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145.A.35 requires the organisation to ensure that certifying staff who issue certificates of release to service hold a valid Part 66 aircraft maintenance licence appropriate to the aircraft or component, and that support staff are adequately trained and supervised.
What it means in practice
Certifying staff are the individuals authorised by the organisation to sign a certificate of release to service (CRS) after maintenance. They must hold a valid Part 66 licence with the appropriate category and type rating for the aircraft or component being maintained. The organisation must issue a certifying staff authorisation that defines the scope of work each individual is permitted to certify.
Support staff are mechanics and technicians who carry out maintenance tasks but do not issue the CRS. They must be appropriately qualified and experienced for the tasks they perform. The organisation must ensure that support staff work under the supervision of certifying staff and that the level of supervision is appropriate to the experience and competence of the individual.
Key requirements
The organisation must maintain a register of all certifying staff, including details of their Part 66 licence, any type ratings, the scope of their authorisation, and the date of first issue. Certifying staff must have at least six months of relevant maintenance experience in a 24-month period to maintain their authorisation. The organisation must ensure that certifying staff can demonstrate they have adequate understanding of the aircraft or component and the relevant organisation procedures.
For support staff, the organisation must assess their competence and ensure adequate task-appropriate training. The level of supervision provided must be proportionate to the individual's experience and the complexity of the task. The organisation must define its supervision policy in the Maintenance Organisation Exposition.
Common compliance gaps
A very common finding is certifying staff authorisations that do not accurately reflect the individual's current competence or that have not been reviewed after changes in the approval scope. Organisations also frequently fail to maintain the six-month recency requirement when staff are reassigned to non-maintenance roles for extended periods. Supervision levels for support staff are often poorly defined and inconsistently applied.
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