[Peetwo]

Alphabets in harmony, Fort Fumble a basket case -

From AMROBA's latest newsletter: Volume 13 Issue 11 (Nov 2016)

1. The Ugly Truth Regarding Maintenance Training.

Incompetence is the only answer to why the maintenance training and licencing is in such a mess and almost unworkable. The previous CASA project managers never spoke with other governments departments and agencies. There was no understanding of the role of the AME/AMT, who work in base maintenance and component shops, let alone understand the role of the ICAO Annex 1, Chapter 4 licence privileges. The Education Department recently confirmed no restrictions on course duration. EASR Parts 66 & 147, implemented properly, can lower costs.

Australian aviation legislation/regulations have been out of step globally since 1990. The ICAO requirements for a LAME is important to adopt and the scope of the licence needs to be documented.

Why are we not harmonised with ICAO, EASA and NZ?

The reason is CASA, who thought they were experts, did not adopt EASRs properly or work with the rest of government. The damage they have done will take a major rethink to correct. Many of our members insinuate that it was deliberately done to damage GA. Considering the inputs they had during the consultation period, it always raised industry concerns how they developed the regulations.

CASA did not adopt provisions from EASRs that are a major reason for the unique LAME rating system applied to the licence. With a small change to EASR 66.A.5, Aircraft Groups, the original CAO 100.90 Series “Groups” could have been retained. For those that are old enough, EASA is similar to the original Group ratings use by DCA before the CAO 100.90 series Group ratings. CASA reintroduced a system from the past that did not work well for GA.

66.A.5 Aircraft groups
For the purpose of ratings on aircraft maintenance licences, aircraft shall be classified in the following groups:

1. Group 1: complex motor-powered aircraft as well as multiple engine helicopters, aeroplanes with maximum certified operating altitude exceeding FL290, aircraft equipped with fly-by-wire systems and other aircraft requiring an aircraft type rating when defined so by the Agency.
2. Group 2: aircraft other than those in Group 1 belonging to the following subgroups:
— sub-group 2a: single turbo-propeller engine aeroplanes
— sub-group 2b: single turbine engine helicopters
— sub-group 2c: single piston engine helicopters.
3. Group 3: piston engine aeroplanes other than those in Group 1.

We need to adopt with reference to original CAO group ratings. The following unused EASR clarifies LAME privileges

EASR 66.A.20 Privileges

(a) The following privileges shall apply:

1. A category A aircraft maintenance licence permits the holder to issue certificates of release to service following minor scheduled line maintenance and simple defect rectification within the limits of tasks specifically endorsed on the certification authorisation referred to in point 145.A.35 of Annex II (Part-145). The certification privileges shall be restricted to work that the licence holder has personally performed in the maintenance organisation that issued the certification authorisation.
2. A category B1 aircraft maintenance licence shall permit the holder to issue certificates of release to service and to act as B1 support staff following:
— maintenance performed on aircraft structure, powerplant and mechanical and electrical systems,
— work on avionic systems requiring only simple tests to prove their serviceability and not requiring troubleshooting.
Category B1 includes the corresponding A subcategory

Other provisions of EASR Part 66 also need to be adopted that will enable self-study plus examination plus experience to obtain a licence and or rating. In addition, to obtain a licence, the use of on-line providers is growing in Europe. Tradespersons from allied trades can also be smoothly introduced into aviation maintenance with a more cost effective system.

For a decade or more, MSA, the now defunct industry skill council, (has been replaced by a new SSO to support the Industry Reference Committee responsible for developing training packages) has mislead the industry in stating the training had to be crammed into the same training hours that existed 2 decades back. Basically 1200 to 1500 training hours, depending on which State; these hours include competency assessment.

The Department of Education has informed us, at a meeting in Canberra on the 23rd November that they have never had a limitation on course duration. Like NZ, the course duration has to be promulgated by CASA. This will correct one problem. It will enable harmonisation of training packages. Under the Trans-Tasman Mutual Recognition Agreement, we should be harmonising as close as possible with education qualifications.

Job skill requirements must be provided by the education system to CASA standards.

In reference to the above quoted post:

From the belatedly released RAAA Winter edition newsletter it would appear the Alphabets (TAAAF) are still singing in sync and the volume is increasing: 

Mike Higgins from the RHS... :

"..We have also begun to ramp up our activities in holding CASA to account in following the current Government directive of International Recognition and Harmonisation wherever possible, particularly overseas maintenance and repair organisations.

The stand out issue here is the face to face audits that CASA insist on conducting on a regular basis at great cost to some of our members, with no risk based safety case to support this extravagance...

---

...CASA finally admitted that the current Engineering Training system has been a failure.

The result is the CASA launch of a Post Implementation Review of CASR Part 66 – Continuing Airworthiness – Maintenance Engineer Licences and Ratings.


The RAAA is fully supporting our RTO members during this review and will be working closely with the Australian Licensed Aircraft Engineers Association (ALAEA) and the Aviation Maintenance Repair and Overhaul Business Association (AMROBA).


The triparte group is called the Engineering Training Action Group (ETAG) and is an RAAA initiative.


The RAAA has driven a different approach this time in that the group (rather than CASA) should lead the review, inviting CASA to join us from time to time.


We will need to involve the Australian Skills Quality Authority (ASQA) and the Federal and State Departments of Education.


This project will take many months, however the impact on the RAAA resources will be quite manageable and will produce an excellent mid to long term return on our investment..."

TAAAF (with RAAA taking the lead) also continue to prosecute the case for holding the now Comardy led CASA to account on properly implementing the ASRR recommendations:

"..A Post Implementation Review (PIR) of the Aviation Safety Regulatory Review (ASRR) is still high on our agenda as we seek visibility of CASA's progress on inculcating the government supported recommendations in to the organisation


CAO 48.1 (Flight and Duty times/ Fatigue Risk Management) is still on the top of the current priorities.


CASA still assert that they have a safety case to support the need for an onerous FRMS and evidence to demonstrate that fatigue is not being managed by our Safety Management Systems.

After many months of unsuccessful lobbying for CASA to produce these documents we recently serviced CASA with notice under the Freedom of Information Act to produce the documents to which they refer.."

Hmm...I see a common theme here - i.e. "show us your safety case??" 


MTF...P2