Project MS 13/10 - Amendment to Part 66 Manual of Standards (MOS) - Miscellaneous Minor Amendments
Project closed 22 May 2014.
The Part 66 Manual of Standards Amendment Instrument 2014 (No. 1) which made miscellaneous minor amendments to the Part 66 Manual of Standards, was registered on the Federal Register of Legislative Instruments - Australian Government ComLaw website (FRLI number F2014L00492) on 2 May 2014 and came into effect on the day after registration.
The amendments contained in this instrument are now incorporated into the Part 66 Manual of Standards which is available on the ComLaw website at the following link:
- There is an inconsistency that exists for the basic knowledge and competency requirements for a subcategory B1.1 and B1.2 licence as currently defined under paragraph 66.A.25 (f) of the Part 66 Manual of Standards (MOS).
Paragraph 66.A.25 (f) of the Part 66 MOS does not currently take into account the relevant optional units of competency listed and coded in Appendix IV of the Part 66 MOS for propellers for applicants of subcategory B1.1 or B1.2 licence ratings that include propellers.
- There is an inconsistency that exists for the basic practical experience requirements for the various aircraft maintenance engineer licence categories and subcategories, as currently defined in section 66.A.30 of the Part 66 MOS.
Subparagraph 66.A.30 (a) 2. will be standardised with subparagraph 66.A.30 (a) 1. so that practical experience received in training is recognised for all licence holders.
- Under subparagraphs 66.015 (2) (n) (i) & (ii) and having regard to subregulation 11.055 (1A) of CASR 1998, the Part 66 MOS may specify the theoretical elements and the training level for each theoretical element required for aircraft type training.
The Part 66 MOS does not currently take into account instances where, for example, two aircraft (engine) types of an aircraft manufacturer/series have the same or similar B2 systems and a B2 licence holder holds an existing rating for one of the aircraft types. If a Recognition of Prior Learning (RPL) assessment has been carried out by CASA, which determines the current aircraft type rating held by the B2 licence holder does not differ from the theoretical element requirements for that same system for the other similar aircraft (engine) type, then CASA may decide that no additional requirement for further training by the B2 licence holder to gain that rating on their licence is required.
- Not all licensed aircraft maintenance engineers (LAME) work a standard day or standard hours with a single employer. Given split shifts and multiple workplaces a literal interpretation of the terms 'months and days' does not always provide enough detail for a LAME to show compliance with paragraph 66.120 (2) (b) of the CASR 1998, which requires a LAME to have had at least 'six months experience in a two year period' exercising the privileges of their licence.
CASA wants to ensure that there is no question that the Acceptable Means of Compliance (AMC) currently developed and further being developed for the paragraph 66.120 (2) (b) of the CASR 1998 requirement, are correctly framed within the law. CASA plans to amend the Part 66 MOS to provide clear legislative cover for the new AMC (which provide hours and days compliance alternatives to the six month requirement).
This matter could become a compliance issue for those LAME not in a standard workplace and employment situation. The risk of no legislative change is that some LAME would not be able to demonstrate continued 'six month in two years' experience even though their hours of experience should demonstrate compliance. The consequences of non-action is that LAME would unnecessarily be required to re-qualify for a licence.
- Feedback from industry suggests the need for clarifying that licence holders seeking their first aircraft type rating in an alternate licence category or subcategory not currently held by the LAME, must first gain the relevant category or subcategory.
The objectives of the project are to:
- Outline in paragraph 66.A.25 (f) of the Part 66 MOS that an applicant for a subcategory B1.1 or B1.2 licence rating that includes propellers must hold each relevant optional unit of competency listed and coded in Appendix IV of the Part 66 MOS that is marked P for the subcategory.
- Correct the inconsistency that currently exists in section 66.A.30 of the Part 66 MOS for the basic practical experience requirements for the various aircraft maintenance engineer licence categories and subcategories.
- Clarify that for instances where two aircraft (engine) types of an aircraft manufacturer/series have the same or similar B2 systems and a B2 licence holder holds an existing rating for one of the aircraft types, the B2 licence holder may be granted the other rating for the other aircraft type if it is determined through an RPL assessment that the training undertaken by the B2 licence holder for that B2 system meets the training requirements of that B2 system for the other aircraft type in such a way as further training is not warranted.
- Provide within the Part 66 MOS and its associated AMC/GM document an AMC, supported by legislation, that details combinations of hours and split shifts that would allow a LAME to demonstrate 'six months in two years' exercising the privileges of their licence.
- Clarify that category training for an alternate licence category/subcategory must first be completed by a LAME prior to seeking a subsequent rating (second rating) on their existing licence.
CASR PART 66
This project was approved by: Peter Boyd, Executive Manager Standards Division on 14 May 2013.
16 December 2013
This Consultation Draft closed for comment 31 January 2014.
View the project history.