Role of Licenced Aircraft Engineer (AME) Associations
Issue Paper Number 1-
Role of Licenced Aircraft Maintenance Engineer (AME) Associations
Prepared by Peter Jenkins, Past President
Purpose: For policy discussion
The existing AME Associations only represent about 10% of Canada's licenced AME’s. In addition there seems to be lack of clarity and uncertainty surrounding the role of AME’s in the Canadian aviation world and in the public's mind. This uncertainty is not helped by the regulator's (Transport Canada) ambivalence to the AMEs' role in general.
The Air Engineer Licence of the early days, 1920s, was meant to assert federal jurisdiction over the certification of airworthiness for Canadian registered aircraft by recognizing a national standard for technical and regulatory knowledge. By the 1970s it was well known the organizational environments greatly influenced the outcomes of AME's work. The best of both worlds was obtained in the 1980s by combining both systems with the introduction of the Approved Maintenance Organization rules.
In the earlier years all technical quality control was invested in the licence, in later years it was known to more truly represent it as an acknowledgement of it as an extension of the Minister of Transport's duties and oversight of aircraft maintenance inspection and certification. It seems the lack of a truly focused national approach by AME’s continues to add to the apparent confusion about roles. This is not helped by the fact that in private aviation the role of the AME has not changed much since the 1920s as it still is the technical standard.
Since the 1980s and the formation of the Canadian Council for Aviation and Aerospace, formerly CAMC, to lead the development of national technical standards for aviation technicians, the role of AME’s should be more clear to all. The building of an extensive technical college system outside of military aviation was a necessary step to professionalize the technical side of the basic block of AME knowledge.
The national reality of the regulatory system forced the local regionally based system of AME associations to form a loose national organization. AME associations have done some great work on symposiums and commenting on regulatory issues but have not been nearly so successful on augmenting and promoting the role of and need for Licenced AME’s to the public and Transport Canada. In fact it can be argued that the AME system only exists because senior people at Transport have supported it. This was not always the case and may not remain so.
• Defining the role of AME associations and AMO's,
• Creating a truly national voice for AME’s,
• Advocating for AME’s at the most senior levels of Government,
• Intervening for AME’s at the industry level and the Transport Civil Aviation HQ and regional level,
• Aligning current associations with TC regional boundaries.
The local AME associations need to create a truly national organization that has a permanent Ottawa based operation.
We also need to refocus on the advocacy role of AME associations and on the higher goals of the AME community, including the rendition of the critical role they play in the safety of aviation.
We need to transition the work done at organizing symposiums to AMO associations to allow better focusing on some larger strategic issues.
We need to rely more on professional full time workers rather than on overloaded volunteers.
We need to recruit AME leaders with significant business and governmental expertise to better navigate the halls of government, industry and academia.
We need to build an action plan based on the suggested items e-mailed to me (Peter) from Dave Dueck and any other items such as listed above.
Transport Canada needs to clarify some of its regulations and advisories regarding AME licensing and privileges relating to it. See appendix A.
Civil aviation industry has some reform activities it needs to fulfill. See appendix B.
We need to ensure Transport Canada's protection of the privilege of being an independent government inspector. We need to obtain a licence definition in CAR 101of the Aircraft Maintenance Engineer licence as a ministerial inspection and certification authorization of maintenance work performed on an aeronautical product, and a Staff Instruction of the correct understanding of the privilege for Transport Canada (TC) inspectors. AME’s needs to request TC to issue an advisory circular about AME privileges.
Have TC remove technical content in the TC AME regulatory exam database that is not relevant to AME licence inspection and certification authority.
Work with the provinces to obtain a correction of the definition of an AME in provincial labour law. Ensure that any effort by provinces to establish an aircraft maintenance apprenticeship is not presented as an AME apprenticeship.
Obtain a change to the incorrect identification of an AME in Quebec as a technician, based on regulatory clarity.
Educate by means of a TC Advisory Circular on the clear distinction between the Canadian AME and American A & P licences.
Obtain improvements and/or corrections as applicable, in regulatory guidance material and other TC publications and the resurrection (with applicable updating/improvement) of Airworthiness Notice C6 as a CAR 403 Advisory Circular.
AME associations need to work with TC to convey the correct distinction to employers regarding the privileges of individual AME’s.
Obtain changes to all regulatory wording that conveys incorrect understanding of the true role of AME’s and support AMO's acceptance of CCAA technician standards for technician qualifications. This will help people understand the difference between a technician's responsibilities and AME’s.
Promote the distinction of the AME licence from any CCAA technician certification and challenge any incorrect understanding by TC regional staff when issuing licences. Be ready to challenge any incorrect understanding by TC regional staff during industry surveillance and challenge any use of references to "AME apprentice", including in employment advertisements. Encourage TC to convey the correct civilian technician and licence distinctions to Canadian military personnel.
Ensure that TC maintains and promotes the difference between maintenance certification and product certification, including the distinction from an operator's maintenance control responsibility of aircraft release/technical dispatch. Work to obtain improvements and/or corrections as applicable in regulatory guidance material and other TC publications.
Advocate for changes in TC regulatory wording from "maintenance release" to a term that clearly conveys certification of maintenance without possibility of being interpreted as certification of an aircraft or any component aeronautical product.
Obtain changes in regulatory wording from "maintenance control" to "aircraft control" or other phrase that clearly conveys owner responsibilities in keeping with the definition of aircraft "owner". Promote in TC clear regulatory wording that conveys the distinction between maintainer work records and owner technical records. Then convey the proper understanding to aircraft operators, including private owners. Promote the correct distinction to college maintenance training program personnel.
Appendix B - Industry Responsibilities
Aviation associations need to clearly explain the distinction between maintenance certification and product certification, including the distinction from an operator's maintenance control responsibility of aircraft release/technical dispatch.
Approved Maintenance Organizations (AMO) need to convey the correct understanding of the AME privilege to members and ensure correct understanding of the privilege to AMO employees.
AMO's should assume the responsibility for the annual symposiums and conduct geographical area workshops by association leadership, including in the northern and other remote areas. They should also support local annual one day AME conferences pertaining to current AMO/AME issues.
Aviation associations need to support AMO acceptance of CCAA technician standards for technician qualifications and promote the distinction of the AME licence from any CCAA certification.
AMO’s needs to support the AME’s by challenging any incorrect understanding by TC regional staff when issuing licences or certification authorities and contest any incorrect understanding by TC regional staff during industry surveillance.