A Kenyan ATR in an Alpine Hangar
Alpine Technik is an EASA Part-145 organisation approved for base maintenance of the A320 family and ATR 42/72. A Kenyan operator contracts a 4C-check on its ATR 72-500, registered 5Y-XXX and operating under a Kenyan AOC, with a valid Kenyan certificate of airworthiness and a maintenance programme approved by the Kenya Civil Aviation Authority. KCAA has issued Alpine Technik no repair station certificate and has notified no particular requirement. The operator asks for 'an EASA Form 1 for the aircraft so our authority accepts the release'. The operator also wants to use its own engineer, who holds a Kenyan licence but no Part-66 licence and no Alpine Technik authorisation, to certify part of the work because he knows the aircraft best.
1. What release document should Alpine Technik issue at the end of the check, and what must be established before signing anything?
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The release must be in a form the State of Registry will accept - that is the starting point, not the EASA Form 1.
- For an aircraft registered in a third country, the Part-145 CRS is issued in accordance with the requirements of that third country where those requirements have been notified to the organisation (Part-145 145.A.75(b)). Alpine Technik must therefore obtain from the operator, in writing, exactly what KCAA requires for the return to service - a Kenyan release form, a statement acceptable under the operator's approved arrangements, or an EASA Form 1 accepted by KCAA by policy. Assuming an EASA Form 1 is what is wanted is precisely the sort of assumption that leaves an aircraft grounded at the destination.
- Approval position: confirm whether KCAA requires the organisation to hold a Kenyan approval for maintenance on 5Y-registered aircraft. If it does, that approval must be in place before the check, not applied for afterwards.
- Scope and data: the work must be within Alpine Technik's Part-145 approval and capability, accomplished to the operator's approved maintenance programme and approved data, with all ADs, SBs and the operator's CAMO requirements identified and actioned.
- Records: a full dual record - the EASA release for its own approval, plus the document the State of Registry requires - with the statement of work, findings and any deviations agreed with the CAMO in advance.
2. The operator's Kenyan-licensed engineer wants to certify part of the work. What can he actually do, and what would have to change for him to certify?
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He can work, but he cannot certify under Alpine Technik's approval.
- Certification privileges in a Part-145 organisation come from a certification authorisation issued under the MOE to staff who meet 145.A.30(g)/(h) - in practice a Part-66 licence (or a licence accepted by the competent authority) with the relevant type rating, recent experience and training. A Kenyan licence alone confers no Part-66 privileges in the EU.
- He may be used as support staff, working under the supervision of an authorised certifier, in accordance with the MOE's provisions for unlicensed/support staff and the organisation's competence records. His type knowledge is an asset; it is not a privilege.
- To certify he would need: recognition of his licence by the competent authority if that route exists, or completion of the Part-66 requirements and the ATR type rating; then the organisation's own authorisation, competence assessment, human-factors/continuation training, and a scope defined in the MOE.
Alpine Technik should record the arrangement in the work order so that nobody assumes the operator's engineer has signed anything on its behalf, and should brief the operator's CAMO accordingly before work starts.