C release and B1/B2 Support Staff
I came on day shift to work on a delayed C check. I was confronted with a pile of maintenance documents to be signed for. The tasks were complete and the tests have been performed by company unlicensed mechanics approved in accordance with the MOE. I was asked to sign as the final signature on the task cards as there was not any licensed staff on duty during the night shift. The aircraft was ready to leave the hangar, all access panels closed up and the tow truck was connected.
My supervisor wanted me to sign and I did because he stated that there is no need to check the work. Is this correct?
No, this is unacceptable. B1/B2 Support Staff are required to do more than simply checking whether the unlicensed mechanic signed off each work requirement in the clearance column. This is not in accordance with the spirit of the law. The regulation makes a distinction between the compliance role of Category-C Engineers and the more “hands-on” role of B1/B2 Support Staff. The role of B1/B2 Support Staff shall not be viewed in isolation, but as part of a comprehensive compliance system that defines properly the role of non-licensed engineers, B1/B2 support staff and Category-C engineers; accordingly the situation faced in this scenario would not be adequate for the purposes of compliance with the regulation.Blind stamping or signing off work that you have not personally been involved with is completely unacceptable and not supported by the regulation.
Being placed under pressure by your superiors is also completely unacceptable. B1/B2 Support Staff signing these tasks cards do so for one reasons and one reason only; they are accountable for the quality of the work performed. Should there are some future point be an incident or accident as a result of poor maintenance, it will be the Support Staff who lose their licence or even their freedom. Even your personal assets are not safe from confiscation depending upon the circumstances. The individual Licensed Engineer has a duty to abide by the regulations; the Judge, the Courts, as well as safety regulators, will directly look into the engineer’s acts and omissions. The endorsement of a bad practice imposed by the organisation on the basis of financial or other considerations would not be a valid defence. Your task is to ensure that the aircraft was maintained as per the regulations and that the aircraft is in complete compliance with the manufacturers data. You have been issued a Licence independently of your company and your decision making process should also be independent of local issues. You are not responsible for the company failing to fulfil their regulatory responsibilities and therfore should not take commercial or any other pressure into consideration.
Are Support Staff Required?
My company have informed me that B1/B2 base maintenance Support Staff are not required, as staff approved in accordance with our MOE can perform certain tasks without supervision even though they have no licence. This has resulted in my company reducing B1/B2 Support Staff manning levels within base and most tasks are performed without any B1/B2 Support Staff involvement. Is this acceptable?
Answer: No, this is unacceptable. The regulations are specific that Support Staff must be B1/B2 Licence holders for the aircraft type and engine combination. In addition B1/B2 qualified Support Staff must ensure that all tasks have been performed in accordance with the aircraft maintenance manual or other approved data and to the correct standard.
The following statement applies: B1/B2 Support Staff must be satisfied with the competence of the persons performing the work prior to the work commencing. B1/B2 Support Staff must also have inspected a sufficiently representative sample of the work and associated documentation prior to completing the task paperwork. All persons involved in aircraft maintenance must also document their involvement. Therefore signatures from both licensed/unlicensed personnel are required.
Furthermore it is one of the functions of the Category C licence holder to ensure that there are sufficient B1/B2 Support Staff available on duty to ensure the above has taken place. Base maintenance organisations should ensure that there are clearly defined tiers of responsibility in place in order to ensure safe and proper maintenance. Unlicensed mechanics are responsible for the quality of the work they perform. Support Staff are responsible for ensuring the mechanic is competent to perform the task, that the work was performed in accordance with approved data and that the work has been properly completed. This will require an element of supervision. The Category C Certifying Engineer is responsible for ensuring that all of the above takes place before issuing the release to service.