Supervision cannot create a licence

No. Supervision is a training and oversight tool; it does not confer licence privileges on the supervised person. The legal act of dispatch release must be performed by a person who holds the appropriate KCAA licence and a valid medical accepted under KCAA rules, and who is authorised by the operator.

• Signing alone: Hassan does not hold a KCAA licence, so she cannot sign.
• Co-signing: A second signature by a Kenyan dispatcher does not cure the defect if the Kenyan dispatcher did not actually perform the dispatch function. A rubber-stamp arrangement misrepresents who exercised operational control and creates a false record.
• Supervision: If the operations manual and the Authority permit supervised familiarisation, Hassan may observe and assist, but the release must be made by the licensed person who genuinely does the work. Her role and the supervisor's role must be described accurately in the record.
• Medical: A foreign medical is not automatically accepted for exercising KCAA privileges; the applicable acceptance or validation rule must be confirmed.

The roster clerk's proposed solution does not solve the legal problem.

There are several lawful routes, but each has conditions:

1. Expedite verification. The operator can support KCAA's request by providing authenticated copies, employer letters, logbook extracts and contact details. Authority-to-Authority verification is often the bottleneck; a polite follow-up through KCAA may help.
2. Check for temporary validation. Some states issue a temporary validation or authorisation while conversion is processed. If KCAA's regulations provide for this, apply formally with medical, licence and experience evidence. Do not assume it exists.
3. Use her in a non-release role. She may assist with flight planning, weather analysis, NOTAM review and training material under the supervision of a licensed dispatcher, provided the operations manual and the Authority allow it and her work is not recorded as a release.
4. Roster licensed staff. Call in a current Kenyan dispatcher, delay the flight or reduce the schedule until coverage is lawful.
5. Plan for the longer term. Once converted, she may need differences or familiarisation training on the operator's routes and procedures, even with four years of experience elsewhere.

All decisions and Authority correspondence should be recorded.

The postholder should explain that dispatch release is a licensed safety function, not an administrative signature. The licence exists so that the State has verified the person's training, experience, medical fitness and continuing competence. Accepting an unverified foreign licence would bypass that assurance and would leave the operator unable to show that the person releasing the flight met KCAA requirements.

A practical framing:

• The risk is not theoretical. The dispatcher makes fuel, weather, NOTAM, MEL and alternate decisions that directly affect flight safety. An unverified licence is an unverified competence claim.
• The operator's manual and the AOC depend on licensed staff. Using an unlicensed person would be a non-compliance that could affect the AOC and insurance.
• The delay is the lawful cost of short staffing. The real failure was the roster and succession plan, not the refusal to cut corners.
• Corrective action: build a conversion pipeline, maintain a standby list, track licence expiries and verification requests, and train more dispatchers.

The answer should be documented and communicated to the accountable manager in writing, with the specific regulatory basis and the actions needed to prevent recurrence.