ILT/KIWA license revocation implications on the aviation industry

Recently, the Dutch Civil Aviation Authority (ILT) announced an intent to suspend aircraft maintenance engineer licenses (AMEL) for engineers who completed their structured on-the-job training (SOJT) at maintenance, repair, and overhaul (MRO) organizations outside Netherlands.?The announcement has sent shockwaves in the aircraft maintenance landscape with several stakeholders questioning the?implications of the suspension of these licenses for the aviation industry, especially for the affected engineers and the AMOs they work for.?

This short article seeks to shed elucidate this matter and explore the implications of the suspension of ILT/KIWA issued engineer licenses. If you are an engineer affected by this issue, a technician currently pursuing an ILT license, or an aviation enthusiast curious about this abrupt and highly consequential intent, this read is for you.

Background?

ILT collaborates with KIWA Register, a professional body that?issues licenses and permits, and qualifies business to operate in the transport, shipping, and aviation industries.?Through this collaboration, ILT grants AMEL to all technicians who meet the Part-66 regulations as stipulated by EASA. These regulations form the basis for the minimum requirements on qualifications, experience, training, and completion of SOJT.?

The aircraft maintenance licenses are divided into the following categories by EASA:

Category A: Line maintenance certifying mechanic for minor scheduled work and simple defect rectification.

Category B1: Maintenance certifying engineer with mechanical privileges (e.g., airframe, engines).

Category B2: Maintenance certifying engineer with avionics privileges.

Category B3: For non-pressurized piston-engine aircraft below 2000 kg maximum take-off mass.

Category C: Base maintenance certifying engineer, with the ability to release aircraft to service following base maintenance.

To attain these licenses, a technician must satisfy the current regulations stipulated by EASA under Part 66 of the EASA regulatory framework, covering?age,?basic knowledge, practical experience,?basic training,?and demonstrated competence.?Only people who are over 18 years of age can hold a part 66 license. Moreover, candidates must?demonstrate theoretical knowledge in various aircraft maintenance disciplines. The necessary knowledge varies depending on the license category one is pursuing, and the exact modules can be obtained in Appendix I of EASA Part 66 document.?

Additionally, all candidates require practical experience obtained at a Part?145 approved maintenance organization. The period of practical experience varies depending on the type of license desired, as follows:

Category A: 1 year of experience in aircraft maintenance if the applicant has completed an approved course, or 3 years without an approved course.

Category B1 and B2: 2 years of experience with an approved course, or 5 years without one.

Category B3: 1 year of experience with an approved course, or 3 years without one.

Candidates who meet these qualifications must complete a training course offered by a Part 147 approved training organization, then demonstrate their competence by passing exams that test their theoretical knowledge and practical skills.?It is disheartening that several engineers who went through this process and got licensed by ILT could have their licenses revoked.?

According to ILT, a recent assessment revealed that the SOJT conducted at select MROs in other EASA member states do not fully comply with EASA standards.?Due to this non-compliance, ILT has issued suspension notices to engineers who were certified by ILT/KIWA following?completion of?their SOJT at these facilities. In the suspension notices, ILT has cited concerns over validity of the training of these licensed engineers, and the safety and reliability of aircraft maintenance by these engineers by extension.

Possible Outcomes

The suspension of these?licenses has?far-reaching consequences, as outlined below.

Outcomes for Engineers

Career disruption: suspension of licenses poses a grave risk of immediate unemployment, leading to professional uncertainty and financial instability for the affected engineers.?

Re-certification requirements: engineers whose licenses are suspended may have to undergo additional training or reassessment to reinstate their licenses. Such?action will attract financial costs and?lost time.?

Professional reputation: having their licenses suspended will likely tarnish the professional standing of these engineers, affecting future employment opportunities.

Engineer?preferences: should ILT go through with the suspension of licenses, most engineers may be reluctant to get certified by ILT/KIWA.?

Outcomes for AMOs

Operational challenges: AMOs with affected engineers under their employment may face workforce shortages, leading potentially to increased workload for remaining staff and delays in maintenance.

Regulatory scrutiny: organizations who lose their?engineers’ capacity to?conduct their tasks will face scrutiny on whether they meet regulatory standards on workforce levels. Additionally, MROs identified by ILT as non-compliant in the SOJT will face regulatory scrutiny for this non-compliance. These MROs will have to implement corrective measures to ensure compliance with all regulatory standards.?

Reputational damage: non-compliance findings have the potential to harm MRO’s reputation, affecting client trust and business prospects.

How can the Situation be Addressed?

Support mechanisms for affected engineers: there is need for?ILT to establish support programs for affected engineers, including financial assistance for retraining and expediting re-certification processes to mitigate the impact on these engineers’ careers.?

Communication: ILT should clearly and transparently offer detailed explanations concerning the specific non-compliance issues identified, the MROs affected, and the steps these MROs and affected engineers need to take to resolve the identified issues.?

Legal recourse and advocacy: affected engineers and AMOs may need to seek legal advice and explore options for contesting the suspensions or negotiating terms for re-certification.?

Collaboration: there is need for better collaboration across EASA member states to ensure consistent application and enforcement of EASA standards across all member states so that a similar situation does not arise in future.?

Regular compliance checks: ILT/KIWA should perform regular?and thorough audits to prevent future non-compliance, ensure all SOJT programs meet EASA standards before certifying engineers, and?ascertain that in case an MRO?is non-compliant in future, the number of affected engineers will be limited.?

Conclusion?

In summary, the intent to suspended licenses due to non-compliant SOJT practices, as communicated by ILT, underscores the critical essence of adhering to regulatory standards in the aviation industry. However, the unclearness of the communication by ILT has created a lot of uncertainties.?It is essential to address the?potential?repercussions on engineers and AMOs fairly and transparently. Consequently, collaborative efforts between regulatory bodies, engineers, and AMOs are paramount to resolve the current challenges following the intent?by ILT, prevent further non-compliance, and promote?aviation?safety.?Elitesphere?will follow up this issue and keep you updated as developments occur.