The concern related to the exclusions which were applied to the maintenance licences when CASA transferred the qualifications from the old licencing system to the new system.
The reporter expressed a safety concern in relation to the removal of exclusion E6 when the B1.1 licence was transitioned from the old licence to the new.
The reporter is concerned about the experience and qualifications of Licenced Aircraft Maintenance Engineers (LAMEs) holding a B1.1 Category licence with E1, E4 and E5 exclusions carrying out and certifying for maintenance tasks in Avionic ATA chapters 22, 23, 31, 34, 44, 45 & 46.
The B1.1 LAMEs with E1, E4 and E5 exclusions have received minimal training, have no prior learning, have next to no experience and do not meet the required competencies in accordance with CASR Part 66 MOS in the avionic ATA chapters 22, 23, 31, 34, 44, 45 & 46 to safely maintain and certify for maintenance in these chapters. However, due to the fact that these B1.1 LAMEs) with E1, E4 and E5 exclusions on their licence do not have the E6 (avionic LRU's) exclusion on their licence, they are allowed under the CASR Part 66 MOS regulations to carry out and certify for maintenance on Avionic Line Replaceable Units (LRUs) in chapters 22, 23, 31, 34, 44, 45 & 46 with minimal and/or no experience and knowledge.
As per CASR Part 66 MOS, Appendix VIII, ‘Units of competency required for removal of an exclusion from a category or subcategory of a licence’, for an E6 (excluding avionics LRU’s) exclusion to be removed LAMEs are required to have completed the following competencies:
- MEA201B – Remove and install miscellaneous aircraft electrical hardware and components
- MEA203C – Remove and install advanced aircraft electrical system and components
- MEA211C – Inspect, test and troubleshoot advanced aircraft electrical systems and components
- MEA246C – Fabricate and/or repair aircraft electrical hardware or parts
- MEA260B – Use electrical test equipment
- MEA343B – Remove and install avionic system and components.
The above competencies and many others are also required to remove exclusions E1, E4 and E5. Therefore if a LAME has an E1, E4 and E5 exclusion on their B1.1 category licence they have not completed any of the above competencies, least of all MEA343B - Remove and install avionic system and components. Therefore, one could argue that an E6 exclusion should also be applied to a B1.1 category licence holder who also has the other E1, E4 & E5 exclusions.
The reporter advised that there are serious concerns over the CASR Part 66 MOS licence category privileges, in that a B1.1 category licence holder with E1, E4 and E5 exclusions, for example, cannot carry out and certify for the replacement and simple test of a light bulb in ATA Chapter 33, however, they have full scope and privilege to carry out and certify for Avionic LRU replacements and tests in ATA Chapters 22, 23, 31, 34, 44, 45 & 46 because they do not have the E6 exclusion on their category licence.
These are the competency requirements for the old licencing requirements and as shown, there is no training provided to account for the removal of the E6 exclusion:
2.3 Airframe Category — Electrical Category Privileges: Certification of maintenance within the electrical category may be made by persons holding the appropriate airframe rating(s), as follows:
a) electrical systems classified as Electrical Group I in aircraft approved only for V.F.R. operations — all maintenance;
b) electrical systems classified as Electrical Group I in aircraft approved for I.F.R. operations or electrical systems classified as Electrical Group 2 or Group 20 limited to;
I. daily or manufacturers’ equivalent inspection; and
II. condition of security of attachment of wiring and components.
2.4 Airframe Category — Instrument Category Privileges: Certification of maintenance within the instrument category may be made by persons holding the appropriate airframe rating(s), as follows:
a) on all aircraft:
I. oxygen systems; and
II. compensation of direct reading magnetic compasses;
b) on aircraft not classified Airframes Group 20 — approved only for V.F.R. operations:
I. instrument systems classified as Instruments Group 1 and Group 3 — all maintenance; and
II. instrument systems classified as Instruments Group 5 to 10, limited to ¬daily, or manufacturers’ equivalent inspection, and condition and security of attachment of wiring and components;
c) on aircraft not classified Airframes Group 20 — approved for I.F.R. operations or instrument systems classified as Instruments Group 20, limited to:
I. daily, or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring, plumbing and components;
d) on aircraft classified as Airframes Group 20, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring, plumbing and components.
2.5 Airframes Category — Radio Category Privileges: Certification of maintenance, excluding operational checks, within the radio category may be made by persons holding the appropriate airframe rating(s), as follows:
a) on aircraft approved only for V.F.R. operation, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring and components; and
III. replacement of removable items of equipment of radio systems; and
IV. periodic inspections;
b) on aircraft approved for I.F.R. operation, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring and components.
3.4 Engine Category — Electrical Category Privileges: Certification of maintenance within the electrical category may be made by persons holding the appropriate engine rating(s) as follows:
a) electrical systems classified as Electrical Group 1 in aircraft approved only for V.F.R. operations — all maintenance;
b) electrical systems classified as Electrical Group I in aircraft approved for I.F.R. operations or electrical systems classified as Electrical Group 2 or Group 20 ¬limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring and components.
3.5 Engine Category — Instrument Category Privileges: Certification of maintenance within the instrument category may be made by persons holding the appropriate engine rating(s), as follows:
a) on all aircraft — compensation of direct reading magnetic compasses;
b) on aircraft approved only for V.F.R. operations:
I. instrument systems classified as Instrument Group 1 and Group 3 — all maintenance, excluding oxygen systems; and
II. instrument systems classified as Instrument Groups 5 to 10, limited to daily or manufacturers’ equivalent inspection, condition and security of attachment wiring, plumbing and components;
c) on aircraft approved for I.F.R. operations, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring, plumbing and components.
d) on aircraft classified as Instrument Group 20, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring, plumbing and components.
3.6 Engine Category — Radio Category Privileges: Certification of maintenance, excluding operational checks, within the radio category may be made by persons holding the appropriate engine rating(s), as follows:
a) on aircraft approved only for V.F.R. operations, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring and components; and
III. replacement of removable items of equipment of radio systems;
b) on aircraft approved for I.F.R. operations, limited to:
I. daily or manufacturers’ equivalent inspection; and
II. condition and security of attachment of wiring and components.
CASA has reviewed the REPCON and does not consider the matter to be a safety concern. The Civil Aviation Safety Regulation 1998 (CASR) Part 66 B1 and B2 licence system has now been in place for four years (post conversion) and CASA is not aware of maintenance incidents arising from former engine or aircraft category personnel providing maintenance certifications in the exercise of their Avionics Line Replaceable Unit B1 licence scope.
At the time of conversion – for Visual Flight Rules (VFR) aircraft – the engine and airframe personnel had significant electrical, instrument and radio privileges as can be seen in the old Civil Aviation Order legislation copied into the REPCON at items 2.3 (a); 2.4 (a) and (b); 2.5 (a); 3.4 (a); 3.5 (a) and 3.5 (a).
The delineation of licence scope, set by whether an aircraft was flown under VFR or instrument flight rules (IFR), was removed with the introduction of CASR 66. Competence was the key; ie an aircraft mechanic carrying out a task on an aircraft being flown VFR was equally competent to carry out the same task on an aircraft that was to be flown IFR.
Given that removal of distinction between IFR and VFR licence scope and given that CASA had undertaken to provide a conversion of existing (old) privileges to the new licences under CASR 66, current competence was taken to be synonymous with current privilege at the time of conversion.
That said, the exercise of Avionic Line Replaceable Unit (LRU) privilege by these B1 personnel is not unbounded.
The CASR 66 Manual of Standards (MOS) states what an avionic LRU is:
…avionic LRU, or avionic line replaceable unit, is an aircraft avionic part that satisfies all of the following requirements:
- it must have no mechanical input from, or output to, another part or mechanism;
- it must contain only electrical, electronic, instrument or radio parts, or software, or a combination of any such part or parts and software, designed to provide control, monitor or display functions, or a combination of such functions;
- it must not require any of the following in order to be installed, secured or connected to the aircraft:
i. specialist knowledge or techniques;
ii. specialised equipment;
iii. rigging, or functional testing or adjustment, using specialised equipment external to the aircraft or brought on board the aircraft, to ensure that it is functioning properly.
And then, at 66.A.20, limits the B1 licence scope in relation to that avionic LRU to be: 4. Subject to Table 1 and paragraph 66.A.45 (b), a person who holds a Category B1 licence endorsed with a subcategory may perform maintenance certification for that subcategory maintenance if: (ii) the maintenance was any of the following: (B) unless the licence is specifically subject to an avionics LRU exclusion, replacement of an avionic line replaceable unit that requires only simple tests (italics added) to prove its serviceability.
The CASR 66 MOS also specifies what a simple test is:
…simple test means a test described in maintenance data that meets all of the following criteria:
1. the serviceability of the system can be verified using aircraft controls, switches, built-in test equipment (BITE), central maintenance computer (CMC) or external test equipment not involving special training;
2. the outcome of the test is a unique go/no-go indication or parameter. No interpretation of the test result or interdependence of different values is allowed.
Given the minimal competence required to change a ‘black box’; the strong and descriptive requirements for the avionic LRU change to be accompanied by a ‘simple test’ and the fact that a need for specialist knowledge, equipment or rigging specifically precludes the avionic LRU replacement by other than a B2 licence holder, CASA does not consider the matter to be a valid safety concern.