Returning certifying engineer, an A321 and a family type rating
An EASA Part-145 line maintenance organisation at a regional airport employs Marek, who holds a valid Part-66 B1.1 licence with an Airbus A320 family type rating. For the past 16 months he has worked in technical records and planning and has signed no certificate of release to service; before that he spent eight months certifying line maintenance on the operator's A319 and A320 aircraft. On 3 March he returns to the line as a shift certifying engineer. The operator's fleet also includes A321s, on which Marek has never worked. The first aircraft on his shift is an A321 needing replacement of a flap track fairing and the associated flap rigging check, a combination the operator's maintenance programme lists as a critical maintenance task. The quality manager has not issued a certifying staff authorisation for the A321 in Marek's name, arguing that 'the type rating already covers the whole family and the licence is still valid'. Only one other licensed engineer is on the shift.
1. Can Marek lawfully certify maintenance on the A321 on 3 March? Separate the licence/recency question from the organisation's obligations.
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Licence and recency (Part-66 66.A.20). The B1.1 category covers turbine-engined aeroplanes, and the A320 family endorsement is the correct type rating for an A321, so the category and type questions are not the obstacle. The recency condition is that, within the preceding two years, the holder must have had at least six months of maintenance experience in accordance with the privileges of the licence. Marek's 16 months in records and planning are not certifying experience, but the eight months of line certification immediately before that fall inside the two-year window, so on the face of the records the recency condition is met - provided those eight months are properly documented and are not themselves older than two years at the date of certification.
Organisational conditions (Part-145 145.A.35). A licence confers nothing inside a Part-145 by itself. The organisation must authorise him as certifying staff, having ensured current knowledge of the aircraft type and of its own procedures, completion of the relevant training, and a formal assessment of competence. No such authorisation exists.
Conclusion: the licence and recency conditions are probably satisfied, but he may not certify the A321 until the Part-145 issues the authorisation and records the assessment. The quality manager's argument answers the wrong question - legality of the licence is not the same as authority to certify within this organisation.
2. The quality manager wants to rely on the family type rating and skip any A321 training. Explain what is required and why.
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A family endorsement in Part-66 Appendix I confirms that the holder has met the knowledge and experience standard for that type rating; it does not confirm familiarity with every variant listed against it. Variants within one type rating differ, and the expectation is that differences training is identified, delivered and recorded before a person works unsupervised on a variant they have not covered.
The A321 differs from the A319/A320 in fuselage length, systems layout and in some cases flight controls and avionics standard, so the organisation must:
- Determine from the TC holder's data and its own procedures which differences matter for the maintenance it performs;
- Deliver and record theoretical, and where relevant practical, differences training;
- Assess Marek on the A321 and on the operator's procedures;
- Amend his certifying staff authorisation to list the A321 and record the basis for it.
Using the family endorsement to skip this would be a finding: the licence states what the holder may do in principle, the Part-145 authorisation states what he may do here, and the two are not interchangeable. Note also that a first return to certification after 16 months off the floor is itself a competence risk the organisation must manage, not only a differences-training question.
3. How must the critical maintenance task be handled given the staffing on the shift?
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Because the operator's programme - and the organisation's MOE, which must list critical maintenance tasks and the associated procedure - designates the fairing replacement plus flap rigging as critical, an independent inspection is required on top of the normal sign-off. The inspector must be a second person who has not performed the task, must be competent and authorised for it, and must physically verify the completed work: torque values, rigging figures, lockwire and clearances before closure. The inspection must be separately signed and recorded; a single signature covering both doing and checking defeats the purpose.
With only two licensed engineers on shift, the organisation must make the second engineer available for the inspection (accepting that other work slips), call in another authorised person, or leave the task incomplete. It must not release the task on one signature. The certificate of release to service may be issued only once the independent inspection is complete, rigging results are within limits, and any required functional test has been carried out and recorded.
Shift handover must not be used to obtain a signature from someone who did not see the work. The event should also be considered under the organisation's human-factors and error-capturing procedures, since the staffing assumption that produced the situation is a systemic issue, not an individual one.