This chapter will cover the general history of the AME licensing system, the past 40 years and the impact of civil aviation regulations on AMEs and the aviation maintenance industry in Canada and internationally.
The first AME licence was issued in Regina, Saskatchewan in 1919 to Robert McCombie simply because a group of Air Board licensing officers happened to be there. They arrived by train from Ottawa as air travel was not yet the business norm. Reading some documents from the nineteen thirties I followed the organization of an aviation inspectors meeting in Edmonton, Alberta. It took three weeks for seven people to meet. One week to travel from Atlantic Region by train, one week of meetings and one week to get back to their home offices. Interestingly enough the Department of Transport had the same regional structure then, that it had when I joined in 1975; Atlantic, Quebec, Ontario, not including north-western Ontario, Central, Western and Pacific. This regional structure lasted until the great 1995 reorganization which saw the creation of the Prairie and Northern Region covering Alberta, Yukon, Manitoba, Saskatchewan, Nunavut and the North West territories. To this day there is some concern about the vastness of the new Region, and I wonder if it will last as long as the old structure.
Certification of individuals can be traced back to the very ancient times. The earliest written records we have from Babylon, Greece, Rome, Israel, China, etc contain accounts of the rigorous training requirements and certification by insignia or rank. Medieval Guilds and trade organizations carried this practice on in Europe from where our western culture was transmitted to the American continents. Canada being a part of the British Empire for some 300 years carried this tradition on. It was a system that had been tried and proven in the days of the sailing ships and the industrial revolution. In free countries and even in those not so free individual accountability has been a standard for many years. The marine and railroad industries were the two transportation sectors which were first to use the power of steam engines to move vast numbers of people and freight. They soon learned you needed knowledgeable design engineers and technicians because a mistake could mean a ship blowing up from a stressed boiler. On the railroads engines, track size and conditions soon became well engineered and of course needed maintenance. The solution was personal certification of designers and trades. These systems were well known so it was easy to carry the concept over into aviation.
It was soon determined that the old practice of anyone buying an aircraft and learning how to fly it from other pilots or manuals was not going to sit well with public. World War I had trained a lot of pilots who had been under military control and discipline. Once the war ended these men were on the civilian streets and carrying on their flying. It was quickly apparent that some sort of regulation was needed. Individuals were dropping things from aircraft, buzzing villages and generally carrying on. The public was demanding some government regulatory protection. So began the long debate between freedom, safety and protection, a debate which still is continuing today and will continue forever, in my opinion.
The two groups selected by the newly created Air Board were pilots and mechanics. Mechanics soon became known as Air Engineers, carrying on an old British practice of labeling anyone operating machinery as “engineers”. The following paragraphs are extracted from an old report from the nineteen thirties, I believe. I quote,”Political and economic conditions in Canada between the wars made it impossible for the Army, Navy and Air Force to obtain adequate funds to maintain their establishments.” Again I quote, “The General Staff, whose influence was then all-powerful and who did not regard with favour the establishment of an independent Air Ministry, were responsible for the complete disruption of the Air Board’s activities, all to which were turned over to the National Defence Department on January 1, 1923, and became a new directorate, reporting to the Chief of the General Staff. This included the Air Force but the Civil Operations, the Air Regulations and the Engineering Branches, so that the whole service, military and civil, became part of the Air Force. All civil employees were given the option of joining the Air Force or resigning their positions”.
The Civil Operations and Engineering Branches were absorbed by the Air Force,
but public opinion insisted on the continuance of the civil activities while the
licensing functions of the Air Regulations Branch were carried out by Air Force
Personnel, detailed to the purpose from the Air Force. Under this scheme, the
Present Member to the Air Council for Organization was lent for civil duties and
Continued to exercise the functions of Superintendent of the Air Regulations
Branch till September 1939.
By 1926, it was evident that the concentration of both civil and military activities
Under control of the Chief of the General Staff did not provide a suitable organization.
Steps were then taken to form a separate branch for Civil Aviation. It was in 1936 that the transfer of the Administration to civil aviation to the Department of Transport was completed.
Airworthiness and AMEs
The story of AMEs and maintenance in Canada cannot really be told without setting out some of the history of what is known as Airworthiness in Canada. First I want to define what I mean by Airworthiness. There have been varying organizational structures in the federal Canadian Government to deal with the certification of aeronautical products in Canada. There were times when Canada’s Public Service dealt with this matter by assigning it to the Air Board, then the Air Force and then to the Ministry of transport, legally known as the Department of Transport later to become Transport Canada. Today “Airworthiness” is still located in Transport Canada’s Civil Aviation Directorate. Today, 2012, Airworthiness is known as Aircraft Certification but its function remains the same.
When I joined the then Ministry of Transport in 1975 Airworthiness included design certification, manufacturing and maintenance. This somewhat followed the then current Air Force organizational structure. The American model in the Federal Aviation authority was somewhat different as Maintenance was in Flight standards, which is Flight operations and maintenance. These differences caused a lot of debate and some difficulty in arranging bilateral agreements and memorandums of understanding as we had to deal with two separate FAA branches in Washington. Most other aviation authorities tended to follow the FAA model. The reasoning was to better work with the FAA and to ensure maintenance and flight operations were tied close together as was the model in most air carriers. There was, however, a strong counter argument which supported the Canadian organizational structure. That is that the three elements, design, manufacturing, and maintenance were mutually supportive. The advent of Continuing Airworthiness confuses the issue even further. Some defined Continuing Airworthiness as maintenance and design correction by Airworthiness Directives, and others simply as Maintenance.
By the early 1900’s it was apparent that professional engineering and scientific discipline would have to be applied to flying machines if they were to become safe and reliable for civil and military purposes. It was not enough to be an enthusiastic fiddler and inventor. People soon needed to study and understand the theories of flight and flight control to say nothing of producing better, lighter and more powerful power plants. Once the early aircraft started to be produced as commercially available machines, the first air safety questions would arise. Initially they were limited to not dropping things from aircraft as the flying machines soon became known. Later local authorities started to think about the safety of the public on the ground, passengers, and the pilots as well. Once the military became interested in aircraft they soon brought the usual military mind set and the need for standardization, parts interchangeability, and repeatability of parts and processes. To achieve that, manufacturing processes must be consistent and standardized. This was a natural outcome from the early experimentation.
The pressures on politicians for standardization of engineering practices in other fields such as construction, railroads, and marine safety soon lead to governments passing legislation to establish engineering as a profession similar to law and medicine. In Canada this was done by the provincial governments under whose constitutional authority this fell. However, aviation was deemed to be a federal jurisdiction since it was evident very early on that aviation and the air did not respect provincial boundaries. However, the federal government did not create its own professional bodies, but followed and accepted by standard practice the provincial ones. You will find that today the standard practice is that the Professional Aeronautical Engineers in Transport Canada and elsewhere in the Federal public service must hold Provincial certification. I will come back to this matter in another chapter as well as it has caused some problems between provincial Engineering Associations and the licensed Aircraft Maintenance Engineer community in Canada.
The Professional aeronautical engineering community was small in Canada in the 1920’s and it seems most aircraft were certified in either the United Kingdom or the United States of America. Canada seems to have simply accepted them. This practice continued for many years until after the DC-8 accident near Toronto in the early 1970’s. This DC – 8 accident soon lead to new emphasis on having enough Canadian aeronautical engineering skill and knowledge in Canada to evaluate Transport Category aircraft. Transport Canada Aircraft Certification would then make a finding as to whether those aircraft could be added to the Canadian civil register and thereby operate under the Canadian Flag.
The man who was chosen to lead this effort was Walter McLeish, who came from an aeronautical engineering and flying background in the Air Force. His task was to set up a similar situation in The Ministry of Transport civil aviation. He began to rapidly build up the capability by bringing in many professional engineers and test pilots. They were able to add special Canadian conditions in an effort to comply with the Transportation Safety Board findings of the Toronto accident. Walter McLeish was rapidly promoted in the department and eventually ended up heading up the Air Administration. His work earned him selection to the Aviation Hall of Fame.
When I arrived in the Ministry of Transport Ken Owen was the Director of Airworthiness and was responsible for oversight of design certification, manufacturing, and maintenance for Canada. He was also a Professional Engineer and pilot. He carried out his duties through six regional managers, five of whom were Professional Engineers and one AME, John Cody in Atlantic regions. John Mew, also a Professional Engineer, was Chief, Maintenance and Manufacturing. John’s division did not include AME licensing, as this was contained in the Licensing Branch which also licensed pilots and Air Traffic Controllers. Gord Rayner had been the Chief, and Canada’s highest ranking AME prior to John Mew being in the position.
Sometime around this period, early nineteen eighties or even late nineteen seventies our name changed. As part of the great rush to be a Bilingual country the government began eliminating nearly everything linked to our old Anglo history including departmental names. So we went to Transport Canada. In 1936 we had been called the Department of Transport, then after the Second World War, the Ministry of Transport and now Transport Canada. Interestingly enough functions have remained much the same and until the SMS world arrived the organization was very consistent through the three changes.
The 1980s were a great time of work and expansion for all those associated with certification. There was a strong Engineering Division, a Test Flight Division, a Programs Division and a Standards Division. The Standards Division, headed up by Maher Kousam, was not only involved in standards work but also working on the new Airworthiness Manual. This team was headed up by John Mew and it took many years of hard work to complete. The renowned Justice Charles Dubin commission had recommended a rewrite of Canada’s aviation regulations and standards, a task Airworthiness undertook with vigour. For reasons not known to me the Flight Standards side of Transport did not really begin this work until after the Justice Mohshansky Inquiry following the Kenora, Ontario F-28 accident.
Some of the names from that period are , Dave Heakes, Chief Engineering, Frank Davies, Chief, Programs, Maher Khouzam, Chief, Standards, Dick Bentham, Chief Test Flight shortly followed by Jake Wormworth , Stan Didrikson, Continuing Airworthiness.. In my division, Roger Menard was Supt. Manufacturing, Repair and Overhaul, Henry Dyck, Supt. Air carrier, Brian Whitehead, Supt.AME Licensing and Training, and Owen Feltham, Supt, Avionics. The regions were headed up by John Cody, Atlantic, Ray Tardiff, Quebec, John Hamel, Ontario, Bruce Gunn, Central, Jim Gunderson, Western and Alex Uygens, Pacific. This was all in the early 1980’s.
The main certification efforts were directed towards Canada’s growing aviation design and manufacturing industry notably Canadair, DeHavilland, Boeing, Pratt and Whitney, Bell helicopters, the large avionics and component manufacturers. There was also an extensive workload on the engineers and test pilots from new foreign manufactured aircraft and components being imported by Canadian air carriers. The domestic programs required thousands of hours of work and review of engineering submission from industry and a lot of meetings etc. There was also test flying to be done and witnessing of many industry qualification tests.
Even though there was in place a significant delegation system there was no shortage of work for Transport Canada staff. I can personally attest to the many meetings and trips needed to get this all done all the while Canadian customers are restlessly waiting and of course the manufacturers are hoping to soon get their product certified and in service. One can only imagine the debates and technical work needed to certify a large aircraft such as the Boeing 767 or even the earlier Challengers. It was an impressive thing to watch and be part of. Canadians can be proud of the work done on their behalf.
So how does all this affect AMEs? Well to be frank AMEs can only maintain a level of safety originally designed in and manufactured. Obviously AMEs carry out modifications that increase or restore safety margins under the guidance of using engineering approved data. This data can be pre approved as in generic industry standards found in such things as FAA circulars or manuals, AC 43-13 for example, or by STCs, One off modification approvals exist. All this to say that AMEs and Maintenance technicians need to work to approved data of some sort and this all relates back to work done by the people involved in the basic certification process.
This data includes the basic maintenance programs for new aircraft either manufacturer’s recommendations or the results of Maintenance Review Boards. These two areas fell under the Chief, Maintenance and Manufacturing. This work was carried out by Transport Canada Airworthiness Branch, Maintenance Division AMEs in conjunction with the aircraft or component certification work. All this had to be completed to allow the Certificate of Airworthiness to be issued based on the type Certificate. A lot of management and co-ordination was required which was the job of the Programs Division. There also needed to be Master Minimum Equipment List for dispatch use. This was developed mainly from the work of the Flight Test division with input from Engineering, Maintenance and Flight Standards. So AMEs was involved in all phases of certifying an aircraft. The manufacturing inspectors were not AMEs; they were highly skilled technicians, technologists and engineers of many types who had a critical role to perform in ensuring that aircraft and components were correctly manufactured. That would be a subject for another writer to take on.
Years later, after the Justice Mohshansky report, under the leadership of Don Spruceton, Director General Civil aviation, and civil aviation began to rewrite all the civil aviation regulations and standards and advisory material. After I left the Chiefs position, Don Sherritt arrived from the Ontario Region where he had been Director of Airworthiness. Don arrived at a time of great change and brought new energy and ideas. I was in Western Region as Director of Airworthiness at the time. We began to discuss some organization changes which would hopefully clarify some areas of responsibility and accountability and to meet new demands. Transport Canada like other departments, faced budget issues which lead to major changes in the department. The creation of Nav Canada, the devolution of the airports and Coast guard to name the big ones were carried out. I ended up being a part of this massive reorganization where we went from 25,000 employees to 5000. I will write more on this in my next chapter.
Don Spruceton, the Director General Civil Aviation decided to retire and to start a new career in the private sector and Art LaFlamme was selected to replace him. Art continued many of Don’s initiatives including some reorganization internally. The entire Transport Canada organization change led to only five regions not six and I was selected to lead the combined western and central one, now known as Prairie and Northern Region.
In the end the big question was where to best place maintenance and what was its mandate. It was ultimately decided to create an Aircraft Certification Branch and Maintenance Branch. Ken Mansfield was to lead Certification and Don Sherritt to lead Maintenance. This elevated Maintenance to a level not seen since the late sixties when the big push on aircraft certification was begun. This does not diminish certification since Canada is now the number four in aircraft and component manufacturing and is immensely important industrial sector. It does allow maintenance, and by virtue of that AMEs and Maintenance Technicians, to take their place alongside flight operations easier than before, while still keeping the linkages to aircraft certification this work mainly revolved around approving maintenance programs for new aircraft. It was decided to leave Continuing Airworthiness in Certification. After further reorganization to implement SMS and IMS under the direction of Merlin Preuss, who succeeded Art as the DGCA, Certification remains a separate Branch while Maintenance is part of Operating Standards and Standards.
Key events in AME History from Dubin until 2012 – From “Hanger Flying” by Brian Whitehead
Until 1982 all personnel licensing had been handled by a single division within the flight operations branch. Not surprisingly, since the main priority of this division was pilot licensing, the staff members were almost all pilots, and they had no one with a real maintenance background, so Aircraft Maintenance Engineer (AME) Licensing got very little attention, and had been neglected for years. Now we needed to update the licensing system and privileges to complement the new maintenance requirements. Roger had spoken to his counterpart in personnel licensing about this and they’d agreed in principle to transfer responsibility for AME Licensing, but no resources were included in the deal. If Roger wanted to take on the job, he’d have to do it with his existing staff and budget.
When he told me this I reminded him of what I’d been saying for the past year or more: There was no need for a dedicated power plant group, so there was nothing to stop him from re-organizing it out of existence and using the freed-up resources for a new AME licensing section. That’s what he did, so I became the new Superintendent of AME licensing and Training. Naturally we couldn’t afford to deal with licensing to the exclusion of everything else, nor would I have wanted to. I had to keep up with my Airworthiness Manual work for John Mew, as well as handling any odd power plant jobs that might still arise. The advantage of this multitasking though, was that it essentially put coordination of the all various interlocking parts of the maintenance and maintenance-related regulations in one pair of hands.
By this time Lorne Clark had moved on to a regional job and had been replaced by Rick Macejewski. Rick was more interested in line duties than staff work so I asked him to handle the operational tasks such as Maintenance Review Boards and type validations, etc. We’d also recently been strengthened by the addition of Jack MacDonald. Jack had a particular interest in training, so I asked him to take over responsibility for that side of the house, leaving me to concentrate on maintenance policy, AME licensing, and approved organization issues. One of Jack’s main contributions was the introduction of Approved Training Organizations. I’d asked him to set up a system for the approval of type training courses so we could have some confidence that at least a minimum standard was being met. He took it a step further, by establishing quality assurance requirements for the schools and professional development standards for the instructors, thus approving not only the courses but the training establishments themselves.
The Canadian AME licensing requirements were contained in a document known as the Personnel Licensing Handbook, familiarly known as the PLH. That document was in much the same shape as the E&I Manual, being full of confusing band-aid solutions to specific problems. I asked Charlie Warren, with Jack’s help, to draft a more streamlined set of requirements starting from scratch. Soon after, I walked in while they were doing this and found them working from a copy of the PLH — essentially fine-tuning what was already there. I wanted a more drastic approach than that, so to make the point I told them; “No, not like that, like this.” I took the PLH from them and dropped it in the garbage bin, then slapped down a pad of lined paper in front of them. Charlie was amused by this and mentioned something to the effect that I was trying to regulate at warp speed. Thereafter, whenever I took an extreme approach on anything (which I must admit in those days was my usual style) he would refer to me as “Warp factor Whitehead.”
When it came to the AME license system, there was certainly plenty to do. The Canadian license was built on the ICAO Type I/Type II model, under which Type II license holders were authorized to certify aircraft as airworthy at periodic intervals and release them after routine repairs, while Type I license holders were authorized to release aircraft or parts of aircraft after overhaul or major repair. ICAO had made no attempt to define ‘major’ repair, so every aviation authority had its own interpretation, many of which differed widely. To complicate things further, ICAO allowed countries a choice between issuing individual licenses and assigning the same privileges to approved organizations.
Canada’s implementation of the ICAO standard was really screwed up. For one thing, the terminology was reversed, so aircraft were certified airworthy after repair and released after scheduled maintenance — the exact opposite of the ICAO requirement. Furthermore, the system included both ICAO options (i.e., both individual licenses and approved company privileges), with an additional requirement that the two systems ‘were not to be mixed.’ This prohibition was usually taken to mean that once a company decided to allow unlicensed personnel to certify in one case, they had to do it in all cases, which meant ignoring the licenses altogether.
The basic ‘A’ license was a Type II, with privileges for small airplanes (up to 12,500 lb gross take-off weight) in six different groups (piston or turbine, pressurized or unpressurized, and combinations). There were individual type ratings for certain aircraft above 12,500 lb., issued on the basis of either an essay-type examination consisting of the same twenty questions in every case, or upon completion of the manufacturer’s course. However, type ratings were only issued for a limited range of older, medium sized aircraft. No ratings were available for larger aircraft certified in Canada after a particular date. I don’t recall the actual demarcation lines, but essentially the effect was than no ratings were issued for any wide-bodied or advanced technology types. To complete this mishmash of restrictions, holders of category ‘A’ licenses (or their rotorcraft equivalent, category ‘R’) weren’t technically authorized to certify the maintenance of parts. However, this latter restriction was honored more in the breach than the observance.
The Type I licenses were also problematic, the most concern being related to the Category ‘B’ license, which came in two versions, for either aeroplanes or rotorcraft, and tended to serve a very different purpose in each case. On aeroplanes, it was mainly used to certify structural repairs. On helicopters it was primarily for the overhaul of dynamic components such as rotor heads, transmissions, etc. On both classes of aircraft though, the ‘B’ was also required to sign a release following any major repair or modification. For these purposes ‘major’ included any modification significant enough from a design point of view to require engineering approval, regardless of how simple it might be to actually perform the task physically. That created a totally unnecessary and artificial demand.
All license applicants had to get a written recommendation from a current holder of the license concerned. That wasn’t too much of a problem with the Type II licenses, but was quite difficult for the ‘B’ category. In some areas of the country small groups of ‘B’ license holders enjoyed a near monopoly, and sought to preserve it by withholding their approval of any new applicants. When you consider that the Type I category itself was artificial in the first place, this was clearly an undesirable situation.
The upshot of all this was that the larger carriers like Air Canada and Canadian Pacific didn’t use AME licenses at all. In a way that was similar to my previous experience at BOAC, only worse, because at least at BOAC the supervisors all held a license with a type rating, even if they didn’t actually use it most of the time.
As if all that wasn’t enough, the privileges of the AME License were soon to be threatened even further. At that time there was a consultative body known as the National Advisory Council on the Training and Licensing of Aircraft Maintenance Engineers and Technicians. Thankfully, with a mouthful of a title like that, it was simply called the NAC for short. It was comprised of representatives the technical training colleges and the major employers of aircraft technicians, primarily the large air carriers and of course, Transport Canada. Oddly enough, there was one key group of individuals who weren’t represented at all in the early stages. That was the AMEs themselves.
The first NAC meeting I attended was the one at which the chairmanship was transferred to Roger, which to the best of my recollection was in 1983. At that meeting Lorne Amos, a TC airworthiness inspector and member of the Atlantic AME Association, proposed that the AME associations should also be represented. Roger and I were both shocked to find that they weren’t already members, given that AME standards were the whole point of the group. We were even more surprised when the established members showed some initial resistance to the proposal before reluctantly agreeing to allow a single representative to speak for all six regional associations. As Roger pointed out, each of the schools was separately represented, along with several individual airlines, so eventually logic and fairness prevailed. In due course all the regional AME associations gained membership in their own right.
There was another surprise at that meeting, when it turned out that several of the established members had been meeting separately. They tabled a proposal to further restrict the license to aircraft with fewer than ninety passengers. Roger was flabbergasted by that, and initially turned on me, assuming I’d been part of the discussions. I quickly assured him it was just as much of a surprise to me as to him. We both argued vigorously against the proposal and the suggestion was withdrawn for the time being, but it was clear that wasn’t the end of the matter. And this push from the world of the ‘big iron’ wasn’t the only challenge to the AME’s turf. There was also a proposal underway to allow private owners of small aircraft greatly expanded rights to maintain their own aircraft, so the license was under attack from both sides. Obviously having maintenance people managing the AME license program hadn’t come a moment too soon. The sooner we started taking active control the better.
Another aspect of AME licensing that needed priority treatment was the need for an avionics license. At one time the traditional fitter (engine) and rigger (airframe) trades had been all that were needed, but as aircraft became more and more complex, electrical and electronic equipment had become increasingly important. Initially, the need was limited to navigation and communication equipment, but it soon expanded to cover a whole range of additional systems. Autopilots, weather radar, terrain avoidance, collision avoidance, digital instruments and the digitization of previously mechanical systems and devices, had all created a need for dedicated avionics technicians. Training courses had been established and a growing number of trained electronic specialists were already employed in the industry, but so far they had no way to sign for their own work. They had to get a category ‘A’ or ‘R’ AME to sign the release. Even worse, if the work done was considered major (and most modification work was) they had to have it signed off by a category ‘B’ license holder, which made no sense at all, particularly since some of them had no avionics training and relatively little systems background, being primarily structural repair specialists.
For this problem at least, there was some good news. A solution was ready and waiting. Owen Feltham, who’d replaced Roger as superintendent of the avionics section, had been working on a new category ‘E’ (Electronics) rating for some time, and he’d already developed a complete proposal that was just about ready for introduction. The Dubin Commission had specifically recommended that TC proceed with this new category. It was now just a case of combining it with the other changes needed, so we would only have one big shake-up of the system rather than a series of separate steps.
I already had a pretty good idea of what was needed to implement all these changes, but we had to avoid the impression of a predetermined outcome. There was some limited funding available for research and development, but only if it was spent outside the department, so we decided to engage a couple of consultants to study the whole field of AME licensing and provide recommendations.
This was familiar territory, and I was reminded of the Falcon purchase back at Northern Telecom. Obviously the selection of the consultants was critical. Based on John Mew’s advice I interviewed Gerry Wolfe, an expert in maintenance training and a long-time Air Canada employee who was now retired; and Gordon Dupont, until recently the Dean of the aviation maintenance program at the British Columbia Institute of Technology. I was pleased to see they both shared my overall philosophy and were unlikely to stray too far from it, so I had no hesitation in offering them the contract.
The key point we all agreed on was the need to prevent any further deterioration in the scope and privileges of the AME license and, if possible, to reverse the damage that had already been done. Gerry and Gordon studied the complete history of the license to find how it had arrived at its present shape and also looked at the main foreign systems, particularly the US and British ones. They reviewed the Dubin recommendations, visited operators and training schools, and consulted representatives of the AME associations. In due course they produced the Wolfe/Dupont Report, which formed the basis for a complete overhaul of the AME license system.
The report contained many recommendations, some more controversial than others, but they all supported the goal of making the AME license the sole authority to release commercial aircraft after maintenance, regardless of their size. Before even beginning to move forward with that one, we were going to need a lot more consultation with the main stakeholders, including the big airlines.
We had several meetings with the technical management of the main carriers, but initially made very little headway. There was a tendency for our opponents to frame the argument as a trade relations issue. Transport Canada senior management was ‘on the fence,’ but generally inclined to put more faith in the opinions of the industry managers who spoke the language of the boardroom, than in those of a bunch of blue-collar AMEs and airworthiness inspectors with the dirt barely out from under their fingernails.
The view from the opposition always seemed to boil down to the statement: ‘One man can’t maintain a 747.’ Naturally, we countered that by pointing out that one man can’t fly a 747 either, but no one was suggesting the elimination of pilot licenses! At the root of the problem was their lack of understanding of the purpose of the license. Obviously the entire maintenance program for even a single large commercial aircraft, let alone a fleet of them, can’t be handled by one man. But that’s not what the AME license is for. It isn’t a license to perform maintenance, but rather to certify that specific maintenance tasks have been done correctly. Far from being beyond the capabilities of a single person, that’s something that in practice can only be done by a qualified, experienced individual. A maintenance release is always based upon an individual decision, and any attempt to portray it otherwise is just a way of avoiding responsibility by hiding behind the corporate veil.
Too often, under the ‘company release’ system, we’d seen instances of technicians expressing concern about a repair (or the need for a repair in the first place) only to be told it wasn’t their decision to make; that they were merely required to act on the ‘company’ decision. Naturally, there was no record of that decision, which had been communicated by the verbal order of a manager, who in many cases hadn’t seen the hardware concerned and may not have even been in the same city. The written record only ever showed the signature of the technician ‘on behalf of the organization.’ During these discussions I was reminded of my supervisor at BOAC, Mr. Chatterjee, and the stance he’d been forced to take.
The naysayers were adamant. They couldn’t conceive of a situation where it would be acceptable for a working-level AME to hold up the dispatch of a large commercial aircraft. They honestly believed their operations were safe enough as they stood, and that they had sufficiently effective checks and balances in place. In effect, they thought they were too big to make a mistake. They never actually used that phrase, but that’s what their arguments amounted to, and we often pointed that out.
Not all the push-back came from management. Often the AMEs themselves were resistant to change. I was beginning to realize that tinkering with the personnel license rules is a lot harder than working with the strictly technical requirements. When you’re dealing with licenses you’re directly affecting an individual’s earning potential and sense of self-worth. They don’t call it personnel licensing for nothing. Licenses really are personal, in every sense of the word.
There was still a lot to be done to put the new licensing system in place and make the necessary changes to the maintenance organization requirements to accommodate it. Under the new system, AME licensing and company approvals were no longer alternative, mutually exclusive, programs. Instead they were complementary, with AMEs acting on the basis of their license within the framework of the approved organization.
The general principle was intended to be something along the lines of a physician working within a hospital. The organization would provide support, standardization and coordination, but couldn’t supplant the professional judgment of the AMEs. Naturally a supervisor would still be able to overrule a subordinate AME when necessary, but only if the supervisor also held the license and was prepared to use it, making the necessary certification himself. The basic principle was that all maintenance must be released by an individual on his or her own behalf, not on behalf of the employing organization.
Except in certain very specific cases (such as amateur built aircraft) all work actually performed on an aircraft (as opposed to component work performed on the bench and certified as such) would have to be released by a licensed AME. For bench work done by approved organizations, while no license would be needed, the release would still be an individual decision. The organization could decide which of their employees could sign, but they couldn’t simply order them to sign in any particular case. The difference may seem subtle, but it was critical. The principle is the same with components as it is with aircraft — only individuals may make maintenance decisions.
Under the new system, the privilege of an approved organization was to perform the work. All maintenance of commercially operated aircraft, as well as certain types of specialized maintenance, regardless of the type of operation, was to be performed by Approved Maintenance Organizations (AMO). Previously, the E & I Manual had permitted several kinds of companies to perform and certify aircraft maintenance. Among them were Approved Inspection Organizations, Manufacturers, and Air Operators. Under the new system, for maintenance purposes all these would be replaced by the new AMOs.
Replacement of the old Approved Inspection Organizations was generally seen as reasonable. Removing the maintenance privileges of the other two kinds of organization was more controversial. Many countries at the time recognized air carrier maintenance privileges, and virtually all countries allowed manufacturers to maintain their own products. The chief example of these was our next door neighbour, the USA.
I was now proposing that if these two kinds of organization wanted to have the privileges of an AMO, they’d have to meet the same standards and hold the same certificate. It was contentious at the time and feelings ran high, but in the end we were able to counter all the objections and show how problems would be lessened by having a single standard for all maintainers. It’s gratifying now to see that several other authorities have adopted a similar policy, including the European Aviation Safety Agency (EASA).
Removing maintenance privileges from the air operator certificate also recognized a modern reality of the industry, that in many cases it’s no longer practical for an operator, particularly one with multiple aircraft types, to do all its own maintenance in-house. It often makes much more sense to contract with an independent provider specializing in the maintenance of the type concerned. If I had to choose which changes to the Canadian regulations have given me the greatest personal satisfaction, the separation of air carrier and AMO privileges would be right up there along with revival of the AME license. The FAA hasn’t yet made this change to the scope of air carrier privileges, and I’d suggest that to a large extent, their lack of a single standard for maintenance organizations is behind many of the problems currently being attributed to ‘outsourcing’ in the US system.
Getting agreement on the AOC/AMO issue was hard, but the Manufacturer/AMO split was even harder. People instinctively seemed to recognize that the ability to operate an aircraft doesn’t necessarily translate into an ability to maintain it. Maybe they can relate that to the car owner experience, which provides some crude parallels. After all, few drivers are comfortable under the hood of a modern car. The difference between the manufacturing and maintenance worlds is harder to grasp. Nevertheless, although it’s not as understandable as the operator versus maintainer issue, it’s no less real.
With manufacturers, the problem isn’t related to technical capability; it’s more a matter of organization. There’s little doubt that most manufacturers have access to all the equipment and expertise needed to perform maintenance, provided they can bring it to bear when needed. The problem is that manufacturing is a repetitive, highly structured and planned activity, whereas much of maintenance is unplanned, reactive and at times even chaotic. Furthermore, production line standards, tolerances and procedures are different to their in-service equivalents. It’s just not practical or even safe to pull people from the structured environment of the production line and throw them into the maintenance world.
Of course, the manufacturer can always establish a separate unit to cope with maintenance activities, and many do just that. But that’s the whole point — if such a separate unit has been set up in recognition of the differences between needs of the manufacturing and maintenance environments, does it make sense for it to be approved under the manufacturing umbrella, which is based solely on production capability, or should it rather be approved as a separate entity, to the same standards as the maintenance organizations with which it will compete?
The manufacturer’s resistance to this approach could really be attributed to two things; simple pride — “We built the aircraft, don’t tell us we don’t know how to fix it” — and the fact that certain parts of the manufacturing process, mostly at the very end of the production line where the aircraft is being prepared for its test and delivery flights, are virtually indistinguishable from maintenance. We addressed the first of these problems by logic and gentle persuasion; and the second by arbitrarily drawing a line across the manufacturing process to determine where the rules of the manufacturing world end and those of the maintenance world begin. That line is at the point of issuance of the first permanent Certificate of Airworthiness (CofA) or Export Airworthiness Certificate (CofX).
Thus, the manufacturer has control over when the aircraft switches between the two regulatory environments. So long as it has never been issued with a CofA or CofX, it can be worked on under the manufacturing rules. Once the aircraft has been initially certified as airworthy for the purpose of obtaining a CofA or CofX though, it’s considered to have left the manufacturing environment for the operational one. After that point any technical work performed on it is considered to be maintenance, with all that entails, including the need for a release signed by an AME. This compromise was eventually accepted by all parties.
Looking back from where we are today, it seems odd that these matters were fought so hard, but the parties concerned were all very committed to their positions, and the outcomes we take for granted now were by no means seen as inevitable at the time.
The NAC did a lot of good work over the years, until it was superseded by the much more formal Canadian Aviation Regulation Advisory Council (CARAC) that was introduced in 1993. During its time it had dealt with a wide range of maintenance and manufacturing issues, but its primary purpose was always AME licensing, and that’s where its main value lay. The overhaul of the license system was one of the NAC’s success stories. By the time all the dust had settled, we’d been able to not only introduce the new ‘E’ category and make other improvement to the type rating system, but also to reverse the previous setbacks and restore the license to its original status as the sole authority for the release of maintenance.
Ratings were once more available for all aircraft, regardless of size, and the large carriers had adjusted their systems to use the license as the basis of their internal release authorities. We also broke new ground by establishing the Canadian AME license as probably the first combined Type I/Type II license to be issued by a leading authority, thus eliminating some of the inequities of the old system. Annex One to the ICAO Convention already included provision for combining the two license types, but to the best of my knowledge no other country had done it until then.
Not long afterwards, ICAO asked aviation authorities to sponsor members for a study group to review the AME Licensing chapter of Annex One and recommend changes to bring the requirements into line with modern needs. Transport Canada submitted my name and I was selected as one of the nine members. The others were from the USA, Russia, Brazil, Great Britain, Australia, New Zealand, France and Denmark. This was during the Soviet era, so I was looking forward to seeing what position the Russian member would take on the question of individual versus collective privileges. As it turned out I never got the chance, because he didn’t attend any of our meetings. Maybe the KGB was afraid he might defect! Without him, our number was reduced to eight.
The ICAO facilitator explained that we weren’t there to speak on behalf of our sponsoring organizations, but as subject matter experts in our own right, so our input should reflect our own personal views. That was because ICAO is an agency of the United Nations, which back then comprised about 170 member states. Since there were only eight of us taking part in the study group, allowing us to speak on behalf of our sponsoring organizations would give our own countries an unfair advantage over all the other states that didn’t have representatives present. By having us speak as private individuals, this could be avoided. Our countries would get their chance to comment officially at the same time as all the others, once the group had finished its work and the report went to the general assembly. Of course, the reverse was also true. As we were speaking only for ourselves, our sponsoring countries were in no way bound to support us, and would be free to vote against our recommendations if they wished. Two thirds of the member states would have to ratify the proposals before they became binding on the rest.
Six of us on the group had significant hands-on maintenance experience. The remaining two, from France and Brazil, were professional engineers with purely academic and civil service backgrounds. The British member was a CAA surveyor, although I’d never met him during my time with the authority. He knew of me by reputation, which may or may not have been a good thing. I’d worked with the US member, Les (Spike) Vipond before, and we got along well together. We became good friends and got to work together again many times over the next twenty years or so. Spike was a kind of renaissance guy, with a wide range of interests and experience. He was a commercial pilot, aeronautical engineer, mathematician and an A&P mechanic. He’d flown for the CIA in the Congo and was currently a ‘national resource specialist’ for the FAA.
Each of us began with a short presentation on our own national systems and our suggestions for improvements to Annex One. Spike’s presentation was very casual and down-to-earth. He likened the US aviation environment to an ocean, representing it on the blackboard with some crude waves. He explained that it was made up of a few big fish (drawing a couple of whales) and lots of little fish (represented by simple fish shapes). Then he drew a menacing triangular fin and told us that they also had to cope with some sharks. It was a good ice breaker and it helped to get us all started on our discussions.
During our presentations we all put forward our own basic wish-list items, and soon found there were some that we all had in common, so we quickly agreed on them before moving on to the more contentious topics. Then we got down to the serious stuff. I presented two ‘hot’ items, the first being elimination of the dual-level, Type I/Type II structure. Although it took a little persuasion, there was no real objection once the others realized that my proposal wouldn’t affect their ability to control the scope of privileges as they saw fit within their own systems, so we soon agreed to drop the two-level concept entirely.
My remaining item was much more difficult and took up most of the group’s time in the subsequent meetings. I wanted to remove the option of granting certifying privileges to approved organizations. That’s where the cultural differences became marked. The group quickly divided into two schools of thought, those who supported individual responsibility and those who favored company control. I turned out to be the main spokesman for the ‘personal responsibility’ group and I was strongly supported by the American, Australian and New Zealand members. The ‘collectivist’ school was led by the French member, supported by the Brit and the Brazilian. The Dane was on the fence, but leaning toward my position.
All the old arguments about one person not being able to maintain a modern aircraft were raised, but after the recently won, long-running fight in Canada, that whole subject was like deja vu to me, so I was well placed to counter them. If it hadn’t been for the French guy, I’m pretty sure I could have got everyone to come around completely, but he was solidly entrenched. The UK rep went along with him, but I suspect that was only out of EU solidarity.
I suggested a compromise. We could remove the reference to company privileges from Annex One, but replace it with a statement to the effect that any persons who were granted AME privileges by an organization approved under Annex Six, would have to meet the same standards of knowledge, experience and skill as a license holder. The group agreed, and the amendment went forward that way. In due course it was ratified by the required two thirds of the member states and it now forms part of the international standard.
Most of the AME licensing work had already been done by Tony, who’d built on my earlier changes and completed extensive consultations with the industry to come up with a simplified system that eliminated actual type ratings, while still requiring type training for the more advanced aircraft. This was a big improvement, although because of the difficulty in obtaining consensus he was unable to consolidate the system as much as we’d have liked. In order to get industry ‘buy-in’ he was forced to retain two ‘group ratings’ — one for large aircraft and the other for small. Tony and I both recognized that there was no need for this, but the AME’s industry associations felt more comfortable with it, so it was the price of getting agreement on the other changes.
What remained for me to do in licensing was to develop a database to manage the system, and design the license document itself, which took the form of a plastic card, similar to a credit card, bearing the holder’s photograph. M&M had obtained control of licensing on the understanding that we’d manage the extra work out of existing resources, so there was no room in the budget for hiring contractors, which would normally have been the way this kind of project would have been handled. As it turned out, this lack of funding turned out to be a blessing as well as a curse. Being forced to do the work ourselves, enabled us to have absolute control of the process, and by learning as we went I honestly think we ended up with a better product than if we’d simply farmed the thing out to experts.
I developed the database and the system to convert the existing information into the new format, and I also did the page layout for the licence card. One of the licensing inspectors, Claude Deshaies, created a new logo for the card, in the form of TC’s stylized jet aircraft symbol flying out of a Maple Leaf. The downside to doing everything ourselves, of course, was the time taken. It took far longer for us to do the work than professional graphic design and database specialists would have needed, and that was all time taken from our normal duties. The finished design though, was exactly tailored to our needs and contained few of the compromises usually seen in better financed projects.
One outcome of being more widely known internationally was that Tony and I were invited to serve on an FAA Aviation Rule-making Committee (ARC) formed to recommend changes to the A&P certificate. The group was being managed by my old friend Les (Spike) Vipond and the members were drawn from various part of the industry, such as the large air carriers, commuter operators, business, general aviation, unions, etc. The job turned out to be a much bigger task than either the mis-fueling working group or the ICAO Annex one study had been. It took over two years to complete, and we met around twenty times, in different cities all over the States, which is typical of FAA working groups. Because of the scope of the topic we agreed to tackle the work in two phases, with the points of general agreement being resolved first. The idea was that those recommendations could be implemented while we worked on the more contentious issues.
The first point was chapter numbering. The A&P requirements are contained in Part 65 of Title 14 of the Federal Code of Regulations (14 CFR). Part 65 deals with the certification of “airmen other than flight crew,” and covers Air Traffic Controllers, Mechanics, Repairmen and Parachute Riggers. The group was unanimous in objecting to A&Ps being lumped in with all these other specialists, so the first point of agreement was to create a new Part 66 for the A&P certificate. Other non-contentious topics included the removal of gender-specific language like ‘he’ and ‘his’ and adopting the term ‘technician’ in place of ‘mechanic,’ along with some other minor tweaks. We submitted these Phase One recommendations to FAA management so the legal process could begin while we continued working on Phase Two, which dealt with the more controversial topics.
The proposed new Part 66 affected more than just the USA. Because aviation is such a global business, there’s a real advantage in having the various country’s requirements structured in a similar way. Just as ATA 100 standardizes the format of maintenance manuals between different manufacturers, it’s also a good idea to standardize the structure of national regulations between different countries by using a common numbering system. Just to be clear, this is not the same thing as ‘harmonization,’ which would imply standardizing the actual content it’s just a case of using a common numbering system to facilitate comparisons.
Several other countries happened to be working on their own regulations at the same time as us, and they’d already adopted standardized numbering for the chapters on design standards, approved maintenance organizations and maintenance performance, so they took advantage of their knowledge of the ARC’s proposal regarding a new Part 66.
As a direct result of this, Australia, New Zealand, Hong Kong, Singapore and the European Union, along with several other countries, all decided to locate their Aircraft Maintenance Engineer requirements in their respective Chapter 66, in place of the Chapter 65 they’d been planning to use. We would have liked to do the same in Canada, but the Canadian numbering system had already been fixed to the extent of requiring all the airworthiness related chapters to have a three-digit number beginning with five. Accordingly, the best we could do was to locate our licensing standards in Chapter 566.
As it happened, the ARC’s Phase One recommendations still hadn’t yet been processed by the FAA lawyers by the time we completed Phase Two, so Spike suggested combining the two reports into a single set of recommendations to simplify the task. It seemed logical to Tony and me, so we went along with the request over the objections of a good many of the other members, who cautioned us against being too trusting. It was a decision we came to regret, because our vote was enough to tip the balance, so the group as a whole ended up complying with Spike’s request. Later, we both wished we’d listened to the others, because combining all the recommendations into a single report caused the whole initiative to fail.
One of the main features of Phase Two had been the elimination of separate Airframe and Powerplant (A&P) certificates in favor of a single Aircraft Maintenance Technician (AMT) certificate, similar to the Canadian AME License. When the Notice of Proposed Rule Making (NPRM) came before the public at large for comment, this point turned out to be the most contentious. Even some of the organizations that had been represented on the working group and had supported the original proposal, turned against it in the public phase. Another problem was the term ‘Technician.’ Many responders saw that as an exercise in political correctness, like calling garbage men ‘sanitary engineers.’ Some were actually offended by the term and felt it implied shame of the time honoured title of ‘Mechanic.’
The FAA had obviously done a poor job of explaining the rationale behind the proposals. In an attempt to salvage something from this mess, some of us argued for a line-item approach, addressing each individual point on its merits with the hope of at least getting the original Phase One items through, but all our efforts were in vain. The FAA took an ‘all or nothing’ stance, and nothing was what we got. All this was a result of our well-meant and seemingly logical agreement to combine all the recommendations into a single NPRM. Talk about learning a lesson!
As I’ve already mentioned, most of the other national authorities had already adopted Chapter 66 of their own regulations for AME licensing on the understanding that the USA was going to do the same. Now the FAA had dropped the idea, which had been a US initiative to begin with. It was a bit reminiscent of the change-over to the metric system in the early ‘seventies, where Canada switched in the mistaken belief that the USA was going to change also, and then got left out ahead on our own. So, if you’ve ever wondered why the rest of the world puts technician licensing in Chapter 66 of their rules, while the FAA still uses Part 65, now you know. We were engaged to the FAA, but they left us at the altar! End of the excerpt from Brian’s book.
Bilingualism and the AME by Tony Soulis Retired Chief AME Licensing Transport Canada
“You are right about my involvement with the attempt to change the title in French from technician to ingénieur. Of course the full title in French was much longer, but the intent of that Licensing initiative was to have equivalent titles in both official languages, as French Canadians felt slighted – being referred to as mécanicien. This all started with me in the early seventies while I was responsible for helicopter maintenance at the Quebec City Coast Guard base, where we made a lot of noise at the time – and it was being heard in Ottawa.
During that era (circa 1972), I had promised Ray Carrier (AME Quebec City), that if ever I had an opportunity to push for the title change – then I would do so once I was back in Ottawa. Of course, that didn’t happen until the early nineties when I moved from Aircraft Services to Aviation Regulation. As Chief, AME Licensing I wrote a white paper advocating changes to the AME licensing system by streamlining and consolidating licensing ratings (ultimately becoming our current M1-M2 licence). As the new licensing model was about to change, you may recall I was so confident that the French title change would go through (as it was approved by Don Spruston – the then DGCA, that I had the new plastic licences; soon to be issued, inscribed with the new French title (French first for Canadians indicating French as their preference – and English first for English-speaking Canadians).
All that came to a sudden stop when, while sitting in the centre block of parliament waiting to be called in to support any questions that might arise from an Order-in-Council that would sign the new French title legislation into law, when I received a call from Don Sherritt. Don asked me to return to Tower C, TC HQ, because he had some bad news: The whole initiative was being brought to a halt by a protesting TC engineer named, Robert Sincennes. He had successfully lobbied the Quebec Association of Professional Engineers to bring the process to a halt – without any one’s knowledge in higher circles at TC.
The rest is history. I had the old French title reprinted on another set of plastic cards and when the new licensing system came into effect, on 1 August 1999, both Historical AME Certificates and the new plastic AME Licenses were sent out across Canada using AME for English, and technician replacing the ingénieur in the French title. There is much more to the story but that is the essence of what my role was in the attempted French title change.
As for Canadian precedence in using the Aircraft Maintenance Engineer title, that information should still be on record, both at Transport Canada, as well as in court archives, where a federal judge’s ruling upheld use of the title when challenged by, I believe; the Ontario Professional Engineer Association.
His ruling was based on the fact that our title had its roots under the British regulatory model (both marine and aviation), and since that was the basis for the Canadian regulatory regime – then precedence carried forward on that basis. I believe that he also noted that the Air Engineer title (predecessor to AME), predated formation of the professional engineer association seeking to block the AME title in Canada. If I’m not mistaken there were at least two P.Eng initiatives, one in the early fifties and a second in the early seventies – seeking to strip us of our AME titles. I could be wrong – but I do remember having to confirm these events for a presentation that I made to ICAO in the mid-eighties when I was Superintendent, Inspector Engineer-Training under Bob Buckles”. This is the end of Tony’s part.
The average aircraft passenger has little idea of the thousands of people involved and the large public sector workload needed to certify and operate an aircraft. I suspect most licensed pilots and AMEs may not be aware of the totality of the effort. Sticking to AMEs, all work they do on an aircraft, routine inspections, heavy maintenance, repairs are all regulated and supported by the initial work done by certification engineers, manufacturing technologists, technicians and all the support people
This is not to take away from their skill but simply to place their work in the proper context. I always was happy to have worked so closely with so many brilliant and dedicated people from all those fields.
In closing, the full credit for most of the work over the 20 years I played a part in these debates must go to Brian Whitehead and Tony Soulis. As then superintendents and later Chiefs they carried the work and developed most of the ideas. I do not believe it detracts from either Don or I that we set the agenda and defended the positions, but the work was theirs. All credit to them. My most proud moment was actually saving the system from proposals which would have meant its end. Not only was it saved but expanded. All the rest flowed from that fateful meeting. Most AMEs do not know how close the some of the people in Transport came to ending the AME system in favour of accompany approval system only.
Another very important group involved in this story that needs to be noted in the National AME Associations. They were ably led by Ben McCarty and provided the industry knowledge and political clout to save the licence and to go on and improve it. I must commend them and give thanks to all of them and the membership over the last decades.