EASA vs FAA

[whyliecoyotez]

Hello everyone, my name is matt and im currently studying for a degree in aircraft maintenance. I am about to start writing a paper on the differences in regulations between the EASA and the FAA regarding aircraft maintenance and thought i would get a heads up from some experienced engineers first.

I have briefly studied the EASA part M + 145 + 66 + 147 regulations and also combed through FAR 43 + 145 + 65 + 147 and to be honoust i cant spot any major difference between the two except of course for the difference in engineering personnel licences :ugh:. Anyone with any experience or knowledge in this field that could point me in the right direction or shed some light on major differences between the two authorities?

Any advice would be much appreciated :ok:

[Alber Ratman]

That will be a Barry College ICAT assignment for Module 10 then..:E

Middle Eastern airline/MRO set up.. Which one is better suited to your CEOs idea of effectiveness and cost..

[whyliecoyotez]

Bingo :D :)
Not exactly the easiest assignment to get, but heck i been putting it off for long enough now! Since i went through the military route i dont have much experience with these regulations so its all new to me, and trying to decipher them paragraph by paragraph is going to lead to my early retirement :O

[Capot]

The rules are becoming more and more harmonised.

What is not harmonised is the way that they are enforced in the two jurisdictions.

The USA is a country where aviation has been nurtured from its very beginnings with the Wright Brothers. By and large, the industry is regulated by people who understand aviation and its importance, and operated - with very few exceptions - by people with high standards of honesty and discipline that is bred into them as part of their aviation DNA.

The UK once had that, and in a few secret corners that spirit can still be found. So did some other European countries; France, Italy and Germany both had magnificent pioneers.

But the dead hand of EASA is now laid on the industry in Europe; an organisation as dysfunctional as many of its Member States. Every decision is a political compromise between the divergent aspirations of 27 States; every Member State has to fill a number of posts regardless of ability, and only people with mediocre ability apply anyway. Ever been to Cologne? Enough said.

And in the UK we have the CAA, the last home for the unemployable. Its propensity for shirking any challenge is now well documented. The lack of competence and knowledge among its Inspectors and Surveyors is quite breath-taking; this is partly the foreseeable consequence of its habit of shoeing cronies into these jobs rather than people who earn them by merit.

It is commonly said of these people, quite rightly, that they make up their own rules as they go along to suit their particular - ill-informed - prejudices, and that this stems from ignorance. The result is total inconsistency between their pronouncements; different day, different answer, is the default position. Their stupidity is exacerbated by their arrogance, personal in many cases as well as institutional. The CAA reaches its nadir in the Personnel Licensing Department (Division? Does it matter?) as many will have experienced, where outrageous charges are combined with outrageously bad and slow service.

The CAA is now obsessed with minutiae, while being evidently unaware of the bigger picture of aviation safety. The process is all; the outcome is not their problem, is how they see it, because they are only there to enforce the process. There are things being done every day, now, that are dangerous, by large airlines especially, which the CAA either condones or is unaware of; what they know is that the right boxes have been ticked and their well-padded bottoms are thereby covered.

The CAA's failings extend well beyond Safety Regulation; as an Economic Regulator they are completely ineffectual. You only have to look at the disaster area that is the "London Airport System", and then to consider that if the CAA had been a strong and effective body for the last decade at least things could have been very different.

The CAA used to be openly corrupt; some years ago it was my job in a particular airline, now happily defunct, to give the FOI his new car every year as he ignored the appalling operational practices going on under his nose. Someone else dealt with the maintenance Surveyor. Now, the corruption is more sinister, as its staff cover for each other's incompetence, and "arrange" jobs for their friends. And when did using their victims' fees and charges to fund a private company become part of their mandate?

This rant may or may not be germane to your studies; but I hope it helps to understand the huge differences between the regulatory regimes, while they apply quite similar rules.

[Safety Concerns]

wow are you bitter or what

[Alber Ratman]

Capot, my licence application only took 10 days to process and return with a ticket! Don't think that is slow!

Whyliecoyotez, the assignment is aimed at you disecting the regulations for EASA and the FAA and come to a conclusion on what you think is the better system for maintenance approvals, certifying staff and training for your companies operation. Capot has given you some clues in his rant about the differences in the way the FAA and EASA stand on the one rule maker and the committee approach of EASA. Don't take any notice about the CAA activities as your assignment has nothing to do with it. It is mainly to look at what is the costs in training certifying staff (A&P vs B1/B2 requirements in 147 does vary), differences in FAR Repair station to PART 145 orgs and the set up of schools being a couple of pointers. Write it in your own hand too, as its a report to a CEO that doesn't want to know rules and regulations verbatuim! LOL

Remember, as a company operating in a country not under the EASA / FAA umbrella, it will come under that countries ICAO recognised NRA for registration of aircraft and AOC and must be in the loop, even if they recognise FAA and EASA modes of approval. BTW, an MRO can hold both EASA and FAA approvals for base and line operations for the types they deal with.

[Avionker]

Not a fan then Capot?

[shumway76]

From a maintenance personnel point of view:
(Note - I am not an FAA qualified maintenance person, but did some reading on their system. I am more versed on EASA)

EASA (With regards to Cat B1 - mechanical certifying technician) - The B1 license holder supervises / assists in carrying out the task at hand done by "fitters" (the person actually getting his hands dirty). The fitter does not have any legal certification privileges, but his name is appended on the paperwork as the person performing the job (for accountability within the company only, not legal), then signed by the B1 licensed holder in the Certifying personnel column, who holds the legal responsibility.

FAA - The A&P mechanic is "licensed" by the FAA. He is the person actually getting his hands dirty, & signs for the work done & is accountable legally. If the work is deemed critical, an Inspector (who is actually an A&P person with at least 5 years experience & passed the Inspector exam by FAA) will counter check the work.

From my experience working in a hangar environment, I much prefer the FAA system. That is because in a hangar environment, many tasks are being done at the same time. In the EASA B1 system, you will be supervising fitters who do not hold any legal responsibility, but they're doing the job, & you are supposed to supervise them (could be lots of them at the same time doing different jobs).
In the FAA system, the A&P mechanic does the actual job is legally responsible for it. More task oriented.

Please correct me if I am wrong in any of the above.
Any A&P mechs, A&P Inspectors & EASA B1 licensed guys out there agree/disagree with my statement above?

[winglit]

Here's a major difference between to two as far as the airlines are concerned.

As an EASA licensed engineer YOU are responsible for the diagnosis and the airworthiness decisions are based on your level of knowledge. You are also ultimately responsible for the CRS that you release with your licence and type rating.

As an FAA mechanic you are an extension of Maintenance Control. For example AA have a huge team of specialists in Tulsa. When you have a problem, you call them up and they walk through the FIM with you, tell you exactly what to do and even tell you what to write in the log with a release number generated by them. You share that culpability with them too.

I am licensed with both and use either license on a daily basis, so that's how I know. I'm an old Section L convertee, but even with the conversion exams it was no picnic!

It took me two weeks to get my A&P and three days to get my IA!

Yes the European level of knowledge required to get your license is far higher. But why? I think that the American system is more than sufficient to keep aircraft airworthy. When was the last time you heard about a maintenance issue on an N reg airliner?

The only bonus about having an EASA license is that you get paid more!

[shumway76]

FAA approach (as in most things within the US) is very hands-on, & everyone starts at the bottom & work their way up.Just ask an EASA B1 "engineer" how much of hands on experience he has if he went through a 147 training course - of the 4 yrs training, hands on OJT training on live aircraft is probably 2 years minimum, the other 2 yrs is classroom studies to pass the modules. Upon completion of training at the end of 4 years, he will be supervising a group of fitters (who are unlicensed, therefore cannot legally certify), most of home are probably twice his age & have been working hands on for many many many more years than he has.Consider the FAA A&P mechanic - he can go through an approved training school, probably about 4 years with hands on experience. Upon obtaining his A&P, he is still hands on but at the same time also certify his own work. Basically he's the fitter & also the certifier. Of course certain critical task an Inspector will have to recheck & certify (RII). If you want to say the FAA A&P mechanic got his "license" easier, probably. But think again, he's doing the work & also certifying for it himself. He will feel the weight / responsibility.While the fitter who is doing the hands on work under supervision of the EASA B1 license holder probably has much less knowledge than a A&P mechanic, and does not hold any legal responsibility...

[Heliarctic]

Hello there
Shumway76, i think it depends a lot on which company you work for, if it´s small or big, which country in EASA land etc.
I don´t have any experience with the FAA system, but in my company all the guys have a B1/B2 rating and type rating on whatever they are working on, the majority also hold the C rating, so we don´t have anyone who does the "rough" work for us so to speak, we do it ourselves, sign off on the papers and release the aircraft.
During major inspections of any kind where the aircraft is grounded for an extended time, a person with the relevant experience will be appointed supervisor and handle all the paperwork and in the end sign it off. But the same guy(or girl) will be working on the line again after the inspection is over, and he could be one of the hands on guys working on another inspection with another supervisor.
Have a nice week-end
Cheers

[BAe146s make me cry]

I'm qualified under both systems, both the FAA & EASA (through the UKCAA). I find myself in full agreement with Capot's assessment. A tickbox culture applied to the wrong industry - within quite a few EASA member states, complete B1/B2 licences seem to have been issued to any bastard deemed worthy??!!

On a recent type course I attended, I found it hilarious about just how much some of my fellow B1/B2's didn't know about aircraft at a most basic level - Just to reassure those still reading, I am no rocket scientist but I was diligent enough like most to earn & learn for these Licences. A few hadn't even heard of Duplicate Inspections (RII) before?? Erm, you what? (Language wasn't a barrier for them before any accusers step up)


There may be a bit of honest poking of our EASA NAA's above but over here in the UK, we continue the plod to further hands-off regulatory oversight..
I love the way my present employer, a UK Part 145 MRO prep for a UKCAA audit & even 'surprise visits' 1+ week in advance.. We have the odd small finding but big ones? Us? We must be lucky or something

[Capot]

We must be lucky or something

The "something" may be the bond between Freemasons; one understands that many in Aviation House are Masons, which would account for the CAA's otherwise inexplicable recruitment decisions, and why some companies get away with very "Light Touch Regulation" and others do not.

[Beeline]

'As an FAA mechanic you are an extension of Maintenance Control. For example AA have a huge team of specialists in Tulsa. When you have a problem, you call them up and they walk through the FIM with you, tell you exactly what to do and even tell you what to write in the log with a release number generated by them. You share that culpability with them too.'

This system is flawed, the Engineer at the other end of the phone line's decision is only as good as the information conveyed to him/her from the person in contact with the aircraft. Therefore he/she in the office 1000 miles away always has a get out of jail free card. This is not safe practice.

As with most Maintenance Control centres the idea is to get the aircraft back to base using you as the puppet to sign for it if they can, even in the best sloping shoulder case the signatory is still 50% accountable, how comes you have to sign the book? In europe the organisation have just signed it off themselves; as with this and in the scenario you describe the aim is to eventually take you the AMLE out of the equation for good.

Aircraft Engineers International (AEI) and the Association of Licensed Aircraft Engineers (ALAE) have been lobbying against the loop hole the EASA CAMOs have found in Part M releasing there aircraft under a Single Release CRS. NPA 145.012 proposing Multiple release has been met by strong opposition from industry, for obvious reasons.

The proposal states that a traded CRS from a Licensed Engineer is MANDATORY for the release of aircraft. Saving the demise of the licensed engineer, and my job!!

We do not want to go the same way as the AA system; how the FAA is letting it go on is beyond me. That N reg mess up is on borrowed time. So is the G reg if NPA 145.012 does not go through Brussels.

[grounded27]

Ok, here is how it works here. There are several Layers.

You need proven experience of several years or 1900 approx hours of training that is text book and hands on to recieve approval from the FAA to test for an A&P, little of this training will prepare you for the modern jet unless sheetmetal is your desire.

Most start off with an MRO or feeder earning 10-15 usd an hour (many are going to A&P school ang getting picked up by energy companies).

The feeder places allot of responsibility in the hands of a "green" AMT. You sign for your own work. The FAA has maintained a loophole that you must have performed a task supervised before doing it yourself and signing it off yourself. This is rarely enforced. The loophole is that the FAA started pushing airlines to provide atleast 40 hours of classroom training that is aircraft specific teaching each ATA.

The MRO is a Jungle of unliscenced, what you call "fitters". There is supposed to be a ratio of liscenced to unliscenced mechanics, leads and supervisors must be liscenced and the mro is often 100% "buyback". Every item requires a liscenced inspector (A&P is the only legal requirement for this type of inspector but they are usually tired old lazy bastards who don't want to get dirty anymore, got layed off from or never made it to an airline). 100% buyback allows a 145 allot of leeway with the FAA as the owner of the aircraft is responsible as well to ensure the MRO is compliant.

Career progression is usually MGT within the above mentioned or off to an airline. Airlines employ 100% liscenced AMT's, usually provide 80-160 hours minimum training on each type, recurrent training for lower landing minimum, engine run, RII etc. This is usually as good as it gets.


GA is a whole different world.

[shumway76]

Looks life FAA leave a lot of loopholes / open to interpretation in their laws, therefore it seems a bit "flexible", as long as you don't get into trouble.

EASA has things for spelled out in black & white, can't deviate much.

[grounded27]

Yeah I suppose Shumway, but you are right for the most part for a Liscenced AMT. I started from the bottom up. Learned standard practices in the mro's, it was about 4 years after 2 years of gaining my A&P before I signed my first logpage.

I feel every LAME/AMT should do a few years changing parts for a MRO before they hit the ramp.

[Prasantha G]

According to Human factors and behavior analysis, I could say that Senior Certifying would win in the Safety grounds.

At normal conditions either of the ways would be considered efficient in safety standards. But at abnormal conditions, like for example Mental tensions, Health problems, bad distractions, alcohol consumption, bad work place ethics, in these kind of situations : A single person doing the work and certifying the work himself, could not be considered safe. Where as, another extra guy / senior remonitoring the work performed, could increase the safety levels.

At normal conditions, and people working under good environment, could not find the difference between the FAA and EASA system of Releasing the Work.

While under the rarely happening Abnormal conditions, unwanted issues would be arising deviating everyone's minds from their normal thinking process.

For example, prominent airlines had been penalised due to inefficient/malpractised maintenance practices, in the year 2008, some licensed technicians supposedly have released the aircraft without actually rectifying the defects, further to say - in an efficient reputated facility and considered controlled environment.

To maintain Higher Safety standards, in comparision, having an upper eye with in an organisation, would always helps, in all conditions and environments.

[batparia]

:uhoh:Dear Beeline,

I am an Indian AME License holder.We are switching to CAR 66B system which is almost the same as Part66 system.You mentioned about NPA 145.012 single release
and multiple release system which is not understood by me and I did not understand how is it going to impact you. Could you kindly explain?