Licence, Type Rating and Company Authorisation Are Not the Same
Lim holds a CAAM Part 66 B1.1 AML with type endorsements for the Airbus A320 and Boeing 737-800. His employer, a Part 145 AMO, has authorised him for A320 line maintenance only; its B737 authorisation requires current type training and six months of recent B737 experience, which Lim does not have. For the past 21 months Lim has worked in the AMO's technical records office and has performed no hands-on maintenance. Tonight the A320 fleet is covered, but a B737-800 requires a main wheel change and a CRS before a 23:30 departure. The operations manager tells Lim: 'Your licence covers the B737, and the company authorisation is just internal paperwork. Sign it and we will sort out the paperwork later.' A licensed B737 engineer is available by phone but is 90 minutes away. The aircraft has 140 passengers booked and the crew is on duty.
1. Can Lim issue the CRS for the B737-800 wheel change? Identify every barrier.
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No. There are at least three barriers. First, the AML is a licence, not an authorisation: under MCAR Part 145 the AMO must authorise certifying staff for specific types and tasks, and Lim's authorisation is A320 only. Second, Part 66 requires recent maintenance experience: typically six months of maintenance experience in the previous 24 months, and Lim has 21 months in technical records with no hands-on work. Third, the AMO's own B737 authorisation criteria require current type training and recent B737 experience, which Lim lacks. The operations manager's claim that the authorisation is 'internal paperwork' is wrong: the authorisation is the mechanism by which the AMO controls certification and demonstrates competence to CAAM. Signing would be a false certification and a breach of both the licence privileges and the AMO's procedures. The licence does not override the authorisation, and the authorisation does not override recency.
2. What should Lim do, and what should the AMO do to manage the departure?
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Lim should decline clearly, explain the specific barriers, and escalate to the quality manager or accountable manager. He should not sign under pressure, and he should not perform the task and ask someone else to sign without that person being satisfied with the work and records. The AMO should use an authorised B737 certifying engineer. The engineer 90 minutes away may still be viable if the wheel change can be completed, inspected, and certified before departure; the AMO should not depart without a valid CRS. If no authorised person can attend, the flight should be delayed or cancelled. The AMO should also review why a B737 task was allocated to an A320-authorised engineer and correct its rostering and authorisation matrix. A one-off authorisation cannot be created by the operations manager; it would need the AMO's documented process and, where required, CAAM acceptance.
3. If Lim had been authorised for the B737 but had not worked on aircraft for 21 months, would that change anything?
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The authorisation would remove one barrier but not the recency barrier. A valid company authorisation does not cure a failure to meet the Part 66 recent-experience requirement or the AMO's competence requirements. The AMO could not rely on an authorisation that was issued without current evidence; that would be a quality-system weakness. Lim would need to regain recent experience under supervision or through an approved programme, and the AMO would need to assess him before restoring certification privileges. The same principle applies to the A320: if he has not maintained aircraft for 21 months, his A320 authorisation should be reviewed even though it is still printed on the matrix. The correct answer is not 'the authorisation says yes'; it is 'the authorisation must be supported by current competence and recency'.