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
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Note: Regardless of the training source, the CAMP organization remains responsible for the administration, adequacy, and currency of its training program and for maintaining the training records.
3.5.5 Define Instructor Qualif ications and Classification.
3.5.5.1 During the development of the course, the CAMP Training Program should have procedures to define instructor qualifications and qualify instructors. The procedures will include employees, individuals hired temporarily, and vendor instructors. The CAMP organization must have controls that ensure the instructor has the technical background and teaching skills necessary to effectively communicate the course material. When developing instructor qualifications, the CAMP Training Program should:
1. Define the instructors’ experience requirements, including the minimum maintenance experience and/or certifications required.
2. Define any requirement to maintain appropriate other certifications, such as those related to the requirements of OSHA, the EPA, and the Department of Transportation (DOT).
3. Define the instructors’ duties and responsibilities.
4. Define instructor evaluation, qualification, and authorization, to include:
• Evaluate an instructor’s level of knowledge, experience, and background relevant to a course.
• Evaluate an instructor’s communication and teaching skills.
• Initially qualify an instructor to teach a particular course.
• Provide formal instructor training and professional development.
• Continually evaluate instructor proficiency.
• Document instructor qualifications and authorizations.
Note: The CAMP Training Program will define the qualifications of its instructors and describe the methods used to ensure any instructors it uses meet those qualifications.
3.5.5.2 Industry research has shown that instructors usually are classified by type, such as:
1. Maintenance Instructor. This is usually a full-time organizational employee who has met the qualifications for the position as described by the job description to teach and/or participate in the development of certain courses.
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2. Contracted Instructor. This is a third-party training vendor contracted and authorized by the maintenance department to teach. A CAMP organization may use contracted instructors to supplement its training program to develop and teach specialized courses or to train maintenance instructors.
However, contracted instructors must still follow the CAMP Training Program.
3. Assigned Maintenance Instructor. An assigned maintenance instructor provides instruction on an as-needed basis. These individuals usually teach specialized skills requiring expertise in a particular subject area, such as fueling, deicing, or taxi/engine run. These instructors should be fully versed and knowledgeable in their specialty.
4. Adjunct Instructor. This is an employee with great skill in a particular area with the authority to teach a course usually taught only by a maintenance instructor. Adjunct instructors differ from “assigned maintenance instructors” in that an adjunct instructor usually is, for practical purposes, a member of the training department, and their duty is to teach courses that “assigned maintenance instructors” are qualified to teach.
5. OJT Instructor. This is an employee and experienced subject matter expert who teaches task-specific skills and information to others on the job. This type of instructor should be able to perform the assigned tasks satisfactorily and should be able to transfer competency skills, knowledge, and techniques to students. This person will monitor the performance level of students and determine their competency skills, knowledge, and abilities.
6. Practical Examiner. The CAMP organization will designate these individuals. They can be either an organization’s employee or a third party. They administer practical tests, such as engine run and taxi practical tests.
3.5.6 Measur e Training Effectiveness. The CAMP Training Program will describe a process to evaluate training effectiveness from different perspectives. This process is distinct from your CASS and SMS reviews; however, the data your CAMP Training Program review produces will be assessed by CASS and SMS.
3.5.6.1 Do es the employee understand the material? The first measure of effective training is usually accomplished with oral or written tests. After each course, employees should be able to demonstrate (via an examination) an understanding of applicable systems and their operation. They should be allowed and encouraged to access maintenance manuals or instructions as the ultimate source for task performance. Regular use of approved manuals is essential to ensure safe and effective performance of maintenance and inspection tasks.