Chapter 6: Independent Certifying Staff

Who are independent certifying staff?

Most AMEs release aircraft on behalf of an approved organisation (CAR-145, CAR-CAO or former CAR-M Subpart F), holding that organisation's certification authorisation. Independent certifying staff are licensed engineers who issue a certificate of release to service (CRS) in their own name, on the strength of their CAR-66 licence, without an organisation behind them. The syllabus (10.4, for B1/B2/B2L/B3) asks you to know their privileges, responsibilities, record-keeping, limitations and oversight under CAR-M, CAR-66 and CAR-ML.

Who may issue a CRS — the three routes

The CAR-M limit — complex maintenance tasks

Under CAR-M, independent certifying staff may not release the complex maintenance tasks of Appendix VII to CAR-M; those must be released by an approved organisation. Complex tasks include:

• modification, repair or replacement by riveting, bonding, laminating or welding of primary airframe parts — box beams, spars, spar flanges, stringers, wing main ribs, engine mounts, fuselage longerons and frames, seat rails, landing gear struts, axles, wheels;
• modification or repair of skin needing a jig or fixture, pressurised skin with damage over 15 cm (6 in) in any direction, or load-bearing parts of the control system;
• on a piston engine: dismantling and reassembly (other than for cylinder access or oil pump inspection), dismantling reduction gears, welding and brazing of joints, disturbing parts of bench-tested units;
• balancing of a propeller (with limited exceptions) and overhaul of variable-pitch propellers and similar specialised work.

Responsibilities of independent certifying staff

• Hold and satisfy CAR-66: a valid licence with the right category and rating, and the 66.A.20(b) conditions — 6 months' experience in the preceding 2 years, adequate competence, and language ability. There is no organisation to check this for you — it is your personal responsibility.
• Use approved maintenance data and follow the aircraft maintenance programme (AMP); perform maintenance to the standards of CAR-M Subpart D / CAR-ML Subpart D.
• Responsible for the tasks performed (ML.A.201(c)). You may be assisted by one or more persons, but only under your direct and continuous control (M.A.801(d), ML.A.801(d)).
• Issue the CRS only when all required maintenance has been properly carried out, and never when there is a known non-compliance endangering flight safety.
• If the required maintenance cannot be completed, the CRS may be issued within approved aircraft limitations, stating that the maintenance was not completed and any airworthiness or operational limitations.

Contents of the CRS (M.A.801(e) / ML.A.801(e))

1. basic details of the maintenance carried out;
2. the date the maintenance was completed;
3. the identity of the person issuing it — for independent certifying staff, name and licence number;
4. any limitations to airworthiness or operations.

Record-keeping

• The CRS must be entered in the aircraft continuing airworthiness record system as soon as possible and not later than 30 days after completing the task (ML.A.305(a)).
• The records comprise the aircraft logbook, engine logbooks or module log cards, propeller logbooks and log cards for life-limited components, and must show the status of ADs, modifications and repairs, AMP compliance, life-limited parts, the current mass and balance report and deferred maintenance.
• Entries must be clear and accurate; a correction must leave the original entry visible.
• Detailed maintenance records are kept by the owner (or contracted CAMO/CAO) for at least 36 months after release, until superseded by equivalent information.
• For your own licence, keep a personal maintenance experience log showing where, when and what you did — needed for the “6 in 24” condition and for extending or renewing your licence (AMC 66.A.10).

The pilot-owner

A pilot-owner holds a valid pilot licence (or equivalent) for the type or class and owns the aircraft (a natural person on the registration, or a designated member of a non-profit recreational body that owns it). Under M.A.803 the pilot-owner may release limited pilot-owner maintenance on non-complex aircraft of 2 730 kg MTOM or less not used in commercial air transport, commercial specialised operations or commercial training. The pilot-owner may not do tasks that are critical maintenance tasks; require removal of major components; are for an AD or airworthiness limitation (unless the AD allows it); need special or calibrated tools (except torque wrench and crimping tool) or test equipment/NDT; are unscheduled special inspections (e.g. heavy landing); affect IFR-essential systems; are Appendix VII complex tasks or component maintenance; or form part of the annual/100-hour check. The CRS records the pilot licence number.

Aircraft grounded where no certifying staff are available

If an aircraft is grounded where no approved organisation and no independent certifying staff are available, the owner may authorise any person with at least 3 years of appropriate maintenance experience and proper qualifications (an ICAO Annex 1 licence for the type, or an authorisation from an ICAO Annex 6 approved organisation) to maintain and release the aircraft. The owner must then:

1. keep in the aircraft records the details of the work and the person's qualifications;
2. have the work re-checked and a new CRS issued by an appropriately authorised person or organisation at the earliest opportunity — within 7 days (CAR-M), or under CAR-ML within 7 days, or 30 days for aircraft not operated commercially;
3. notify the contracted CAMO/CAO — or DGCA if there is none — within 7 days of the authorisation.

Oversight of independent certifying staff

• DGCA oversees independent certifying staff mainly through their licence: CAR-66 conditions, Rule 61 and Rule 19 (suspension, cancellation, endorsement), and the obligation to produce the licence within 24 hours when asked (66.A.55).
• Their work is also seen through the aircraft: the owner must give DGCA access to the aircraft and records (ML.A.201(g)); DGCA carries out airworthiness reviews and issues the ARC for CAR-ML aircraft (ML.A.901 — the ARC is valid for 1 year); aircraft continuing airworthiness monitoring and inspections (Rule 156) may review CRS entries.
• In DGCA's CAR-ML, the airworthiness review paragraphs that EASA gives to independent certifying staff (ML.A.903–905) are reserved — so in India independent certifying staff do not issue ARCs.

Chapter summary

• Independent certifying staff release in their own name under CAR-66, for privately operated general aviation aircraft.
• CAR-M: not for complex maintenance tasks (Appendix VII). CAR-ML: may release maintenance on privately operated light aircraft.
• Personal responsibility for the 66.A.20(b) conditions; assistants only under direct and continuous control; CRS shows name and licence number.
• CRS entered in the aircraft records within 30 days; records kept at least 36 months; keep a personal experience log.
• Owner-authorised person: 3 years' experience, re-check within 7 days (30 days non-commercial ML), notify within 7 days.
• Oversight through the licence, aircraft inspections and DGCA airworthiness reviews.