Licensing and the Labour Process in Australian

Aircraft Maintenance: Deskilling by Stealth?

Ian Hampsoni and Sarah Gregson
School of Management, Australian School of Business, UNSW
and
Industrial Relations Research Centre, UNSW

Prepared for the International Labour Process Conference,

18-20 March 2013
Rutgers University, New York
Abstract
Licensing protects society (Polanyi, 1944) from the
consequences of improperly trained and incompetent
practitioners work. It is a key component mechanism to
preserve job territory and to socially construct skill
(Attewell,
1991).
Becoming
a
licensed
aircraft
maintenance engineer (or LAME, pronounced lay-mee),
therefore, has historically meant that the holder has
undertaken sufficient theoretical and practical training to
be entrusted with the completion of skilled tasks for which
they have been duly certified competent by senior peers
and by the state (Fry, 1980; ICAO 2011). This gives them
state sanction not only to perform work, to supervise the
work of others, but also to certify that all work has been
completed to an acceptable safety standard. In this paper,
however, we discuss ways in which licensing can actually
drive deskilling and reduce social protection, highlighting
reforms to aircraft maintenance licensing in Australia
that, we posit, may be creating a multi-faceted move
away from safe maintenance systems.

Acknowledgement
The research underpinning this paper was funded by an
Australian Research Council Linkage Grant (LP110100335)
The Future of Aircraft Maintenance in Australia:
Workforce Capability, Aviation Safety and Industry
Development.
We thank the ARC, and our Partner
Organisations who have been generous with their time
and support for this project.

Licensing and the Labour Process in Australian

Aircraft Maintenance: Deskilling by Stealth?
Introduction
Deskilling is a central concept in labour process theory and a central
reference point in discussions about workplace change. We interpret
the concept of deskilling to be multifaceted as an employer
strategy to control workers, as well as diminishing the skill content of
work. Deskilling applies to individual workers, to a workforce in
general, as well as to a labour process. Babbagisation is a variant
on deskilling the concept registers processes through which
management seeks to fragment complex labour processes so that
less skilled workers on lower wages can be hired to perform
particular defined tasks or sets of tasks, obviating employer need to
waste money through paying more highly qualified tradespeople to
perform tasks that are, in terms of skill, beneath them (Braverman,
1974; Thompson, 1989). As an instrument of trade skill dilution,
competence-based training has been criticised (or praised,
depending on your point of view) for its tendency to fragment work
processes and their underlying skills, and to reduce underpinning
theoretical knowledge in the pursuit of training that is immediately
useful in the workplace (e.g. Ashworth and Saxton, 1990; McKay,
2004). In the case of aircraft maintenance, important conceptual
knowledge is being lost due to babbagisation of the labour process.
Licensing is a component of the social construction of skill
which contributes to the preservation of job territory, as well as
protecting society from twin evils the consequences of work
performed by improperly trained or incompetent practitioners and
the destructive effects of market forces on work quality (Polanyi,
1944; Attewell, 1991). Achieving a license has, therefore, usually
been linked with an assumption that the holder has undertaken
sufficient theoretical and practical training to be entrusted with the
completion of skilled tasks for which they have been duly certified
competent by their more senior peers and by the state. A key
Australian policy document, for example, defines an occupational
license as:
any form of regulation that restricts entry to an occupation
or a profession to those who meet competency-related
requirements stipulated by a regulatory authority (ANTA,
2002:33)
To meet the standards of national authority, aircraft maintenance
training has comprised acquiring technical knowledge to a uniform
standard, accruing time on the job applying that knowledge to the
performance of a broad range of technical tasks and attaining

sufficient knowledge of the legislative environment surrounding

aircraft maintenance and airworthiness (Fry, 1980:9).
Although seen predominantly as technicians operating
between aviation design engineers and unlicensed maintenance
workers, the history of LAME industrial organisation suggests a
widespread shared sense of independence, professionalism and
high ethical standards that underpin a sense of duty to protect the
public from the consequences of inexperienced, negligent or
malevolent work practices. Members of the Australian Licensed
Aircraft Engineers Association (ALAEA), for example, see themselves,
as described in the organisations motto, guardians of air safety.
The Associations executive members continually lobby to improve
the political, industrial and legislative environment in which LAMEs
can perform, supervise and certify high quality maintenance work
for the safety of all who fly (ALAEA website, accessed 2013). For
them, the license is an important marker of the knowledge, skill and
commitment to safety their members share, and the Association
has, on numerous occasions, mounted political and industrial
challenges to any threats to the prestige and substance of the
maintenance license their members hold.
In order to respond to a widely predicted (eg ICAO 2011b)
impending global (if not necessarily national) shortfall of licensed
aircraft maintenance engineers, proposals to change the licensing
system have been put forward by the International Air Transport
Association (IATA) the global peak employer body for airline
operators. Its Training and Qualification Initiative (or ITQI) proposes
to reduce maintenance worker training times and to introduce
competence-based training (IATA 2009) in other words, to deskill
the workforce. Seemingly in response, the reform program of
Australias Civil Aviation Safety Authority (CASA) bears an uncanny
resemblance to agendas pursued historically by employers in
several contests over the role of LAMEs in crucial decisions about
when an aircraft is safe to return to the skies. Where once LAMEs
had strong regulatory backing from the State to make this decision
independently and against organisational pressure, employers have
lobbied for years that the operators know best when this important
stage should take place in other words, they prefer a company
approval system and prosecute the familiar argument that selfregulation is entirely appropriate as operator risk aversion is
sufficient to prevent safety infractions. Therefore, the IATA
proposals articulate what the major airline lobbyists have always
coveted, and while there are dark rumblings about airline influence
on the reform process, our research so far does not allow us to make
such claims with certainty. We note however that two recent chairs
of the IATA were two CEOs, one former and one current, of Qantas,
Australias national airline, which is at the forefront of militancy in
airline industrial relations. In addition, recent changes to the
regulatory regime, we can more confidently say, have a great many
3

benefits for the operators while limiting the role of skilled LAME
decision-making but at the price of reducing the socially protective
role occupational licensing of AMEs was designed to play.
This paper reports some outcomes from an Australian
Research Council-funded research project called The Future of
Aircraft Maintenance in Australia. It is based on over 50 hours of
interviews and briefings with a range of industry participants, as
well as desk research into the changing suite of regulations issued
by CASA. First we briefly describe the labour process of AMEs and
licensed AMEs, locating its importance in the wider safety literature.
Second, we describe the reforms to the labour process proposed by
CASA that have undermined the industrial strength of aircraft
maintenance unions, and the role of a license in the decision to
return an aircraft to service after maintenance. The third section of
our paper shows how this contest over the role of the licensed AME
is far from new in fact, using members licenses as a speaking
platform, the ALAEA has campaigned vociferously over many years
against the dominance of managerialist agendas in the aviation
industry that may overlook safety hazards in the quest for profit
maximisation.

1. The Labour Process of Licensed Aircraft Maintenance

Engineers and its Socially Protective Role
In earlier work (Hampson, Junor and Gregson, 2010; 2011) we have
described the labour process of L/AMEs, and we propose only to
provide a sketch here. As their motto suggests, licensed AMEs
perform aircraft maintenance, supervise the work of unlicensed
maintenance workers and are authorised by the state to certify that
a release to service of an aircraft is appropriate. However, their
work involves a fascinating dichotomy on the one hand, LAMEs
skill, knowledge and experience are vital factors in ensuring that
non-routine matters that commonly arise in aviation maintenance
are handled appropriately through significant autonomous
judgement. In addition, as we have noted elsewhere, this work
involves significant relational skills directing work, knowing which
workers can be trusted to work independently and those who
cannot, negotiating with supervisors about the relative seriousness
of particular problems etc. On the other hand, it would be difficult to
find workers more heavily circumscribed by regulatory and
manufacturer mandates that carry heavy penalties for procedural
violations. Notwithstanding potentially punitive regulatory and
management systems against rule-breaking, we know that a variety
of factors unclear manuals, not having the correct tools,
management pressure to get the plane back into service, simply
knowing a better way or making an inadvertent mistake mean that
divergences from recommended procedures, both erroneous and

deliberate, are relatively common (Hobbs, 2004:4; 2008:12-25,

passim; Reason, 1997:49-54). The main point relevant here is that
the skill, training, analytical powers and professionalism of the LAME
become crucial in determining whether departures from procedure
whether accidental or intended are innocuous, innovative or
disastrous (Hampson, Junor and Gregson, 2010).
It is here that babbagisation of the LAME labour process
supported by the new licensing system we discuss below might be
most damaging. A worker licensed to perform only a narrow range of
tasks may not see a glaring fault in a nearby component because it
is outside their training and experience. Knowing something about
everything so that a worker at least knows when to consult those
with more expertise is far preferable to maintenance workers who
know something about very little and who may miss significant
problems through lack of knowledge. Broader training also provides
constant reminders to apprentices of the importance of each
maintenance component for overall flight safety, whereas
babbagisation risks separation of the conception from the execution
of the task and might inappropriately downplay its importance in the
total labour process and safety management system. The aviation
maintenance industry in Australia has also been characterised by a
high degree of personnel mobility, both internationally and between
the Regular Public Transport (RPT) and General Aviation (GA)
sectors, and this has been important for the incubation and
transmission of expertise and skill.
However, in Australia, that mobility has been limited by two
main factors. More generally, motivation to enter the industry and to
upskill within it is limited by low levels of state and management
sponsorship of training. Introductory training and type training
modules are expensive and workers may find it difficult to get
sufficient hours of experience to qualify as skilled. As Fry (1980:10)
noted decades ago, new aircraft models and greater technological
sophistication may create an infinite variety of specialist functions
for which specific type training is something of a quick fix. For him,
broader, principles-based early apprenticeship training has, and still
has, we would argue, far greater potential to equip maintenance
workers to adapt quickly to new technologies as they appear.
Nor does the industrial relations environment provide a
propitious environment for LAMEs, in terms of working conditions,
job opportunities and related skill development. Qantas CEO, Alan
Joyce, makes constant references to the need for maintenance job
cuts and wage restraint if the company is to be profitable and
internationally competitive. In July, 2011, he pointed to the airline's
maintenance and repair costs as among the least efficient and most
expensive in the world because unions were getting in the way of
his plans to rejuvenate operations. Mr Joyce said that unions were
stuck in the past, trying to retain outdated work practices. A new

maintenance-on-demand system would mean fewer licensed

engineers working at airports, because aircraft would no longer
undergo a routine inspection before their next take-off. Only those
planes where pilots notice and report defects will be examined (Ooi,
The Australian 21 July 2011:2). There was no need, Joyce said, for
licensed engineers to do transit checks on modern aircraft, for
example, when pilots could do this work. CASA agreed, ruling that
pre-flight safety inspections could be done by the pilot, a decision
that ALAEA federal Secretary, David Kemp, derisively characterised
as the same as asking a bus driver to do the work of a mechanic
(Benns, 2011:163). In addition, Qantas has recently done a $2 billion
deal with GE Aviation for A320 engines that reduce fuel burn and so
extend the intervals between services. According to the companys
managing director, 'the cheapest [maintenance] shop is the one you
don't have'; he envisaged that a 20-year old aircraft might have had
only one or two shop visits in its life (Heasley, SMH, 21 April
2012:5). This is, of course, music to the ears of cost-conscious
operators but betrays technologically optimistic assumptions that it
is possible to design, build and operate aircraft that will never have
problems.

2. The Reforms to the License Structure, Training and

Qualifications
The licensing of aircraft maintenance workers began in the aftermath
of World War One and, since then, engineer industrial organisations
have fought an ongoing battle to increase the status of the license
and associated remuneration. The current reform program can thus
be viewed as the latest chapter in an ongoing struggle.
Maintenance work is heavily regulated from the international
sphere. Developed countries are signatories to the International
Convention on Civil Aviation (the Chicago Convention) which in
1944 formed the International Civil Aviation Organisation (ICAO)
(Yadav, 2010). Part of the ICAOs role is to develop and support a
range of technical standards for international civil aviation the socalled Standards and Recommended Procedures (SARPS). Among
these, the Conventions Chapter 4 (4.2.2.1) of Annex 1, on personnel
licensing, tells us that:
the privileges of the holder of an aircraft maintenance licence
shall be to certify the aircraft or parts of the aircraft as
airworthy after an authorized repair, modification or
installation of an engine, accessory, instrument, and/or item of
equipment, and to sign a maintenance release following
inspection, maintenance operations and/or routine servicing
(ICAO, 2011a, Ch 4, , also see ICAO 2003:vii)

These standards are applied by national regulatory bodies, like

Australias CASA and the American FAA.ii They do not fully determine
standards and systems at the national level however, and their
application and interpretation in particular national spheres have
increasingly diverged in particular between European and
American models. Cross-jurisdictional collaboration took place
between the European Civil Aviation Conference (ECAC) and the
Federal Aviation Authority (FAA) together constituting the JAA (Joint
Aviation Authorities), until the formation of the European Aviation
Safety Authority (EASA) in 2003. EASA branched out on its own,
developing a system of regulation which caught the eye of
Australian reformers. They sought to reshape the existing licensing
requirements towards the EASA standard, in particular because the
new system was being widely adopted throughout Asia (CASA,
2010a). There had been indecision over whether Australia would
follow the US or Europe and, after going some way with the US
system, CASA abruptly switched course towards the European
system in the early to mid-2000s. Transition to the new licensing
system began in 2007, with Civil Aviation Order 100.66, reforming
the old Civil Aviation Regulations (CAR31), and ushering in new
Civil Aviation Safety Regulations (CASR part 66), which laid out the
structure of the new system (CASA 2010b;c). New licenses were
issued to LAMEs on 27 June 2011, with a transition period
extending until 2015.
The changes were justified on the following bases: to allow
increased international labour transfer through mutual recognition
of skills, qualifications and licenses between Australia and the
various national aviation authority (NAA) jurisdictions of Europe, as
well as other international EASA-approved MROs (maintenance
repair and overhaul organisations). Harmonisation, it was claimed,
would also produce an efficiency dividend, by overcoming work
demarcations between holders of licenses in the five former license
categories Airframes, Engines, Electrical, Instrument and Radio
and thereby improve the labour flexibility allegedly required to
meet the highly technical demands of modern aviation systems. As
well as providing globally recognised licenses and qualifications for
employees, it was argued that these reforms would allow Australian
MROs to attract more maintenance work from overseas operators
who used the EASA system (CASA, 2010c). However, as it turned
out, the reformed licenses and their underpinning qualifications
were not recognised by EASA itself, nor in some other EASAapproved MROs, indicating a serious failure of the reform process
we will return to this point.

The old CAR 31 License system

The structure of licenses known as the CAR31 system (Civil Aviation

Regulation 31) that had developed in Australia, was fundamentally
different to the new EASA system because it enabled LAMEs to
certify for completion of a stage of maintenance or to supervise and
coordinate maintenance on either a specific type of aircraft, like the
Boeing 747 or types of components (eg engines), more commonly
found in large aircraft in the RPT sector as well as on a broad
category of aircraft, like single piston engine aircraft (such as might
be found in general aviation (GA) (CASA, 2007: 11; CASA 2002: 1618). LAMEs were also responsible for signing the release to service
certifying that the plane was airworthy. The strength of the CAR31
system was its ability to encompass both RPT and GA within a single
licensing system based on adoption of ICAO Annex 1 AME privileges
(ICAO, 2011a (4.2.2.1), also see ICAO 2003:vii). Arguably, the
greater deployment of small planes making up GA in Australia (with
a population of 22 million people in a land mass the size of Europe)
made its aviation requirements fundamentally different to Europe
where it was economically viable to use larger planes.
The building blocks of the old system were categories within
which LAMEs would hold group ratings. There were five categories:
Airframes, Engines, Instrument, Electrical and Radio. Groups
defined license privileges within and across each category. This can
be illustrated more easily with the aid of a table (see Table One).
In addition, license privileges could be held on types of aircraft.
For example, a person might be trained, qualified and licensed in
group one engines (allowing them to work on, and certify
maintenance for, engines in light planes). The same person might
then seek to move into, say, group 21 engines such as might be
found on a large passenger jet.
This would require specific
knowledge about each particular large complex engine these were
seen as sufficiently different to each other to warrant a separate
type license. A person could start on broad categories in GA then
move into larger more complex types in the RPT sector this work is
generally better paid, and with pay increments linked to license
types (a complex industrial relations issue we lack space to explore
here). Importantly for our purposes here, however, a career path
existed from GA to RPT.

Table One
GROU

AIRFRAMES

ENGINE

ELECTRICAL

PS

INSTRUMEN

RADIO

Aeroplanes not
covered in
Groups 2-20

Piston engines in
aeroplanes and
airships

Single
generator
power
systems

All general
instrument
s not in
gps 3 or 20

VHF and
HR other
than
group 20

Helicopters not
with hydraulic
flight control

Piston engines in
Helicopters

Multi
generator
systems
except gp
20

Auto pilots
(except gp
20)

Audio
and
cockpit
recorder
s

Wooden
Airframe

Supercharging
and
turbocharging
systems

20

Aeroplanes,
with (jets) and
heavier than
8,000kg as
specified by
CASA (after
2011 reforms
now
5,700kgs)

Auto pilots
(except gp
20)
Electrical
systems in
aeroplanes
above
8000kg

21

Piston and gas

turbine engines
in aeroplanes
and airships

22

Piston and gas

turbine engines
in Helicopters

Radios in
RPT
sector

Adapted from Civil Aviation Safety Authority (CASA) (2007:19-20) also see CASA
(2002:16-18)

Becoming a LAME
To become a LAME under the old system, a person was required to
gain a basic Aircraft Maintenance Engineers certificate. This meant
doing a four-year (Certificate IV) apprenticeship, combining
classroom training at a recognised provider (TAFE) with work
experience under the guidance of qualified personnel. Governments
typically allowed for around 1,280 funded classroom training hours
that took place alongside practical workplace experience. Since the
training reforms of the mid 1990s (a useful time point to begin our
exposition) a typical career path would see an AME complete a fouryear apprenticeship in one or two of the broad streams structures
and engines (to become a framie, or blackhander) or electrical,
9

instrument and radio (to become a sparkie). In practice, however,

many framie AMEs working in GA would be called upon to do
electrical work due to the fact that most Air Operator Certificate
(AOC) holders utilising small planes were also small employers,
without the capacity to employ large numbers of maintenance
workers. In these situations, AMEs would often be required to work
across the category boundaries and, indeed, many LAMEs
eventually gained licenses across numerous categories. This is an
important strand to our deskilling argument prior to the
EASA/CASR part 66 reforms, there existed many multiskilled AMEs
and LAMEs with licenses spanning multiple categories and crossing
the framie/sparkie divide. The new system will not allow for this
flexibility to slowly acquire license privileges in chunks.
At this point, it is important to distinguish between AME
qualifications, and licenses. Recall qualified (and/or approved)
people do aircraft maintenance, but only licensed people can return
a plane to service. Under the CAR31 system, to gain a license, a
person first needed to be trained towards an AME qualification
(entailing a mix of classroom and on job training), then gain
experience in the type of maintenance for which s/he seeks to
exercise license privileges (with records kept in a Schedule of
Experience or SOE). The license was issued by the Civil Aviation
Safety Authority (CASA), after the applicant passed a set of relevant
theoretical examinations and had their SOE accepted. People
seeking licenses could self study certain theoretical modules and
then sit the examination (see CASA 2002; 2007).
The examination provided proof that a person had the
necessary theoretical underpinning knowledge for a license. The
recent changes, however, downgrade the importance of this
knowledge. Our interviewees have recounted how the examination
process used to be predominantly essay-based assessment that
required the examinee to explain concepts and even to draw certain
aircraft systems from memory to demonstrate a depth of
understanding. In the 1980s, however, this form of assessment was
abruptly replaced with multiple-choice tests. Also, formerly,
granting the license was also a ritual of enculturation, signifying
membership of an important community, with a crucial socially
protective role. Interviewees have recounted how, to inculcate a
professional ethic, it was common practice for the CASA
representative to personally deliver the license and give the
recipient a motivational talk about how the LAME was in the front
line of passenger safety and bore a weighty responsibility in the
event of an aircraft crash attributed to faulty maintenance and
would therefore enjoy the support of the regulator to that end if a
conflict with management arose. Eroding the role of the examination
and the issuance of a license has been a central aspect of deskilling
(as employer strategy to control labour), which we will examine
further below in the context of a description of the licensing reforms.
10

The EASA/CASR part 66 reforms and their Interaction with

the training system
As mentioned, CASA began the training and licensing reform
process in 2007, with the issue of Civil Aviation Order 100.66. These
ushered in CASR (1998) parts 42, 66, 145 and 147. Not all of these
are germane to our argument about deskilling. For our purposes,
the key points are the part 66 licensing system, and the training and
assessment done under part 147 (and, to a lesser extent, part 145).
Part 145 governed the activities of Maintenance Organisations. Part
147 laid out the requirements for CASA to approve training
organisations to deliver and assess competence as a prelude to the
issue of a license. After the transition period, CASA would still issue
the license, but only on the recommendation of an approved part
147 organisation. CASA would no longer administer the
examinations and, crucially, would not set the central bank of
questions. In the eyes of some critics, this removed one important
guarantee of safety that the examination would really test whether
an applicant for a license actually possessed sufficient and
reasonably uniform underpinning theoretical knowledge.
To fully appreciate this, it is important to be aware of the
broader context of training reform in Australia. As argued
elsewhere, in recent decades, Australias training reforms have been
problematic, in part due to excessive reliance on market design
principles (Hampson and Junor, 2010). Australia is a Federation, in
which the Constitution assigns powers over training to the States,
each with its own training authority. Australias training institutions
are undoubtedly prone to poor assessment practices (see
SEWRSBERC, 2000; Hampson, 2004) and difficulties assessing
recognition of qualifications.iii Similarly, because Registered Training
Organisations (RTOs) are profit-making organisations and have to
compete for students, there is a tendency to lower standards
through a competitive race to the bottom where lowest required
class hours and cheapest price per module are the key
determinants for attracting high student numbers. Some
interviewees complain that standards in competing RTOs are too
low, but under the system of mutual recognition they have little
option but to accept students they think may have substandard
training when granting prior standing to students seeking or RPL
towards further training. The competitive profit-driven environment
similarly puts pressure on the content of theoretical exams. Under
the old system, the content was standardised, but under the new
system, RTOs have to develop or purchase their own examinations
with concomitant risks to standardisation and potentially quality.
We now turn to the changes made to the Australian license
structure to highlight some of the ways in which they promote

11

deskilling. The EASA part 66 system sought to incorporate the

former CAR 31 system of five categories of license (Airframe,
Engine, Electrical, Instrument and Radio) and numerous Group and
Type ratings, into the EASA system of B 1 (Airframe, Engine,
Electrical) and B 2 (Electrical, Instrument and Radio Avionics)
(See figure 1). The C category engineer does not do any direct
maintenance in this framework s/he is conceptualised as an
academically trained (bachelors) engineer, who handles the
paperwork and does the final release to service of the whole plane
but only after base maintenance (see below), based on the
paperwork that the B level support staff engineers provide.
CASA oversaw the (re) distribution of privileges through
exclusions which meant that a person might be granted a B1
license that covered the old categories but contained some
limitations (see CASA 2011). The system created a situation where
license holders who had worked across multiple categories were
crammed uneasily into one of two broad categories through
exclusions and, in this way, the new framework actually works
against the rationale of flexibility that justified the changes. A full
B1 license holder is permitted to sign for Airframe, Engine and
Electrical work. However, the distribution of electrical privileges was
not straightforward. As our interviewees report, some LAMEs were
left unsure about the extent of their privileges and some even
claimed to have lost privileges in the transfer ergo deskilling by
legislative decree in that they were not allowed to exercise license
privileges they possessed by virtue of changes to the regulations.
Perhaps even more alarmingly, some LAMEs claimed to have been
issued with privileges they did not formerly have! Although in some
cases this may have been due to misunderstanding the complex
documentation the new licenses sometimes came with 30 pages of
text, replacing one or two pages that clearly described their
privileges what they could do, with long statements of what they
could not to. It left many utterly confused about what exactly their
hard won licenses entitled them to do and anxious, lest they
unwittingly exceeded their license privileges and failed to adhere to
the regulations.

12

The other methods for obtaining a licence based on recognising defence force or international
qualifications will remain largely unchanged. The licensing for specific aircraft types will also
remain largely unchanged. The number of base licence categories will be reduced from five to two;
and two release to service engineer categories will be introduced which will align Australias
licence categories with those operating in Europe (Figure 1).
Figure1:
Current LicenceCategories

Proposed LicenceCategories

Airframe
Engine

B1

Electrical
Instrument

B2

Radio
Release to service engineers
A

C
5

Source: Modified from CASA 2010c: 5

A more serious instance of the deskilling of the LAME labour
process takes place with the possibilities presented by the A
Category license. The Cat A license can be awarded after achieving
Certificate 2 level training (680-800 hours) and two years work
experience. Such a person would be qualified to perform, and
licensed to certify for, certain limited line maintenance tasks
including simple defect rectification.iv The list of tasks includes
the replacement of wheel assemblies, brake units, emergency
equipment, ovens, boilers, beverage makers, lights, seats,
harnesses, aircraft batteries, and replacement of any other
component for an aircraft type if the task is one that CASA approves
as a simple task (emphasis added). We argue that there is the
possibility for the scope of work performed and certified by Cat A
license holders to expand under this latter provision. To appreciate
this point once again requires understanding two basic aircraft
maintenance concepts line and base (or heavy) maintenance.
Line maintenance is simple, turnaround, hangar or overnight
maintenance checking that equipment works, topping up the oil
and hydraulic fluid etc. Base (or heavy) maintenance takes place
off-line when the aircraft is not in service. At the extreme, D checks
involve, inter alia, stripping the interior out of the aircraft and
checking the frame for cracks and corrosion, and perhaps engaging
13

in considerable rectification work on major components, such as

wheel assemblies. These checks can involve 75,000 person hours
on a large plane, and, being labour intensive, they are prime targets
for outsourcing and offshoring (a topic beyond our reach here but
see Quinlan, Hampson and Gregson, 2013 forthcoming). They are
also targets for babbagisation. Phased maintenance is a process in
which some of the intermediate content of base maintenance (B,
C checks) is brought within the purview of line maintenance. That
is, some maintenance operations are packaged up in such a way
that they can be performed alongside or at the same time as line
maintenance.
It is now possible that many maintenance operations will
eventually come under the purview of a Cat A license holder, who
will have considerably less training and experience than a B level
license holder. Under the system proposed above, there is a distinct
possibility that there will be an expansion of the scope of Cat A work
with regulatory approval and, in particular, there exists the
possibility that B and C check work will leak to a Cat A licensed
person doing line maintenance. Strong financial incentives exist in
the form of leasing costs to use the time an aircraft is undergoing
line maintenance overnight (Sydney airport has a curfew where
planes cannot land or depart between 11pm and 6am) to perform
maintenance that would otherwise take the aircraft out of service.
Therefore, as a direct consequence of the part 66 reforms, the
possibility exists for the transfer of much work currently done by
experienced licensed engineers to a category of lower skilled license
holder in a process clearly recognisable as the babbagisation of
aviation maintenance work.
The shift towards Cat A licenses is also industrially
contentious, due to the coverage questions it raises between the
main aviation unions. The ALAEA covers licensed aircraft
maintenance engineers, but the work identified above in the CASA
part 145 MOS Appendix as destined for Cat A license holders is work
already, for the most part, covered by another union, the Australian
Manufacturing Workers Union (AMWU), whose rules cover AMEs
currently doing much of the above work. The introduction of the Cat
A license has certainly sparked industrial tensions indeed, several
of our interviewees were suspicious that this was part of its intent.
The ALAEA claims that its rules give it coverage of license holders
ie Cat A license holders should be able to be recruited to the ALAEA.
The AMWU claims that the potential holders of a Cat A license are
workers they already potentially or actually cover and they are
unlikely to give up coverage to the ALAEA easily. A member
poaching war between the two unions has already broken out but, at
the time of writing, there are signs that the two unions may join
forces against certain negative aspects of the Cat A.

14

Both these unions have a common interest in the construction

of an orderly career path through the Cert II / Cat A license to Cert IV
and to the Diploma which is now, following the part 66 reforms, the
underpinning qualification for B level licenses. A similar career path
exists in Germany, although our research has found that the
implementation and use of the Cat A license in Europe varies
considerably, with some countries using them extensively, while
other countries, notably Sweden, have so far successfully resisted
them, in part because of the industrial relations problems they
engender. The development of a coherent training and career
pathway would entail some major changes to the qualifications and
license structure, with some careful thought given to the industrial
relations issues. Currently, some of the competencies written for
the Cert II qualification are not written in such a way that they can
provide advanced standing for the Cert IV (or even Cert III). Another
problem arises when AMEs with a Cert IV qualification are
considered. If they are to gain the Cat A license, they will be
required to undertake gap training to fill certain gaps that currently
exist between a Cert IV AME qualification and the Cert II in Line
Maintenance (concentrated as it is on certain very specific tasks).
Clearly, many Cert IV holders will not be happy to learn they will
require extra training to get a Cert II qualification, especially if they
have to pay for it.
We now turn to the issue of safety. Examination of the new
system makes it difficult not to conclude that Cert II qualified people
may lack the underpinning knowledge, experience and workplace
maturity to make safe calls on certain aircraft maintenance
procedures. Firstly, it is foreseeable that inexperienced Cat A license
holders might perform their allotted task adequately, but lack
sufficient diagnostic skills, underpinning theoretical knowledge and
situational awareness to recognise safety-critical problems in their
area. For example, it is easily conceivable that a Cat A license holder
might change a wheel in a wheel bay and not notice that there is a
crack in the spur above their line of sight or they may not notice or
appreciate the significance of a hydraulic leak, whereas an
experienced LAME would take into account the whole wheel bay
area when performing the same task. Workplace maturity refers to
the capacity of a young person with Cert II training and a Cat A
license to operate independently of organisational pressure, with
flight safety as the highest priority. We recognise that it would be
difficult for that person to resist pressure applied by an aggressive
manager who is perhaps motivated more by a performance bonus
for on-time departures. Increasingly, such managers do not have
technical qualifications, and their pressure on staff to sign off that
certain procedures have been completed may well be motivated by
organisational, rather than safety, considerations. In the same vein,
the Cat C license holder may sign off that the aircraft is safe to fly
without ever coming near the aircraft itself. Similarly, if the difficult
conversations LAMEs must sometimes have with more senior airline
15

officials where they insist a plane is not safe to return to service are
marginalised by the regulatory process, this may have catastrophic
consequences. These conversations are only possible if the license
holder is mature enough to resist potential bullying, backed by a
strong union and supported by an appropriately interventionist
regulator the new reforms make some of these important supports
problematic.

EASA-fication of Australian aircraft maintenance?

Another fundamental development limiting Australian aviation
workers capacity to resist deskilling is the emphasis on company
approval in the EASA system. CASA has uncritically emulated this
feature, arguably even taking it further, by requiring employers to
approve aircraft maintenance engineers (licensed and unlicensed)
to perform specific roles and tasks as well as potentially allowing
an expansion in the scope of Cat A licensed tasks (with the consent
of the regulator). Our partner organisations and researchers have
identified subtle changes in the language of regulation that indicate
that the role of the license is being downgraded, and that the power
to release an aircraft to service is being diffused from licensed and
potentially unionised workers to other parts of the organisation.
As we will see in the following section, this is far from
unprecedented historically reflects long-standing employer
intentions.
Early in our research we found there were fundamental
misunderstandings about the EASA system within Australia as well
as within Europe itself! Commentators on the development of the
EASA system (eg Haas, 2009; 2010) describe a political contest
over how best to assure the high skills necessary for high
reliability functions (like airline maintenance). For him, this was a
choice between a system based on company approvals of training
and qualifications, and a system based on occupational licensing via
national aviation authorities and national qualification authorities
systems harmonised at the European level. According to Haas
(2010:597), in the case of aircraft maintenance and contrasting with
other occupations, the European states have achieved the
impossible in completely harmonizing qualifications and having
them automatically recognised across Europe. Based on our
preliminary interviews with European contributors to the project, we
reject these claims our interviewees report a large variation in
training standards and in the organisation of aircraft maintenance
work across Europe (which subsequent research will track with more
precision). The variation reflects in part the EASA systems emphasis
precisely on company approvals, and the right of employers to
define the terms of the exercise of license privileges. For example, a
licensed engineer may hold the EASA Cat B1 license but be

16

approved (at the time of employment) to do only Cat A work and,

of course, paid only according to work performed.
In Britain, the implementation of the EASA system, with its
high training hours requirements (2,400 hours to B level) was
deemed not sustainable within the framework of existing training
institutions (Watson, 2006:322). Something similar may be the
case in Australia. Part of our research has attempted to compare
the hours required by the EASA syllabus with the training hours
currently funded in Australia, which stands at around 1,280 hours
for classroom training, which looks unfavourable. On the other hand,
it is not really an apples-with-apples comparison, since much of the
European EASA training towards the B license takes place in off-thejob simulated environments, while much of this training in Australia
takes place on the job. At time of writing we are unsure how to do a
valid comparison we do note, however, that the capacity of airlines
(and small air operator certificate holders) to provide on-the-job
training in aircraft maintenance is probably in decline, due to
competitive pressures and the need to eliminate idle time at the
workplace. We do expect, however, that the comparison will be
unfavourable to Australia such is the view of many potential
overseas employers of Australian maintenance labour, who have
refused to recognise the new licenses and qualifications.
Sections of the aviation industry are scathing about the
workplace effects of these reforms, although their feedback does
not present an entirely consistent picture. Competence-based
training has been blamed for stripping conceptual knowledge from
training while, at the same time, the training is portrayed by some
as requiring increasing academic content at the expense of practical
competence. Training organisations are bound by their profit
orientation to offer content within government-funded training
hours, potentially reducing the possibilities for trainees to develop
hand skills through supervised practice. Employer interviewees
thus complain that new graduates lack hand skills while training
organisations and employers disagree over the proper place for
these skills to be developed and, of course, over who is to make
the necessary resources available.
One fundamental difference between the CAR 31 license
system and the new part 66 framework is that the old system
allowed a license capacity to be acquired in chunks, as explained
above, and allowing learned theory to be reinforced by on job
practice. The new system requires an extended period of front end
training, with a greater emphasis on academic learning. Making the
two compatible is difficult. As mentioned above, many of the AusEASA licensed people cannot gain employment overseas, as the
outputs of Australias EASA Lite training and licensing system are
not recognised uniformly outside the country. In the cruellest of
ironies, airlines are now importing overseas trained and EASA-

17

qualified LAMEs on temporary employment visas (457s) which are

operational as long as the employment relationship is maintained.
These workers can, however, be deported almost immediately if
they are dismissed, a situation which directly undermines the
workplace environment necessary for workers to feel free to speak
up about safety issues.

3. The History
LAMEs first began to organise into a separate union from the late
1950s on the basis that their licenses created unique industrial
issues for members that were not well served in larger, more
diverse unions. Although the newly organising Australian Licensed
Aircraft Engineers Associations arbitral registration was hotly
disputed by other unions and took five years to achieve, officials
argued that licensed engineers interests required special
representation and expertise beyond common union issues. Officials
needed to understand the complicated position of licensed workers
who were both agents of the state and operator employees. They
also argued that their new Association was uniquely equipped with
specialist expertise to represent members in the event of an
aviation incident or accident where there might be a risk of
prosecution.
The expertise, responsibilities, powers and remuneration
pertaining to a license holder have been contested for many years.
Although the license could put LAMEs in an invidious position, it also
allowed them to operate at the apex of a complex labour process
whereby the requirement to get their signature on a maintenance
release form gave them enormous workplace and industrial power.
For that reason, operators, and particularly QANTAS, have
consistently lobbied politicians and the regulator for lower levels of
regulatory oversight, including downgrading of LAME powers, citing
red tape as an unwarranted business constraint.
In 1971, in particular, this issue came to a head in what John
Aldiss, former ALAEA president, described as the most concerted
effort by the regulator to respond to operator calls for more control
over licensing (Aldiss, 2013). There are many similarities with
todays landscape. From the late 1960s, the Department of Civil
Aviations (DCA, a forerunner to CASA) had been making noises
about changing the regulations to increase flexibility for operators.
Two formal proposals (the second to allegedly answer the confusion
engendered by the first) were issued in 1969, containing
recommendations that would undermine the LAMEs role in certifying
aircraft maintenance work as safe.v At the heart of the issue was the
Departments view that it should regulate the airlines and the
airlines should control the LAMEs, ensuring there was no conflict of

18

interest between employer and employee that it claimed might

constitute a violation of common law. In its view:
It is not possible for LAMEs to be responsible to both operator
and the Department. If they act contrary to the directions of the
operator in the belief that they act in the interests of their
responsibility to the Department, the operator would then be
held responsible in an area over which he has no control. An
employee should be responsible only to his employer who is
responsible for the actions of his employee. (DCA 1971)
In the DCAs view, the operators needed more flexibility to
control what maintenance engineers did and what training they
received. The breadth and depth of knowledge acquired by LAMEs
through careful training and long experience was wasted if LAMEs
current positions did not utilise what they knew. On the other hand,
the regulator asserted that it was now outside the capabilities of
generalist licensed engineers to have sufficient expertise regarding
all the highly specialised tasks required on every complex aircraft
type they might be expected to service. Damned both ways in the
DCAs formulation, LAMEs knew both too much and too little.
The changes the DCA suggested to rectify these problems
were significant but, at the time, the ALAEA complained that the
Department was failing to consult sufficiently beyond the large
operators. In a letter seeking legal advice on the changes, the
ALAEA federal secretary pointed out that the regulatory backing
LAMEs received from the Department was under threat. Until that
time, he argued, LAME licenses stipulated that holders were
responsible to the Director-General for Civil Aviation for the quality
of their work. Under the proposed amendments, however,
Regulation 39 (1) was to make reference to work performed while
acting in the course of [their] employment, making LAMEs
responsible only to their employer in respect of all matters
pertaining to air safety. In addition, the amendments allowed the
Director-General to authorise appropriate persons to perform
certification duties, but did not define the qualifications and
experience required of persons so authorised to certify work as
safe.vi
The DCA maintained that the airline operators should be
permitted a degree of latitude about assessing who was sufficiently
skilled to certify specialist work, its proposal suggesting that
complex aircraft type ratings could be replaced by an employercertified maintenance authorisation for particular work (DCA,
1969:27). This was not an attempt to relax standards, the DCA
assured the industry and other interested parties in fact, the
Department argued, it had always supported policies that would
delegate as much authority as possible to the airlines and, to this
end, the new arrangements were designed so that [t]he training of

19

each LAME could be directed specifically towards those duties and

responsibilities which he is required to accept within the
organisation. (DCA, 1969:29). The certification would provide no
authority to perform similar work outside the issuing organisation,
the DCA pointed out, although it might influence subsequent
employers and the regulator to issue later authorisations. Relieved
of the burden of expectation that engineers would know all there
was to know about every aircraft, the DCA argued that LAMEs would
have more time to devote to accruing expertise on the aircraft
models and specific tasks for which they were actually employed.
Department officials appeared confident that employers could be
entrusted to provide detailed directed formal training and formal
authorisation without compromising safety. Although, unlike today,
it did maintain that all training programmes would be subject to
Department approval, its insistence on training that covered only
those aspects appropriate to the duties suggests it wanted to
maintain oversight to ensure that the training offered did not
become too broad and therefore irrelevant (ibid). According to the
DCA, if an operator is considered capable of maintaining an aircraft
of the size of a DC9 he [sic] must also be considered capable of
maintaining it in accordance with the system which does not require
such endorsements DCA, 1969:28). Although the DCA expressed
hope that its recommendations would not reduce LAME
remuneration or inspire industrial disputation, obviating the need to
remunerate highly skilled LAMEs for each qualification they gained
outside employer requirements was a key factor driving operator
pressure for this change. (DCA, 1969:29). The proposal was
summarised with the following rationale: ...the flexibility of the
proposed licensing arrangements will permit more autonomy for the
operator and will achieve greater economy in training than is
possible under the current system (Ibid, :30). That the regulator
proposals were an attempt to meet operator wishes is further
supported by a Qantas document, prepared at the same time as the
DCA proposals were emerging and forwarded to the ALAEA by
Senator Cotton, the then Minister for Civil Aviation. The key tasks
for Qantas outlined in the document were to reduce DCA activity to
surveillance only in all aspects, secure full delegation for basic
training and eliminate DCA mechanic licence. Dates were set for
the achievement of a company approved person system that
would give greater flexibility and control to Company.vii
These were not changes that the ALAEA could accept.
Firstly, Association officials resented the inference in the DCAs
position that maintenance work comprised merely a series of
allotted tasks that, if too complex, would be beyond the
capabilities of a LAME. Secondly, it disputed the possibility that,
under the new regulations, operators could appoint authorised
or specified persons to perform release functions who would not
necessarily be licensed aircraft engineers and could, in fact, be
simply company supervisory staff. Thirdly, although the
20

Association thought the level of training at Qantas was

exceptionally high it warned of the dangers in making the
employer the final arbiter of employee competence and
qualification level (ALAEA, 1971:5). Fourthly, it opposed the
bifurcation of training modules according to employer need,
stating that broad training across all categories, even where
employees were not rated, was a vital component of inter-LAME
cooperation and, therefore, safety (ibid: 22). Most of all, it
disputed the Departments claim that LAMEs delegated powers
and responsibilities made operators responsible for actions not
under their authority. The ALAEA position was that the license
simply made each LAME responsible for their own actions to the
Department and, more importantly, their delegated authority
enabled the LAME to resist organisational pressures that even the
Department acknowledged existed to release aircraft they were
not satisfied were safe. As the ALAEA report asserted, No LAME
could reasonably be expected to resist pressure if an operator
(with all of an employers sanction) is to be the final arbiter as to
the release of an aircraft (ibid:4).
This dispute is like a familiar song on the aviation hit parade,
where so many of the aspects of the dispute the conceptualisation
of LAME work, each LAMEs authority to issue maintenance releases,
the nature of LAME training were, and still are, disputed refrains.
The main difference between this dispute and todays situation,
however, is the industrial context in which the two disputes are
taking place. Although LAMEs are greater in number now than they
were in the 1970s, union density is much lower, while still
impressive in the larger airlines. Higher membership density meant
that, in 1971, the regulators recommendations were beaten back
by the ALAEAs strategy of political lobbying, legal action and the
mere threat of national industrial action. Today, the operators wield
outsourcing as a significant industrial weapon and it has a
significant disciplining effect on labour organisations in the aviation
sector. In addition, the divide and rule strategies exploited by the
operators during enterprise bargaining periods cuts against, but
does not ever rule out, the possibilities of united action against
employer incursions into working conditions and aircraft safety.

Conclusion
The outcomes of this deskilling and babbagisation of the L/AME
labour process are at the time of writing uncertain particularly as
the terms of the debates over the safety of aviation maintenance
could be transformed in an instant in the event of a major disaster
that was traceable to a maintenance problem. The crucial factor
mitigating against this strategy is the limit imposed by the safe
functioning of aircraft. That said, safety is a socially constructed and

21

contested concept, existing in a vortex between the twin pressures

of production and protection (Reason, 1997). At the workplace,
where one side of the employment relationship defends the
importance of safe operating procedures, the other sees rolled gold
maintenance and union featherbedding that is ripe for lean work
reorganisation. In Australia, the main employer has offshored
significant amounts of maintenance to escape union influence, while
harmonisation of Australian licensing and qualifications with
European systems has allowed the importation of EASA licensed
engineers. Meanwhile, ironically, Australian licenses and
qualifications have encountered problems with recognition in key
European and other MRO providers. This weakens Australian
aviation workers ability to resist, as their employment opportunities
are limited to Australia, while EASA-licensed workers are welcomed
by employers under the skilled immigration program.
The intersections and interactions between regulations,
licenses, qualifications, skills, work organisation and industrial
relations, in the realm of aircraft maintenance, are complex. Labour
process theory provides a fruitful, if broad brush, explanatory
framework through its concepts of deskilling, babbagisation,
resistance, and its critique of technological determinism. The
reforms to the Australian licensing and training systems have set
the scene for labour cheapening and the degradation of work and
potential increased risk to the safety of the flying public. Individual
workers, hemmed in by restrictive and expensive licenses, may not
be sufficiently supported by government or employers to learn and
develop expertise. In addition, entire sections of the maintenance
workforce might not be given the opportunity to expand their skills
because the work available in the industry does not offer sufficiently
complex scenarios on which they can build experience and
knowledge (for example, where heavy maintenance facilities are
closed as a cost-cutting measure, thereby diminishing the extent of
on-the-job training opportunities). Amid the increasingly tired
political rhetoric about Australia as the clever country, we note
that the deskilling agenda within aircraft maintenance has been
ratified by, and even implemented by, the very licensing regime
charged with monitoring and regulating safe standards of work in
the industry. While we acknowledge that air travel is still
comparatively safe, it is foreseeable that these changes signify a
dilution of training and maintenance standards and contain
concomitant risks to the safety of aircraft released to service after
maintenance.
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24

i Corresponding Author: I.Hampson@unsw.edu.au

ii The institutions of international airline regulation are discussed in Belobaba et al,
2009, ch. 2, although the regulation of aircraft maintenance and its implications are
not.
iii Indeed, as we write, the training system awaits the announcement of yet another
new set of standards for the conduct of training and assessment in RTOs. Similar
exercises take place periodically in the Australian training sector, with each of the new
systems since 2000 coming with a fresh set of standards that ultimately fail to ensure
quality of training and assessment (see Hampson and Junor, 2010).
iv The tasks are listed in an appendix to the CASR Part 145 Manual of Standards. See
http://www.comlaw.gov.au/Details/F2011C00688, Appendix II
v It should be noted that the second proposal was issued only after meetings with
airlines that had raised concerns, see DCA (1971). Department of Civil Aviation,
Proposals for changes in aircraft maintenance engineer licensing with respect to major
regular public transport operators, Issue 2, November 1969, copy contained in ALAEA,
A report on proposals to alter the system of licensing aircraft maintenance engineers
and the system of maintenance and certification authority in the Australian aircraft
industry, Sydney, June 1971, p. 31.
vi Letter, D.G. Coleman, Federal Secretary, ALAEA to W.C. Taylor and Scott, Solicitors,
19th March 1971, ALAEA archive. Bexley.
vii Copied document, Box labelled Licensing Committee, ALAEA archives, Bexley.