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O'Shea
Feedback on proposed amendments to Part 66 Manual of Standards aircraft engineer licensing training - (CD 1908SS)
Please provide your comments on the proposed amendments to Part 66 MOS in the comments box below.
Comments
I support there amendments I full but for clarity I specifically mention
Item [6] paragraph 66.A.25 (h) - I support this amendment
Item [9] subparagraphs 66.A.30 (a) 1. and 2. - I support this amendment
Item [13] Section 66.A.30 - I support this amendment
Item [29] Appendix I, Part 3, Module 12 - I support this amendment
Item [6] paragraph 66.A.25 (h) - I support this amendment
Item [9] subparagraphs 66.A.30 (a) 1. and 2. - I support this amendment
Item [13] Section 66.A.30 - I support this amendment
Item [29] Appendix I, Part 3, Module 12 - I support this amendment
General comments
Do you have any additional comments about the proposed policy?
Comments
Clearly the availability of type training through Part 147 MTO, with the inclusion of POC, is the best option where available. I do accept that that path is not always practical nor affordable to many who are currently in the industry.
One pathway proposed by you (self- study) is the pathway that gave me a start as a LAME in the industry 40 odd years ago. I am sure many current engineers will be concerned about any possible negative impact on the profession of watering down some requirements however the industry demographics are clearly showing that we need to get some 'fresh' engineers qualified and authorised and into the system. Many companies can not afford to support the training of those numbers that have realistic and commendable ambitions. To enable them to achieve their goals we do need to provide multiple pathway. Ones that are beneficial to learning on the job, practical to achieve and also cost effective.
Self-study in my experience is not by any means the 'easy' path. On the contrary, it takes some focus and dedication to both undertake the study, perform the work and complete the SOE in order to attain the qualification sought.
Whilst the Regulator and the Quality professionals will make sure there is good rigour in the system, the ultimate gatekeepers for a steadfast SOE system are the individuals who sign off the multitude of tasks as they are presented for scrutiny. It is ultimately in your hands my fellow engineers.
Therefore, I support the proposed amendments in full.
I also would like to see improved harmonisation with EASA for recognition of the qualifications.
One pathway proposed by you (self- study) is the pathway that gave me a start as a LAME in the industry 40 odd years ago. I am sure many current engineers will be concerned about any possible negative impact on the profession of watering down some requirements however the industry demographics are clearly showing that we need to get some 'fresh' engineers qualified and authorised and into the system. Many companies can not afford to support the training of those numbers that have realistic and commendable ambitions. To enable them to achieve their goals we do need to provide multiple pathway. Ones that are beneficial to learning on the job, practical to achieve and also cost effective.
Self-study in my experience is not by any means the 'easy' path. On the contrary, it takes some focus and dedication to both undertake the study, perform the work and complete the SOE in order to attain the qualification sought.
Whilst the Regulator and the Quality professionals will make sure there is good rigour in the system, the ultimate gatekeepers for a steadfast SOE system are the individuals who sign off the multitude of tasks as they are presented for scrutiny. It is ultimately in your hands my fellow engineers.
Therefore, I support the proposed amendments in full.
I also would like to see improved harmonisation with EASA for recognition of the qualifications.
Your priorities
Priority 1
Comment
Continue to have safety and quality orientated professionals in the industry regardless of the pathway travelled to get there.
Priority 2
Comment
Provide the realistic pathways for those that do not have the MTO/POC 'sponsored' options available to them.
Priority 3
Comment
Ensure the industry is able to build and maintain a good cross section of youthful enthusiasm blended in with industry professionals who all meet maintain the standards expected of us all.