Recency, Category Limits and a Foreign Licence on a Saturday Night
Mr Adeyemi holds an NCAA AME licence with a B1 (mechanical) category rating and a Boeing 737-800/CFM56-7B type endorsement. For the last 26 months he has worked in the airline's technical records and training departments and has certified nothing; his operator type refresher was due 18 months ago and the airline's authorisation record for him has not been updated. On a Saturday night the airline is short-staffed. A 737-800 is due out at 05:40 after a main fuel pump replacement, an engine ground run and a VHF radio swap. The station manager asks Adeyemi to certify the fuel pump, the ground run and the radio. A newly recruited engineer with an EASA Part 66 B1.1 licence and no NCAA licence offers to 'co-sign the radio to keep it quick'. The AMO's exposition requires six months of certifying experience in the preceding 24 months and a current company authorisation before any certification.
1. Assess Adeyemi's position: can he certify the fuel pump replacement and the engine ground run tonight?
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Holding the licence is necessary but not sufficient. Three gates must all be open:
- Licence scope: a B1 category with the 737-800/CFM56-7B endorsement covers mechanical work on that type, so a main fuel pump replacement is within the category and type. An engine ground run is normally a separate company authorisation with its own training and assessment, even for a licensed engineer.
- Recency: the exposition requires six months of certifying experience in the preceding 24 months. He has 26 months without certification and has not completed the operator type refresher due 18 months ago. The recency gate is closed.
- Company authorisation: his authorisation record has lapsed and has not been updated. The third gate is also closed.
Therefore he cannot certify the fuel pump, and certainly not the ground run. The licence itself may remain valid, but exercising its privileges without meeting the recency and authorisation requirements is a breach of the Nig. CARs and of the approved exposition, and is exactly the kind of finding that leads to a suspension after an audit or an occurrence.
The practical answer for the station manager is that the aircraft waits, or another currently authorised certifying engineer is found. The pressure of a 05:40 departure does not reset the clock.
2. Can the EASA-licensed engineer certify the VHF radio, and could Adeyemi sign it off under his B1 rating?
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No on both counts.
The EASA Part 66 licence is a foreign personnel licence. Under the Chicago Convention framework, personnel licences are issued or validated by the State whose rules apply: Articles 32 and 33 deal with licences and the recognition of certificates. Nigeria may validate a foreign licence for a limited scope and period, subject to NCAA acceptance and any conversion requirements, but a foreign licence holder with no NCAA validation cannot exercise certifying privileges on a Nigerian-registered aircraft operating under a Nigerian AOC. Article 32(b) makes the point sharper if the engineer is a Nigerian national, since a State may refuse to recognise, for flight over its own territory, licences issued by another State to its own nationals.
On the second question: a B1 mechanical rating does not cover avionics replacement. In a category system of A, B1, B2 and C ratings, the VHF radio is B2 territory. Some approved organisations permit B1 staff to carry out defined simple avionics tasks after specific training and authorisation, but that must be written into the exposition and the individual's authorisation; it is not implied by the B1 licence. Adeyemi also fails recency and authorisation, so he cannot certify anything tonight.
The correct outcome is that a currently authorised B1 engineer signs the fuel pump and the ground run, and a B2 engineer signs the radio, each within their own scope.
3. Design the compliant route to get the aircraft out tonight and to restore Adeyemi's privileges over the following weeks.
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For tonight, the compliant route is a personnel one, not a paperwork one:
- Identify who on the roster holds a current NCAA licence, current company authorisation and the correct category and type for each task.
- Split the certification: B1 for the fuel pump and the ground run (with a ground-run authorisation), B2 for the VHF radio.
- If no B1 or B2 is available, the aircraft does not depart. A delay is cheaper than an invalid release.
To restore Adeyemi:
- Put him on a documented recency programme under the exposition: supervised maintenance work, a type refresher course and an assessment covering the CFM56-7B and 737-800 systems.
- Re-issue his company certifying authorisation with a defined scope and an expiry date, and record the evidence file.
- Notify the NCAA as the exposition requires, and keep the training records available for audit.
- Review why the authorisation record silently lapsed while he remained on the certifying roster: this is a quality-system finding, not just an individual one, and it should be raised as an internal occurrence so the roster control is fixed.