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Aerodav
14th Aug 2019, 08:36
Good morning,

I am looking for a bit of assistance in regards to Aviation Legislation particularlly the OJT for the first type rating. Would you confirm if OJT can be obtained while still getting the Basic Experience for the B1.1 license and a example case below:

Let's say I am employed by a Part 145 MRO performing line maintenance to various types of aircraft. As no technical relevant experience apply I will need 5 years of experience and the task I am carrying out during this period I log in my logbook accordingly in order to prove the Basic Experience.

Imagine at the same time, as I have already made the decission that the first type to be introduced in my license will be the A320 family (as it is the type more frequently maintained in my company), every time I work on this type not only I record the task in my Basic Experience Logbook but also in a separate logbook for the OJT. Will this be acceptable or OJT has to be performed once your blank license is issued i.e. if the license is issued the 1st of August 2020 then first entry in OJT logbook not earlier than 2nd of August.


I am aware only the 50% of the OJT can be carried out before the Level 3 type course but this has nothing to do with the license issuance.
Also aware that the type course and OJT shall be started and completed within the three years preceding the application of a type rating endorsement but again this has little to do with the timeline of the license itself.


Additionally one of the FAQ in EASA states the following reference the type trainng but there is not a equivalent answer for the OJT even though this is part of the Type training in my view:


I have passed the aircraft type rating training (TRT) in an approved EASA Part-147 organisation, although I have not completed the basic knowledge training. Is this TRT valid for life? Would it be possible to endorse it on my Part-66 licence as soon as I get one?

Aircraft type rating training must have been started and be completed within the 3 years preceding the application for a type rating endorsement (Part-66, Appendix III, paragraph 1 refers).

It does not make sense to attend in the first instance a TRT course with the intent of getting this TRT later endorsed on the maintenance licence for two main reasons:

at the time the TRT is gained, the holder has no licence and it may take more than 3 years before the applicant is compliant with the basic knowledge (66.A.25) as well as the experience requirements (66.A.30). Therefore the applicant runs the risk to get its TRT certificate expired at the time he applies for the licence and the TRT endorsement; and
From an intellectual point of view, this is not logical to demonstrate maintenance competence on a specific aircraft type without having acquired the basic knowledge, skills and attitude related to the maintenance and the technologies used in aviation in general.
Legally speaking the situation is not forbidden. However be sure that you get your licence within the 3-years’ timeframe from the date you passed the TRT course.


Hence and in brief can I assume that after the 2 first years of Basic Experience obtained, it will be wise to start bulding my OJT logbook (3 years before license application and type endorsment application to be done at the same time).

Thanks a lot and regards,

BluFin
14th Aug 2019, 13:49
Yes you can do both at the same time.

If I was your employer I would not put you on TRT course until you were pretty much complete on your basic experience requirement and confident in your ability. Maybe issue you an OJT book about 6 months before your TRT. - financial risk is to great - sorry but you are just a number
Dont forget times quoted in 66.A.30 are the minimum duration, to gain the required exposure to the tasks to meet the requirements may take longer, if your application was rejected using the time basis that you have used the whole plan falls apart.

Read the FAQ fully & digest what it is saying seems you just want to meet the minimum duration rather than be the best engineer you can be, key point to the EASA response is in the last but 1 line
"From an intellectual point of view, this is not logical to demonstrate maintenance competence on a specific aircraft type without having acquired the basic knowledge, skills and attitude related to the maintenance and the technologies used in aviation in general."

Just My thoughts

Aerodav
14th Aug 2019, 14:15
Thanks for your answer and comments noted. I don't want to rush the process just saw some post in this Forum and some others of Technicians with blank licenses having a hard time trying to get the OJT completed even loosing the type training as OJT not completed in 3 years or paying themselves for the OJT so I just wanted to make sure I understand the specifics of the Regulations. I agree meeting the minimum duration shouldn't be the goal but neither be screwed by a lack of legislation knowledge or an unscrupulous company hence the question.

Thanks a lot for your feedback,

BluFin
14th Aug 2019, 18:08
Most of the issues arise where people have started the type course far to early and they then have a non moveable backstop which creates all the problems.

Good Luck