Issue Assessment Group AME licensing (No.8) Agenda Tuesday 25th May 2010 Chair / Facilitator: Scribe: Time: Location: Chris Lamain Rose Hughes 11.30am 12.10pm Bunker Room, Miramar Links, Miramar, Wellington Item Subject 1 Introduction 2 9/ISS/5 - Eurocopter epicyclic changes 3 8/ISS/13 - Pt43 Pt145 performance of maintenance demarcation 4 8/ISS/57 - Part 66 IA eligibility requirements 5 8/ISS/19 - AMEL Installation privileges for 406MHz ELTs 6 7/ISS/96 - AME license structure 7 7/ISS/45 - Review of Part 66 8 10/ISS/4 - AME Licensing Groups and Privileges Invitees/Attendees Phil Hone CAA Don McCracken AEANZ John Keyzer CAA Bob Feasey AIA Bob Jelley CAA Phil Byrne Fieldair Peter Gill CAA Martin Adam Design Engineer ltd Mark Price CAA Don Fleming Hawker Pacific Chris Lamain CAA John Cook Air NZ Maurice Gordon AEANZ John Marshall Jetconnect Bruce Robertson AEANZ Wally Sturgeon AEANZ Apologies Mark Sefton Aviation Management Limited Gerard Robertson Air NZ John Funnell Helicopter Services (BoP) Ltd John Bushell CAA 17/06/2010 Page 1 of 5 Date saved: 16/06/10
MINUTES OF ISSUE ASSESSMENT MEETING AME Licensing (No.8) Item Led by Description 1 Chris Lamain This meeting was carried out in conjunction with the meeting on airworthiness/maintenance issues. 2 Paul Elton 9/ISS/5 - Eurocopter epicyclic changes Rule 43.54(b)(6) allows for the dismantling of a helicopter transmission for inspection. It does not allow for the replacement of the epicyclic gear module assemblies on a series of Eurocopter helicopters as part of maintaining the aircraft. The factory consider the changing of the epicyclic module as part of maintenance of a "field" replaceable item and they provide the information for this task in the aircraft maintenance manual. There is a need for the rule to be changed so this function can be carried out in the field. Both 9/ISS/5 and 8/ISS/13 look at the demarcation of who looks after component maintenance: a Part 145 organisation or a Part 66 license holder. Tasks specifically listed in associated manual as field tasks should be considered as being suitable for maintenance by a Part 66 air maintenance engineer. Issue 9/ISS/5 should be cancelled and its intent incorporated into issue 8/ISS/13. 3 Paul Elton 8/ISS/13 - Pt43 Pt145 performance of maintenance demarcation CAR 43.54(b)(4)(ii) and (b)(6). These two specific paragraphs do not provide for the replacement of a single part e.g. a single gear in an engine gearbox even thought the engine gearbox is a condition monitored item, and the engine manufacturer details the task in the maintenance manual. For example, a turbine housing could be split, and a complete turbine wheels rotating assembly could be removed and a replacement assembly installed, where as a single spalled gear or bearing making metal could not be replaced within the existing rule definition. I believe this rule needs to be re assessed by technical and rule specialists. Currently, engineers are splitting some helicopter transmissions, removing epicyclic assy's that are due overhaul, and re-installing overhauled assemblies. This is a common occurrence, but I believe not legally provided for within the rule demarcation data. There was general discussion on this and the previous issue with a general agreement that such maintenance should be permitted. Rule-making is required. Issue 9/ISS/5 should be cancelled and its intent incorporated into issue 8/IS/13. 4 Paul Elton 8/ISS/57 - Part 66 IA eligibility requirements Inspection Authorisation eligibility requirements, CAA rule 66.203, qualifies only NZ CAA LAME's with aeroplane and power plant ratings to have an IA. With technology development where avionics engineers are now playing a major role, it is requested to allow avionics rated engineers to hold an IA. It was noted that the IA privileges for avionics engineers would be limited to the conformity of avionics modifications. In Part 145 organisations, an avionics person can be trained and authorised to carry out a conformity inspection. It was noted that this is potentially quite a big rule and process change for the CAA. There was agreement for rule-making. 17/06/2010 Page 2 of 5 Date saved: 16/06/10
Risk Med/High 5 Paul Elton 8/ISS/19 - AMEL Installation privileges for 406MHz ELTs With the introduction of 406 MHz ELTs (FAA TSO-C126) the current rules relating to Part 66 AMEL privileges for the installation of these ELTs do not reflect CAA's intent for which category of AMEL holders can install these ELTs. This is due to the fact that the new 406 ELTs operate at two frequencies of 406 MHz and 121.5 MHz. 406 MHz is considered in the UHF frequency range. The current AMEL additional privilege for the installation of radio systems prescribes HF and VHF frequencies. The previous ELTs (FAA TSO-C91) operate at 121.5 MHz only which is in the VHF frequency range. This Rule currently has a general exemption which suggests the need for a rule change. Mark Price explained that the exemption was put up initially as the pace of the rule requirement for putting 406MHz ELTs in GA aircraft, and the time scale could not be achieved without the exemption. There have also been some ELT failures noted due to some very poor installations by non-avionics people. If nothing is done the exemption will revert back to the status quo which is not considered to be an option. 6 Paul Elton 7/ISS/96 - AME license structure The current Part 66 licence system requires acceptable line and base maintenance training, qualification and experience for the issue of type ratings. With new technology aircraft and the subsequent increase in reliability it will take a significant period e.g. 14 years for a B787, to meet the current experience requirements. In addition the design philosophy alters the way aircraft are maintained. These changes point to a logical change in the Part 66 licence requirements to provide separate licence category and rating classifications for line and base maintenance activities. The EASA Part 66 provides a suitable model. It was noted that this is a big issue for the AME license structure. The introduction of new aircraft technology requires a rule change. The EASA model is being used by many different states but needs to be looked at cautiously. CASA have taken a cautious approach. The EASA model is used for transport category aircraft; CASA has left the GA license structure alone until they have a solution. It was commented that this is a recurring problem airlines are coming up against all the time. Chris Lamain explained that in order to be considered for the 2011/2012 rule programme, dialogue needs to start now. The rule programme for 2010/11 is already being prepared and this project will not make the programme. More background work is needed. A PIRA, with options and costings should be prepared in order to be ready for consideration by Dec 2010 for consideration in the FY2011/2012 programme. Comment Chris Lamain In response to a query regarding inclusion of 10/ISS/4, Chris explained that the group will review all the issues individually for Part 66 today. All those to do with licensing and Part 66 structure and Part 66 requirements should be grouped together in one rule project Part 66 Update or Review. 7 Paul Elton 7/ISS/45 - Review of Part 66 17/06/2010 Page 3 of 5 Date saved: 16/06/10
There are three issues: 1. Certification of Aircraft Maintenance Engineer (AME) Training Organisations. There is no requirement for training organisations delivering training to aircraft maintenance engineers to be certificated to the existing Part 141, or certificated to a dedicated rule such as Rule Part 147 which is common in many other States. There is no requirement for an aircraft maintenance engineer to undertake their training within a certificated training organisation. Nationally, aircraft maintenance engineer training will be the only aviation training toward a licence, to be delivered outside a recognised organisation certification structure. Internationally, the developed nations that we have traditionally benchmarked against have moved to organisation certification for aircraft maintenance engineer training. (i.e. Part 65 training is only permitted under a Part 172 or Part 141 certificate), with the appropriate quality management and quality assurance elements in place. There is currently a Part 61 NPRM requiring Part 61 training to be conducted under a Part 141 certificate, with the appropriate quality systems in place.) 2. On-going competency Checking Regime for Part 66. There is no ongoing competency requirements incorporated into Rule Part 66, for competency checks to be conducted after the initial licence issue. This is unlike the Part 61 and Part 65 licensing regime (i.e. In Part 61 and Part 65/172 there are competency requirements for pilots and controllers, as well as instructors and examiners. This is not the case in Part 66) 3. General review of all requirements. The Rule has not been reviewed since 1997, and the rules that New Zealand have traditionally benchmarked against have moved on since that date. Three issues are combined in this issue. There was general discussion covering: the certification of AME training organisations competency assessment best practices the ICAO Annex 1 recommendation - the CAA views this as a good thing clarification that this would not be the only way of obtaining licenses the CASA model options for New Zealand e.g. work in the industry and attend apprenticeship training modules at polytechs signed off by CAA, the use of block courses etc the need to formalise trade training with a formal assessment And to modernise the approach to training costs for implementation of such a system e.g. the cost for polytechs to conform to the unit standards etc. the need for licensing bodies to be independent from training organisations. Otherwise concern regarding commercial interest. the need for informal debate around Part 66 Rule making-required Including a complete review of Part 66. 8 Paul Elton 10/ISS/4 - AME Licensing Groups and Privileges CAR 66 Appendix B and C are both out of date and do not reflect current systems and technology. This shortcoming has resulted in an exemption being needed for the installation and maintenance of 406 MHz ELTs. As an example, the Radio licence still has Omega listed when the system has been out of service for about ten years; ground proximity warning systems and TAWs are not listed. The discussion suggests the need to consolidate this issue into a Part 66 update. 17/06/2010 Page 4 of 5 Date saved: 16/06/10
Paul suggested the issues 7/ISS/6, 10/ISS/4, 7/ISS/45 be combined. Chris responded saying there was a need to consider the issues and determine those which could be consolidated into the Part 66 issue review. Those sitting outside this scope will need to be addressed separately. Session finished at 12.30pm. The meeting record of this IAG will be added to the CAA website 17/06/2010 Page 5 of 5 Date saved: 16/06/10