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2.6.5 While not all-inclusive, initial training topics usually cover:
• Company and aircraft manual management;
• Records control and its associated system of reporting;
• Maintenance scheduling;
• Organizational procedures and techniques;
• Specialized equipment and its use;
• Aircraft type, aircraft systems, and ground equipment;
• Specific skills, such as avionics, composite repair, aircraft run-up and taxi training, and skills upgrade;
• A general overview of human factors training as applicable to aircraft type; and
• Other task-specific training that ensures predefined and validated competencies.
2.7 On-the-Job Training (OJT).
2.7.1 OJT is direct instruction, usually one-on-one training located at the job site. A large majority of maintenance learning occurs through OJT training. OJT is a planned, structured training event conducted at a worksite and validated by a designated OJT trainer. This type of training provides direct experience in the work environment in which the employee is performing or will be performing on the job.
2.7.2 Since OJT is a one-on-one exchange, it provides a method for the CAMP organization to evaluate individual competencies and ensure employees understand the task expectations and performance standards. It is often the final validation that employees have the knowledge and skill to perform a task competently before being fully authorized to perform on their own. A well-managed OJT program that utilizes instructors that are current and well-versed in the task is an asset to a CAMP Training Program. However, a poorly managed OJT program presents a high-risk safety issue. It can be the root cause of bad habits, tribal knowledge, and repeated norms that can cause noncompliance or create unsafe conditions.
2.8 Recurrent Training.
2.8.1 Recurrent maintenance training, also known as refresher training, is continuing education that occurs on a repetitive basis to ensure the individual maintains a required level of competency and remains capable of properly performing their assigned job. Recurrent training also is used to introduce the employee to aircraft modifications; new or different ground equipment; new procedures, regulations, techniques, and methods; or other new information. The training program should have procedures to determine the type and frequency of recurrent training required for each of its employees through the needs assessment process (see paragraph 3.4).
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2.8.2 The recurrent training program usually includes two types of training:
• Training conducted on demand to bring employee skills and competencies up to date with existing equipment, new/different equipment, and/or procedures; and
• Training conducted on a scheduled basis to maintain employee competency (refresher training).
2.8.3 Recurrent training should not include repetitive information unless it is necessary to maintain the desired degree of competence. Examples of recurrent training include:
• Continuing training based on individual competencies that is designed to maintain regulatory and certificate currency requirements;
• Training on a seldom-accomplished task or seldom-used skill;
• Update training for particular tasks or skills, which can include the use of training bulletins, bulletin board items, self-study tasks, and computer-based instruction;
• Scheduled recurrent human factors and safety management training;
• Specific training designed to correct deficiencies identified by CASS, self-disclosure programs, or other event reporting systems; and
• Any other continuing education or training not provided on a defined schedule.
2.9 Requalification Training.
2.9.1 Requalification training is conducted specifically to restore previously qualified maintenance personnel to a qualified status in a particular task or job assignment. To be eligible for requalification, maintenance personnel must have been previously qualified in that particular task or job assignment and have subsequently lost that qualification.
2.9.2 Maintenance personnel become unqualified when they fail to:
• Remain current through experience as required by the regulations (i.e., are not current), or
• Complete recurrent training within the eligibility period established by the CAMP Training Program (i.e., becoming overdue).
2.9.3 Maintenance personnel meet requalification training objectives by completing requalification curriculum segments. The reasons for and the length of the maintenance personnel’s unqualified status will usually determine the training and qualification curriculum segments needed for requalification. Requalification may be as simple as having individuals demonstrate their ability to accomplish tasks for which they were previously qualified, or having the individual repeat the initial training for the task.
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2.10 Remedial Training.
2.10.1 Remedial training assists an employee in building knowledge, skill, or aptitude for performing specific tasks where deficiency in competence has been demonstrated. The maintenance training portion of the manual should have procedures to determine when an individual requires remedial training. In some instances, this type of training should consist of a suitably experienced individual who reviews procedures with an employee through OJT. The maintenance training program should be especially flexible in this area and provide the means necessary to provide the individual in need with the immediate knowledge or skill in which they were found to be deficient. Remedial training may focus on one individual at a time, but can also be delivered to several individuals at the same time if more than one person was involved with triggering the specific or reoccurring event.
2.10.2 Successful remedial training will show an individual what happened, why it happened, and, in a positive manner, how to prevent it from happening again. Remedial training and its general use and descriptions will be part of the maintenance training portion of the manual and may be included within the recurrent training requirements.
2.11 Aircraft/Airplane Equipment Specific Training. For example, type, engine, accessories, etc.
2.11.1 The CAMP Training Program portion of your manual outlines and explains your expectations in order to qualify individuals to perform work for you on specific airplanes or other products or articles. This training is specific to the type of work being performed
(e.g., heavy maintenance, light maintenance, or aircraft line maintenance, and considers aircraft size and type). Aircraft/airplane equipment-specific training is technical training applied formally and followed up with OJT. It is very specific in the use and references within your manual system that provides the methods, techniques, and practices that must be followed.
2.11.2 Your CAMP Training Program is your method to ensure each person performing maintenance, preventive maintenance, or an alteration on an aircraft, engine, propeller, or appliance knows where to find and use the methods, techniques, and practices prescribed in your manual. Each person must know how to obtain and use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with your procedures. If the manufacturer recommends special equipment or test apparatus, you must ensure they know how to use that equipment or apparatus or its equivalent.
2.11.3 Your CAMP Training Program should provide sufficient instruction so that individuals know how to determine that the adequacy of their work, and (if required) the work of others, is in the manner prescribed by you. Personnel should receive instruction in the use of your manuals and equipment. This enables them to be able to validate that the work done is in such a manner and the materials used are of such a quality that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on is at least equal to its original or properly altered condition. This is with regard to aerodynamic function,
2-8 structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness, as required by part 43, § 43.13(b).
2.11.4 Your CAMP Training Program should educate individuals in your approved methods to identify inspections or other maintenance identified as airworthiness limitations (AL).
Individuals must understand the strict need to follow your approved instructions for continued airworthiness when performing an AL inspection or maintenance.
2.12 Specialized Tasks.
2.12.1 Maintenance training for specialized tasks focuses on competency in specific tasks or areas of responsibility. The training program may combine specialized task training with initial or recurrent training. The maintenance training portion of the manual should identify job assignments that require special skills or are complex. It should also identify the associated specialized training needed to validate that the individuals assigned have the skills and ability to competently perform the work. Some subject areas that may require specialized training include:
• Special inspection or test techniques, such as nondestructive inspections;
• Special machining operations;
• Complex welding operations;
• Complex assembly operations;
• Complex rigging procedures;
• Engine test cell runs; and
• Engine overhauls.
Note: Individuals who attend specialized training and develop competency in a particular job assignment or task may be tasked by the organization to convey the information to other employees. This would be a form of OJT.
2.12.2 Specialized training also may include enrichment training courses that are not necessarily required for a qualification but are simply a means to enhance skills and knowledge in support of an individual’s trade or subjects that are not maintenance related, such as:
• Management skills training for new supervisors,
• Computer skills, or
• Other training necessary because of a change in an individual’s duties and responsibilities.
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2.13 Competency-Based Training.1 1 The information cited in paragraphs 2.13.1 through 2.13.3 is available at https://www.efrontlearning.com/blog/201 5/10/4-ways-to-imp lement-a-competency-based-training-program.html.
2.13.1 This trai ning measures employee learning rather than time spent in training or in class. Its focus is on the learning achieved in the course and the rate of its transfer to the performance context. It allows flexibility to move through training based on the skills of the learner. Learners are able to tackle chapters and exercises in any order they desire.
The grading scheme measures student knowledge, skills, ability, and performance.
2.13.2 Consider the power of technology for teaching and learning. This can give learners the ability to respond to each other’s help questions, making leaders in those respective areas.
A typical feature of competency-based training is that it may be computer mediated. This training could be online in a learning management system, or it could be standalone.
Educational technology provides the desired flexibility to modify the training and development plans according to the learners. Technology fulfills the learning measurement requirement of the competency-based program. Have the learners submit their assignments using a variety of educational technology tools. Create links to tutorials or create short tutorials that teach learners how to use a tool to develop an assignment.
You can use Facebook, YouTube, and Twitter to communicate with your learners by creating dedicated course pages in these social media applications. In short, try to re-create the real-world work environment scene through productivity-enhancing technology.
2.13.3 Shift the focus from the trainer to the trainee. When trainers become talking heads holding scheduled training sessions for a predetermined time, the instruction takes place at the trainers’ pace. For most trainees, this will be the wrong pace. Some will need to go more slowly; others will be able to move much faster. Competency-based learning shifts the role of the trainer from that of “a sage on the stage” to a “guide on the side.” Trainers become the mentors who redirect conversations to synthesize and transfer knowledge according to the work context of the learners. This is one of the biggest benefits of an eLearning course. Learning is focused more on the learner than on the trainer. This means that the course dynamics will change with each batch of learners based on their unique needs, experiences, and goals.
2.14 Maintenance Provider Training.
2.14.1 You may arrange with another person for the performance of your CAMP. A maintenance provider is a person other than one you have trained and employed directly.
However, you must ensure those maintenance providers who determine the adequacy of work know how to access your manuals and are able to meet your expectations. Persons who perform work under your CAMP must have a full understanding of their assigned duties and authority and fully understand that performance in accordance with your CAMP is required. You may administer your CAMP Training Program to a maintenance provider, or you may accept the maintenance provider’s training. To accept a maintenance provider’s training, your CAMP manual will include policies, procedures,
2-10 methods, and instructions for you to assess the maintenance provider’s training and ensure competence by your standards. Your CAMP manual will include a means to present, explain, and ensure the methods, techniques, and practices defined in your manual are understood.
2.14.2 When you arrange with another person to perform the work of your CAMP, your CASS must be especially diligent to validate the performance and effectiveness of your CAMP.
Your CASS is always required to correct deficiencies in your program regardless of whether those programs are carried out by you or by another person. When deficiencies (related to competence) are identified, your CASS must be able to influence and correct a maintenance provider’s training whether this training is administered by you or by the provider. A maintenance provider may have a very robust training program; however, you must ensure those you contract with and authorize to perform maintenance (including inspection), preventive maintenance, and alterations understand and do so per your manual. You may arrange with another person for the performance of any maintenance, preventive maintenance, or alterations. However, this does not relieve you of the responsibility for the airworthiness of your aircraft (including airframes, aircraft engines, propellers, appliances, and parts thereof) and the performance of the maintenance, preventive maintenance, and alteration of your aircraft (including airframes, aircraft engines, propellers, appliances, emergency equipment, and parts thereof) in accordance with your manual.
3-1 CHAPTER 3 TRAINING PROGRAM BASIC COMPONENTS
3.1 General Components.
3.1.1 An effective CAMP Training Program will reflect the size and complexity of your CAMP. These training programs can range from small and simple to large and complex.
The following sections describe components of an effective CAMP Training Program.
These sections or their equivalent should be documented in the manual section that contains your CAMP:
3.2 Job A nalysis.
3.3 Competency Standards.
3.4 Training Needs Assessments.
3.5 Course Development.
3.6 Training Completion Documentation.
3.7 Training Program Review and Evaluation.
3.2 Job Analysis.
3.2.1 Job analysis is the foundation for all competency assessments and selection decisions. To identify the best person for the job, it is crucial to fully understand the nature of that job.
Job analysis provides a way to develop this understanding by examining the tasks performed in a job, the competencies required to perform those tasks, and the connection between the tasks and competencies.
3.2.2 Information from a job analysis is used to determine job requirements within your CAMP. From this analysis, you can establish your training needs and position descriptions. Job analysis will establish where you need positions and which of these positions are directly in charge of your maintenance activities. It is through job analysis that you are able to accomplish performance appraisals, enhancements, correction, and job promotion.
1. Job analysis of your CAMP requires you to evaluate measurable patterns of knowledge, skills, abilities, behaviors, and other characteristics (competencies) that an individual needs to perform your CAMP tasks and functions successfully.
2. Your CAMP job task analysis should focus on the “how” of performing CAMP job tasks, or what the person needs to do in order to accomplish the task successfully.
3.3 Competency Standards.
3.3.1 Competency standards are the measurable pattern of knowledge, skills, abilities, behaviors, and other characteristics that are needed to perform your CAMP duties and job tasks.
3.3.2 Your CAMP job tasks require competencies that are general, technical, or both.
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1. General competencies reflect the cognitive and social capabilities (e.g., problem solving and interpersonal skills) required for job performance under your CAMP.
2. Technical competencies are more specific as they are tailored to the particular knowledge and skill requirements necessary for a CAMP-specific job.
3.3.3 A person who is competent in your CAMP knows how to determine the adequacy of their own work, and (if required) the work others do, in relation to and in accordance with your manual.
3.3.4 To perform under your CAMP, individuals must understand their respective roles toward releasing airworthy aircraft into service. Competent personnel have a full understanding of their assigned duties and authority. They fully understand their part in your overarching responsibility to ensure airworthiness.
3.4 Training Needs Assessment.
3.4.1 Assessing what knowledge, skills, and abilities your entire CAMP organization needs to manage and apply your CAMP effectively will allow you to structure your CAMP Training Program to the size and scope of your overall CAMP maintenance organization.
A training needs assessment ensures that throughout your organization competent personnel are available to determine the adequacy of work.
3.4.2 Assess three levels of your CAMP organization:
3.4.2.1 An organizational assessment determines where you need certain competencies to lead, guide, perform, and control your CAMP. This assessment relies on real-life analysis of your CAMP and the conditions under which your operation exposes it. An unbiased analysis of these conditions will identify where you need leadership, technical skill, inspection expertise, and supervisory competencies. Reliance on facts and data rather than norms, favoritism, cronyism, and office politics will allow you to take advantage of personnel strengths, mitigate process risk, and manage human behavior.
Continual analysis and surveillance of positions within your CAMP organization will allow you to ensure the right people, with the right skills, are in the right position regardless of changing demographics, operational trends, technology, and the economy. Understanding the competency demands of your organization’s positions will allow you to take full advantage of the strengths of your people and prepare them for the duties you expect them to perform both now and in the future.
3.4.2.2 Occupational assessments examine the knowledge, skills, and abilities in relation to the authority you delegate to individual groups (e.g., directors, managers, inspectors, Required Inspection Item (RII) authority, mechanics, maintenance control, maintenance planning and scheduling, recordkeeping, receiving inspection, etc.). Continual occupational assessment of group performance of your CAMP will identify discrepancies or gaps that creep in over time. Regularly scheduled and routine occupational assessments will
3-3 allow you to enhance through training the competencies needed to perform your CAMP job-related duties and tasks. Your occupational assessment becomes the mechanism to introduce new and more efficient ways to do the work of your CAMP while eliminating competency gaps.
3.4.2.3 Individual assessments analyze how well an individual employee is doing a job and determines the individual’s capacity to do new or different work.
Individual assessment provides information on which employees need training and what kind.
3.4.3 Training needs assessment process:
1. Establish training program goals and standards.
2. Perform CAMP organizational, occupational group, and individual job analysis.
3. Establish certification and qualification standards for:
• Your Director of Maintenance (DOM) and Chief Inspector.
• Those directly in charge of maintenance (including inspection).
• Those who may perform maintenance (including inspection), preventive maintenance, and alterations.
• Those with approval for return-to-service authority.
• Those required to perform required inspections.
• Those who review records to ensure aircraft airworthiness.
4. From your job analysis, identify specific competencies (e.g., knowledge, skills, and abilities) needed by:
• Those who work under your CAMP to fill specific CAMP organizational oversight positions.
• Those who work under your CAMP to fill an occupational group position.
• All individuals who perform under your CAMP, including maintenance provider individuals performing contracted CAMP work.
3.4.3.1 A CAMP organization must have a means to determine that all of its maintenance personnel, including maintenance provider personnel, are competent to accomplish their duties. An individual needs assessment evaluates the current capability of its technical and nontechnical employees.
An employee needs assessment usually is performed when an individual is hired; however, the CAMP organization may require a needs assessment when an employee changes jobs. Even though only those individuals performing maintenance, preventive maintenance, alterations, or required inspections (and those who determine the adequacy of work) must be trained under §§ 91.1433,
121.375, and 135.433, the certification rules §§ 119.65 and 119.69 require the organization to have sufficient management and technical personnel to ensure
3-4 safety. These individuals who serve in the organization must be qualified (through training, experience, and expertise to the extent of their responsibilities) and have a full understanding of the material governing the operation. While you may hire individuals with the training, experience, and expertise you require, your CAMP Training Program identifies the competencies required of these positions. The CAMP Training Program empowers you to train and prepare your employees for management roles and responsibilities within your organization.
3.4.3.2 The training program should differentiate between those employees that require training under §§ 91.1433, 121.375, and 135.433, and those trained at its discretion and in accordance with its organizational procedures. An assessment of each employee’s capabilities should be made as it relates to the tasks they are expected to perform and will identify employee-specific training needs.
3.4.3.3 When carrying out any assessment of an individual’s capabilities, the assessment process should be as objective as possible and well-structured to produce consistent results. The training program should have procedures to ensure the individual conducting the assessment is qualified to conduct the evaluation and interpret the results. It may be necessary to use more than one method to adequately assess an individual’s capability.
3.4.3.4 The training program also should have procedures to accept prior experience, training, or education to establish an individual’s capability. For example, a CAMP organization may accept graduation certificates from a 14 CFR part 147 school and/or an Airframe and Powerplant (A&P) certification as acceptable evidence of a basic knowledge and skill level in a particular area.
A CAMP organization also could have procedures for accepting certificates/documentation of previous training by manufacturers, airlines, operators, or associations, and also maintenance experience obtained at airlines, operators, repair stations, or the military. The CAMP organization should have procedures to document the assessment in the individual’s training records.
3.4.3.5 Yo ur CAMP training assessment must ensure competent people are available.
Employee evaluation methods and their usefulness are listed in Table 3-1.
3-5 Table 3-1. Employee Evaluation Methods Method for Capability Evaluation Usefulness of Method Formal examination This may include development of formal written test procedures with pass/fail criteria. While it is an effective method for assessing knowledge, it does not necessarily determine whether an individual can apply the knowledge to the assigned tasks.
Certificate Possessing a certificate may be a prerequisite for some specialized positions. The certification of qualifications or education from a credible source can measure an individual’s knowledge. However, it does not necessarily assess the individual’s ability to apply that knowledge to assigned tasks.
Completion of a training course A review of the documentation or instruction provided may be used to establish an individual’s knowledge of a subject. Completion of training courses is most useful when there is some verification, through testing or demonstration, that the individual absorbed the course objectives. However, successful completion of a training course does not necessarily translate into the ability to accomplish a task.
Practical evaluation A practical evaluation permits the employee to demonstrate skills in a controlled environment that is similar to a situation, or part of a situation, encountered in real life. Such an evaluation might, for example, allow the reviewer to focus on the critical steps in a time-consuming process without actually going through the entire process. This can be an effective way to determine an individual’s capability; however, the assessment can depend on the skills of the individual designing the practical evaluation mechanism.
Group exercise A properly designed group exercise can help demonstrate the understanding of a group that must work together on a project.
Where an employee’s understanding of their role in a larger scheme is important, a group exercise that tests that knowledge in an appropriate context can illuminate whom within the group needs assistance and can illuminate human factors elements of the training that might otherwise be misunderstood by the students. This process lends itself well to immediate remedial training as well as reinforcement of the training given to other members of the group, where properly administered.
On-the-job assessment These types of assessments should be objectively based and judged by successful accomplishment of specified tasks. This is an effective way to determine an individual’s capability; however, the assessment can depend on the skills of the individual accomplishing the assessment unless objective criteria are established.
3-6 Method for Capability Evaluation Usefulness of Method Oral examination in the working environment These types of assessments should be objectively based and judged by the proper response to a consistent set of questions. This is an effective way to assess an individual’s knowledge and ability to apply that knowledge. It also is a valid method of determining whether an inspector or supervisor is capable of reading, writing, and understanding the English language. However, it can depend on the skills of the individual conducting the examination unless objective criteria are established.
Note: The above list of evaluation methods should not be considered exhaustive. Unique instructional and teaching methods often give rise to unique evaluation mechanisms. The FAA encourages the use of new techniques for conducting evaluations.
3.4.3.6 Your CAMP training assessment can allow you to address human error due to lack of competency.
1. A human factors analysis looks at how your employees communicate and perform in the work environment and then seeks to incorporate that knowledge into the design of equipment, processes, and organizations.
2. Analysis of human factors will identify issues affecting how people interface with technology and operational systems; how well people understand new or changed equipment, technology, and documentation;
and how well people perform within the general workplace environment.
3. Knowledge gained from human factors analysis can help you avoid maintenance errors, ensure that an individual’s initial skill sets match task requirements, and enhance the overall work environment.
3.4.3.7 Document the results of the training assessment and the standards required for each job position or task. Each CAMP organization may approach this documentation differently, but the ultimate outcome should be a document outlining the training requirements by category. For example, a CAMP organization may define training based on:
• Job positions or functions,
• Job tasks,
• Aircraft worked on, or
• A combination of the above.
3.4.4 Figures 3-1 through 3-4 provide examples of documentation for a training needs assessment. These are examples; the exact format is up to you.