The Saturday Charter and a Type Rating That Is Not on the Licence
5Y-BKT, a Beech B200 King Air operated by a Nairobi charter company, is scheduled to leave Wilson Airport at 06:00 on a Saturday with eight passengers. On Friday evening the right engine (PT6A-42) developed a fuel nozzle leak; the on-call engineer replaced the nozzle, ran the engine and found the leak cured. He holds a KCAA AMEL, category B1.1, issued on 12 March 2019. His licence carries type ratings for the Cessna 208B (PT6A-114A) and the DHC-8-100 (PW120A). He has never attended a King Air type course. Three years ago his employer ran a three-day in-house 'King Air differences' course with no examination, and since then he has performed King Air tasks under supervision. The AMO's approval covers the B200 and its capability list includes King Air fuel systems. At 22:40 he asks the duty manager whether he can sign the certificate of release to service so that the charter is not cancelled.
1. Can this engineer lawfully sign the certificate of release to service for 5Y-BKT? Work through the licence category, the type rating and the organisation approval separately.
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Step 1 - what the category allows. A B1.1 licence gives mechanical, airframe and engine privileges, so replacing an engine fuel nozzle is within the category. Category alone is never a permission to certify any aeroplane.
Step 2 - what the type rating allows. The type ratings endorsed on a licence are the only aircraft on which the holder may exercise certification privileges. The B200 is not endorsed. A three-day in-house differences course with no examination is not a type course and cannot create an endorsement; supervision builds experience but does not widen a licence.
Step 3 - what the AMO approval does. The approval belongs to the organisation and defines what work it may perform and release. It does not extend any individual's licence privileges. That the capability list covers King Air fuel systems is therefore irrelevant to his signature.
Conclusion. He must not sign. Doing so would be a certification of airworthiness made by a person without the privileges to make it, exposing the engineer, the AMO and the operator to enforcement action. He may perform the task under the supervision of an appropriately type-rated person, and that person certifies.
2. The duty manager proposes that the engineer sign anyway and that the 'paperwork be sorted out on Monday'. Identify the pressures at work and set out the compliant options for protecting the 06:00 departure.
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Pressures. A firm departure time, eight fare-paying passengers, a single engineer on call at night, and a signature that looks routine. The proposal to regularise later is the classic trap: a certificate signed before the certifying person holds the privileges is false when made, and no later endorsement cures it.
Options, in order of preference. First, locate another B1.1 holder with a B200 rating - within the AMO's own staff, through the operator's contracted maintenance provider, or through a KCAA-licensed engineer available at Wilson. Second, if the aircraft can wait, delay the departure until such a person is available. Third, the unrated engineer may still do the work under supervision so that only the certification waits.
What must be avoided. Backdating, signing 'for the AMO', or treating the duty manager's authority as a substitute for licence privileges. Authority in a company is not a licence privilege.
Record. The refusal and the reason should be noted on the work order so that the decision is visible at audit and so the same pressure is not reapplied on the next night shift.
3. Suppose the task had instead been replacement of faulty fuel-quantity indicator wiring, and the engineer argued that avionics work is not restricted by type ratings because the avionics syllabus is generic. Assess that argument.
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The argument fails on two independent grounds.
He is not a B2 holder. On a B1.1 licence the avionics privileges are limited; a B1.1 engineer cannot certify avionics work simply because the wiring looked simple. The category question must be settled before the aircraft question even arises.
Even a B2 holder is bound by type ratings. The two dimensions work together: the licence category fixes the systems and the depth of work a person may certify, and the type rating fixes the aircraft on which those privileges may be exercised. A generic syllabus argument confuses training content with licensing scope; it is the endorsement on the licence, not the breadth of the course, that governs.
Practical consequence. For this aircraft, avionics certification requires a B2 (or appropriately privileged B1, where the scheme allows simple tasks) holding the B200 rating. The engineer may assist, and may certify only what his own category and ratings permit.
Record. Note the category and rating assessment on the work order.