Part 145 Appendix IV Certifying Staff and Support Staff not qualified to Part 66

“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 licence (national licence) must have been evaluated in all categories by the Part-145 organisation and in particular any differences compared to ICAO Annex I must be addressed (refer to checklist 5 in section 7 of ).

The national licence to be considered depending on the organisation location is summarised in the table “Summary of topics to be assessed for aircraft C/S & S/S not qualified to Part-66” (see checklist 2 in Section 7 of the CAP2375).

 

 

 

“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 Part 66 “C”, “B1”, “B2” and “A” categories and implement the necessary limitation. The result of the comparison shall be summarised in the MOE Section 1.6.

Any limitation addressed in the national licence or in the A/C C/S and S/S authorisation issued under the national regulations shall be specified in the Part 145 C/S or S/S individual authorisation.

The organisation can also endorse an A/C type in the Part 145 C/S or S/S individual authorisation that is not endorsed on the national licence provided compliance is met with the other Appendix IV requirements.

In the case of national regulations using the same C/S or S/S codes (A, B1, B2 and C) of Part 66, this condition does not release the organisation from comparing the scope of the national licence and the scope of work of the Part 66 “C”, “B1”, “B2” and “A” categories and implement the necessary limitation.

 

 

The A/C C/S and S/S must be able to demonstrate they received:

• Training on human factors referred to in module 9 of Appendix I to Annex III (Part-66). The organisation must ensure they are in a position to demonstrate that the human factor training syllabus and the training level are compliant to the syllabus and the level (B1/B2) of training of Appendix I to Annex III (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 Annex III (Part-66): The organisation must ensure they are in a position to demonstrate that the UK aviation legislation training syllabus and the training level are compliant to the syllabus and the level (B1/B2) of training of Appendix I to Annex III (Part-66). The demonstration process is left to the discretion of the organisation.

A proposed A/C C/S or S/S is considered compliant with Appendix IV, paragraph 1(c) without further need of investigation, if one of the following evidences is available:

• Examination certificate of recognition (CoR) (CAA Form 148) issued by a UK CAA approved Part-147 Aircraft Maintenance Training Organisation (AMTO) for the relevant module 9 or 10; or
• When only a statement issued by a UK CAA approved Part-147 AMTO can be provided, stating that the person has attended the relevant module 9 or 10 according to the corresponding Part-66 syllabus, then the maintenance organisations must also ensure that the course is carried out according to a detailed syllabus including level of training as per Part-66 Module 9 and/or 10 as applicable (the duration of the course need to be specified to demonstrate the adequacy to cover all subjects).

When selecting a non-UK Part-147 organisation to provide the human factor training and/or UK aviation legislation, the UK CAA approved Part-145 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 Part 66 Module 9 and/or 10 as applicable (the duration of the course needs to 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 (HF principal to be considered).
• A maximum of trainees per group of trainees (28 persons)

The A/C C/S and S/S 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 A/C C/S and S/S can demonstrate recent experience. The recent maintenance experience shall be understood as meeting the requirement of 6 month of experience in two-year period preceding the intended date of issuance of the individual authorisation (refer to 145.A.35(c) for further details). This concept is the same applicable for the renewal of the authorisation as described in the following chapter related to “additional training” requirements.

 

Further information is provided in CAP2377 Guidance to all UK CAA Part 145 organisations on how to achieve the 6/24-month requirement as per 145.A.35(c)’.

 

A/C type training for category B1, B2 C/S, S/S and category C C/S

The A/C C/S and S/S 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 Annex III (Part-66) for each aircraft type intended to be endorsed in the Part-145 C/S or S/S individual authorisation.

In the case of category C C/S, for the first aircraft type to be endorsed in the Part-145 C/S - S/S individual authorisation, the type training and examination shall be at the category B1, B2 level.

An A/C type training is made up of two parts:

• Theoretical element: composed by theoretical training and examination.
• Practical element: composed by practical training and assessment*.

the case of maintenance organisations for which the UK CAA is the competent authority, please refer to Engineer licensing requirements after 1 January 2023 | Civil Aviation Authority (caa.co.uk).

* This point is not applicable to level 1 type training (e.g., category “C” Certifying Staff who has already one A/C 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 by a type training for differences (including both the theoretical and practical element) which has been received by a UK CAA approved Part-147 organisation. The following requirements need to be met:

• The applicant for Part-145 C/S or S/S individual authorisation, needs to 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 Part 66, as amended); For example, a person who already completed a type training on the A320(CFM 56) and needs to be qualified also 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 shall cover both theoretical and practical elements of type rating training.

A type rating must only be endorsed on Part-145 C/S or S/S individual authorisation after differences training when the applicant also complies with one of the following conditions:

• Having been already endorsed on the Part-145 C/S or S/S individual 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 are being identified but has not yet been endorsed in the Part-145 C/S or S/S individual authorisation.

 

Tasks training for category A C/S 

The persons 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 CAA approved Part-147 AMTO or a UK CAA approved Part-145 AMO appropriately approved on the specific aircraft type for which the Part-145 C/S individual 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 AMTO or Part-145 AMO which has delivered the training.

It is the responsibility of the maintenance organisations issuing the Category “A” Part-145 C/S individual 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 AMTO or Part- 145 AMO) different from the one issuing the authorisation.

When the maintenance organisations intend to issue the Category “A” Part-145 C/S individual authorisation based upon a complete type training delivered by a UK CAA approved Part-147 AMTO, a demonstration must be performed and documented that the type training (theoretical and practical elements) covers the tasks to be authorised.

 

 

The UK CAA approved Part-145 organisation needs to consider that:

 

• Type training may have covered certain, but not all the models/variants included in a type rating (e.g., A type training on Boeing 747-200/300 (GE CF6) which did not cover the Freighter model).
• Some systems and technology present in the particular aircraft being maintained may not have been covered by the training/examination/experience (e.g. work being carried out on a model/variant for which the technical design and maintenance techniques have significantly evolved from the original model used in the type training; or specific technology and options selected by each customer which may not have been covered by the type training).

 

As a consequence, the maintenance organisations must ensure that A/C C/S and S/S have received additional training, as appropriate, on the differences for the particular model/variant and/or the particular configuration of the aircraft intended to be maintained by the maintenance organisations. This additional training may take various forms depending on the complexity of the differences to be covered (e.g., read and sign document, on the job training, classroom training, etc.).

 

Note: the additional aircraft training described in this chapter must not be confused with the case where the differences that need to be covered are related to different Part-66 aircraft type ratings. In such case the chapter on ‘Type training differences’ in this guidance applies. Such cases also involve necessarily an extension of the Part-145 C/S or S/S individual authorisation following an assessment by the maintenance organisations, and in the case of Part-66 licence holders, the type endorsement on the licence remains as a pre-requisite.

The C/S and S/S must receive recurrent / continuation training that covers up-to-date information on relevant technologies, Human Factors, FTS, EWIS, organisation procedures (including changes in aviation legislations), as applicable to the organisation scope of approval and individual authorisation held.

The C/S and S/S must demonstrate a 6 month of experience during the two-year period preceding the renewal of the Part-145 C/S or S/S individual authorisation.

The 6 months maintenance experience in 2 years must be understood as consisting of two elements; duration and nature of the experience.

Further information on recent experience requirements is provided in CAP2377 Guidance to all UK CAA Part 145 organisations on how to achieve the 6/24-month requirement as per 145.A.35(c)’.

 

The aim of the assessment is to ensure compliance of the A/C C/S and S/S with the relevant Part-145 requirements, with the criteria defined in this guidance and to ensure that each A/C C/S and S/S possesses the expected competence(s) associated to their job function (proposed scope of work, authorisation category), before granting then an initial Part-145 C/S - S/S individual authorisation, to renew or to extend the scope of their already existing authorisation. This assessment must also take into consideration attitude and behaviour.

As a consequence, the organisation must demonstrate through a competence assessment that the C/S and S/S:

Meets the qualification criteria addressed above.

• Has the relevant knowledge, skills and ability to perform the maintenance tasks related to their job function including the relevant language knowledge.
• Is able to determine when the A/C is ready to release to service and when it shall not be released to service.

In the case of initial authorisation or extension of the scope of an already existing authorisation, the competence assessment must:

• Be specifically tailored to the aircraft type(s) intended to be covered by the Certifying Staff authorisation.
• The competence assessment must include evaluation of “On the Job Performance” and /or “testing of knowledge” by appropriately qualified personnel.

In addition, it is recommended that the assessment form contains an open text field where the person responsible for the assessment records the questions raised, comments or any other information useful to support the recommendation for the pass/fail result. A “box-ticking” exercise would be pointless.