Is it true? what?
DCAM Part 66 Support MRO Industry in Malaysia. Is it true?
To know whether it is true or not, you have to read my assignment which being pasted below.
This assignment are not providing perfect answer for those who want to know deeper about DCAM Part 66. It is just a general study from our group.
Our first PBL inquire us to do a research on new aircraft maintenance engineer’s licensing system adopted by Malaysia’s Department of Civil Aviation (DCA) to support the Malaysia’s MRO industry.
As we know, Maintenance, Repair and Overhaul (MRO) industry is work field for licensed aircraft maintenance engineer (LAME). So, the implementation of the new licensing system which is known as DCAM Part 66 would give an impact on MRO.
Doing the research, I as a group leader had assign for each team member to do some info-searching and get some preview on the topic because our group members didn’t come from aircraft maintenance background. For me, I google for part 66 and previous licensing system which is based on BCAR section L. Most of information I get from forum like flylah.com and also some blogs. Details for the new DCAM part 66 can be reach by DCA website in Airworthiness Notices No.1011. I’m not finish it yet at this time, will update later.
The beauty of having background in aircraft maintenance is I have few friends that had done their LAME with old system and they are the last batch for that section L exams. Thus, I called them to get their opinion on new Part 66 and old Section L, and manage to get info from the MRO perspective.
To know whether the new DCAM Part 66 support MRO or not, we need to have general view of MRO. MRO industry is one of the major contributor to the global aviation market. In 2011, MRO contribute USD46.9 Billion of global market and it is expected to grow 5% to USD49.5 Billion this year,2012. According to TeamSAI in their report “ The Global MRO Forecast 2012-2022: A Changing Landscape”, MRO industry being forecast to grow USD68.4 Billion by 2022. While our country targeted to be a regional hub for MRO industry and conquer 5% of global MRO market by 2015. Malaysia also expected to have MRO value around USD 65 Billion by 2020. Seems that the expectation made by Malaysian Industry-Government Group for High Technology (MiGHT) is very high compare to the global MRO forecast in 2022 as mention before.
There are some reason why DCAM adopt the new aircraft maintenance licensing system DCAM Part 66. One of the main reason is to align with global requirements (“to align” is the word use by Director General of DCAM in his presentation- you can search for his presentation slide in Scribd). This is parallel with ICAO Annex 1 which is to ensure that international licensing standards are kept in line with current practices and probable future development. ICAO Annex 1 Chapter 4 had listed the minimum requirements in term of subject to cover and period of experiences for aircraft maintenance engineer. Malaysia as an ICAO member state took it as a main guideline to come out with DCAM Part 66.
Besides ICAO, DCAM also look at EASA Part 66 as a guideline. Why? What I have found that because of aircraft technology. Airliners in Malaysia especially AirAsia was totally use Airbus manufactured-aircraft, while Airbus follow the EASA requirements and their aircraft maintenance standards also under the provision of EASA. Thus, MRO in Malaysia which doing maintenance service on such aircraft definitely prefer licensed aircraft maintenance engineer (LAME) who has same standards and adopt uniform understanding as EASA LAME who has more privileges compare to old system adopt by DCAM, BCAR Section L. Therfore, it become a request from industry for DCAM to transform their licensing system to harmonize with other countries standards.
This new system, DCAM Part 66 was officially adopt by DCAM in January 2011 and will be fully implemented by January 2016. It is involving the BCAR Section L License holder and also the new applicants for LAME. I do not found any valid reason from the authorize source on why they use Part 66 as the name for the licensing system, is it because it is same with EASA Part 66 (while we also do not know why EASA name it as Part 66) or other reason?. From my reading and internet searching, the most logic reason or assumption is the 66 Books in Bible, which refer to the words of God or Christian Law. I think EASA inspired from that and use it as the name for their ‘law’ or requirements for personnel licensing, while we in Malaysia just follow whatever they did.
DCAM Part 66 and EASA Part 66
Because both share the same number for that part, people get confused or misunderstand that both are the same, while the reality is not. Yes, both have some similarities but also have differences.
We discover some differences as follows:
- License Categories
Differences of License Categories between DCAM Pt66 and EASA Pt66
DCAM Pt 66 has 3 categories of license while EASA Pt66 has 4 categories.
DCAM Pt 66 has license categories consist of A, B1, and B2 while EASA Pt66 consist of A, B1,B2, and C. The privileges for categories on both DCAM and EASA is same except DCAM do not have C category. License of C Category is a license for service in base maintenance for aircraft.
Category A is license for technician, B1 for the fixed-wing and rotary wing aircraft engineer, and category B2 for avionic engineer.
- Basic qualification
DCAM require person at least 21 years old eligible to apply for the LAME while EASA directly follow the ICAO Annex 1 Chapter 4 requirements which stated that the applicants shall be at least 18 years old.
- Language requirement
DCAM Part 66 require the applicants to have competent in English language while EASA Part 66 do not require applicants to have competency in English language, this due to EASA member state not only the country who use English as their main language like France and Germany their language also well known and well use internationally.
DCAM Part 66 give benefit to MRO to have multitasking staff.
DCAM Part 66 License Categories
Compare to the old licensing system, DCAM Part 66 give benefit to MRO organization to have multi-tasking aircraft engineer. For instance, previous BCAR Section L license divided the engineer license into so many category like category C only for engine section, category X for electrical section. With the DCAM Part 66, it is an integrated function of aircraft engineer because for category B1, LAME can sign on engine, airframe and also electrical part compare to the old system, each part need be sign by each qualified engineer except the engineer has all the three categories of license, then he can sign all. Whereas DCAM Part 66 only require one engineer to sign all those three section.
The picture above shows the old system require at least 2 type of engineer to complete powerplant and airframe job whilce with the new system MRO just require 1 type of engineer to do both job specification.
Therefore, with the new licensing system MRO organization can have multi-tasking engineer at the same time able to eliminate the engineer shortage. Besides, it is more cost-saving for MRO organization since they don’t have to spend their expenses so much on engineer salary when the number of engineer can be reduced. In addition, the DCAM Part 66 can save operation time which sometime cannot be avoided with the old system. For example, in the old system, if Category X engineer want to fix the electrical part but that part involve airframe section then he need to wait for category A or A&C to do their job first. With Part 66 the same engineer can open airframe, engine and electrical parts and has privileges to certify those parts. It is more time-saving, meaning that the company can reduce their operating cost. DCAM Part 66 gives so much benefit and support MRO but on the engineer side maybe it is not so good. Thus, it is not strange if DCAM adopt this new system because of request from MRO industry.
The examination for applicants to apply for Part 66 is much harder or difficult compare to Section L
Yes it is, but both old and new system have their own pros and cons. In term of syllibus, DCAM Part 66 look more easy since it is based on modular system. The applicants can focus one by one and pass the exam paper one by one which look more organize. But it is that easy to get the license?. For some people, old system much easier because the examination mix all the subject in one examination. Means that it save time and cost.
Part 66 require applicants to have 2 years working experiences after or along with the examination. But it is depend on the engineer to pass the applicants or not. While the old system, require applicants to have basic training for example for the trainee from approved training school can directly take exams after they finish their study and they will get the license straight away after pass the exam, no need to work for 2 years.
The holder for Section L’s License have to neglect and abandon their certification and retake the learning process altogether again
No, it isn’t. The license holder for BCAR Section L do not have to retake the examination again to have a valid license but they have to do license conversion at DCA with limitation because their previous knowledge not cover all the subject that need to be covered in DCAM Part 66. The converted license will has limited privilages compare to the DCAM Part66 holder. The limitation can be removed by taking examination on the limitation modules.
DCAM gives the BCAR Section L license holder 5 years to do conversion starting January 2011 until January 2016. Once they do the conversion they will receive the license in the DCAM Part 66 format.
For further information you just click this > AN 1101
DCAM Part 66 adopted due to enforcement of regulatory body such as ICAO
It is not an enforcement by ICAO but it is merely an advisory to the state member. However, DCAM adopt the Part 66 mostly because to standardize and harmonize country requirements with the global requirements. Thus, our airlines or local-certified aircraft will be recognized as airworthy. As been mentioned above, ICAO is used as a guideline while EASA is used as a reference and minimum standards.
EASA, FAA, DCAM, CASA, and Civil Aviation Authority of Singapore (CAAS) use the same Part 66
It is not the same part 66 but same name for the personnel licensing system. All use Part 66 as their licensing system except FAA who use FAR 65. Why the rest use the number 66 is already discuss before. FAR 65 is quite different compare to other countries authority such as DCAM Part 66, EASA Part 66, CASA part 66 and SAR 66, all of them almost similar and take EASA Part 66 as their guideline, but it is not for FAR 65. It has its own unique requirements.
Among the differences that my group figure out is, elibility of applicants to take examination for the license is different. DCAM Part 66 require at least 21 years of age to be eligible while FAR 65 require at least 18 years old. For the working experiences, DCAM require 24 month working experiences while FAR require 18 month only. FAR 65 only have 2 categories of license which is airframe and powerplant while DCAM Part 66 has 3 categories which is A, B1, and B2.
For the EASA, CASA, DCAM and CAAS all those authority did not share same requirements and learning method. For CAAS, it not use Part 66 but Singapore Airwothiness Requirements 66 (SAR 66), only the same 66 number. Infact, SAR 66 also use EASA Part 66 as its main guideline. Thus, it has similarities and differences with DCAM. The most obvious different is license category where SAR 66 has 4 categories of license which is Category A, B1, B2, and C similar with EASA Part 66 license categories.
Referring to the problem statement given, my group finding shows that the new aircraft maintenance licensing system (DCAM Part66) is supporting MRO industry in Malaysia. It is more beneficial for MRO rather than applicants or engineer. Therefore, it is acceptable and logic if DCAM said that this adoption of new system is because of industry request. DCAM part 66 support MRO to have efficient operation, cost-saving and time saving.
Although there several countries that use the same name Part 66 for their licensing system, its not mean that they have similar requirements. Every country have their own aviation regulatory body and have their own standards for aircraft personnel licensing although the guideline is same (ICAO Annex 1) but they modify it depend on the country law and regulation.