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.
Figure 3-1. Sample Training Needs Assessment Documentation by Job Description and Task Mechanic/Inspector To Sign Training Required Experience Required Airworthiness release Maintenance initial training 90 days of aircraft type applicable to aircraft type; experience or 1 year OJT experience on air carrier, transport category jet aircraft Job procedure cards General familiarization course 90 days of aircraft type for aircraft type experience or 1 year experience on air carrier, transport category jet aircraft Servicing OJT familiarization course for 90 days of aircraft type aircraft type experience or 1 year experience on air carrier, transport category jet aircraft Personnel Assigned to B737 Task Minimum Training Required Course Receipt and dispatch Pushback procedures No. 123 B737 familiarization OJT No. 347 Sign maintenance B737 initial No. 476 checks CAT I/III Autoland B737 initial or recurrent No. 123 B737 OJT No. 173 B737 CAT /| initial/recurrent No. 456 B737 CAT OJT No. 217 Figure 3-2. Sample Training Needs Assessment Documentation by Type of Work Line Maintenance B737 Initial Qualification
• General Familiarization
• Avionics Systems
• Policies and Procedures
• System Review
• Cockpit Proficiency Requalification - Every 2 years
• Policies and Procedures System Review
• Cockpit Proficiency Engine Start/Run Up/Taxi
• Policies and Procedures
• Ground Handling Engine Operation
• Safe Aircraft Movement
• Qualification JT8 RII (Engine Shop Personnel Only) Initial Qualification JT8 General Familiarization
• Required Inspection Items Requalification - Every 2 years
• Required Inspection Items 3-7
Figure 3-3. Sample Training Needs Assessment Documentation by Job Description Mechanic General Work Scope
• Qualified to perform maintenance, preventive maintenance, alterations, inspections, and repairs in accordance with approved data on any fleet type aircraft under the supervision of a fleet-type qualified mechanic Requirements
• Maintenance Orientation Course
• GMM Familiarization Course
• General Safety Course
• Federal Regulations Course
• Human Factors in Maintenance Course Certifications
• FAA mechanic certificate with airframe and/or powerplant ratings B737 Mechanic Work Scope
• Qualified to perform B737 aircraft maintenance, preventive maintenance, alterations, inspections, and repairs in accordance with approved data.
Work limited to FAA mechanic certificate rating. Qualified to sign approval for return to service.
Requirements
• Mechanic General Qualification
• B737 Aircraft Familiarization Course Certifications
• FAA mechanic certificate with airframe and/or powerplant ratings Figure 3-4. Sample Training Needs Assessment Documentation by Job Description and Timeframe Line Mechanic Training Requirements Within the first 15 days of employment Paperwork Policies and Procedures
• Maintenance Basic Safety Awareness
• Computer Systems Annual required after first year
• Maintenance Basic Safety Recurrent Within 2 years of employment
• Aircraft-Specific Systems Every 3 years after the first year of employment Paperwork, Policies, and Procedures Within 15 days of assignment to ABC station
• Station Ramp Safety Procedures Annual for ABC station specific personnel only
• Deicing/Anti-Icing 3-8
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3.5 Course Development.
3.5.1 Develop the Course. O nce the CAMP organization identifies its training requirements for each job function from its needs assessment, it should have procedures to begin developing or defining the individual courses it needs to meet those requirements. The training program should have procedures to develop each course or course of study, regardless of whether the course will be taught in-house or by an outside vendor.
Consider the following as you develop a training course:
• Purpose of the training;
• Th e in-service experience of the personnel on the aircraft type or equipment, if applicable;
• Feedback from in-service difficulties/occurrence reporting;
• Significant Airworthiness Directives (AD) and/or Service Bulletins (SB); and
• Known human factors issues associated with the particular aircraft type.
Note: An outside vendor may be used to develop any part of a training course or develop and provide the entire training program. However, the CAMP organization is responsible for its performance and effectiveness.
3.5.2 Define the Course. Each course should define the following:
• Purpose,
• Applicability,
• Prerequisites,
• Detailed subject matter to be covered,
• Objective or desired outcome (gained technical knowledge or skill),
• Time requirements (if desired), and
• Course completion standards.
Note: Studies have shown that it may be better to train individuals to a competence-based standard rather than require a specific number of training hours to ensure employees have the competencies needed for their jobs. This type of training does not need to be done on a defined schedule or for a specific number of hours. Rather, CAMP organizations would test each individual to evaluate what training they need. Training to competence permits a CAMP organization to tailor its training programs to the specific requirements of its individual maintenance personnel and maintenance providers.
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3.5.3 Identify the Training Method. The training program will outline and describe the appropriate training method for each course. There are many training delivery methods available. Each training program may include some or all of the following training delivery methods, as applicable to a particular course or operation.
3.5.3.1 For mal Classroom Instruction. Training can be structured as a formal course delivered by an instructor in a classroom setting. The value of this delivery method depends on the objectives and subject matter of the training.
The interaction among students and between students and a knowledgeable instructor is very important for certain types of information to be transferred.
Consequently, classroom discussions are important. This type of training, which is typical in a formal school environment, depends heavily on the quality of the instructor. It also requires relatively long periods away from the normal workplace. However, it may be cost effective because a classroom setting can accommodate a number of students at once.
3.5.3.2 On-the-Job Training (OJT). OJT is a process of learning while watching another demonstrate a task, and then accomplishing the same task under that individual’s supervision. It is a very effective method of training for subject matter and tasks that are difficult to understand if described, but relatively easy to understand while observing the task being performed. Practical skills are best taught using OJT. OJT depends heavily on the capability of the instructor. Typically, OJT is given by an individual very experienced in the technical subject matter being taught. Even with a very capable instructor, the training organization should ensure all OJT is well structured to ensure all the key elements of the training are included and treated the same way from one instructional period to another. It is paramount that OJT be provided by maintenance production personnel and no other individuals, such as quality control inspectors. Having well-qualified OJT instructors is essential for OJT to be effective. The instructors should be thoroughly familiar with the knowledge, skills, and objectives of the training and should be capable instructors. It is not enough for an instructor to be technically qualified. An instructor also should be able to impart that knowledge and/or skill to another.
The training program should have a process to verify that its OJT instructors are qualified and the quality of the OJT instruction is acceptable. The FAA expects the CAMP organization to have a logical process for selecting and monitoring its instructors. OJT usually is most effective when:
1. The trainees already have prerequisite knowledge and skills and do not need detailed explanations or lengthy discussions.
2. The target skill or knowledge can be taught or is best learned only in an actual work environment.
3. The work environment cannot be reasonably simulated or replicated in the classroom or with computer-based training (CBT) devices.
4. The training process very closely matches the actual tasks that would be performed.
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5. OJT best matches the needs and constraints in terms of scheduling, costs, and human resources.
6. There are documented course outlines, measures of effectiveness, and training records.
7. There are qualified instructors readily available.
3.5.3.3 Computer-Based Training (CBT). Interactive CBT courses can be used to impart knowledge and teach practical skills at the correct pace for each employee and produce certificates of training at the completion of the course.
CBT can be accomplished at any location at times convenient for each employee. To ensure the effectiveness of this type of training, the training program, Continuing Analysis and Surveillance System (CASS), and Safety Management System (SMS) should evaluate the information provided against its particular needs.
3.5.3.4 Distance Learning. Distance learning applies to situations where the instructor and the employees are not in the same location. It can take the form of mail-based correspondence courses using written, videotaped, or CBT materials; videoconferencing, teleconferencing, or a combination of both, sometimes called “virtual” classrooms; or intranet-based instruction that allows employees to interact with an instructor or with courseware similar to CBT. The advantages of this training method are that the courses can be tailored to a specific need and an instructor can respond to individual questions. The disadvantages are that the communications can be misinterpreted because of technical difficulties, and the interaction of the employee and instructor may be inhibited.
3.5.3.5 Embedded Training. Some equipment, particularly those that use software for testing or to perform a maintenance function, have training embedded into the process. Incorporating a tutorial or “help” menu are simple examples of how a software program can provide instruction as the user performs a specific task. Embedded training is most useful when:
1. The employee already knows the underlying technical information related to the basic task and needs only to learn the details of the procedure;
2. The procedure is straightforward and can be easily understood with a written explanation;
3. The media and method in which training is embedded are part of the task or equipment to be learned; and
4. There is a method to assess the employee’s performance and a record that the training took place.
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3.5.3.6 Other Methods. Other methods include self-study, case study, video-recorded demonstrations, and seminars. These methods of training or acquiring knowledge may be appropriate provided the information gained applies to the job function and skills required to perform the work capably.
3.5.4 Identify the Training Sources. T he training program should describe procedures for selecting a particular training source. The CAMP organization may elect to provide training in-house using its own personnel or contract with an outside vendor. Some common vendor training sources include the following:
3.5.4.1 Orig inal Equipment Manufacturers (OEM). OEMs may deliver technical information regarding maintenance or alteration on its articles by formal classroom instruction, OJT, distance learning, embedded technology, or CBT material. OEM instructors may come to a CAMP facility to conduct training onsite or deliver the information during seminars, sessions, or extended study at other locations. When the organization chooses to use an OEM course, it should ensure its employees have the prerequisite training and/or experience for the course to be most effective. In addition, the organization should verify that the area of study, course objective, material, and any instructors assigned by the OEM meet the CAMP organization’s training standards.
3.5.4.2 Aviation Maintenance Technician Schools (AMTS). An AMTS approved under part 147 can be an effective source of training, particularly for basic knowledge and skills. A CAMP Training Program may need to supplement the training with information unique to its operations and equipment.
3.5.4.3 Repair Stations. Repair stations may provide specific employees with specialized training by contract.
3.5.4.4 Government Agencies. Government agencies provide training on Occupational Safety and Health Administration (OSHA) regulations, Environmental Protection Agency (EPA) regulations, and hazardous materials (HAZMAT) recognition and handling. They also may be a source of training related to maintenance human factors and general safety subjects.
3.5.4.5 Trade Associations. Entities that represent certain segments of the aviation or business community offer training classes on technical and regulatory subjects. Again, the training organization must ensure the individual attending the training completed the course and acquired the necessary knowledge required by the particular maintenance operations and that the course meets the CAMP requirements.
3.5.4.6 Other Sources. There are a variety of other training sources, including independent seminars, product demonstrations, computer-based instructions, and videos. Your CAMP Training Program should view all sources of information as potential training sources. The training program should have a