Does EASA plan to propose changes to the implementing regulation to establish specific adaptations applicable to persons with learning difficulties (e.g. dyslexia, attention deficit disorder, hyperactivity,…) who wish to undertake aircraft maintenance training in a Part-147 approved training organisation as required to apply for Part-66 licenses?
Answer
Anybody able to pass the basic knowledge examinations and fulfil the basic experience requirements can get the related Part-66 licence. There are no additional conditions such as a medical certificate or any other proof regarding the mental or physical abilities. In other words, people with specific learning difficulties or physical impairments are not discriminated by Part-66 or Part-147.
Obtaining the licence does not give the certification privileges. Before granting such privileges, the maintenance organisation will have first to check the competence, including the assessment of the skills and abilities and considering the Human Factors principles. The scope of the certification authorisation will be commensurate to these competence/abilities. Please note that in some EU Member States additional occupational safety and health requirements may apply (working on heights, confined spaces, etc.).
EASA does not plan to propose amendments to the regulations to account for cases of people with special needs during examinations: a single regulation cannot cover all individual cases. If a Member State intends to introduce any such adaptation, Regulation EU 2018/1139 (the BR) includes the possibility for the Member States to grant an exemption under the Article 71(2), after evaluation of the individual conditions for the case.
As an additional information, the Agency already issued several positive recommendations for such exemptions (e.g. for candidates with confirmed dyslexia, i.e. 25% additional time). Please contact your competent authority for details.
For further information about the flexibility provisions under the BR, please see 'Safeguard & Flexibility Provisions'.