Maintenance Experience
Why Track It?
By Tony Soulis
February 1999
Occasionally I am asked about the importance or value of maintaining personal records as they pertain to the Aircraft Maintenance Engineer (AME) licensing control system. For the most part, the average AME pays little attention to this licensing requirement until the need arises to seek additional licensing privileges. Then of course, the obligation to prove relevant and applicable experience in support of additional maintenance release privileges takes on a renewed sense of urgency. This is often accompanied with a certain level of frustration on the part of the applicant AME who is fully aware of his or her maintenance experience, but has failed to adequately document that history.
For those individuals who can relate to this scenario and have lived through such an ordeal, personal record keeping takes on a renewed meaning. So, where does it say that an AME must maintain a personal record of maintenance experience, and what is the criterion that the regulator seeks before authorizing additional privilege? Taking it from the top — CAR 403.03, Issuance and Endorsement of AME Licence, is the regulation and subpart that deals with issuance requirements; and CAR 403.03(b) iv and v, further identify experience and skill as two essential elements that must be satisfied before a rating or privilege can be sought. So much for the higher authority. By the way, remember that a regulation always identifies what requirement must be met, while a standard defines how it can be done.
In that regard, let's look at the standard that supports the regulatory requirement and determine exactly what needs to be addressed — and why. Airworthiness Manual (AWM) Chapter 566 is as good a place to start, as it is the controlling licensing standard. For those of you that don't have a copy on hand, but have access to the web, you can follow along at the Transport Canada web site, www.tc.gc.ca. In particular, focus on 566.03 (6), (7), and (8), as well as Appendix A, Examples of Suitable Maintenance Tasks. Both (6) and (7), detail how an applicant can show experience and provide proof of having accomplished applicable maintenance tasks for privileges being sought. While (6) deals with maintenance experience requirements, (7) focuses on Skill and Maintenance Tasks. As such, both of these elements must be satisfied when applying for additional ratings.
That brings us around to 566.03(8), which deals with how that experience and skill can be recorded in a manner acceptable to the Minister. In this regard, and in addition to the AME Log Book produced by TC for that purpose, the regulator will accept any form of record or documentation that respects the intent of the standard. Essentially, this means that so long as the recorded event has been properly witnessed and documented, TC will recognize the record as a means of providing proof of maintenance related experience.
What is meant by witnessed and documented? Specifically, this means that the recorded maintenance task or tasks, have been successfully completed by the holder of the record, objectively assessed under direct supervision, and certified by a qualified individual. The certifying individual must be the holder of an AME Licence, or alternatively, be another competent individual who has superior knowledge over the applicant on the task being performed. In other words, a systems specialists in hydraulics, avionics, NDI, structures, and so on, would also qualify to certify a maintenance experience record. A sample listing of eligible maintenance tasks is contained in Appendix C.
With respect to the certification itself, the signatory is confirming that the individual performing the maintenance task: was directly supervised; identified the proper standard for task accomplishment; selected proper tools; and, completed the necessary documentation. In addition to the maintenance task itself, entries should identify the type of equipment, model, component, serial number, and registration number where applicable. Of course, time, place, and date are fundamental to each entry. In short, everything should be recorded that supports traceability to the source.
While you're at it, use the personal log as a means of compiling relevant training records and job employment history. In this manner, the personal record becomes a handy and centralized location for the retention of all recorded aviation maintenance experience.
Incidentally, the TC-produced personal AME log has just recently been amended and is now available for purchase. Additional information regarding price and availability can be obtained by contacting the Transport Canada Civil Aviation Communication Centre, Place de Ville, 330 Sparks St., 5th Floor, Area A, Ottawa, ON. K1A 0N8, or call,1-800-305-2059, or 613-993-7284.
While we're on the subject of log books, TC regularly receives requests from industry to approve personal logs that have been developed by an organization to meet its particular needs. These logs often mirror the TC-produced personal log in terms of format and content — complete with a listing of eligible tasks for the various AME licence ratings.
For the record, while TC does not approve personal maintenance history logs per se, it does encourage and accept their use. In that regard, TC licensing personnel are aware of the many varieties that exist to record all sorts of trade related history. However, when presented by an individual for licensing purposes, each of these records are reviewed for content and applicability against recording criteria contained in AWM 566. In that regard, an individual is free to use whatever type, form, or number of records he or she desires, as all can be submitted for AME licensing purposes.
Regardless of recording method used, it is in the best interest of all AMEs to ensure that personal maintenance experience and history is recorded in the manner prescribed by the Minister. By taking a few minutes to properly record your maintenance experience as it unfolds, unwarranted frustration associated with inadequate licensing documentation can easily be avoided. Remember that personal documentation for AME licensing purposes is your responsibility — not the employer's. So, take the time to protect your interests — your livelihood may be affected by it.
