ENG760 - Engineering licensing system

Initial Report

Precis of Report Text
I have been in aircraft maintenance for over two decades, certifying as a Licensed Aircraft Engineer (LAE) for 10 years. I worked with multiple MROs and airlines within line and base maintenance. This is the most I have become concerned about aircraft maintenance safety and standards. Directly related to how individuals can and are circumventing the system. LAEs play a crucial role in ensuring aircraft safety and airworthiness. Becoming a LAE requires rigorous training, experience, education, and certification. My particular concerns include:

  1. Education and Training. Many individuals entering the field lack completion of an approved apprenticeship or relevant educational background in aircraft maintenance.
  2. Work Experience. Many individuals have not had relevant experience in role and it’s difficult to prove otherwise. It is believed that staff can have their experience logbook fictionally created and stamped by way of financial rewards.
  3. Licensing Requirements. While applicants are aware of licensing criteria, there are instances where individuals may exploit loopholes in the system.
  4. Examinations. It usually takes many years to achieve all modules. A colleague of mine informed me he recently completed one module at [Training Organisation]. The instructor openly talked about how he is sent to different countries to deliver CAA-approved instruction and examination in 3 months to complete; the first month to teach English then two months to complete and pass all modules to B1 and B2 level. I have also heard some people taking as little as two weeks. Some pay other people to sit their exams using their identification.
  5. Licence Application. Similar to licensing requirements, the application process itself may not be immune to manipulation.
  6. Continuing Education and Renewal. Continuation training can be completed online and is not difficult, even for a novice.

Other concerns to note:

As a licensed engineer, I observe significant differences in human factors and culture, particularly regarding honesty and integrity, compared to previous work environments. The fear of termination for errors is evident, as noted in the incident described below concerning a routine Variable Frequency Starter Generator (VFSG) service where unsupervised actions could have led to fitting a damaged chip detector.

Regarding interviews, allegedly candidates have access to interview questions beforehand, allowing them to rehearse responses. Some applicants have provided identical answers, indicating prepared responses to specific questions. Similarly, during authorisation oral boards, candidates have access to questions beforehand, raising concerns about the integrity of the assessment process. The shortage of qualified engineers in the industry exacerbates these issues, driven by commercial pressures and the company’s struggles to attract suitable staff.

I filed a report in relation to a routine maintenance task, the inspection and reinstallation of two magnetic chip detectors on the two left engine VFSGs. During the installation of the L1 VFSG magnetic chip detector, damage to the detector was noted. Despite searching, we could not locate the missing piece [of chip detector], leading us to conclude that the L1 VFSG likely contained FOD (Foreign Object Debris). I advised that dispatch in this condition would require following the MEL/DDG, including manual disconnection of the drive, an engine ground run, and removal of the airbridge. During installation of the L2 magnetic chip detector, an attachment bolt had been sheared and helicoil damage was identified. Later in the shift, I was informed of additional damage to the L1 MCC and threads on another fastener, which had also damaged the helicoil. These VFSG mag chip detectors have x3 attach bolts and are offset, so can only be fitted one way. Somehow, they were both installed in the incorrect orientation and excessive force was used to try to install them resulting in the damage.

Another instance involved performing a straightforward task: replacing an Oil Debris Monitoring System (ODMS) sensor that necessitated wire locking. Conditions for the task were favourable, with good access and ample time, and all necessary tools were readily available. The mechanic, who claimed six years of experience and had passed all module exams, struggled to complete the task despite three attempts over 40 minutes. In contrast, I successfully completed the task in approximately two minutes.

I believe they do not realise (or are willing to take the risk for their rewards) the consequences of their actions. Some LAEs will willingly sign everything off and if faults are raised, [using the] MEL 05 or 25 because they don’t know where to find the relevant data, thus resulting in aircraft degradation and safety for passengers and crew.

Internal reporting to the [quality/safety/compliance] department has not prompted any discernible changes, raising the question of whether escalation to the CAA or higher authorities, such as the Department for Transport, is warranted.

To address these issues effectively, the implementation of project management for new employee onboarding is necessary to ensure accountability and proper training. Thorough background checks are also required. While acknowledging that not all overseas engineers fall below expected standards, a significant proportion demonstrate inadequate proficiency and pose tangible safety risks due to inexperience.

comments

CAA Comment

Thank you for your report, the items raised will be monitored in the oversight programme and we have made requests for further information from the organisation. At this stage, all investigations have demonstrated that the organisation is completing appropriate checks within their competency process and no concerns have been highlighted.

It should be noted that in some cases the HR/probation process is being utilised, which is confidential and not one which is regulated by the CAA. Competency remains the remit of the Part 145 organisation, therefore regulation does not support the CAA in reviewing the status of a Part 66 licence where claims are made against an individual’s competence. Should reports be received that imply that the individual does not meet the fit and proper character requirements of the CAA, then this would be reviewed.

The CAA meet regularly with the organisation and review the internal safety and compliance meeting minutes and MOR data prior to these meetings. This allows any specific reports of concern to be reviewed in greater detail.

It is well understood the size and demographic of the UK pool of licenced engineers. There is high demand for engineers and an increase in salaries across the industry, this situation is being monitored by the CAA and discussed with industry to avoid any risks that this may introduce.

CHIRP Comment

The CAA was contacted with the reporter’s permission. The Part 145 regulations have passed various issues away from the regulatory authority which reduces their workload, costs and liability but is now shouldered by the Part 145 organisation. Although the CAA did not find evidence of falsified documents, it should be noted that making false representation is an offence under Part 10, Chapter 4, Article 256, punishable under schedule 13 Part 3 of the Air Navigation Order (ANO). Promulgating such activity remains the responsibility of the CAA of course.

Assessment is complicated and includes a competency-based process, which is subject to clear CAA guidance, but also an HR process behind this. The CAA therefore does not have the full picture and there may be additional complications. Companies must share the competency assessment element but, to protect individuals and confidentiality, will not share HR information. The CAA-published competency assessment guidance document – CAP 1715 – provides simple but comprehensive support for companies in establishing a robust assessment process and determining fitness of character, although this latter element is particularly difficult to quantify.

Competence is defined in ICAO Doc 10098 (Competency-based Training and Assessment for Aircraft Maintenance Personnel) as ‘A dimension of human performance that is used to reliably predict successful performance on the job. A competency is manifested and observed through behaviours that mobilise the relevant knowledge, skills and attitudes to carry out activities or tasks under specified conditions.’

In this case of the specific example cited by the reporter, the system worked. The company’s effective competency assessment identified shortfalls, and the individual concerned had their employment terminated before they were qualified to work on equipment and aircraft. If a new member of staff demonstrates alarming and dangerous shortfalls, how quickly should such an individual be removed from the workplace? Ideally as soon as possible and certainly before they gain autonomous safety-critical responsibility. Organisations should consider whether their systems would be fully effective in a situation like the one reported. The Management System (SMS) of the organisation should be monitoring the effectiveness of the Competence Assessment Procedure. However, it is difficult to assess if the assessment process itself is sufficiently robust and at what point is it necessary to decide that it has failed? CHIRP wonders if the regulations might also benefit from a revisit in this area.