Aircraft and Shop Certification Authority in a Commercial Environment
By Tony Soulis
In Canada, all commercial aircraft as defined in CAR 571.05, must be maintained in an approved maintenance organization (AMO) appropriately rated for the scope of work to be undertaken. As well, all specialized work, regardless whether it involves commercial or private aircraft, must also be performed in an AMO rated for that particular specialty. In both instances, as referenced in CAR 571.04, the work must be released for return to service by an aircraft maintenance engineer (AME) who holds aircraft certification authority (ACA) for the product or aircraft to be released. Let's examine how an individual receives this authority and why it is such a key component within the regulatory process (CAR 573.05).
Before an individual can be nominated for ACA authority by the organization that person must first: be the holder of a valid AME license rated for the aircraft type (CAR 571.11), or component to be released, and have satisfied all training requirements related to the aircraft type(s) — both initial and update. Knowledge of internal maintenance management control systems is also essential.
Once this criteria has been satisfied and documented, the organization is in a position to issue ACA authority to the AME. It should be noted, however, that not all qualified AMEs necessarily receive ACA authority from the AMO. Under CAR 573, the AMO must identify which of the qualified AMEs have been granted that authority. The authority will take the form of either a company selected numbering system or the AME license number of the holder.
In both instances, the individual is exercising personal licensing privilege granted by the minister. In all instances, the individual — not the organization — is fully responsible for the maintenance release. This is a key point which is sometimes misunderstood. Especially, for those individuals who were products of a past system wherein maintenance release, with or without an AME license, was signed on behalf of the organization using a company approval system.
Another characteristic of the ACA system is the fact that an organization may choose to further limit individual maintenance release privilege to an aircraft system, subsystem or process. This is very often the case in large organizations where maintenance release control is supported by a highly specialized work force. Notwithstanding the basic privileges of the license, in a commercial environment, the AMO determines who and to what degree a qualified AME can issue a maintenance release. Remember as well, that all "on-aircraft maintenance" must be released by an AME, within or outside of the AMO, regardless of aircraft type, size, or weight.
Now, let's look at shop certification authority (SCA) to better understand what it is and how it differs from ACA. To begin with, just as in the case of ACA, SCA is a controlling instrument which is used within the AMO process. However, a significant difference between the two privileges is that while ACA is associated with "on-aircraft" maintenance release, SCA is limited to off-aircraft certification. In other words, a qualified individual may certify an aeronautical product(s) for which SCA has been issued, but the privilege will be limited to off-aircraft work. In most instances, qualification standards are such that training and experience is equal to or greater than that required by the generalist AME for that particular area. This is the highly specialized individual who certifies after repair, modification or overhaul, at the rotable, appliance, or component level within a shop environment.
It is important to remember that in all instances following SCA certification, once the item is pulled from stores or the shop and installed on the aircraft, a maintenance release must be issued by the holder of an ACA authority within in that organization. If the item is sent out for outside use, maintenance release becomes a third party responsibility following installation. In this manner, system integrity is assured and confirmed by the holder of the broader based on-aircraft license. On the other hand, there is nothing limiting the AMO from granting SCA authority to an ACA holder if that individual has satisfied AMO qualification requirements.
Another distinction which is sometimes misunderstood is the difference between work performance and maintenance release requirements. In the first instance, TC controls work performance by approving the AMO's policy manual and control system. In this regard, the documented program will include a policy statement by the organization regarding minimum trade qualification standards for its technical personnel engaged in the performance of work. In most instances, the AMO will opt to satisfy this requirement by citing nationally accepted standards such as CAMC, CGSB, MIL, SAE, or other occupational trade standards acceptable to the minister, which satisfy AMO work performance requirements.
On the other hand, maintenance release authority is a regulatory privilege granted to certain individuals who have satisfied TC licensing requirements. Remember that this is a privilege which can be withdrawn for cause by the minister. This is generally not the case for an individual who has successfully demonstrated and received trade qualification recognition to a recognized industry standard.
In certain instances, confusion between licensing and work performance standards sometimes arise where an AMO cites AME licensing standards as a means of satisfying AMO work performance standards. An example of this is the use of the AME Structures License in lieu of a defined structures-related work performance standard such as that issued by CAMC. This is a scenario which sometimes prevailed in the past where there was often an absence of adequate performance standards to satisfy AMO requirements. However, that is no longer the case as there are now sufficient work standards to address the various technical areas within an AMO.
The point to remember here is that the two standards should always be viewed as distinctive, serving different purposes in the regulatory regime. As pointed out earlier, the AME license is authority to sign a maintenance release, while the work performance standard is an attestation that the individual is competent to perform work in a particular discipline within an AMO environment.
Both aircraft and shop certification authority serve distinctive yet complimentary roles in a commercial environment where work performance and maintenance release contribute equally to a safety-oriented aviation maintenance industry.