Avionics Licence Holder Asked to Certify a Flight Control Repair
A newly appointed shift supervisor in an AMO asks an AME who holds an NCAA avionics licence rating to sign off a repair on a flight control pushrod and the subsequent rigging check on a Piper PA-31. The airframe/engine licensed AME who normally certifies this work has called in sick, and the aircraft is promised to a customer in four hours. The avionics AME has 12 years of line experience, has previously assisted with pushrod replacement on the same type, and the approved maintenance manual procedure is available. The supervisor argues that the avionics AME is 'competent' and that the licence is just a formality. The avionics AME is also asked to certify the aircraft's maintenance release for the flight. The AMO's procedures require certification by a licence holder within the scope of the rating. The pushrod repair is not an avionics task.
1. Can the avionics AME certify the pushrod repair and rigging check? Explain the licensing principle.
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No. The avionics rating defines the scope of work the AME may certify. A flight control pushrod repair and rigging check are mechanical/airframe tasks, not avionics tasks. The AME's 12 years of experience and prior assistance may show competence, but competence does not expand the legal privilege granted by the licence. Certification is a regulatory act, not a formality.
The AMO's procedures also require certification within the scope of the rating. Signing the repair would misrepresent that the work was certified by a person authorized for that task. The correct course is to have the work certified by an appropriately rated airframe/engine AME, or to arrange a qualified person to supervise and certify. The avionics AME may assist with the task if authorized by the AMO, but must not sign the certification.
2. What options are available to the supervisor to avoid delaying the aircraft?
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The supervisor can call in another qualified airframe/engine AME, reassign the work to a qualified certifying staff member on another shift, or arrange for an approved contract certifying person. If the repair can be deferred safely under the operator's MEL or maintenance procedures, the flight might be dispatched with an appropriate deferral, but that decision must be made by authorized persons and must not be used to bypass the certification requirement.
Another option is to have the avionics AME perform the work under the supervision of a qualified airframe/engine AME, who then certifies it. The supervision must be real and documented, not a paperwork signature. If none of these options is available, the aircraft should be delayed. The supervisor should not pressure an avionics AME to certify outside the rating.
3. What should the avionics AME do if the supervisor insists on the signature?
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The AME should refuse clearly and in writing, citing the licence scope and the AMO's procedures. The refusal should be recorded in the work package or by email so there is a traceable record. The AME should offer the compliant alternatives and escalate the matter to the quality manager. If the pressure continues, the AME should use the organization's safety reporting system and, if necessary, report the matter to the authority.
Signing outside the licence scope could expose the AME to licensing action and could compromise the aircraft's airworthiness. The maintenance release must also be signed by a person authorized for the aircraft and the work performed. The AME should not sign the release if the aircraft's maintenance status cannot be properly certified.