The regulatory requirements regarding the provision of trained
staff by operators engaged in commercial operations is contained in
regulation 213 of CAR 1988. For maintenance organisations, the
requirement for the number of qualified and experienced persons in
the employ of the organisation at the time of application for a
certificate is contained in regulation 30 (2) of CAR 1988.
While CASA monitors maintenance organisation compliance under a
periodic system of surveillance, it is accepted that maintenance
organisations have a superior advantage in monitoring their own
performance for planned and unplanned maintenance, etc. This day to
day monitoring includes not only compliance with maintenance
requirements contained in legislation and maintenance control
manuals but also for the provision of adequately trained personnel
for given workload situations. Such workloads can vary considerably
between scheduled, unscheduled and contract maintenance
inputs.
Future regulation will require maintenance organisations and
operators to implement an internal evaluation system (IES) designed
to ensure continued compliance with regulatory requirements. There
will also be advisory material provided on the subject of human
factors in maintenance as a means of bringing to the attention of
all persons engaged in maintenance of their limitations and the
impact this can have on their performance due to fatigue, sickness
etc. To this end, legislation is being proposed that requires
maintenance personnel not to engage in any activity that they are
permitted to carry out if suffering from fatigue, illness, injury
or are under the influence of alcohol or drug or any other
substance to the extent that their ability to carry out the
activity is impaired.
Although there will remain a requirement for organisations and
operators to provided adequate numbers of trained staff, there is
little scope available to CASA to ensure, in real time, that
adequate numbers are available at any one time. This is clearly the
responsibility of the operator or organisation who will need to
consider their responsibilities with regard to their quality
control, assurance and internal evaluation systems, maintenance
control and procedures manual practices and procedures, together
with their obligations under State law as it applies to employee
work cover arrangements.
Irrespective of the above, it is recognised that oversight
arrangements by CASA should adequately address the matters raised
by BASI. In this regard it is recommended that further comment be
made by the Aviation Safety Compliance Division.
