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.