Concerns relating to fatigue amongst the operator’s Licences Aircraft Maintenance Engineers (LAMEs) and the licence coverage

• Maintenance on [aircraft type] is performed by staff under the Civil Aviation Safety Regulation CASR Part 145 approval of [airline] not that of [operator]. This is a commercial/contractual arrangement which is currently under review but the staff, as it stands at this point in time, certify under [airline] approval not [operator]. 
• We have a fatigue policy in place which meets the current guidelines provided by CASA and best industry practice. Where we need to go outside the normal parameters of this policy it is done in consultation with the QA manager and HR and additional mitigation of risk is included in exceptions which are documented. The instance of this is not common but has occurred due to situations where the aircraft cannot fly due to a serious maintenance issue (Aircraft on Ground (AOG)) and short notice absenteeism.
• We support [airline] operations at two Australian Ports, [location 1] that has one daily flight plus an additional flight on Tuesday, Thursday and Sunday and [location 2] which has recently commenced daily flights.
• Overtime worked by our employees has reduced from approximately 18% in FY 13/14 to 6% in FY14/15. This is reflected across all ports and all classifications.
• There are currently 18 active B1 certifying staff, of these 8 hold unrestricted B1 license.
• In addition there is a B2 engineer who under normal circumstances is present in [location 1] whenever a restricted B1 is rostered to work on [aircraft type].
• There are a small number of disgruntled employees who believe that we are responsible for their personal development and expect to have their skills upgraded. Since the introduction of the current licensing system numerous employees have upgraded their skills and where possible these employees have then had their type rating restriction removal training supported and funded by the company.
• We have recently had reason to discipline an individual for refusing to perform duties on aircraft other than the [aircraft type] to which he was assigned despite the fact that the aircraft was a transit in excess of 6 hours with no other maintenance required. The matter is now resolved but there may be some individual lingering resentment.
• The responsibilities and privileges of Restricted and Unrestricted B1 Engineers have been explained in numerous CASA publications and information is available on CASA website. In addition we have issued communications surrounding this matter in the past and our QA manager is available to provide clarification at any time. CASA Advisory circular AC 66-5 v1.2 was issued in June 2014 and we will issue this as a company ‘read and sign’ next week to reinforce the understanding.

We have issued the CASA Advisory Circular to all certifying staff as a read and sign today.

• As part of our safety management system (SMS), a confidential reporting mechanism exists and employees are encouraged to use this facility. We have not received any report similar to this from our employees.

Our Safety Management System and confidential reporting system has recently been reviewed and approved by CASA as part of a significant change to our Part 145 approval, we would welcome the opportunity to demonstrate this system to either the ATSB or CASA.

• No employee has ever to my knowledge been encouraged or permitted to ‘ignore defects or certify beyond the limits of their license’. This is in conflict with our policy and culture.
• It is our understanding that upon transition to the new licensing system CASA provided each license holder with an explanation of what the privileges of a restricted license are and there has been extensive dialogue surrounding this in the period following transition.