U.S. Depar tment of Transportation Federal Aviation Administration Advisory Circular Subject: Continuous Airworthiness Maintenance Program (CAMP) Training Program Date: 10/24/23 AC No: 120-124 Initiated by: AFS-300 Change:
This advisory circular (AC) provides Federal Aviation Administration (FAA)-acceptable information to use in the development of the required maintenance training program element of a Continuous Airworthiness Maintenance Program (CAMP).
The AC contains methods that operators of aircraft under Title 14 of the Code of Federal Regulations (14 CFR) parts 121, 135, and 91 subpart K (part 91K) (fractional ownership operations) that maintain their aircraft under a CAMP may use to comply with the maintenance training requirements of the regulations. Operators may elect to follow an alternate method, provided it is acceptable to the FAA. Because the means of compliance we present in this AC is not mandatory, the term “should” applies only if you choose to follow these particular methods.
Operators must tailor their maintenance training program to their specific operation, personnel, management structure, and organizational needs. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, and the document is intended only to provide information to the public regarding existing requirements under the law or agency policies.
Wesley L. Mo oty Acting Deputy Executive Director, Flight Standards Service
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CONTENTS Paragraph Page
Chapter 1 General1-1
1.1 Purpose of This Advisory Circular (AC)1-1
1.2 Terms We Use in This AC1-1
1.3 Applicability1-1
1.4 Audience1-2
1.5 Where You Can Find This AC1-2
1.6 What is “Competent” as Used in the Regulations and This AC?1-2
1.7 What is the Regulatory Basis for the CAMP Training Program Element?1-2
1.8 Who Accepts CAMP Training?1-2
1.9 Who Receives CAMP Training?1-4
1.10 How Does Your CAMP Training Program Interface With Your Safety
Management System?1-6
1.11 Is My Non-Extended Operations (ETOPS) CAMP Training Program Sufficient
for ETOPS?1-7
1.12 What Determines the Complexity and Scope of a CAMP Training
Program?1-7
1.13 Which Regulations and Other Guidance Material are Related to This AC?1-8
Chapter 2 Types of Training2-1
2.1 Purpose of This Chapter2-1
2.2 CAMP Indoctrination2-1
2.3 Code of Federal Regulations (CFR)2-2
2.4 Maintenance Policies and Procedures Content and Usage2-2
2.5 Human Factors Training (Initial and Recurrent)2-2
2.6 Initial Training2-4
2.7 On-the-Job Training (OJT)2-5
2.8 Recurrent Training2-5
2.9 Requalification Training2-6
2.10 Remedial Training2-7
2.11 Aircraft/Airplane Equipment Specific Training2-7
2.12 Specialized Tasks2-8
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2.13 Competency-Based Training2-9
2.14 Maintenance Provider Training2-9
Chapter 3 Training Pro gram Basic Components3-1
3.1 General Components3-1
3.2 Job Analysis3-1
3.3 Competency Standards3-1
3.4 Training Needs Assessment3-2
Table 3-1. E mployee Evaluation Methods3-5
3.5 Course Development3-9
3.6 Training Completion Documentation3-17
3.7 Training Program Review and Evaluation3-18
Chapter 4 Main tenance Training Course Subjects4-1
4.1 Regulatory Maintenance Training Course Subjects4-1
4.2 Maintenance Human Factors Training4-4
4.3 Safety and Risk Management Subjects4-6
4.4 Maintenance-Specific Courses4-7
Chapter 5 Contract Maintenance Training5-1
5.1 Contract Maintenance Oversite5-1
5.2 Basic Training Program Requirements5-3
5.3 Subject Areas5-5
Chapter 6 Admin istrative Information6-1
6.1 Copies of This AC and Other FAA Publications6-1
6.2 Further Information on This AC6-1
6.3 AC Feedback Form6-1
Appendix A. S a mple Training ProgramA-1
iv List of Figures Figure 3-1. Sample Training Needs Assessment Documentation by Job Description
and Task3-7
Figure 3-2. Sample Training Needs Assessment Documentation by Type of Work3-7
Figure 3-3. Sample Training Needs Assessment Documentation by Job Description3-8
Figure 3-4. Sample Training Needs Assessment Documentation by Job Description
and Timeframe3-8
Figure 3-5. Sample 1 of Course Requirements Documentation3-16
Figure 3-6. Sample 2 of Course Requirements Documentation3-17
1-1 CHAPTER 1 GENERAL
1.1 Purpose of This Advisory Circular (AC). This AC explains the scope and detail the Federal Aviation Administration (FAA) expects of a Continuous Airworthiness Maintenance Program (CAMP) Training Program and offers a means (but not the only means) of compliance with Title 14 of the Code of Federal Regulations (14 CFR) part 91, § 91.1433; part 121, § 121.375; and part 135, § 135.433, the regulations requiring maintenance and preventive maintenance training programs.
1.2 Terms We Use in This AC.
1.2.1 When we use “must” or “will” in this AC, we are referencing actual regulatory requirements.
1.2.2 When we use “we,” “us,” or “our” in this AC, we mean the FAA. When we use “you,” “your,” or “yours,” we mean you, the air carrier certificate holder (CH), or the part 91 subpart K (part 91K) program manager.
1.2.3 We use the term “person” as defined in 14 CFR part 1, § 1.1, meaning an individual, firm, partnership, corporation, company, association, joint-stock association, or governmental entity. It includes a trustee, receiver, assignee, or similar representative of any of them.
1.2.4 When we use the acronym “CAMP,” we are referring to an “Aircraft Maintenance – Continuous Airworthiness Maintenance Program (CAMP) Authorization” the FAA issues to you via operations specification (OpSpec) D072 if you are a part 121 or 135 air carrier, or via management specification (MSpec) D072 if you are a part 91K fractional ownership operations program manager. A table within each D072 specification identifies a document or set of documents that describe comprehensively, and in detail, your maintenance program design. The table associates your document(s) (i.e., your maintenance program) with the specific make/model/series (M/M/S) aircraft you intend to maintain by following it. FAA authorization of a CAMP includes acceptance that the CAMP Training Program is compliant with §§ 91.1433, 121.375, and 135.433.
Note: Incorporation by reference: instead of repeating information contained in another document, a CAMP operator may incorporate information from a document or part thereof, by referring and/or providing links to it in the text of its CAMP manual.
1.2.5 The regulations related to CAMP authorizations and use are essentially the same for parts 91K, 121, and 135 operations. Therefore, phrases such as “CAMP operators,” “CAMP operations,” “CAMP organization,” and “CAMP Training Program” address parts 91K, 121, and 135 operations that maintain aircraft subject to a CAMP.
1.3 Applicability. A CAMP authorization is a requirement for all CHs operating under part 121. A CAMP authorization is also the preferred means of meeting the continuing maintenance requirements of § 135.425 for part 135 aircraft that are type certi ficated for a passenger-seating configuration, excluding any pilot seat, of 10 seats or more. It is an
1-2 option for part 135 CHs who are not otherwise required to maintain their aircraft under a CAMP, as well as an option for part 91K fractional ownership operations.
1.4 Audience. This AC applies to persons who obtain MSpec or OpSpec D072. To receive this authorization, you must have a CAMP Training Program that is acceptable to the FAA.
1.5 Where You Can Find This AC. You can find this AC on the FAA’s website at https://www.faa.gov/regulations_policies/advisory_circulars and the Dynamic Re gulatory System (DRS) at https://drs.faa.gov.
1.6 What is “Competent” as Used in the Regulations and This AC? Competent, as used in §§ 91.1425, 91.1433, 121.367, 121.375, 135.425, and 135.433, means a measurable pattern of knowledge, skills, and abilities; as well as past behavioral experience and expertise that is relevant to an individual’s specific duty, task, or job assignment. The specific competency may be substantiated by a certificate, authorization, training record, résumé, or some other form of documentation.
1.6.1 General and Technical Competencies. Compe tencies tend to be either general or technical. General competencies reflect the cognitive and social capabilities
(e.g., problem solving, interpersonal skills) required for job performance in a variety of occupations. On the other hand, technical competencies are specific and require you to tailor them to the particular knowledge and skill requirements necessary for a specific job.
1.6.2 A Competent Person. A c ompetent person knows how to determine the adequacy of the work they do and, if required, the work others do in accordance with your procedures. A competent person has a full understanding of their assigned duties and authority and fully understands their part in your overarching responsibility to ensure airworthiness.
1.7 What is the Regulatory Basi s for the CAMP Training Program Element?
Sections 91.1433, 121.375, and 135.433 provide the direct requirements for you to have a maintenance training program. In addition, you are required to ensure the provision of competent personnel to perform maintenance, preventive maintenance, and alterations (§§ 91.1427, 121.369, and 135.427). Title 14 CFR part 119, §§ 119.65 and 119.69 require specific training requirements for parts 121 and 135 CHs’ management and technical personnel and anyone in a position to exercise control over operations.
1.8 Who Accepts CAMP Training? The FAA must accept your training program’s documented design and validate its performance before issuing a D072 authorization.
You should assess, accept, and authorize contractor maintenance training when you choose to use them. The FAA expects your documented training program design will cover the access, use, and content of your CAMP manual; your assessment methods that ensure a person is fully informed and competent; training recordkeeping; acceptance of contract maintenance programs when you choose to use them; and a solid interface with your Continuing Analysis and Surveillance System (CASS).
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1.8.1 Basic Content of the Maintenance Manual. The emphasis and significance of your manual cannot be overstated. Your CAMP is unique to you, and therefore §§ 91.1023,
121.133, and 135.21, in conjunction with §§ 91.1437, 121.369, and 135.427, require you to produce a manual that reflects your design. Your manual provides personnel with your direction, procedures, instructions, guidance, and information that you require them to follow in order for you to meet your primary responsibility requirements and maintain safe operations. Therefore, an acceptable CAMP Training Program must derive its basic content and curriculum from your CAMP manual and will address the unique nature and requirements your CAMP requires. The FAA should be able to identify some form of introductory training that ensures each person knows how to access the CAMP manual part(s) that is relevant to them. The CAMP Maintenance and Preventive Maintenance Training Program must inform, teach, reinforce, and emphasize the methods, techniques, and practices of your CAMP manual.
1.8.2 Method to Ensure a Person is Fully Informed and Competent. A CAMP Training Program is your means to present, explain, and ensure maintenance personnel understand the methods, techniques, and practices defined in your manual. Your CAMP Training Program is your means to emphasize to those you employ, contract with, and authorize to perform maintenance (including inspection), preventive maintenance, and alterations that they must do so in accordance with your manual. Your CAMP Training Program is where you determine personnel are fully informed and competent based on your standards and expectations. The method you use to meet the requirements of §§ 91.1425,
121.367, and 135.425 to provide competent personnel must be documented in your CAMP manual per §§ 91.1427, 121.369, and 135.427.
1.8.3 Training Recordkeeping. The FAA expects your CAMP Training Program to gather, produce, and maintain training records of your employees and include a method that explains how you oversee and verify contractor employee records. Training records validate that personnel have a full understanding and are competent. These records should show that you or your contract provider have considered past and present training, experience, and certifications; compared them to the competency standards you have set in your manual; and provided additional training as required to fill any identified knowledge or competency gaps.
1.8.4 Contract Provider Training Programs. You should assess, accept, and authorize contractor maintenance training when you choose to use them. The regulations accommodate the significant safety benefits afforded by contract maintenance providers, especially in highly technical and specialized areas of maintenance; however, doing so induces risks that the CAMP operator needs to control and explain within its CAMP manual. The CAMP operator has overarching responsibility for training regardless of whose program it is or who is delivering it. Sections 91.1427, 121.368, 121.369(b)(10),
135.426, and 135.427(b)(10) require your manual to include your methods to evaluate maintenance provider training, supplement it as is necessary, accept its content and delivery methods, authorize its use through a maintenance provider agreement or method your manual describes, and continuously verify training performance and effectiveness.
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1.8.5 CASS Interface. Sections 91.1431, 121.373, and 135.431 require CHs t o establish and maintain a system for the continuing analysis and surveillance of the performance and effectiveness of its inspection program and the program covering other maintenance, preventive maintenance, and alterations. This includes the correction of any deficiency in those programs, regardless of whether those programs are carried out by the CH or by another person. Therefore, regardless of whether your CAMP Training Program is of your design or a contract maintenance provider training program you accept as part of your design, your CASS must be able to influence your training when it identifies or associates root cause deficiencies with your training program design or delivery of your maintenance training. You are responsible for ensuring that maintenance, preventive maintenance, and alterations performed by your maintenance employees, or by other persons for you, is performed in accordance with your manual.
1.9 Who Receives CAMP Training? The CAMP Training Program applies to your entire maintenance organization. Sections 91.1423, 121.365, and 135.423 require an organization to adequately perform maintenance, preventive maintenance, alterations, and required inspections. Sections 91.1427, 121.369, and 135.427 require you to place in your manual a chart or description of your organization and a list of the persons you have arranged with to perform any of your required inspections, other maintenance, preventive maintenance, or alterations. The performance of maintenance (including inspection), preventive maintenance, and alterations, followed by the article’s subsequent return to service, is an organizational responsibility with individual duties that are often divided and diverse. Each person performing functions such as manual management, maintenance control, records control, maintenance scheduling, assuring serviceability of parts, and maintaining your CASS has a role in determining the “adequacy of work.” As such, your CAMP Training Program, per §§ 91.1433, 121.375, and 135.433, should ensure each individual (within their respective organizational roles) is fully informed about procedures, techniques, and new equipment in use, and is competent to perform their duties as they relate to determining the adequacy of the work done under your CAMP authority.
1.9.1 Your CAMP Organizational Manag ement. The management-related provisions for part 91K for fractional ownership operations, and those in §§ 119.65 and 119.69 for parts 121 and 135 air carriers, require sufficient management and technical personnel who are qualified through training, experience, and expertise. AC 120-16, Air Carrier Maintenance Programs, explains these positions are necessary to perform, supervise, manage, and amend your CAMP; manage and guide your maintenance personnel; and provide the direction necessary to achieve your CAMP objectives defined in §§ 91.1425,
121.367, and 135.425. The duties, responsibilities, and authority of personnel that fill these required or approved positions must be as stated in the general policy provisions of the manual required by §§ 91.1023, 121.133, and 135.21. While you may hire individuals with the training, experience, and expertise you require, your CAMP Training Program should ensure the personnel you provide have a full understanding of their duties, authority, and responsibility. The CAMP Training Program empowers you to train and prepare your employees for management roles and responsibilities within your organization. To the extent of their responsibilities (per §§ 119.65 and 119.69), these individuals should fully understand:
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• Aviation safety standards and safe operating practices;
• Title 14 CFR Chapter I (Federal aviation regulations);
• Your OpSpecs;
• All appropriate maintenance and airworthiness requirements (e.g., 14 CFR parts 1, 21, 23, 25, 43, 45, 47, 65, 91, and 121); and
• Your manual required by §§ 91.1023, 121.133, and 135.21.
1.9.2 Those Who Perform Maintenance, Pr eventive Maintenance, and Alterations and Those Who Approve Work for Return to Service.
1.9.2.1 The training program must ensure that CAMP operator personnel, or the persons with whom the CAMP operator has arranged to perform the work, understand the policies, procedures, and instructions in their maintenance manual; are fully informed about procedures, techniques, and new equipment in use; and are competent to perform their duties. Sections 121.379 and
135.437 grant parts 121 and 135 CHs th e authority to perform maintenance, preventive maintenance, and alterations as provided in their maintenance manuals. In addition, they authorize those CHs to approve for return to service any airframe, aircraft engine, propeller, rotor (rotorcraft may be used in part 135, but not part 121), or appliance after performing that maintenance, preventive maintenance, or alteration. As part of the approval for return to service, §§ 121.709 and 135.443 restrict airworthiness releases, logbook entries, and approvals for return to service to only appropriately certificated persons.
1.9.2.2 Un like air carriers, part 91K operators are not maintenance entities. The performance of maintenance, preventive maintenance, and alterations, and the subsequent approval for return to service, must be by a certificated person authorized to do so under part 43. A part 91K program manager may perform and/or approve maintenance for return to service only if properly certificated.
However, the part 91K program manager still has the responsibility, with the Director of Maintenance (DOM), to ensure the personnel they employ or contract with are appropriately certificated, have a full understanding of the CAMP manual procedures and techniques, are fully informed of any new equipment in use, and are competent in accordance with their manual.
1.9.3 Required Inspection Personnel. Sections 91.1429, 121.371, and 135.429 provide that persons who perform required inspections for you must be appropriately certificated, properly trained, qualified, and authorized to do so, and must perform under the supervision and control of an inspection unit.
1.9.4 Contract Mai ntenance Personnel. It is common for persons performing maintenance, preventive maintenance, or alteration functions for you to have a training program of their own. When you arrange with others to perform work for you, your responsibility is to ensure these individuals are fully informed about your procedures, techniques, and new
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1.9.5 Individuals Who Perfo rm CASS Functions. Individuals who perform CASS functions must be able to validate your CAMP’s performance and assess its effectiveness. These individuals collectively determine the adequacy of all CAMP work; therefore, the CAMP Training Program is a method to ensure they are competent to do so.
1.9.6 Maintenance Department Employe es. Parts clerks, records clerks, and auditors may not need training under your CAMP Training Program; however, parts and records control, as well as complete and accurate audits, are essential to ensure airworthiness. Competent performance of these duties is expected, necessary, and may be required. Refer to §§ 91.1433, 121.375, and 135.433.
1.10 How Does Your CAMP Training Program Interface With Your Safety Management System? The Airline Safety and Federal Aviation Administration Extension Act of 2010 directed the FAA to “require all part 121 air carriers to implement a safety management system.” As a result, in 2015, the FAA published 14 CFR part 5, Safety Management Systems, applicable to air carriers conducting operations under part 121. Persons other than part 121 air carriers are encouraged to implement a Safety Management System (SMS) voluntarily. AC 120-92, Safety Management Systems for Aviation Service Providers, provides an acceptable means of complying with part 5. SMS is not a standalone program; rather it is a system that emphasizes safety and is integrated throughout all aviation-related facets of an organization. An SMS does not have to be extensive, expensive, or sophisticated to do what it is supposed to do. Part 121 air carriers and others with an FAA-accepted SMS should understand that developing and delivering any training (including maintenance training) is an opportunity to promote safety.
Because the performance and approval of maintenance is relative to your safety performance, your maintenance executives, managers, and other employees are all accountable for your safety performance (refer to § 5.23). Note that the requirements in § 5.91 (competencies and train ing) and § 5.93 (safety communication) apply for part 121 operators and should be considered in developing your CAMP Training Program. Note also that § 5.97(c) (SMS records) requires you to ma intain a record of all training provided under § 5.91 for each individual, and that those records must be retained for as long as the individual is employed by the operator. Additionally, § 5.97(d) requires part 121 operators to retain records of all communications provided under § 5.93 for a minimum of 24 consecutive calendar months.
1.10.1 Your CAMP Training Program May be a Mitigation Strategy. You may use a CAMP Training Program as a mitigation strategy to address the hazard/risk of a “nonproficient” employee or work unit.
1.10.2 Your CAMP Training Program is a Means to Gather Safety Data. E xisting programs, such as an Aviation Safety Action Program (ASAP), the CAMP Training Program, and the CASS, provide valuable data that you can integrate into an SMS. Feedback from these programs will “feed” your system, which may often identify underlying causes and identify additional hazards or increased risk.
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1.11 Is My Non-Extended Operations (ETOPS) CAMP Training Program Sufficient for ETOPS? No. A CH conducting ETOPS with two-engine airplanes must enhance its CAMP Training Program to comply with the ETOPS maintenance requirements as specified in §§ 121.374 and 135.411(d). An ETOPS CAMP has additional training requirements and expectations. In accordance with § 121.374(m) and part 135 appendix G, subparagraph G135.2.8(m ), for each airplane-engine combination, you must develop a maintenance training program that provides training adequate to support ETOPS. This may be a standalone program or an enhancement to your existing non-ETOPS CAMP Training Program. Either way you must ensure ETOPS-specific training for all persons involved in ETOPS maintenance, and this training must focus on the special nature of ETOPS. This training is in addition to your CAMP Training Program used to qualify individuals to perform work on specific airplanes and engines.
1.12 What Det ermines the Complexity and Scope of a CAMP Training Program? Your CAMP Training Program is unique to your organization. The complexity of your CAMP Training Program is proportional to the maintenance organization, the number of aircraft, aircraft make, aircraft model, and aircraft equipment configurations. The number of courses, content, time requirements, training methods, and sources within a CAMP will vary accordingly. For example, one maintenance organization may have separate indoctrination courses for technicians, inspectors, managers, and supervisors. Another maintenance organization may have only one indoctrination course appropriate for all of its employees, including temporary personnel. The FAA expects the CAMP Training Program, like the CAMP itself, to be sufficiently comprehensive in scope and detail to fulfill its responsibility to provide competent personnel and authorize inspection personnel to maintain the aircraft in an airworthy condition in accordance with the regulations. Competent individuals who perform the inspections and other maintenance, preventive maintenance, and alterations under the CAMP:
1. Understand and use the applicable portions of the CH’s/program manager’s manual to perform their assigned tasks;
2. Perform the work;
3. Determine the adequacy of the work;
4. Determine the adequacy of the work done under their supervision;
5. Accomplish the approval for return to service under §§ 91.1443, 121.709, and
135.443, as applicable, on behalf of the maintenance organization;
6. Identify Required Inspection It ems (RII) and ensure they are verified and that the required items are correct; and
7. Create complete and accurate maintenance record entries.
1.12.1 Persons tasked with reliability program or CASS data collection and analysis duties may require specialized training and technical backgrounds. It is your responsibility to ensure those who perform these duties are competent to do so. In general, these auditors and analysts should:
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1. Have a sufficient maintenance background applicable to your program.
2. Be familiar with your maintenance procedures, technical documents, and aircraft systems.
3. Be able to understand and interpret data to evaluate the facilities, equipment, and processes you use.
4. Have training and experience specific to their assigned functions and duties.
5. Have systems analytical skills.
6. Have skills in auditing techniques.
7. Be able to apply risk assessment and risk management (RM) techniques.
8. Be able to perform Root Cause Analysis (RCA).
9. Fully understand and consider human factors.
1.13 Which Regulations and Other Guidance Material are Related to This AC? For more information, consult the current editions of the following documents:
1.13.1 Title 14 CFRs .
1. Part 1, Definitions and Abbreviations. Part 1 contains the definitions of some of the words used in 14 CFR.
2. Part 5, Safety Management Systems: Subpart E—S afety Promotion.
3. Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration. Part 43 contains the rules for maintenance, preventive maintenance, rebuilding, and alteration.
4. Part 91, General Operating and Flight Rules: Subpart K—F ractional Ownership Operations.
5. Part 119, Certification: Air Carriers And Commercial Operators: Subpart C— Certification, Operations Specifications, and Certain Other Requirements for Operations Conducted Under Part 121 or Part 135 of This Chapter.
6. Part 121, Operating Requirements: Domestic, Flag, and Supplemental Operations:
Subpart L—Maintenance, Preventive Maintenance, and Alterations.
7. Part 135, Operating Requirements: Commuter and On- Demand Operations and Rules Governing Persons On Board Such Aircraft: Subpart J—Maintenance, Preventive Maintenance, and Alterations.
1.13.2 Advisory Circulars (AC).
1. AC 120-16, Air Carrier Maintenance Programs. T his AC describes a Continuous Airworthiness Maintenance Program (CAMP). It explains the background as well as the FAA’s regulatory requirements for these programs.
2. AC 120- 66, Aviation Safety Action Program. This AC provides information encouraging employees to voluntarily report safety information.