AME license ratings

[qa guy]

Just hoping someone can shed some light on this situation. From what I read in the CARS an AME license rating covers all S and E work that fall under the scope of the M1 or M2 ratings. The AMO I work for is approved for certain amounts of E and S work. eg: Transponder correlation tests. We have contracted E and S guys that sign off this work. I have done alot of research, and according to the CARS this is not necessary. My transport inspector syas it is specialized work and requires that rating on a licence. However the regs only state that an AMO must be approved for the specialized work. I have asked him to show me where it states this info.
Agree or disagree?

566.03 Issuance and Endorsement of an AME Licence
(8) Ratings.

(a) The scope of maintenance release privileges will be indicated by rating designators entered on the licence, as follows:

(i) M1: Non-turbojet aircraft built to CAR 522, 523, 523-VLA, 527, 549 and equivalent standards (includes all airframe, engines, propellers, components, structures, and systems of those aircraft), and the aircraft listed in paragraph 566.03(8)(b).
(amended 2003/09/01; previous version)

(ii) M2: All aircraft not included in M1 (excluding balloons) (includes all airframes, engines, propellers, components, structures, and systems of those aircraft), and the aircraft listed in paragraph 566.03(8)(b).
(amended 2003/09/01; previous version).

(iii) E: Aircraft electronic systems. (includes communication, pulse, navigation, auto flight, flight path computation, instruments and the electrical elements of other aircraft systems, and any structural work directly associated with the maintenance of those systems);

(iv) S: Aircraft structures. (includes all airframe structures);

(v) Balloons.

(b) Holders of either an M1 or M2 rated AME licence also have maintenance release privileges for all:
(amended 2003/09/01; no previous version)

(i) turbine powered helicopters; and

(ii) SFAR 41C aeroplanes, including their associated variants and derivatives.

(9) Additional ratings.

An AME may apply for additional ratings by meeting the requirements specified in 566.03. Credit will be granted for any requirements that were met in qualifying for the currently held ratings.

Information Note:
Individuals who hold both an M1 and M2 rating will not be issued any additional ratings (e.g. E or S ratings), as those privileges are already held within the scope of the combined M1/M2 rating privileges

[iflyforpie]

An M1 and M2 covers S and E (I've got M1 and M2 myself as well).

If the AMO is approved for the specialized work, has the equipment and facilities, and you have been trained in how to use them and are comfortable signing them off on your license, then you can sign it off.

The only thing that would change this is if you have something in your MPM that says only an avionics guy can do it (due to unions, company structure, etc).

I limit what I sign to what I know about. Even if my AMO had approval for specialized avionics work I would never sign it off since I've had no formal training (CYA)-even though I know how to do things like a transponder correlation.

[jetdoc]

Agree, if the AMO has the specialized rating, they specify in their manual what the qualifications are of the person who performs the work. I.E. if the manual is written is such a way that it specifically says a "E" licensed person must perform the work then that is the way it must be. Hopefully the company manual is broad enough to include a M1/M2 individual with E experience/training.

PS you not the first to have this problem, I have had this argument with a couple of companies, even lost out on a job several years ago over it, they would not accept my M1/M2 and all my avionics training (an approved school) plus experience because their manual said an avionics person had to have a "E". period>>!!

I even gave them this bit of legislation that you have quoted and they still did not change their mind...maybe they have now?

[qa guy]

Luckily for us the manual only states that the company is approved. No reference is made to who signs it off. At the time of MPM approval (and presently) we had an E and S guy. I am just hoping to prepare should these guys call it quits. (they are oldtimers).
Thanks guys for the quick input. Want to make sure I have all the facts before I challenge this.

[jetdoc]

The only point I think you inspector has a point on is since it is still specialized work that falls under the E umbrella, how do you justify/qualify the person who signs the work?

Just like many other AMO's it only takes one qualified person employed within the company to do the work, you will still need a "E" person of some type and that will have to be a M1+E, M2+E, or M1/M2 (with "E" background) to retain the specialized rating.

[mag check]

As far as I know, the only way that an M1 or M2 guy can sign off the S or E stuff is if he can show the relevant training/experiance. ie the tasks specific to the scope of work certified in his AME logbook. You gotta have those ATA's signed off.

[Ballsssssss]

I believe that with an M1/M2 license you have the authority to sign out E and S work, but you have to have sufficient documentation/training records to show that the person doing the work (not necessarily the signatory) has relevant training/experience in that type of work. For your MPM requirements all you would likely have to do is have an S or E trained contractor on file.

[qa guy]

That makes sense to me but....
Information Note:
Individuals who hold both an M1 and M2 rating will not be issued any additional ratings (e.g. E or S ratings), as those privileges are already held within the scope of the combined M1/M2 rating privileges
Keep in mind we are only dealing with m1 at my AMO. The regs do not even state anything about additional training. Just that the AMO needs the approval.

[mag check]

Correct, you won't get a new license with an s or e on it, however, just having an M1 and M2 doesn't let you sign off everything under those headings.
If you have an M1M2, but no welding experiance, you can't weld up and certify a beaver birdcage.

[qa guy]

Correct, you won't get a new license with an s or e on it, however, just having an M1 and M2 doesn't let you sign off everything under those headings.
If you have an M1M2, but no welding experiance, you can't weld up and certify a beaver birdcage.

Yes having an M1 or M2 does give me all those privelleges. It does not mention anything about a new licesnce ....It states a person can not obtain the rating since it is unnecessary. Specialized maintenance only references an AMO's approval for it. It is within the licensing scope. May sound crazy, but thats how the regs read. Hoping somwone can prove me wrong, before I challenge Transport on this.

[qa guy]

Another eg: Helicopters are also included in the scope of the license. I have never worked on one.....but am licensed to sign off the work. (not that I would)

[jetdoc]

The point is regardless of the license you hold, you cannot sign anything that you do not hold experience and training.

An M1/M2 guy with say a -8 type course can not sign out a 747 anymore than he can sign out a transponder recert.

The big grey area is since TC got out of the business of managing type ratings on AME lic, it is up to the AMO's to come up with their own system of deciding who can sign out what, and in their respective manuals they spell out what training/experience/recency an individual has to have in order to qualify for the AMOs authority to sign on behalf of them.

Saying that because the regulation is that an M1/M2 individual has the same priviliges as an E or S is saying that this person would have to have the SAME training/experience as an E or S person in order to certify the work.

The privilige of our license is we have the meet the standard in order to certify the work.

I have an M1/M2. started as an E. I am very comfortable signing out any work on any aircraft I have type training on (M2), loads of small M1 catagory stuff, avionics on just about anything, but if someone asked me to sign out a specialized sheet metal repair on 152 I would say no!! I do not have the training or expericence to sign out any S work and would not, and if an AMO i worked for told me to I would tell them to pound sand.

[Wonderdog]

QA at Tindi, Borek or Zimex would a deregulated answer.
SMcL.

[qa guy]

I agree training is a must. Keep in mind though there is no type rating on M1 a/c.
In the late 90's transport included structures training in the program. I did it, as well as transport exams relating to structures. (the real exams...done at the T.C office) Riveting a skin....or a spar is not much different. Just follow the book.

[qa guy]

QA at Tindi, Borek or Zimex would a deregulated answer.
SMcL.

???

[mag check]

http://www.tc.gc.ca/civilaviation/maint ... s/C011.htm

"Note: Exercising the privileges of the license is subject to the holders’ experience, skill and training."

Seems pretty clear. If you can't prove you have the "skills" then you can't sign it out.

When they come looking, you better have the experiance/training, or you're toast.

[Ballsssssss]

http://www.tc.gc.ca/civilaviation/maint ... s/C011.htm

"Note: Exercising the privileges of the license is subject to the holders’ experience, skill and training."

Seems pretty clear. If you can't prove you have the "skills" then you can't sign it out.

When they come looking, you better have the experiance/training, or you're toast.

I disagree with that. It is my understanding that you can sign out S or E work provided the work was done by someone qualified to do it. When they come looking you had better have the paper trail showing that the person that did the work was qualified.

[mag check]

http://www.tc.gc.ca/civilaviation/maint ... s/C011.htm

"Note: Exercising the privileges of the license is subject to the holders’ experience, skill and training."

Seems pretty clear. If you can't prove you have the "skills" then you can't sign it out.

When they come looking, you better have the experiance/training, or you're toast.

I disagree with that. It is my understanding that you can sign out S or E work provided the work was done by someone qualified to do it. When they come looking you had better have the paper trail showing that the person that did the work was qualified.

I have to disagree with that, a first year apprentice can do the work, the guy certifiying needs the "skills" to certify it was done properly.
Not that it really matters, cause when TC comes looking, the're going to find something to fault you on

[log sheet]

I agree, how can you certify that the job was done correctly if you don't know how to do it yourself? Well they say if you have the combination of M1,M2 and the relative experience and training you have the other privelages. Really , how do you prove the experience and training? Your college diploma? Your logbook tasks? I had experience and training and Log book tasks before I got issued an AME E Licence but without the Licence I couldn't sign a maintenance release.
Now I have an M1,M2 so the E Rating does not appear on my Licence anymore. Now if I want to move on to a new company, how do I get an E ACA , all I can "prove" is I have an M1,M2. Thats all I have on paper. The way I understand it's the proof that you are qualified is what is needed before an AMO can grant you the ACA? I guess if the company makes up a 5 question exam and you pass it you can now have the ACA. What a Freakin joke!
The statement in CARs says if you ave the combination of M1,M2 no other rating will be granted...........too bad it didn't tell them what to do if a guy with an E or S got an M1, M2. I guess in their eyes we will strip the E or S rating and leave them without proof that they ever had the other.

[log sheet]

Now for the original question, I'll ask 2 questions. How does an AMO get the rating added to their AMO? Look up what is considered specilized maintenance with respect to "E". Now ask youself if the work you want certified is specialized or not?
Answer those 2 questions and I think you'll have yor answer.
Other than that it's all opinion.
Cheers!

[SeptRepair]

Hey logsheet, not sure how long ago you were an E but they did at one time give out the historical record for those of us who had S or E. It was to prove you had a license in that area in case you became M1/M2 much like yourself. My historical record says I used to have S32,S33 and M1. My license now says i have S and M1. The historical record is handy in the case you just stated.

[SeptRepair]

The point is regardless of the license you hold, you cannot sign anything that you do not hold experience and training.

An M1/M2 guy with say a -8 type course can not sign out a 747 anymore than he can sign out a transponder recert.

The privilige of our license is we have the meet the standard in order to certify the work.

I agree with this explanation. Recently i had to get type training to be ACA on a Turbine powerd Cessna 206. I have tons of expereince maintaining 206's/210's but minimal amount on a Rolls Royce C20-250. If i had a course on the C-20 then no problem, however I didnt and had to get a type course on this peculiar machine. I disagreed with this ruling by transport, but fortunately I have an excellent company backing me and they willing put me on course to satisfy Transports requirements.

[SeptRepair]

Riveting a skin....or a spar is not much different. Just follow the book.

Thats a pretty bold blanket statement. Its not all cut and dry like you seem to think stuctures is.

[iflyforpie]

Remember that doing the actual work does not have to be done by the person signing it out. It simply has to be inspected to ensure all critical steps were done by an appropriately rated individual. After all, we all know that 90% of the work is done by apprentices anyways.

Jetdoc I don't agree with the -8-747 and M1,M2-E comparison. If I was to go get an 747 endorsement I could add it to my license next to the -8 one. But if I was to go back to school or do OJT for avionics and log it TC wouldn't issue me an E license.

I remember there was a chart of license privelages (based on an appropriately rated AMO) that layed out specialized and non specialized work. In the case of specialized avionics work, an E license could sign it out, or an M1, M2 could. I wish I could remember where I put it or find it online.

If you've been trained how to do a correlation in accordance with company SOPs (there isn't a correlation endorsement) then do it. Ask the company to provide training records. The CARs spells it out pretty clear that you can exercise E privelages with an M1,M2 provided you know and are comfortable with signing.

I won't use the E and S privelages only because I don't have the skills...yet.

[log sheet]

they did at one time give out the historical record for those of us who had S or E.

Hey , thanks for reminding me of that, I did have that at one time when they changed the Licencing , used to be E21,E22, and E 23 then they went to E. Should be able to get a copy from Transport..... pretty sure the one I had is gone, a casualty of one of my moves.
Cheers!