Contract certifying staff, recent experience and an invalid authorisation
A Part-145 organisation holds a line-maintenance approval for the A320 family at a station where three certifying staff are authorised. One is on sick leave and another's authorisation was suspended pending a human-factors refresher. A contractor is provided by another Part-145 organisation for two weeks. The contractor holds a B1.1 licence with A320 type endorsement and has worked on A320s for 14 months in total, but his last A320 task was 22 months ago; since then he has worked on A330s. The host organisation's MOE requires certifying staff to have six months of relevant experience on the type in the previous 24 months and to complete the organisation's human-factors and fuel-tank-safety training before authorisation. The contractor's own organisation says he is 'current and authorised' and proposes that he sign CRSs under his own organisation's approval while working at the host station.
1. Can the contractor sign CRSs at the host station under his own organisation's Part-145 approval? Explain.
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No. The CRS is issued under the approval of the Part-145 organisation whose work is being certified. A certifying staff authorisation from another Part-145 does not transfer with the person. The host organisation must accept the contractor into its quality system, verify the licence, type endorsement, recent experience and required training, and issue its own written authorisation before the contractor signs anything. The contract between the two organisations can define responsibilities, but it cannot make the contractor's own organisation's approval apply at the host station. Allowing him to work under the host approval without authorisation would be a finding.
2. Does the contractor meet the host organisation's recent-experience requirement for the A320? What should the organisation do before authorising him?
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The MOE requires six months of relevant experience on the type in the previous 24 months. He has 14 months on A320 in total, but his last A320 task was 22 months ago and his recent work was on A330, which is not relevant to the A320 type. Whether he satisfies the 'six months in the last 24 months' test depends on when those 14 months fell: if at least six months fall inside the 24-month window, he meets the letter of the MOE; if not, he does not. Even if he meets it, 22 months without A320 work is a competence risk. The organisation should require a type refresher or supervised OJT before authorisation and must not rely on his own organisation's statement.
3. The contractor signs a CRS after only a one-hour briefing, and an audit later finds that the required human-factors training was never completed. What are the consequences and who is responsible?
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The authorisation was granted without the training required by the MOE, so it was not valid under the organisation's procedures. The CRS is not automatically void by law, but the organisation must treat the matter as a serious finding: quarantine the records, review the task and any aircraft released, assess whether the work was correct, and re-certify if necessary. The organisation should suspend the contractor's authorisation, notify the competent authority as required by its MOE, and take corrective action on its authorisation process. Responsibility for the CRS rests with the host Part-145 organisation, not with the contractor's own employer.