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Thread: CRS issue within EASA AEI Press release

  1. #11
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    Default Re: CRS issue within EASA AEI Press release

    Quote Originally Posted by litebulbs View Post
    Now on topic....

    I am not someone who works in base maintenance, but I don't think this is a CRS issue, more having a normal practice of support staff not "verifying" the work of unlicensed and unauthorised staff and the tasks they are completing. As to the politics of why EASA and the LBA are not acting to enforce regulation, this approach of the AEI to write directly to the European Transport Commissioner, who has now been officially warned....
    Are you saying that the European Transport Commissioner [ETC] has warned AEI? Did the warning include an advice on how to route letters to ETC? Who knows, maybe starting from the Village Head up through the MEP?
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  2. #12
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    Default Re: CRS issue within EASA AEI Press release

    Quote Originally Posted by Rigga View Post
    I believe this issue goes back some years and applies mainly to Line work. Where a Part M organisation can approve work done by a different organisation to the one signing the CRS - Essentially, the CRS covers the work done by a third party, beyond the oversight of the CRS signatory. - There has been a EASA 'Working Party' trying to sort this out since 2012...
    The regulation does not give any certification rights to any work on TC aircraft in line maintenance to unlicenced staff is my understanding. You must be B1, B2 or A and within your approvals. Third party organisations have to comply as well in my understanding. Base maintenance now has approved mechanics for signing off workpack tasks of a hangar input, but the complexity of those tasks is dependant on the companies restrictiosnand some tasks are totally the preserve of type rated licence holders (of course there was no A licence certification in base maintance, unlike the line). I saw the approved mechanics situation in a certain MRO not far from Rigga's pad. It was quiet comprehensive in what they could do or not do and the training was very throught. A lot of the task had A licenced level guys doing tasks that you would commonally see them carrying out on the line without oversight. One can disagree on that (and yes I am for protecting the use of licenced engineers as the safety stop in releasing aircraft).
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  3. #13
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    Default Re: CRS issue within EASA AEI Press release

    For clarity the regulation does not give any certification rights to work performed by unlicensed staff in line or base maintenance. That is why we have B1/B2 Support Staff in base maintenace and their role is exactly the same as that of a B1/B2 on the line. The only difference is they verify the task has been completed to the correct standard prior to the Cat C issuing a release.

    The regulation does not permit an administrative function for the licence. The licence is there to enable the holder to either verify their own work or the work of others. There are no other options available as the regulations require that ALL work be verified by a licence holder.

    I would highly recommend licensed personnel refresh themselves with CAP 562 Section H-20 (Licence Responsibilities) and the briefing document issued by AEI particularly appendix 2 which is the CAA response to the issue raised by AEI.

    It is also worth noting that if there is an NAA approved procedure in place contradicting the above statements, it is the duty of all licensed engineers covered by that procedure to challenge the process via the reporting system. This still means you are working outside the regulation but it may assist your defence should you become embroiled in a worst case scenario and you have not been properly exercising your privileges, i.e. not inspecting all of the work covered by the release you issued.

    https://sites.google.com/airengineer...vice/documents

    https://drive.google.com/file/d/1-0T...CO1tqBTZc/view
    Last edited by ALAE (1981); April 17th, 2018 at 06:56.
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  4. #14
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    Default Re: CRS issue within EASA AEI Press release

    The regulation does not permit an administrative function for the licence. The licence is there to enable the holder to either verify their own work or the work of others. There are no other options available as the regulations require that ALL work be verified by a licence holder.

    I think that sums it all rather well and any B1 or B2 who thinks differently needs to go back to school! That is why we are given a Licence after all, to enable the Inspection of others work and certify it....... simple.

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    Default Re: CRS issue within EASA AEI Press release

    Quote Originally Posted by No Smoking View Post
    Are you saying that the European Transport Commissioner [ETC] has warned AEI?
    No, I was saying that the AEI as warned the ETC regarding this non compliant issue. I am sure that if I was actually righting personally to the ETC, I would not use a word like "warned", more "made aware", but there can be no denying now.....

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    Default Re: CRS issue within EASA AEI Press release

    Quote Originally Posted by Neil Armstrong View Post
    The regulation does not permit an administrative function for the licence. The licence is there to enable the holder to either verify their own work or the work of others. There are no other options available as the regulations require that ALL work be verified by a licence holder.

    I think that sums it all rather well and any B1 or B2 who thinks differently needs to go back to school! That is why we are given a Licence after all, to enable the Inspection of others work and certify it....... simple.
    So what does this rubbish off the EASA website mean?

    GM 145.A.48 is added as follows:
    ‘GM 145.A.48 Performance of maintenance
    AUTHORISED PERSON
    An ‘authorised person’ is a person formally authorised by the maintenance organisation to perform or
    supervise a maintenance task. An ‘authorised person’ is not necessarily ‘certifying staff’.
    SIGN-OFF
    A ‘sign-off’ is a statement issued by the ‘authorised person’ which indicates that the task or group of tasks
    has been correctly performed. A ‘sign-off’ relates to one step in the maintenance process and is, therefore,
    different to a certificate of release to service."

    My point is made having seen and spoken to people in a certain base maintenance MRO next door. I read the rule changes in 2012 and saw it rolled out in that MRO. Of course the CRS is a C Cert function, but the wording of support staffs had changed and that organisation was driving that home as much as it could get. That is why it had level 5 to level 1 approved mechanics. This of course was the rule changes of 2102, that hit the UK in 2013 and hurt me big time with the OJT shite. 145.A48 . It is the watering down back to the company approvals of Europe pre JAA that certainly the company I refer to could not wait to push people through.This of course was for the hangar base work packs, not for any line maintenance (that is all I have referred it to). I totally disagree with it of course.
    Last edited by Alber Ratman; April 18th, 2018 at 00:19.
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    Default Re: CRS issue within EASA AEI Press release

    Quote Originally Posted by Alber Ratman View Post
    So what does this rubbish off the EASA website mean?

    GM 145.A.48 is added as follows:
    ‘GM 145.A.48 Performance of maintenance
    AUTHORISED PERSON
    An ‘authorised person’ is a person formally authorised by the maintenance organisation to perform or
    supervise a maintenance task. An ‘authorised person’ is not necessarily ‘certifying staff’.

    SIGN-OFF

    A ‘sign-off’ is a statement issued by the ‘authorised person’ which indicates that the task or group of tasks
    has been correctly performed. A ‘sign-off’ relates to one step in the maintenance process and is, therefore,
    different to a certificate of release to service."


    ...........
    The way I read it, quite logical to how we understand it. In the Base scenario, folks may be authorised, not even being a licensed certifying staff, to issue a sign-off for Tasks they have completed.

    When I contracted at a Base MRO as B1 holder long before the 3012 amendment, I had oversight over the work done by mechanics, each of whom would sign the "Done By" section on the Task Card before I would clear the card. The Master CRS statement would later be signed by the C-licensed engineer. While the mechanics, leckies and sheeties did not have stamps, their specimen signatures were retained at QA. Visiting specialists like Borescope and NDI inspectors would issue their Form 1s to cover what they did on each check while I would clear the cards for access to those Tasks.
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    Default Re: CRS issue within EASA AEI Press release

    So what does this rubbish off the EASA website mean?
    It means exactly this: https://drive.google.com/file/d/1SSD...G_ArTV2pK/view

    And this is what is written in CAP 562 Section H-20.

    When issuing a Certificate of Release to Service for work performed by others, the certifying engineer assumes responsibility. The certifying engineer must have inspected a sufficiently representative sample of the work and the associated documentation, and be satisfied with the competence of the persons who have performed the work.
    Unlicensed but authorised sign off personnel are perfectly acceptable within an MRO and their presence should be welcomed as they enhance standards but that doesn't change anything with regards verification of the work performed and CRS. As mentioned in the email from the CAA, the CRS is intended to be a quality control process.
    Last edited by ALAE (1981); April 18th, 2018 at 04:55.
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  9. #19
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    Default Re: CRS issue within EASA AEI Press release

    Cheers for the clarification.
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  10. #20
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    Default Re: CRS issue within EASA AEI Press release

    And that is why those that are not members, should be.

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