want to keep your licence/job!
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want to keep your licence/job!
I received the following from the ALAE, for those that are not members (join) or too apathetic to actually do anything I would suggest you read it and make your vote count, if not see you in the job centre!
Dear Colleague
As you are probably aware EASA has finally published its proposed amendment to the current release to service regulations. The notice more commonly referred to as NPA 145-012 (multiple/single release) had been hijacked by industry in an attempt to undermine the significance of the Licensed Engineer and their contribution to aircraft safety. The NPA is already three years behind schedule due to the politics surrounding the issue. A further concern was the inaction or refusal of numerous European NAA's to lend their support to a harmonized method of releasing aircraft back into service through the use of licensed personnel.
ALAE ensured that sufficient resources were available to challenge this approach and uphold safety levels. The result contained within this NPA justified our activities and over four years of hard work proved to be well worth the effort. However we are only half way there. ALAE's involvement in this legislative process must now cease after having secured a proposed decision fully endorsing the continued use of Part 66 qualified personnel to certify maintenance. We say proposed because NPA 145.012 now has to make its way through the political arena in Brussels in order for the proposed amendments to become law.
This is where you play your part. The lobbying against NPA 145.012 continues unabated with industry claiming it's too complicated and expensive to implement. The decision itself in our opinion is on the contrary rather simple in as much as all maintenance must be certified by appropriately qualified Category A, B1, B2 or Category C licensed personnel.
Obviously the aviation industry has strong connections within the European parliamentary system which will enable them to adequately voice their concerns. As far as NAA's are concerned the French, Dutch, Scandinavian and UK NAA's opposition to this NPA to date is no secret. Therefore to have some chance of countering this continuous lobbying, active Licensed Engineers need to declare their support for NPA 145.012. This is relatively easy to do, takes only a couple of minutes yet will assist tremendously in our attempts to secure your future.
The final stage of any proposed amendment is the comment response stage. There are a number of reasons for the existence of the commenting stage but one prominent reason is to ensure transparency of process. Therefore we all need to ensure that our views are made known. The comments received will be taken into consideration.
Officially one should create a commenting account on the EASA website by following this link: EASA CRT application
However should there be technical issues in creating an account or the EASA website is down one can email comments to: [email protected]
Either way you will be required to identify yourself in order for the comment to be accepted.
This same action is being recommended throughout Europe by AEI to all its affiliates as there is a lot at stake here. So please take the couple of minutes required and participate.
ALAE will forward the comments at the end of this message to be entered in the response document. Members and non member alike are welcome to use these comments as a basis for their own. Please be aware however that EASA will consider identical comments as one comment no matter how many are sent in. Therefore if you wish to use our comments as a basis for your own, please ensure there are sufficient changes in order for your comment to be considered in its own right.
Please pass this information on to all Licensed Engineers regardless of affiliation or membership status. This issue is about protecting the Licensed Engineer and upholding safety, nothing else.
Please be aware that the cut off date for comments is 5th October 2010. Comments received after this date will not be considered by EASA. If you require more information on this subject please don't hesitate to contact our head office in Bagshot.
ALAE will enter the comments below in the Comment Response Document. Feel free to use the text as a basis for your own opinion but please ensure you do not just cut and paste. This could undermine our efforts. Many thanks.
Best Regards
ALAE (1981)
A Branch of Prospect
"All parts of EC Regulation 2042/2003, Parts 147, 66, 145 and the engineering function of Part M are worthless if the reasons for certifying an aircraft after maintenance are not fully understood.
Each Part (Annex) of EC Regulation 2042/2003 enhances the next thereby ensuring a tier of compliance all of which exists to guarantee acceptable levels of flight safety. Reduce the importance or influence of any Part and safety will be compromised.
It should therefore be perfectly clear that the certification of certain limited task orientated activities can be performed by Category A licence holders. However the Category A privileges do not include systems troubleshooting. Therefore it should also be perfectly clear that avionic systems troubleshooting for example can only be certified by appropriately approved Part 66 B2 Licence holders just as troubleshooting of mechanical systems can only be certified by B1's.
The Licence holder would have successfully completed Part 147 basic and type/task training whilst their employer, a Part 145 approved Maintenance Organization, would have issued the Licence holder a company authorisation document authorizing the individual to certify on their behalf. The Part 145 Maintenance Organisation itself would also be bound contractually by a Part M organization or airline to ensure that maintenance is performed to the standards set by EC Regulation 2042/2003.
The fundamental reasons behind the creation of a legal requirement to certify any engineering activity is to legitimate and harmonise the whole regulatory structure thereby offering the public an assurance that common acceptable levels of safety have been maintained at all times.
The proposed amendment for 145-012 Multiple and Single release will remove the current ambiguity contained within the regulation that could compromise safety and in doing so will ensure that all Part 145 organisations harmonise the certification of maintenance process. With outsourcing and third party maintenance work on the increase, harmonisation of the release to service process is a safety issue.
As a Part 66 Licence Engineer tasked with certifying maintenance on a daily basis I fully support the proposed amendment to the regulation as it is simple, logical and clearly enhances safety at no extra cost to industry".
Dear Colleague
As you are probably aware EASA has finally published its proposed amendment to the current release to service regulations. The notice more commonly referred to as NPA 145-012 (multiple/single release) had been hijacked by industry in an attempt to undermine the significance of the Licensed Engineer and their contribution to aircraft safety. The NPA is already three years behind schedule due to the politics surrounding the issue. A further concern was the inaction or refusal of numerous European NAA's to lend their support to a harmonized method of releasing aircraft back into service through the use of licensed personnel.
ALAE ensured that sufficient resources were available to challenge this approach and uphold safety levels. The result contained within this NPA justified our activities and over four years of hard work proved to be well worth the effort. However we are only half way there. ALAE's involvement in this legislative process must now cease after having secured a proposed decision fully endorsing the continued use of Part 66 qualified personnel to certify maintenance. We say proposed because NPA 145.012 now has to make its way through the political arena in Brussels in order for the proposed amendments to become law.
This is where you play your part. The lobbying against NPA 145.012 continues unabated with industry claiming it's too complicated and expensive to implement. The decision itself in our opinion is on the contrary rather simple in as much as all maintenance must be certified by appropriately qualified Category A, B1, B2 or Category C licensed personnel.
Obviously the aviation industry has strong connections within the European parliamentary system which will enable them to adequately voice their concerns. As far as NAA's are concerned the French, Dutch, Scandinavian and UK NAA's opposition to this NPA to date is no secret. Therefore to have some chance of countering this continuous lobbying, active Licensed Engineers need to declare their support for NPA 145.012. This is relatively easy to do, takes only a couple of minutes yet will assist tremendously in our attempts to secure your future.
The final stage of any proposed amendment is the comment response stage. There are a number of reasons for the existence of the commenting stage but one prominent reason is to ensure transparency of process. Therefore we all need to ensure that our views are made known. The comments received will be taken into consideration.
Officially one should create a commenting account on the EASA website by following this link: EASA CRT application
However should there be technical issues in creating an account or the EASA website is down one can email comments to: [email protected]
Either way you will be required to identify yourself in order for the comment to be accepted.
This same action is being recommended throughout Europe by AEI to all its affiliates as there is a lot at stake here. So please take the couple of minutes required and participate.
ALAE will forward the comments at the end of this message to be entered in the response document. Members and non member alike are welcome to use these comments as a basis for their own. Please be aware however that EASA will consider identical comments as one comment no matter how many are sent in. Therefore if you wish to use our comments as a basis for your own, please ensure there are sufficient changes in order for your comment to be considered in its own right.
Please pass this information on to all Licensed Engineers regardless of affiliation or membership status. This issue is about protecting the Licensed Engineer and upholding safety, nothing else.
Please be aware that the cut off date for comments is 5th October 2010. Comments received after this date will not be considered by EASA. If you require more information on this subject please don't hesitate to contact our head office in Bagshot.
ALAE will enter the comments below in the Comment Response Document. Feel free to use the text as a basis for your own opinion but please ensure you do not just cut and paste. This could undermine our efforts. Many thanks.
Best Regards
ALAE (1981)
A Branch of Prospect
"All parts of EC Regulation 2042/2003, Parts 147, 66, 145 and the engineering function of Part M are worthless if the reasons for certifying an aircraft after maintenance are not fully understood.
Each Part (Annex) of EC Regulation 2042/2003 enhances the next thereby ensuring a tier of compliance all of which exists to guarantee acceptable levels of flight safety. Reduce the importance or influence of any Part and safety will be compromised.
It should therefore be perfectly clear that the certification of certain limited task orientated activities can be performed by Category A licence holders. However the Category A privileges do not include systems troubleshooting. Therefore it should also be perfectly clear that avionic systems troubleshooting for example can only be certified by appropriately approved Part 66 B2 Licence holders just as troubleshooting of mechanical systems can only be certified by B1's.
The Licence holder would have successfully completed Part 147 basic and type/task training whilst their employer, a Part 145 approved Maintenance Organization, would have issued the Licence holder a company authorisation document authorizing the individual to certify on their behalf. The Part 145 Maintenance Organisation itself would also be bound contractually by a Part M organization or airline to ensure that maintenance is performed to the standards set by EC Regulation 2042/2003.
The fundamental reasons behind the creation of a legal requirement to certify any engineering activity is to legitimate and harmonise the whole regulatory structure thereby offering the public an assurance that common acceptable levels of safety have been maintained at all times.
The proposed amendment for 145-012 Multiple and Single release will remove the current ambiguity contained within the regulation that could compromise safety and in doing so will ensure that all Part 145 organisations harmonise the certification of maintenance process. With outsourcing and third party maintenance work on the increase, harmonisation of the release to service process is a safety issue.
As a Part 66 Licence Engineer tasked with certifying maintenance on a daily basis I fully support the proposed amendment to the regulation as it is simple, logical and clearly enhances safety at no extra cost to industry".
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Believe it or not, i've read that NPA before and still struggle to understand how it will improve jobs prospects or increase safety.
All it seems to do for me is allow operators to wash their hands of any responsibility and issue a CRS based on a 2nd tier "CRS" from an intermediate company.
I'm a member of the ALAE as are many of my colleagues and I fully appreciate the efforts they've gone to with this but I still find it hard to see what the problem is if the NPA doesn't go through.
Any chance of a simple laymans explanation as to why i'll be in the job centre if the NPA is blocked.
Also , do you know how you can view others comments from the EASA CRT site (I am logged in).
All it seems to do for me is allow operators to wash their hands of any responsibility and issue a CRS based on a 2nd tier "CRS" from an intermediate company.
I'm a member of the ALAE as are many of my colleagues and I fully appreciate the efforts they've gone to with this but I still find it hard to see what the problem is if the NPA doesn't go through.
Any chance of a simple laymans explanation as to why i'll be in the job centre if the NPA is blocked.
Also , do you know how you can view others comments from the EASA CRT site (I am logged in).
If I remember correctly, this is because of a fear that Part M Organisations may be given the responsibility to Sign-Off the final CRS's - not a Part 145 Organisation.
This means that the operators (probably sitting in a Maintrol Office) can sign off their aircraft without using Line Engineers. No use of Line Engineers for this task means less Line Engineers...
If this system works it will undoubtedly be rolled out across many other areas and replace (CAT B) Line Maintenance Technicians for task-trained (CAT A) Mechanics at best. At worst all Licences could disapear and be replaced by locally trained and company approved mechanics, unable to move jobs without losing pay rates (loss of freedom of movement)
...I think!
This means that the operators (probably sitting in a Maintrol Office) can sign off their aircraft without using Line Engineers. No use of Line Engineers for this task means less Line Engineers...
If this system works it will undoubtedly be rolled out across many other areas and replace (CAT B) Line Maintenance Technicians for task-trained (CAT A) Mechanics at best. At worst all Licences could disapear and be replaced by locally trained and company approved mechanics, unable to move jobs without losing pay rates (loss of freedom of movement)
...I think!
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I agree with Rigga from how I interpret the NPA.
If you read through your past tech logs their are examples of how Part-M companies have been using their interpretation of the legislation to defer maintenance to the 145 organisation until a convenient time. e.g Acceptable Carry Forwards on bird strike inspections etc.
The NPA should rule out the company approved CRS holder. This scenario incorporates that no Part-66 licence is required, just the 145 approved 6 week course passer from the street.
This is the first time I have seen an NPA to oppose the path authorities are undertaking. The regulation of the aircraft since EASA came into affect is becoming more the Airlines responsibility than the NAA. C of As, Part 21 sign offs for out of MM limits damage, Part-147 licence exams to name a few.
A plea to our Flight Crew collegues.
If you do not wish for your damaged aircraft to be assessed from a person in an office 5000 miles away, or an unqualified engineer at the line station; please take a minute to email EASA to back this NPA. This would be gratefully appreciated by your Engineering collegues.
Kind Regards
Beeline
If you read through your past tech logs their are examples of how Part-M companies have been using their interpretation of the legislation to defer maintenance to the 145 organisation until a convenient time. e.g Acceptable Carry Forwards on bird strike inspections etc.
The NPA should rule out the company approved CRS holder. This scenario incorporates that no Part-66 licence is required, just the 145 approved 6 week course passer from the street.
This is the first time I have seen an NPA to oppose the path authorities are undertaking. The regulation of the aircraft since EASA came into affect is becoming more the Airlines responsibility than the NAA. C of As, Part 21 sign offs for out of MM limits damage, Part-147 licence exams to name a few.
A plea to our Flight Crew collegues.
If you do not wish for your damaged aircraft to be assessed from a person in an office 5000 miles away, or an unqualified engineer at the line station; please take a minute to email EASA to back this NPA. This would be gratefully appreciated by your Engineering collegues.
Kind Regards
Beeline
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In the interests of job security and the fact that some mechs I have had the pleasure to work with wouldn't even know which end of the pen to use in the tech log I have left my comments for EASA to peruse
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Car 145.30
Gents
it is already common practice. Where do you guys have to certify a B737 on a outstation ? Good luck to all of us
CAR 145.30 clearly states:
For a repetitive pre-flight airworthiness directive which specifically states that the flight crew may carry out such airworthiness directive, the organisation may issue a limited certification authorisation to the aircraft commander and/or the flight engineer on the
basis of the flight crew licence held. However, the organisation shall ensure that
sufficient practical training has been carried out to ensure that such aircraft commander
or flight engineer can accomplish the airworthiness directive to the required standard
it is already common practice. Where do you guys have to certify a B737 on a outstation ? Good luck to all of us
CAR 145.30 clearly states:
For a repetitive pre-flight airworthiness directive which specifically states that the flight crew may carry out such airworthiness directive, the organisation may issue a limited certification authorisation to the aircraft commander and/or the flight engineer on the
basis of the flight crew licence held. However, the organisation shall ensure that
sufficient practical training has been carried out to ensure that such aircraft commander
or flight engineer can accomplish the airworthiness directive to the required standard
it is already common practice. Where do you guys have to certify a B737 on a outstation ? Good luck to all of us
The flight crew can only ACF if there is no engineering cover available. (unfotunately the word 'available' is being abused by a few to include "well, the engineer would be 5 mins before he/she turned up so we used ACF" which isn't exactly in the spirit of the thing is it?)
Transit inspection is done by the flt crew, anything found or higher check required, IE Daily, is certified by a line eng who, depending on the level of certification required is either Cat A or B1.
My letter is in the post, I suggest we all do the same.
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Interesting that this subject has dropped off the radar screens already.
Working for free whilst many old sweats haven't grasped the fact yet that industry want rid of you (licensed guys and gals) in order to cover the maintenance demands of the enormous amount of civil jets that are going to be sold over the next 10-15 years.
The aviation industry will go to the wall just like the motorcycle, car and shipping industries. The reason is simple. Those affected were unable to pull in one united direction.
You only have yourselves to blame
Working for free whilst many old sweats haven't grasped the fact yet that industry want rid of you (licensed guys and gals) in order to cover the maintenance demands of the enormous amount of civil jets that are going to be sold over the next 10-15 years.
The aviation industry will go to the wall just like the motorcycle, car and shipping industries. The reason is simple. Those affected were unable to pull in one united direction.
You only have yourselves to blame
