EASA Issue Opinion 07/2015 – Part 66 Basic Module Exams
The current Annex III (Part-66) to Regulation (EU) No 1321/2014 allows that basic-knowledge examinations for maintenance certifying staff can be conducted either by an approved Part-147 Maintenance Training Organisation (MTO) or by the competent authority (CA). In the case of Part-147 MTOs, the examination can be performed either in conjunction with the basic-training course they provide or as a stand-alone examination.
Although there is no safety concern in relation to the examinations performed by Part-147 MTOs when they are part of a basic-training course (typically lasting between two and three years), this is not the case with stand-alone basic examinations. A significant number of fraud cases in approved Part-147 MTOs providing unofficial training lasting only for a few days have been reported, where said MTOs released focused information on the content of the upcoming examination to their students. These practices take place in and outside Europe, mostly away from the base of the Part-147 MTO, where oversight by the CA is more difficult to exercise or even impossible to plan.
The situation has spiralled quickly out of control as, progressively, more Part-147 MTOs have been following this practice, enticing their customers with very short, so-called ‘refresher courses’ supposed to guarantee them that they would pass the official Part-147 examination. In some cases, fraud or malpractice has been confirmed by the Agency or the CAs, which necessitated action being taken against the issued licences or certificates. This has generated a major safety concern, with the risk of having the aviation system overwhelmed with licence holders releasing to service aircraft after maintenance without having the basic knowledge required.
The Agency therefore proposes restrictions to the stand-alone basic examinations when they are performed outside the locations listed in the approval certificate of the maintenance training organisation. This would address the immediate safety concern without the significantly higher impact of completely removing the privilege of Part-147 MTOs to perform examinations.