(a) In addition to the requirements of points 145.A.30(g) and (h), the organisation shall ensure that certifying staff and support staff have an adequate understanding of the relevant aircraft or components, or both, to be maintained and of the associated organisation procedures. In the case of certifying staff, this shall be accomplished before the issue or reissue of the certification authorisation.
1. ‘Support staff’ means those staff holding an aircraft maintenance licence under Annex III (Part-66) in category B1, B2, B2L, B3 and/or L with the appropriate aircraft ratings, working in a base maintenance environment while not necessarily holding certification privileges
2. ‘Relevant aircraft and/or components’, means those aircraft or components specified in the particular certification authorisation.
3. ‘Certification authorisation’ means the authorisation issued to certifying staff by the organisation and which specifies the fact that those staff may sign certificates of release to service within the limitations stated in such authorisation on behalf of the approved organisation.
AMC 145.A.35(a) Qualifications
1. Holding a Part-66 licence with the relevant type/group rating, or a national qualification in the case of components, does not mean by itself that the holder is qualified to be authorised as certifying staff and/or support staff. The organisation is responsible to assess the competence of the holder for the scope of maintenance to be authorised.
2. The sentence ’the organisation shall ensure that certifying staff and support staff have an adequate understanding of the relevant aircraft and/or components to be maintained together with the associated organisation procedures‘ means that the person has received training and has been successfully assessed on:
— the type of aircraft or component;
— the differences on:
— the particular model/variant;
— the particular configuration.
The organisation should specifically ensure that the individual competencies have been established with regard to:
— relevant knowledge, skills and experience in the product type and configuration to be maintained, taking into account the differences between the generic aircraft type rating training that the person received and the specific configuration of the aircraft to be maintained.
— appropriate attitude towards safety and observance of procedures.
— knowledge of the associated organisation and operator procedures (i.e. handling and identification of components, MEL use, Technical Log use, independent checks, etc.).
3. Some special maintenance tasks may require additional specific training and experience, including but not limited to:
— in-depth troubleshooting;
— very specific adjustment or test procedures;
— engine run-up, starting and operating the engines, checking engine performance characteristics, normal and emergency engine operation, associated safety precautions and procedures;
— extensive structural/system inspection and repair;
— other specialised maintenance required by the maintenance programme.
For engine run-up training, simulators and/or real aircraft should be used.
4. The satisfactory assessment of the competence should be conducted in accordance with a procedure approved by the competent authority (item 3.4 of the MOE, as described in AMC 145.A.70(a)).
5. The organisation should hold copies of all documents that attest the competence and recent experience for the period described in 145.A.35(j).
Additional information is provided in AMC 66.A.20(b)3.
In the case of base maintenance, what are the functions and responsibilities of “support staff”? The qualification criteria for certifying staff and support staff are identical as both: - must have a Part-66 licence with the corresponding type ratings; - must have the same recent experience and continuation training; - must have training in human factors and company procedures; and - are subject to the same competence assessment; The only difference is that in the base maintenance environment there is an additional function, the category C certifying staff. However, this function is more administrative due to the more complex environment. Regarding the level of involvement of the support staff, 145.A.30(h) states that “B1 and B2 support staff shall ensure that all relevant tasks or inspections have been carried out to the required standard before the category C certifying staff issues the certificate of release to service”. This requirement is of a similar nature to the one contained in 145.A.50(a), where certifying staff are required to ensure that “it has been verified that all maintenance ordered has been properly carried out”. As a consequence, the level of involvement expected from the support staff follows the same principles as indicated in Section 6 above for certifying staff.
145.A.35(b) Certification authorisation
(b) Except for the cases listed in points 145.A.30(j) and 66.A.20(a)3(ii), the organisation may only issue a certification authorisation to certifying staff in relation to the basic categories or subcategories and, except for the category A licence, any type rating listed on the aircraft maintenance licence as required by Annex III (Part-66), subject to the licence remaining valid throughout the validity period of the authorisation and to the certifying staff remaining in compliance with Annex III (Part-66).
AMC 145.A.35(b) Competent authority involvement
The organisation issues the certification authorisation when satisfied that compliance has been established with the appropriate paragraphs of Part-145 and Part-66. In granting the certification authorisation the maintenance organisation approved under Part-145 needs to be satisfied that the person holds a valid Part-66 aircraft maintenance licence and may need to confirm such fact with the competent authority of the Member State that issued the licence.
145.A.35(c) Maintenance experience requirements
(c) The organisation shall ensure that all certifying staff and support staff are involved in at least 6 months of actual relevant aircraft or component maintenance experience in any consecutive 2-year period.
For the purpose of this point ‘involved in actual relevant aircraft or component maintenance’ means that the person has worked in an aircraft or component maintenance environment and has either exercised the privileges of the certification authorisation and/or has actually carried out maintenance on at least some of the aircraft type or aircraft group systems specified in the particular certification authorisation.
For the interpretation of ‘6 months of actual relevant aircraft maintenance experience in any consecutive 2-year period’, the provisions of AMC 66.A.20(b)2 are applicable.
145.A.35(d) Continuation training
(d) The organisation shall ensure that all certifying staff and support staff receive sufficient continuation training in each two year period to ensure that such staff have up-to-date knowledge of relevant technology, organisation procedures and human factor issues.
AMC 145.A.35(d) Continuation training
1. Continuation training is a two way process to ensure that certifying staff remain current in terms of procedures, human factors and technical knowledge and that the organisation receives feedback on the adequacy of its procedures and maintenance instructions. Due to the interactive nature of this training, consideration should be given to the possibility that such training has the involvement of the quality department to ensure that feedback is actioned. Alternatively, there should be a procedure to ensure that feedback is formally passed from the training department to the quality department to initiate action.
2. Continuation training should cover changes in relevant requirements such as Part-145, changes in organisation procedures and the modification standard of the products being maintained plus human factor issues identified from any internal or external analysis of incidents. It should also address instances where staff failed to follow procedures and the reasons why particular procedures are not always followed. In many cases the continuation training will reinforce the need to follow procedures and ensure that incomplete or incorrect procedures are identified to the company in order that they can be corrected. This does not preclude the possible need to carry out a quality audit of such procedures.
3. Continuation training should be of sufficient duration in each 2 year period to meet the intent of 145.A.35(d) and may be split into a number of separate elements. 145.A.35(d) requires such training to keep certifying staff updated in terms of relevant technology, procedures and human factors issues which means it is one part of ensuring quality. Therefore sufficient duration should be related to relevant quality audit findings and other internal / external sources of information available to the organisation on human errors in maintenance. This means that in the case of an organisation that maintains aircraft with few relevant quality audit findings, continuation training could be limited to days rather than weeks, whereas a similar organisation with a number of relevant quality audit findings, such training may take several weeks. For an organisation that maintains aircraft components, the duration of continuation training would follow the same philosophy but should be scaled down to reflect the more limited nature of the activity. For example certifying staff who release hydraulic pumps may only require a few hours of continuation training whereas those who release turbine engine may only require a few days of such training. The content of continuation training should be related to relevant quality audit findings and it is recommended that such training is reviewed at least once in every 24 month period.
4. The method of training is intended to be a flexible process and could, for example, include a Part-147 continuation training course, aeronautical college courses, internal short duration courses, seminars, etc. The elements, general content and length of such training should be specified in the maintenance organisation exposition unless such training is undertaken by an organisation approved under Part-147 when such details may be specified under the approval and cross referenced in the maintenance organisation exposition.
145.A.35(e) Training programme
(e) The organisation shall establish a programme for continuation training for certifying staff and support staff, including a procedure to ensure compliance with the relevant points of 145.A.35 as the basis for issuing certification authorisations under this Part to certifying staff, and a procedure to ensure compliance with Annex III (Part-66).
AMC 145.A.35(e) Continuation training programme
The programme for continuation training should list all certifying staff and support staff and when training will take place, the elements of such training and an indication that it was carried out reasonably on time as planned. Such information should subsequently be transferred to the certifying staff and support staff record as required by 145.A.35(j).
145.A.35(f) Certifying staff assessment
(f) Except where any of the unforeseen cases of point 145.A.30(j)(5) apply, the organisation shall assess all prospective certifying staff for their competence, qualification and capability to carry out their intended certifying duties in accordance with a procedure as specified in the exposition prior to the issue or re-issue of a certification authorisation under this Part.
AMC 145.A.35(f) Competency assessment
As stated in 145.A.35(f), except where any of the unforeseen cases of 145.A.30(j)(5) applies, all prospective certifying staff and support staff should be assessed for competence related to their intended duties in accordance with AMCs 1, 2, 3 and 4 to 145.A.30(e), as applicable.
145.A.35(g) Certification authorisation issuance
(g) When the conditions of points (a), (b), (d), (f) and, where applicable, point (c) have been fulfilled by the certifying staff, the organisation shall issue a certification authorisation that clearly specifies the scope and limits of such authorisation. Continued validity of the certification authorisation is dependent upon continued compliance with points (a), (b), (d), and where applicable, (c).
145.A.35(h) Certification authorisation scope
(h) The certification authorisation must be in a style that makes its scope clear to the certifying staff and any authorised person who may require to examine the authorisation. Where codes are used to define scope, the organisation shall make a code translation readily available. ‘Authorised person’ means the officials of the competent authorities, the Agency and the Member State who has responsibility for the oversight of the maintained aircraft or component.
145.A.35(i) Certification authorisation monitoring
(i) The person responsible for the quality system shall also remain responsible on behalf of the organisation for issuing certification authorisations to certifying staff. Such person may nominate other persons to actually issue or revoke the certification authorisations in accordance with a procedure as specified in the exposition.
145.A.35(j) Certifying staff records
(j) The organisation shall maintain a record of all certifying staff and support staff, which shall contain:
1. the details of any aircraft maintenance licence held under Annex III (Part-66); and
2. all relevant training completed; and
3. the scope of the certification authorisations issued, where relevant; and
4. particulars of staff with limited or one-off certification authorisations.
The organisation shall retain the record for at least three years after the staff referred to in this point have ceased employment with the organisation or as soon as the authorisation has been withdrawn. In addition, upon request, the maintenance organisation shall furnish the staff referred to in this point with a copy of their personal record on leaving the organisation.
The staff referred to in this point shall be given access on request to their personal records as detailed above.
AMC 145.A.35(j) Personnel records details, format and access
1. The following minimum information as applicable should be kept on record in respect of each certifying staff and support staff:
(b) Date of Birth
(c) Basic Training
(d) Type Training
(e) Continuation Training
(g) Qualifications relevant to the authorisation
(h) Scope of the authorisation
(i) Date of first issue of the authorisation
(j) If appropriate – expiry date of the authorisation
(k) Identification Number of the authorisation
2. The record may be kept in any format but should be controlled by the organisation’s quality department. This does not mean that the quality department should run the record system.
3. Persons authorised to access the system should be maintained at a minimum to ensure that records cannot be altered in an unauthorised manner or that such confidential records become accessible to unauthorised persons.
4. The competent authority is an authorised person when investigating the records system for initial and continued approval or when the competent authority has cause to doubt the competence of a particular person.
Can a certification maintenance requirement (CMR) be performed by the Flight Crew before flight?
Normally the flight crew should not release CMR task unless that task is included in a “repetitive pre-flight airworthiness directive” under the conditions of 145.A.30(j)(3), M.A.606(h)(1) or CAO.A.040(c)(1) In case of aircraft operated away from a supported location, the provisions of 145.A.30(j)(4), M.A.606(h)(2) or CAO.A.040(c)(2) could be used for CMRs as long as all the applicable conditions are met. In particular: - sufficient practical training has been carried out. - there is a procedure in the Maintenance Organisation Exposition, Maintenance Organisation Manual or Combined Airworthiness Exposition(CAE). the task is considered “minor maintenance or a simple check” (AMC 145.A.30(j)(4) point 2(i) or AMC M.A.606(h)(2) point 2).
145.A.35(k) Certification authorisation copy
(k) The organisation shall provide certifying staff with a copy of their certification authorisation in either a documented or electronic format.
145.A.35(l) Certification authorisation availability
(l) Certifying staff shall produce their certification authorisation to any authorised person within 24 hours.
145.A.35(m) Age requirements
(m) The minimum age for certifying staff and support staff is 21 years.
145.A.35(n) Category A AML
(n) The holder of a category A aircraft maintenance licence may only exercise certification privileges on a specific aircraft type following the satisfactory completion of the relevant category A aircraft task training carried out by an organisation appropriately approved in accordance with Annex II (Part-145) or Annex IV (Part-147). This training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment carried out by the organisation.
1. It is the responsibility of the Part-145 organisation issuing the category A certifying staff authorisation to ensure that the task training received by this person covers all the tasks to be authorised. This is particularly important in those cases where the task training has been provided by a Part-147 organisation or by a Part-145 organisation different from the one issuing the authorisation.
2. ‘Appropriately approved in accordance with Annex IV (Part-147)’ means an organisation holding an approval to provide category A task training for the corresponding aircraft type.
3. ‘Appropriately approved in accordance with Annex II (Part-145)’ means an organisation holding a maintenance organisation approval for the corresponding aircraft type.
145.A.35(o) Category B2 AML
(o) The holder of a category B2 aircraft maintenance licence may only exercise the certification privileges described in point 66.A.20(a)(3)(ii) of Annex III (Part-66) following the satisfactory completion of
(i) the relevant category A aircraft task training and
(ii) 6 months of documented practical experience covering the scope of the authorisation that will be issued.
The task training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment. Task training and examination/assessment shall be carried out by the maintenance organisation issuing the certifying staff authorisation. The practical experience shall be also obtained within such maintenance organisation.
1. The privilege for a B2 licence holder to release minor scheduled line maintenance and simple defect rectification in accordance with 66.A.20(a)(3)(ii) can only be granted by the Part-145 approved organisation where the licence holder is employed/contracted after meeting all the requirements specified in 145.A.35(o). This privilege cannot be transferred to another Part-145 approved organisation.
2. When a B2 licence holder already holds a certifying staff authorisation containing minor scheduled line maintenance and simple defect rectification for a particular aircraft type, new tasks relevant to category A can be added to that type without requiring another 6 months of experience. However, task training (theoretical plus practical hands-on) and examination/assessment for these additional tasks is still required.
3. When the certifying staff authorisation intends to cover several aircraft types, the experience may be combined within a single 6-month period.
4. For the addition of new types to the certifying staff authorisation, another 6 months should be required unless the aircraft is considered similar per AMC 66.A.20(b)2 to the one already held.
5. The term ‘6 months of experience’ may include full-time employment or part-time employment. The important aspect is that the person has been involved during a period of 6 months (not necessarily every day) in those tasks which are going to be part of the authorisation.