. To a greater degree I agree with you.

However, as I said before, the authorisation (at least my own authorisation was quite specific) only allows for a pilot to carry out specific minor tasks that he has been specifically trained to do. His competence must be confirmed and signed off by an authorised engineer on an annual basis.

Genghis, a pilot is NOT allowed to carry out any troubleshooting or rectification of any defect other than carrying out those relatively minor things in his authorisation.

For example: Defect - starboard nav light not working. Pilot is authorised to replace the bulb. If replacing the bulb with a known serviceable one doesn't cure the fault, he isn't allowed to troubleshoot or touch the wiring. An engineer must then carry out any further work.

Although I do see myself as quite competent for more than the tasks required of me, I didn't particularly like carrying them out. I did it because it was quite normal with that employer, where there was no engineering support on site because of the way the contract had been made. In an ideal world, of course, I would much rather have an engineer drive 120 miles to change a lightbulb for me, especially at midnight... :)

The tyre changing wasn't applicable as our aircraft had skids!

As already mentioned, some pilots might not be skilled enough to carry out certain tasks. I think that is an individual problem that should be caught if the training is carried out correctly. If the pilot can't be trusted to do the task, then he shouldn't be signed off as competent. I have to say that I have known some pretty ham-fisted engineers in my time, too; I have worked with good and bad and occasionally knew I could have done a neater job myself.

I have to ask the question: Are any of you worried about pilots making engineers jobs less secure? I don't think you need to worry on that score. At present, a pilot's auth. ceases as soon as he moves to a new employer or fails to be annually re-auth'ed for any other reason. If, as Bus 429 would seem to prefer, pilots were to be given an engineering licence/qualification as it seems you are suggesting, it might be another matter. An organisation could then make it a requirement for a pilot to hold an "A" licence or engineering "type rating" as a pre-condition of employment and use it as an excuse to reduce their engineering establishment.

In any event, it would be totally impractical to put a pilot off-line for a year in order for him to satisfy the terms of an "A" licence.

I think it better all round that the situation is left as it is. If not, aviation is suddenly going to become even more expensive than it is now, which will be worse for all of us <img src="frown.gif" border="0">

(My edit is due to spelling mistakes, which only got noticed after posting).

[ 19 January 2002: Message edited by: ShyTorque ]</p>

[A/c Slave]

Bus thankx for the info.

Shy Torque, Valid points, but you are missing exactly what Bus is trying to say.
Basically it's because you don't understand how difficult and how much time and work is required to achieve a JAR 66 'A' Licence, just to carry out those simple task as you say!

Just a few weeks ago I was going over the exam requirements and required knowledge standard thats needed for the 'A' licence with a fellow workmate, this bloke(unlicence) is a top mechanic with excellant knowledge and long history of A/Craft Maint. And I tell you he was honest enough to admit he will strugle to pass it all...
I myself (Licenced) thinks it is over the top for what will be achieved after.

Basically what I am trying to say is that I will put anything that there is NOT ONE pilot around that can take those exams now and PASS without the correct training and experience!!!!!!

But the point is the "CAA" (w@nkers) are GIVING the jockeys a free pass to what others will be trying and working really hard for!

"Pisses me off I say"


best regards
SLAVE...........

[ShyTorque]

Slave,

I don't think I am missing the point but sympathise that maybe the CAA have made the licensing jumping hoops too tight; I can't comment further on that.

I am quite sure that a pilot would not pass these exams, any more than an engineer would pass a pilot's meteorology, navigation or aircraft tech exam without the required training.

I am only trying to put forward the view of a pilot with some experience of what the thread is about. I was prompted by a couple of respondents putting forward that pilots are a bunch of prima donnas who will do anything to avoid breaking a fingernail. Some of us don't mind too much getting our hands dirty and have proved ourselves to be competent to carry out certain engineering tasks. In doing so we have allowed an engineer to get a good night's sleep. I think that is what the dispensations were designed for.

I repeat my view that pilots have no intention to take bread out of your mouths BUT if a formal qualification WERE to be required for pilots, then that is a possible consequence.

I'll say no more now unless invited.

[Bus429]

Let's not get into the "pilots are prima donnas" argument (I have, on many occasions, but in different forum), most are OK. Let me iterate (means the same as re-iterate, according to Bill Bryson), any pilot could perform these task-trained...tasks (if they should want to). My problem, simply put, is the JAA/NAA have two different standards in this regard.

[Blacksheep]

ShyTorque,

It isn't a case of pilots not being capable of carrying out limited tasks and certifying them. Provided they have received specific training, Pilots ARE quite capable and both the previous and the present rules allowed it. As an avionics LAE I was also trained to do transit inspections and perform and certify specific airframe tasks, such as wheel and brake unit changes for example. I haven't converted to a JAR 66 licence and probably never will, but if I did I would be required to meet the experience requirements and pass the JAR66 examinations for an A rated licence as well as receive task specific training before I would be allowed to continue to do that for which I was previously qualified. It is that situation concerning limited authorizations, and which makes no sense, that Bus429 is trying to highlight.

**********************************
Through difficulties to the cinema

[ShyTorque]

Blacksheep,

I take your point; I hadn't quite grasped the correct nettle leaf. So under the old regs you were allowed to do more than under the new, despite you now having more experience than the first time you carried out those inspections...yes, that's ridiculous.

This affects the industry as a whole, so why are employers not claiming "grandfather rights" on your behalf?

[A/c Slave]

Well stated 'blacksheep'.

Shy Torque I was not trying to **** on pilots at all, it's just that I, like many of us in the Maint trade are really fed up now with the 'CAA' shafting of us.
I think the biggest problem is the lack of communication between the CAA and Maint. personnel as there is NOT a proper body to work with the CAA on our behalf and have a view on our impact and inputs.

The CAA have come out with this new system of Licencing which is grey and patchy in some areas, but try to call or write or whatever to clear anything with them is an absoult waste of time, seems they are making it up as they go along!

Pissed off again!!!!!!!!!

Best regards
SLAVE

[Genghis the Engineer]

My dear chap, that's exactly what the CAA have been doing to pilots since the introduction of JAR-FCL. The treatment, if nothing else, is entirely equal and impartial.

G

[Mice]

Gents, . .after reading two pages of this, I have no objection to pilots doing any of the work mentioned.. .However, it is the signing of a CRS that I have an objection to, on safety grounds.

Yes, let the crew do the work if needed (within the scope of their approvals), but then it should be inspected by an appropriate, qualified LAE the first available station for completion of a CRS methinks. It can operate on some form of permission till that time (within certain time constraints no doubt).