Aircraft Certifying and Support Staff not qualified to Part-66
This guidance is provided for organisations with facilities located outside the UK that utilise the provision 145.A.30(j)(1) and (2). Such organisations must ensure that aircraft certifying staff and support staff not qualified in accordance with UK Part 66 are compliant with the following UK Part-145, Appendix IV requirements.
Appendix IV paragraph 1(a)
“(1)(a) The person shall hold a valid national licence, or a Certifying Staff authorisation issued under the national regulations in full compliance with ICAO Annex I.”
The basic national licence must have been evaluated in all categories by the Part-145 AMO and any differences to ICAO Annex I must be addressed. Refer to Checklist 5 in Section 3 of Part 145 Maintenance Organisation Exposition Guidance (CAP 2375).
Depending on the organisation’s location, the national licence to be considered is summarised in the table titled “Summary of topics to be assessed for aircraft certifying staff and support staff not qualified to Part-66”. Refer to Checklist 2 in Section 3 of Part 145 Maintenance Organisation Exposition Guidance (CAP 2375).
Appendix IV paragraph 1(b)
“(1)(b) The scope of work of the person shall not exceed the scope of work defined in the national licence or the certifying staff authorisation, whichever is the most restrictive.”
The proposed authorisation privileges must have been evaluated to ensure they do not exceed the scope of the national licence. The organisation shall compare the scope of the national licence and the scope of work of the UK Part 66 C, B1, B2 and A categories and implement the necessary limitation. The result of the comparison shall be summarised in the organisation’s MOE Section 1.6.
Any limitation addressed in the national licence or in the aircraft certifying staff and support staff authorisation issued under the national regulations must be specified in the UK Part 145 certifying staff or support staff authorisation.
The organisation can also endorse an aircraft type in the Part 145 certifying staff or support staff authorisation which is not endorsed on the national licence provided all other requirements in Appendix IV are satisfied.
In the case of national regulations using the same certifying staff or support staff codes (A, B1, B2 and C) as UK Part 66, this condition does not relieve the organisation from comparing the scope of the national licence and the scope of work of the UK Part 66 C, B1, B2 and A categories and implement the necessary limitation.
Appendix IV paragraph 1(c)
The aircraft certifying staff and support staff must be able to demonstrate they received the following:
Training on human factors referred to in module 9 of Appendix I to UK Part 66. The organisation must ensure they are able to demonstrate that the human factor training syllabus and the training level are compliant to the syllabus and the level (B1 or B2) of training of Appendix I to UK Part 66. The demonstration process is left to the discretion of the organisation.
Training on UK aviation legislation as referred to in module 10 of Appendix I to UK Part 66. The organisation must ensure they are able to demonstrate that the UK aviation legislation training syllabus and the training level are compliant to the syllabus and the level (B1 or B2) of training in Appendix I to UK Part 66. The demonstration process is left to the discretion of the organisation.
A proposed aircraft certifying staff or support staff is considered compliant with Appendix IV, paragraph (1)(c) without further need of investigation, if one of the following conditions is satisfied:
Examination Certificate of Recognition (CoR) (CAA Form 148) issued by a UK CAA approved Part 147 MTO for the relevant module 9 or 10 is provided.
Or when only a statement issued by a UK CAA approved Part 147 MTO can be provided, stating that the person has attended the relevant module 9 or 10 according to the corresponding UK Part 66 syllabus, then the maintenance organisations must additionally ensure that the course is carried out according to a detailed syllabus including level of training as per UK Part 66 module 9 and/or 10, as applicable. The duration of the course must be specified to demonstrate the adequacy to cover all subjects.
When selecting a non-UK Part 147 approved MTO to provide the human factor training and/or UK aviation legislation training, the UK CAA approved Part-145 organisation’s compliance monitoring department must be able to demonstrate, as a minimum, that:
- The course is conducted according to a detailed syllabus including level of training as per UK Part 66 module 9 and/or 10, as applicable. The duration of the course must be specified to demonstrate the adequacy to cover all subjects.
- The qualification criteria for instructors are defined.
- A maximum number of training hours per day is defined (Human Factor principals to be considered).
- A maximum of trainees per group is 28 persons.
Appendix IV paragraph 1(d)
The aircraft certifying staff and support staff must be able to demonstrate:
- 3 years of maintenance experience for line maintenance certifying staff in category A.
- 5 years of maintenance experience for line maintenance certifying staff or base maintenance support staff in category B1, B2.
- 8 years for base maintenance certifying staff in category C.
In addition, the organisation must ensure that the aircraft certifying staff and support staff can demonstrate recent experience. The recent maintenance experience shall be understood as meeting the requirement of 6 months of experience in two-year period preceding the intended date of issue of the authorisation (refer to 145.A.35(c) for further details). This concept is the same for the renewal of the authorisation as described in the following chapter related to “additional training” requirements.
Further information is provided in Part 145 - 6/24-month Recency Guidance (CAP2377) to all UK CAA Part 145 approved organisations on how to achieve the 6/24-month requirement as per 145.A.35(c).
Appendix IV paragraph 1(e) and (f)
Aircraft type training for category B1, B2 certifying staff, support staff and category C certifying staff.
The aircraft certifying staff and support staff must be able to demonstrate that they received the type training and passed the examination at the relevant category level (depending on the category of authorisation), referred to in Appendix III to UK Part 66 for each aircraft type intended to be endorsed in the UK Part 145 certifying staff or support staff authorisation.
In the case of category C certifying staff, for the first aircraft type to be endorsed in the Part 145 certifying staff authorisation, the type training and examination shall be at the category B1, B2 level.
An aircraft type training consists of two parts:
- Theoretical element: composed by theoretical training and examination.
- Practical element: composed by practical training and assessment (this point is not applicable to level 1 type training, for example, category C certifying staff who has already one aircraft type in their authorisation).
Type training for differences.
In order to meet the requirement of Appendix IV paragraph (1)(e) and (f), a person may also be qualified through a type training for differences, including both the theoretical and practical element, which has been received by a UK CAA approved Part 147 MTO. The following requirements must be met:
The applicant for Part 145 certifying staff or support staff authorisation, must cover the differences between two different aircraft type ratings of the same manufacturer as determined by the UK CAA (refer to the aircraft type ratings provided in Appendix I to AMC to UK Part 66, as amended); For example, a person who already completed a type training on the A320(CFM 56) and requires to be also qualified on the A320(V2500), does not need to complete a full aircraft type training on the A320(V2500), but may only complete a type training for differences between the two aircraft type ratings (e.g. engine plus aircraft interfaces);
Differences training must cover both theoretical and practical elements of type rating training.
A type rating must only be endorsed on Part 145 certifying staff or support staff authorisation after differences training when the applicant also complies with one of the following conditions:
- Having been already endorsed on the Part 145 certifying staff or support staff authorisation the aircraft type rating from which the differences are being identified.
or
- Having completed the type training requirements for the aircraft from which the differences have been identified but not yet endorsed in the Part145 certifying staff or support staff authorisation.
Tasks training for category A certifying staff.
The person whose scope of work does not exceed those of a category A, certifying staff may receive task training in lieu of a complete type training.
Task training must be conducted by a UK Civil Aviation Authority (CAA) approved Part 147 MTO or a UK CAA approved Part 145 AMO appropriately approved on the specific aircraft type for which the Part 145 certifying staff authorisation is to be issued.
This training must include practical hands-on training and theoretical training for each task authorised. Satisfactory completion of the task training must be demonstrated by an examination or by workplace assessment conducted by the UK CAA approved Part 147 MTO or Part 145 AMO which has delivered the training.
It is the responsibility of the maintenance organisations issuing the Category A Part 145 certifying staff authorisation to ensure that the task training covers all the tasks to be authorised. This is particularly important in those cases where the task training has been provided by an organisation (the UK CAA approved Part- 147 MTO or Part 145 AMO) different from the one issuing the authorisation.
When the maintenance organisation intends to issue the Category A Part 145 certifying staff authorisation based upon a complete type training delivered by a UK CAA approved Part 147 MTO, a demonstration must be performed and documented that the type training (theoretical and practical element) covers the tasks to be authorised.
Appendix IV paragraph 2(a) – Protected Rights
“(2)(a) The personnel having privileges before the entry into force of the relevant requirements of Annex III (Part-66) may continue to exercise them without the need to comply with points 1(c) to 1(f)”.
It is recognised that prior to EU Exit the UK were a member state of EASA. As of the effective date of 1 January 2021 (EU Exit), any authorisation (privileges) previously issued to a certifying staff and valid at the time of the EU Exit, continues to be valid, if renewed and unchanged, unless cancelled, varied or revoked.
Appendix IV paragraph 2(b) – Protected Rights
“(2)(b) However, after that date (defined in para 2(a)), any certifying staff willing to extend the scope of their authorisation to include an additional privilege shall comply with point 1”.
After the effective date of 1 January 2021, if the certifying staff is extending their authorisation based on UK Part 145 to add a new type rating, they will require a type training course carried out by a UK Part 147 approved MTO or by a UK Part 145 approved AMO delivering the type training course approved directly by the UK CAA. If the scope of work does not exceed that of a category A certifying staff, then this can be achieved with task training in lieu of complete type training.
Appendix IV paragraph 2(c) – Protected Rights
“(2)(c) Notwithstanding point 2(b) above, in the case of any additional type training, compliance with points 1(c) and 1(d) is not required”.
Should the certifying staff holding an authorisation recognised under the protected rights require training for additional types, then compliance with respect to paragraphs 1(c) and 1(d) is not required.
Examples – Protected Rights
Protected Rights - Example 1:
A UK approved Part 145 organisation utilising Appendix IV certifying staff for locations outside the UK prior to 1 January 2021 that had applied and was issued with a UK Part 145 approval via the saving legislation.
In this case, the scope of authorisation that is issued based on the national licence of that state, is deemed to be covered by protected rights whilst remaining current, valid and unchanged. If the authorisation were to be renewed with changes, cancelled, varied or revoked, the authorisation holder must demonstrate compliance with UK Part 66 and UK Part 147 for any authorisations held or re-instated as it is no longer covered by protected rights.
Protected Rights - Example 2:
An overseas organisation applies, after 1 January 2021, for a UK Part 145 approval.
This application is treated in the same manner as any initial UK Part 145 application. The supporting certifying staff authorisation (and any ratings held) are subject to compliance with Appendix IV to 145.A.30(j)(1) and (2) paragraphs (1)(a) to (1)(f). An initial application does not benefit from protected rights as per paragraphs (2)(a) to (2)(c).