Back on the Line after Nineteen Months
EuroLine Maintenance holds a Part-145 line-maintenance approval for the A320 family at a regional airport. Marek holds a valid Part-66 B1.1 licence with an A320 type endorsement and a company certification authorisation that has never been withdrawn. For the past nineteen months he worked in the operator's CAMO as a maintenance planner: no hands-on tasks, no certification, no continuation training. Three weeks ago he returned to the line. On Tuesday the shift manager asks him to sign the CRS on OE-LXX, which has just had its left main wheel and brake assembly replaced by an unlicensed mechanic and a boroscope inspection of engine 1 carried out by a second mechanic. The aircraft departs at 06:00. During handover Marek notices that the torque wrench used on the wheel change carries a calibration label that expired five weeks ago.
1. Marek's licence and his company authorisation are both in date. Can he sign the CRS tonight? Set out what must be satisfied before the authorisation can actually be exercised.
Read the worked answer
No - an in-date licence and an in-date authorisation do not by themselves confer privileges.
- The Part-66 licence is only the qualification; the privileges come from the certification authorisation issued under the organisation's MOE, and that authorisation is conditional on the organisation being satisfied that the holder remains competent.
- Part-145 145.A.35(d) requires certifying staff to have, relevant to the task, either six months of maintenance experience in the preceding two years, or appropriate type training and examination completed within the preceding two years. Marek has roughly twenty months without relevant experience; three weeks on the line does not restore it.
- 145.A.35(e) requires the authorisation to be reviewed at least every two years. A twenty-month gap with no continuation training means the review cannot simply be a paper exercise.
Before any certification, the MOE competence route must be completed: gap analysis, refresher/human-factors and continuation training as required, a documented supervised period under a nominated eligible certifier, and formal re-issue or review of the authorisation signed by the responsible manager.
Tonight, the CRS must be issued by another authorised B1 certifier who has personally inspected the work. If none can attend, the aircraft does not depart - commercial pressure is not a factor in the decision.
2. The unlicensed mechanic asks whether a licensed person may certify work they did not perform, and whether Marek could in future certify work he carried out himself. Explain the principle and where the limits are.
Read the worked answer
The principle: certification is a statement that the work has been performed satisfactorily and to approved data - not a statement that the certifier physically did it. A certifying person may therefore release work carried out by other, appropriately trained staff, provided they have satisfied themselves that it is complete, correct and to approved data (Part-145 145.A.35 and 145.A.50, implemented through the MOE).
In practice this means Marek must: check the work order and the approved data used; physically inspect the installation (torque marks, lockwiring, clearances, part numbers/serial numbers against the documentation); confirm any functional test or operational check has been done; and confirm tooling and parts used were serviceable and traceable.
The limits:
- Where the maintenance programme, AMM or MOE calls for an independent or duplicate inspection (typically flight controls, engine controls, critical assemblies), the second inspection must be by a different qualified person - a self-certified duplicate inspection is worthless and is a breach.
- The MOE may prohibit self-certification of defined critical tasks; where it does, the certifier must not be the person who performed the task.
- Certifying your own work is not forbidden by Part-145 as such, but it is a judgement call controlled by the MOE, and no person may certify work they cannot demonstrate they are competent to assess.
3. It emerges the torque wrench used on the wheel change had been out of calibration for five weeks. What must the organisation do, and how does this affect the CRS?
Read the worked answer
The work done with that tool is of indeterminate quality and must be treated as suspect until proven otherwise. A calibration label is the evidence of traceability; once it is missing or expired, the torque values achieved cannot be demonstrated.
Actions:
- Quarantine the tool immediately and label it as unserviceable, to prevent further use.
- Trace all use since the expiry date from tool-issue records and work orders - this is rarely confined to one aircraft. Every affected fastener must be identified.
- Re-work/re-inspect the affected tasks to approved data (re-torque, re-check locking) and certify that action; the original work cannot be declared satisfactory.
- Review the release. If the CRS was already issued and the aircraft has flown, the organisation must determine whether the aircraft was airworthy at release. If there is any doubt, the operator/CAMO must be informed without delay so that the aircraft is checked before further flight.
- Occurrence reporting and investigation under 145.A.60 and the national occurrence-reporting framework if the event had or could have had an airworthiness effect; root-cause analysis of the tool-control system (Part-145 145.A.40 requires calibrated tooling and records), corrective action and audit.
A tooling non-conformance is never closed by the existence of a signature on a CRS - the signature only records what the certifier believed at the time.