Avionics, Maint Release

[ourkid2000]

Here's a fight that's been kicking around our shop for quite a while..........Avionics guy with an E license but no type course signing the maintenance release for the aircraft. We say this is not in accordance with CARS 571.11, the company says otherwise.

All the guy has is basic training and his license & according to the company's MCM, is granted ACA authority on the aircraft because according to them, Avionics do not require type course in order to have ACA authority.

The E-ACA is completely portable, no matter what the aircraft type........and we have several. What does everyone think of this? Is this allowed?

[HS-748 2A]

This would be one best put to Prairie Chicken but the E lic. actually allows for a pretty broad scope, as you will see below.

Here is CAR 571.10 (8)

(8) Ratings.

(a) The scope of maintenance release privileges will be indicated by rating designators entered on the licence, as follows:

(i) M1: Non-turbojet aircraft built to CAR 522, 523, 523-VLA, 527, 549 and equivalent standards (includes all airframe, engines, propellers, components, structures, and systems of those aircraft), and the aircraft listed in paragraph 566.03(8)(b).
(amended 2003/09/01; previous version)

(ii) M2: All aircraft not included in M1 (excluding balloons) (includes all airframes, engines, propellers, components, structures, and systems of those aircraft), and the aircraft listed in paragraph 566.03(8)(b).
(amended 2003/09/01; previous version).

(iii) E: Aircraft electronic systems. (includes communication, pulse, navigation, auto flight, flight path computation, instruments and the electrical elements of other aircraft systems, and any structural work directly associated with the maintenance of those systems)

[ourkid2000]

Scope........sure, the E license covers a broad spectrum however, this isn't the issue.

Without the type course, are you able to sign the release? According to CARS 571.11, you require a type course.

From CARS:
4) Except as provided in subsection (5), no person shall sign a maintenance release in respect of maintenance performed on a transport category aeroplane or a turbine-powered helicopter, unless the person
(amended 2000/12/01; previous version)

(a) has successfully completed a course of maintenance training that has been approved by the Minister and that is applicable to the type of aircraft, engine or system on which the maintenance is performed, in accordance with Appendix M of Chapter 571 of the Airworthiness Manual; or
(amended 2000/12/01; previous version)

(b) held a type rating applicable to the type of aircraft, engine or system on which the maintenance is performed, issued by the Minister before August 1, 1999.
(amended 2000/12/01; previous version)

(5) The holder of an applicable AME licence may sign a maintenance release in respect of maintenance performed on a transport category aeroplane or a turbine-powered helicopter that consists of any of the types of work set out in Schedule III without having successfully completed the course required by paragraph (4)(a) and without having held the type rating required by paragraph (4)(b).
(amended 2000/12/01; previous version)

Appendix M refers to Type Courses, if you were wondering

[bombardierfixer]

Are we talking about the actual release that goes on the bottom of the log book? Or the release saying that the work was done. As far as I know a E license has to sign for the "specialized" maint that was performed, unless the person has a m1/m2. The final release for flying can only be signed by a appropriatly M rated aca. Unless the company some how wangled a deal through their MPM saying any aca can sign the final release, but as far as I would know thats impossible.

[bombardierfixer]

Its the same as a S licensed ACA. E licensed guys donèt need the type course. They can sign all they want but like I said the final release is a M guy.

[ourkid2000]

Precisely........

Yes, the maint release at the bottom of the log page. According to our MPM, E guys can sign the release..........however, we question the legality of this. Of course, we can sign for the work performed and I have no problem with this.

I would gladly sign the release if I had a type course. According to the company, I am fully qualified to do this with no type course.

[log sheet]

Avionics guy with an E license but no type course signing the maintenance release for the aircraft. We say this is not in accordance with CARS 571.11, the company says otherwise.

He would be signing for the work completed,not signing a Maintenance release for the A/C. As a matter of fact nobody signs a maintenance release for an aircraft, it's for the maintenance completed IAW applicable standards. If it falls under his scope, he's cool. If your company has had their AMO aproved by Transport with it written that an E-Licenced person does not need a type course, he's cool. Many places require a Type course to hold an ACA but mainly because thats how the MPM is written. Speciality Licences, since I've been around anyway, have never been limited to type.
Cheers!

[bombardierfixer]

Well as far as I know if your MPM is cool then give-er. It has to be sanctioned and approved by transport so they said it was okay ( well the inspector who approved it did ) I still think when the shit hits the fan though there is going to be a whole lot of finger pointing......................C.Y.A.

[log sheet]

Curious as to why the AME with the E Rating does not have Type Training, is the company cheap?

[ourkid2000]

Arent they all?

Most of the E guys do not have type training there............I guess because their MPM is approved, they don't feel the need

[Vickers vanguard]

[ As a matter of fact nobody signs a maintenance release for an aircraft, it's for the maintenance completed IAW applicable standards.

well said logsheet, many people still don't seem to grasp that concept.

[bombardierfixer]

With my experiance there is a seperate release for return to service, maybe thats what I'm thinking of.

[ourkid2000]

Our logbooks have a place for you to sign for your work completed, as in snag rectified. This is the spot where the E guy signs his/her work.

At the end is the Maintenance Release which you have to sign and put your ACA stamp on. After this is done, the aircraft is fit to fly. This is where the problem lies. Can the E guy sign this without Type Course?

[log sheet]

Have had opportunity to work for places where the logbooks are set up like that. Now I could be wrong, but I'm pretty sure that it's only the way the book was printed at the Companies request.
There is probally a spot after each line for an AME's signature, date, Licence/ACA number right? Well once the AME sign's the Maintenance release, the job has been released. Wether it's a block check, a Phase Insp. ,a wheel Ass'y or a light bulb.
The guy who sign's at the bottom of the log isn't really releasing anything, he's just following company procedures.

[quote="ourkid2000"]Can the E guy sign this without Type Course?
He cannot sign anything beyond his scope. Look at it that way. Talk to your DOM/PRM and ask them to explain what that final signature at the bottom of the page means to the AMO. I really don't think that that signature re-releases all the work.
Good topic!

[log sheet]

well said logsheet, many people still don't seem to grasp that concept.

Very true Vickers

[HS-748 2A]

Our logbooks have a place for you to sign for your work completed, as in snag rectified. This is the spot where the E guy signs his/her work.

At the end is the Maintenance Release which you have to sign and put your ACA stamp on. After this is done, the aircraft is fit to fly. This is where the problem lies. Can the E guy sign this without Type Course?

At my company, non-ACA holders can write a defect and / or rectification.

In the far LH column, they sign, date and stamp for their work.

Now, at the very bottom of the page, this statement appears:

"The described work has been performed in accordance with the applicable standards of airworthiness."

According to our MPM, an on-type ACA holder signs after this statement, effectively taking responsibility for the 'described work' being completed to the 'applicable standard'.

Concievably, if all the 'described work' was E licence, an E rated person without an ACA could sign at the bottom too, but that is not allowed under our MPM.

That is totally fine. Your grandmother can write in the log book. It doesn't matter, as long as somebody with an ACA on type will certify that she did her work in accordance with an applicable standard.

If she is an ACA holding AME - she could sign part that too.

[Hedley]

(iii) E: Aircraft electronic systems ... and any structural work

It is complete insanity that if you get an E licence,
you get an S licence "for free".

I'm a graduate EE, and I'll bet I could pick up an E
licence without breaking a sweat. But I don't know
diddly about structures.

[iflyforpie]

It is also complete insanity that you get an E and S license with an M1 and M2. You don't want to see me near an aircraft with a rivet gun or soldering iron.

[still_bluenoser]

Our logbooks have a place for you to sign for your work completed, as in snag rectified. This is the spot where the E guy signs his/her work.

At the end is the Maintenance Release which you have to sign and put your ACA stamp on. After this is done, the aircraft is fit to fly. This is where the problem lies. Can the E guy sign this without Type Course?

Yes. If the work described is E catagory, they can sign the maintenance release without type course. As long as you are covered under the company MPM.

That is why you will almost never find an E guy that is type endorsed on anything. Not only are the AMO's cheap, but they also know that there is no need. (in their opinion )

[NeverBlue]

Log Sheet, You're bang on...exactly right

Vickers V: So are you...The E and S licences seem to be completeley misunderstood

Hedley: ...I'm still speechlees from your comments

If you had a clue, 566 says approved training for the E licence includes structures training to a certain level.
They don't have an S licence they can just sign out the work they've done which according to their scope is very minor with regards to radio installations...i.e. Instrument panels, LRU trays, Antenna Mounts...not extremely complex

If an E licence receives a basically airworthy aircraft with an electronic or electrical snag and easily fixes the snag, why wouldn't the aircraft be airworthy again ? Did something magically happen to the aircraft when the AME Licenced Person was doing their job as a professional to the applicable standards required


P.S. Hedley your comments are so typical from an EE...I've heard the exact same thing from about a half dozen I've seen fired in aviation

[still_bluenoser]

(iii) E: Aircraft electronic systems ... and any structural work

It is complete insanity that if you get an E licence,
you get an S licence "for free".

I'm a graduate EE, and I'll bet I could pick up an E
licence without breaking a sweat. But I don't know
diddly about structures.

You also decided not to finish the quote. "any aircraft electronic systems and any structural work directly associated to the maintenance to the maintenance of those systems "

So no. you do not get an "S" licence for free. We get to engineer and fabricate antenna mounts, avionic racks, etc. Not spar repairs

Judging by your coments I'm sure there is more than structures that you dont know diddly about

[log sheet]

So , 2000, did you get an answer from your DOM? You have an M2 and E , I'll bet there are companies out there that will give you Type Training!
Cheers!

[ourkid2000]

I haven't gotten an answer yet as i've been on midnights and I don't get to see the day folks..........

In any case, I guess i'm still confused because CARS says you need a type course to sign a maintenance release. It doesn't come out and say this only applies to M licenses but, rather, to all licenses.

Our MPM says that in order for an E to sign a maint release, they have to have either type training or approved OEM training on the system in question. The company says that our schooling counts as this and therefore we don't need a type course, however, that seems awfully cheap and we question if this actually counts in the first place.

[Hedley]

Wow, that's a lot of timber to haul around on your shoulder.

[HS-748 2A]

So '2000, are really trying to say, like as a for-instance, an apprentice changes a tire on your 727, makes an entry in the book and you are expected to sign at the bottom of the page that the work was completed to the appropriate standard?

If that is the case, that is fuct.