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Responsibilities and Standards

Responsibilities -- Individual, Company and Regulator
ALAE are receiving an ever increasing number of reports relating to maintenance companies and their respective Quality Departments continuously attempting to dumb down the maintenance process. This often involves moving the goal posts or stretching the envelope of acceptability to very near or even beyond the boundaries set by the regulations. It is a complex game of cat and mouse that is making it ever more difficult for the licensed engineer to apply and maintain a professional standard while at the same time attempting to guarantee that safety remains paramount.
In some recent cases company orientated individuals have forgotten their basic responsibility to maintain an acceptable level of safety in a desperate bid to increase profits. In its worst form this has led to unnecessary and completely unfounded disciplinary action being instigated against engineers who have merely attempted to uphold safety. Fortunately common sense has prevailed so far, although not without intervention but those on the receiving end have received full apologies. We can only hope that those involved in instigating such actions have also learnt their lesson from these appalling episodes and will think twice about their motives next time.
Therefore ALAE felt it may be useful to review and highlight a few regulations in order to remind engineers, management and regulators of their responsibilities. It is not comprehensive but covers those subjects and issues that are currently most commonly commented upon.
A good place to begin is with the Flight Safety Foundation’s “Certifier’s Oath”, which states:
"Upon My Honour, I swear that I shall hold in sacred trust the rights and privileges conferred upon me as a certifier. Knowing full well that the safety and lives of others are dependent upon my skill and judgement, I shall never knowingly subject others to risks which I would not be willing to assume for myself, or those dear to me. In discharging this trust, I pledge myself never to undertake work or approve work which I feel to be beyond the limits of my knowledge, nor shall I allow any non-certified superior to persuade me to approve aircraft or equipment as airworthy against my better judgement, nor shall I permit my judgement to be influenced by money or other personal gain, nor shall I pass as airworthy aircraft or equipment about which I am in doubt, either as a result of direct inspection or uncertainty regarding the ability of others who have worked on it to accomplish their work satisfactorily. I realise the grave responsibility which is mine as a certifier, to exercise my judgement on the airworthiness of aircraft and equipment. I therefore, pledge unyielding adherence to these ideals for the advancement of aviation and for the dignity of my vocation".
Fine words indeed but more importantly are they supported by the law?
Well, in ALAE’s opinion yes they are. Certifier’s responsibilities conveyed by Airworthiness Notices have now been incorporated in CAP 562 particularly Part 15. ALAE strongly recommends that every engineer familiarise themselves with this document. CAP 562 fully supports the intent of the Certifier’s Oath above. Furthermore
EC regulation 2042/2003 also goes into great detail to describe what is required in order to meet the intent of the requirements. Requirements that insist upon an organisation having in place a well defined team structure which should ensure that the organisation consistently meets the required high standard.
We should at this point make one thing clear; it is a team game. However it should not lead to lop sided conditions where one or more elements are given a higher or lower priority. This only leads to an obvious imbalance and the organisation will fail to meet the required standard. 
Therefore do not allow yourself to be sidetracked by reference to company procedures as if all else can be forgotten. The Company also has a legal obligation to publish procedures which must as a minimum align with the regulations. That is not to say that the procedures must mirror word for word the regulations but they must offer at least an equivalent, if not a higher standard.
It is quite common in base maintenance for example for companies to try and push the boundary of acceptance as far as possible. One example is the use of unlicensed but trained and authorised colleagues. This is perfectly acceptable within our structure based upon teamwork as long as the checks and balances remain in place. Every individual is responsible for their own work and tasked trained individuals can be a huge asset to an organisation. Part 145 rightly allows for this. However it is important that such individuals remain acutely aware of their limits and resist the temptation or any company applied pressure to work outside of their authorisations. Worst case scenario is that you may fall foul of the law and your once very supportive company may drop you quicker than a red hot coal, as they themselves hide behind procedures and the law.
The same logic of course also applies for licensed colleagues. In some respects it’s a little tougher as many companies actively attempt to undermine and reduce their influence on the end product. B1/B2 support staff in particular are often viewed as an easy target with companies attempting to place more and more of a burden on unlicensed staff at the expense of support staff. We now however begin to enter that area mentioned earlier of balance. B1/B2 support staff are required to ensure that all relevant tasks or inspections have been carried out to the required standard before the Category C issues the release to service.

Well what does that mean, where are the limits? The official response from EASA was as follows:

“B1/B2 support staff must assess the complexity of each task, assigning it to personnel authorised to sign-off to the corresponding level, supporting those personnel in case of any mistakes or unexpected difficulties and verifying that the job has been completed and signed-off properly”.
The UK CAA informed us that:
Category B1/B2 support staff must still ensure all relevant tasks and inspections have been carried out to the required standard in accordance with 145.A.30 (h) before the Category C certifier issues the Certificate of Release to Service. In practice the CAA expects the B1/B2 support staff will sample the mechanic’s work in order to ensure it has been carried out to the required standard”(Letter)
Both of the above obviously requires an active input from support staff and so just checking for a signature for example could not in any way be classed as supervision or as meeting the intent of the regulation. In addition ALAE also asked for EASA’s opinion on who is actually responsible for the quality of the work performed. We felt that a clear explanation was required because although teamwork is an excellent form of work methodology, someone has to be ultimately responsible.

So who is responsible for the quality of the work performed on an aircraft? Again I will quote EASA:

“Each job category both within Part 145 and CAMO organisations has its own responsibilities and all of them have an influence on the quality of maintenance performed. However the quality of the maintenance performed is finally certified by certifying staff”

So there you have it. Any individual certifying will be held accountable for the quality of the work performed. Although often easier said than done do not allow your professional qualification to be compromised in any way. If you are certifying and responsible, it is only to be expected that you wish to exercise an element of supervision. Company procedures cannot take that away from you. This applies to B1/B2 support staff as well.
To that end Part 145.A.30 paragraph (h) is quite specific and in fact has no corresponding AMC material. It is ALAE’s opinion that any dumbing down of this paragraph is totally unacceptable and any NAA authorising procedures that allow for such a dumbing down are obviously in urgent need of a re-evaluation of their relationship with the organisation they have approved. One only has to look at the current FAA crisis to see how easy NAA’s can become too close and too cosy to the airlines and maintenance organisations that they should in fact be regulating.
Finally a quick mention of the options open to all of us, licensed and non licensed should you find yourself in a difficult situation that perhaps requires further investigation or maybe just a better explanation. The first point is report. EU Directives are in force which protects the reporter. Any company attempting to silence a reporter or dismiss them will be in breach of European law. The regulators and operators are in fact legally bound to operate a just, no retribution reporting system with the priority being to promote and uphold safety. Therefore reading CAP 382 is a must, particularly the statement made by the CAA Chairman.
That aside there are many avenues open; GOR, MOR, CAA, CHIRP and of course ALAE. We are always 100% behind you and will offer support and advice all of the way. The most important aspect is that the issue gets reported and brought out into the open. Otherwise the potential consequences do not bear thinking about.
 


 
 
 
 

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