Foreign Licence, Kenyan Aircraft
A Kenyan AOC is launching a new route in 12 days. It has hired a cabin crew member with six years' experience on the A320, a foreign cabin crew licence, A320 type training from the foreign operator, a valid aviation medical certificate, and a clean security clearance. She has never held a KCAA CMC. The operator's training manager proposes to roster her as a required cabin crew member on the first passenger flight because 'the aircraft and procedures are the same' and 'her foreign licence is ICAO-compliant.' The flight will carry 180 passengers and requires four cabin crew. The operator has an approved cabin crew training programme but has not yet scheduled her for its Kenyan differences course or its emergency procedures check. KCAA has not issued any validation or acceptance letter.
1. Can she act as a required cabin crew member on the first passenger flight? Explain why the foreign licence and ICAO compliance do not settle the question.
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No. A foreign cabin crew licence is evidence of foreign training and experience; it is not a KCAA CMC. To act as cabin crew on a Kenyan-registered aircraft operated by a Kenyan AOC, she needs a KCAA CMC or a valid KCAA validation or authorisation. No validation or acceptance letter has been issued. ICAO compliance is a baseline for international licensing systems, not automatic recognition by KCAA. The operator also has not completed its approved Kenyan differences course or emergency procedures check. Rostering her as one of the four required cabin crew would leave the flight without a properly licensed crew member. The fact that the A320 type and procedures are similar does not bridge the licensing gap.
2. What should the operator and the applicant complete before she can be rostered?
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Applicant: apply to KCAA for the CMC or validation; provide the foreign licence, training records, experience evidence, medical certificate, security clearance, and any required forms. If KCAA requires an assessment or conversion course, complete it. Operator: verify the foreign documents; enrol her in the approved cabin crew training programme, including Kenyan regulatory differences, operator procedures, type-specific emergency equipment and drills, dangerous goods, first aid, and crew resource management; conduct the emergency procedures check and line check required by its approved programme; keep records. KCAA: issue the CMC or validation before line duty. Until then she may attend training but not act as cabin crew.
3. Would it change if the flight were a ferry flight with no passengers and she was carried only as a supernumerary? Explain the distinction between being carried and acting as cabin crew.
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If no cabin crew are required and she is carried only as a supernumerary with no cabin crew duties, the CMC requirement for acting as cabin crew may not apply. But the operator must define her role in writing. If she is assigned any cabin crew duty, operates exits, gives safety briefings, or is counted in the complement, she is acting as cabin crew and needs the CMC or validation. The ferry label does not override the actual duties.