The Type-Rated Certifying Staff Sign-Off on an Aircraft Outside Rating Scope
A CAR-145 organisation holds ratings for the A320 family and the ATR 72. On a busy Friday a Boeing 737-800 operated by a foreign charter company arrives with an AOG hydraulic leak. The operator's own certifying staff are not present, and the flight is scheduled to depart in 20 hours. The maintenance manager assigns Ramesh, a B1.1 licence holder whose type rating covers the A320 family only, to supervise the repair. Ramesh has 14 years of line experience and previously worked on 737s at another organisation, though that rating is not on his current licence. The organisation's capability list does not yet include the 737. The customer is willing to sign a one-off authorisation letter. The repair involves replacing a hydraulic hose and performing a system leak check per the AMM.
1. Can the organisation legally issue a CRS for this 737 repair using Ramesh? Identify every regulatory barrier and state what must be true before any certification.
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No - not on the facts as stated. Three independent barriers exist:
- Organisation scope (CAR-145): The organisation may only certify maintenance on aircraft types listed in its approval/limitation schedule. A 737 is outside its ratings, so a CAR-145 CRS cannot be issued regardless of staff competence. A customer letter cannot extend a DGCA approval.
- Staff authorisation (CAR-66): Ramesh's licence carries A320 type ratings; a 737 is not on his licence. Prior experience and a one-off letter do not create a rating. Under CAR-66 (and CAR-145 145.A.35), certification privileges are limited to the types endorsed on the licence and the scope authorised by the organisation.
- Capability list: The organisation's capability list must reflect actual approved scope; adding a type requires approval action, not an internal memo.
Path forward: Either the operator brings its own properly rated/authorised certifying staff, or the work is subcontracted to a CAR-145 organisation rated for the 737, or the DGCA grants an appropriate approval extension (which will not happen in 20 hours). A permit-to-fly or one-off flight approval is a separate matter and does not authorise maintenance certification outside scope. Signing a CRS here would be a serious breach exposing both Ramesh and the organisation to enforcement action.
2. Suppose the DGCA later extends the organisation's rating to the 737 and Ramesh completes a type course and obtains the endorsement. What authorisation steps must the organisation still complete before Ramesh may certify?
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A licence endorsement alone is not sufficient. The organisation must:
- Verify the licence, type endorsement and recent experience against CAR-66 requirements.
- Assess Ramesh's competence on the specific task and type (practical assessment, familiarity with the organisation's procedures, GMM, MEL, technical records).
- Issue a formal certifying staff authorisation under CAR-145 145.A.35, specifying the scope (aircraft type, systems, base/line) and any limitations.
- Update the capability list and the organisation's exposition/manual as required.
- Maintain records of the authorisation, training and assessment.
Only after the authorisation is issued in writing does Ramesh hold certification privileges for the 737 within that organisation. The customer letter remains irrelevant to this process.