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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.
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3.5.6.2 Did the employee demonstrate the ability to perform the tasks for which the training was given? This normally consists of a practical demonstration of the task by the student. Individuals should be able to demonstrate their skill and ability to:
1. Work according to the maintenance manual and other relevant instructions appropriate for the type of aircraft and task at hand;
2. Correctly use technical literature and documentation associated with the performance tasks;
3. Correctly identify and use special tooling and test equipment; and
4. Competently perform removal and replacement of components and modules unique to the type, including any on-wing maintenance activity.
3.5.6.3 As a course concludes, training instructors should evaluate the effectiveness of that course as well as their own performance.
3.5.6.4 The CAMP Training Program should obtain feedback from employees and review subject areas that may have been commonly misunderstood.
Training instructors should be open minded and allow course critiques, self-evaluations, and information sharing to improve the overall effectiveness of the course.
3.5.7 Course Curriculum and Ou tline. At the completion of the course development phase, the CAMP Training Program will produce a course curriculum or equivalent that includes:
1. The course title.
2.
Applicability. Identify to whom the course applies.
3. Objective or desired outcome. A statement that clearly describes what employees will be able to do at the conclusion of the training. For example, successfully perform and document maintenance actions.
4. Prerequisites or minimum student qualifications prescribed by the regulations or required by the CAMP organization for enrollment in the course. For example, the type of airman certificate, aircraft, product and/or article qualifications, previous training, experience with other operators, and recent experience requirements.
5. Anticipated time of instruction for completion and/or the knowledge or skill requirements that must be demonstrated to obtain credit for the course/lesson.
6. Training methods. How the course will be taught, such as classroom or OJT.
7. Training sources. Identifies who teaches the course, and whether it is taught in-house or provided by a vendor.
8. Instructor qualifications. The qualifications an instructor needs to have to teach the course.
9. Qualified instructors. Identifies who is qualified and authorized to teach the course.
10. Method of evaluation/course completion standard. The method the instructor will use to validate the degree to which learning objectives have been met, including minimum test scores.
11. A course outline arranged by major topics and subtopics.
12. A lesson plan that includes teaching aids, major points, notes, and references for use by the instructor.
13. A study guide containing training data for the employee that supports the course presentation and allows the employee to take notes.
14. Training certificates, forms, and/or training records. These types of documents are used for recording student attendance, progress, and/or completion and to justify certain authorizations, such as airworthiness release, approval for return to service, RII, engine run, and aircraft taxi.
3.5.8 Documentation Examples. Figures 3-5 and 3-6 provide examples of course requirements documentation. The FAA is not prescribing these examples, but merely providing samples used by the industry.
Figure 3-5. Sample 1 of Course Requirements Documentation COURSE NO. 123 Recurrent Paperwork Class 4 HOURS Training Objective: To provide personnel with refresher training on common and new paperwork in daily use.
Performance Objective: Upon completion, the student will have demonstrated working knowledge of all covered maintenance paperwork.
Course Requirement: Student must participate in class.
Course Prerequisite: Open to anyone in the maintenance and engineering department.
Course Content:
I. Introduction II. Flight Log Book III. MEL/CDL IV. Deferred Maintenance V. Non-routine Card VI. RIs VII. Parts Tags VIII. Etc.
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Figure 3-6. Sample 2 of Course Requirements Documentation
1.1.0 Initial Maintenance Employee Recurrent Training A. Guidelines
1. Student: All Maintenance Department employees
2. Objective: To provide the training required to perform duties as outlined in the GMM.
3. Method: Classroom lecture
4. Course Time: 16 hours: Hangar/shop personnel 12 hours: Planning/records personnel 8 hours: Stores personnel
5. Necessary Equipment: Projector
6. Materials: Training handouts
7. References: GMM, FAA regulations
8. Recurrent training:
9. Course Completion Standards: 80% on written test B. Course Outline
1. Company History
2. Introduction to the Maintenance Department Organizational Chart Job Descriptions
• Key Personnel
3. Safety
• Policies and Procedures
• Fire Extinguisher Training
• Lockout/tag Procedures
• Eye Wash Stations
• First Aid Kits
4. Etc.
3.6 Training Completion Documentation.
3.6.1 A CAMP Training Program should provide a means to document employee training. The competency of each employee depends on acquired training, knowledge, and experience.
Consequently, an important source of information to determine employee competencies is the employee's training records.
3.6.2 A CAMP Training Program should provide a means to retain its training records electronically or as a hard copy. In either case, standardize the format and content of your training records according to your organizational, occupational, and individual training needs assessments. A review of industry practices suggests that each employee's record should contain at least the following information:
1. Name and job position.
2. Employment history or résumé.
3. Training requirements as determined by the employee's needs assessment, including requirements for indoctrination, initial and recurrent, and other training required by areas and course titles.
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4. FAA certificates applicable to the employee’s qualifications. For example, supervisors, RII personnel, and individuals approving articles for return to service must be appropriately certificated under 14 CFR part 65.
5. Other certifications, diplomas, and degrees.
6. Authorizations and qualifications (other than those listed in item 4).
7. Proof of training course completion, if determined applicable to capabilities. This includes training provided by other employers.
8. A list of accomplished training, to include enough information to determine whether it is applicable to the employee’s capability to perform assigned tasks. Such information may include:
• Course title or description,
• Course objective,
• Date completed,
• Test results,
• Total hours of training,
• Location of training,
• Name of instructor and instructor qualifications, and
• Signature of employee.
9. Any other relevant documentation determining the capability to perform tasks associated with assigned duties, such as past employment as well as written, oral, and practical test results.
3.6.3 The CAMP Training Program, CASS, and SMS should have procedures to regularly review all training records to ensure they comply with the requirements set forth in the training program manual.
3.7 Training Program Review and Evaluation.
3.7.1 The CAMP Training Program and your CASS should have documented schedules set to provide for periodic review of the training program. During this review, determine if any changes should be made to the program, including revising, adding, or deleting courses.
These periodic reviews should validate that your annual training plan is effective. The program should have a means to document this review.
3.7.2 A variety of sources will influence a CAMP Training Program evaluation:
1. Student course feedback through course evaluations and student course assessment results.
2. Negative trends in quality control inspection results for finished work.
3. Voluntary disclosures that have root causes of improper training or a lack of training.
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4. Internal audit results.
5. CASS program findings.
6. Aircraft, equipment, or tooling changes.
7. Employee recommendations or concerns due to competencies for work assignments or training needs.
8. Industry trends and shared information.
9. FAA and operator information gathered during an investigation of noncompliance.
4-1 CHAPTER 4 MAINTENANCE TRAINING COURSE SUBJECTS
4.1 Regulatory Maintenance Training Course Subjects.
4.1.1 The Manual.
4.1.1.1 A manual is required of part 91K fractional ownership program managers and part 121 and most part 135 air carriers. It is the foundational document that includes the instructions and information necessary to allow personnel concerned to perform their duties with a high degree of safety.
Sections 91.1427, 121.369, and 135.427 require you to place in your manual:
• The inspection program;
• The program covering other maintenance, preventive maintenance, and alterations;
• A chart or description of the CAMP organization;
• A list of persons with whom the CAMP organization has arranged for the performance of any of its required inspections;
• A list of persons with whom the CAMP organization has arranged for the performance of maintenance, preventive maintenance, or alterations; and
• A general description of arranged work.
4.1.1.2 The relevance and importance of this manual, as well as its outline and availability, is normally covered during indoctrination training. Every aspect of the CAMP is explained within this manual and the FAA expects it to be easily understood, easily accessed, and frequently referred to and used.
4.1.2 Course Subjects. It i s through your CAMP Training Program that you ensure competent personnel (those who are fully informed about procedures, techniques, and new equipment in use) are provided to perform maintenance, preventive maintenance, and alterations. A competent person knows how to determine the adequacy of their work, and (if required) that the work of others is done in accordance with your procedures and they have a full understanding of their assigned duties and authority. They should fully understand their part in your overarching responsibility to ensure airworthiness. Your CAMP Training Program is your means to present, explain, and ensure the methods, techniques, and practices defined in your manual are understood. Those you employ, contract with, and authorize to perform maintenance (including inspection), preventive maintenance, and alterations must fully understand your manual procedures and techniques and fully understand that they must perform as your manual prescribes. The following is a list of suggested subjects that are reflective of the CAMP elements as explained in AC 120-16, Air Carrier Maintenanc e Programs:
1. The CAMP airworthiness responsibility.
2. The manual (in general):
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a. Maintenance manuals.
b. Revising and availability.
c. The manual’s role.
d. Major sections of the manual, such as:
• Administrative policies and procedures.
• Instructions for the administration, management, and accomplishment of the CAMP.
• Technical data, standards, methods, techniques, and procedures.
• Work cards (e.g., job or task cards).
• Inclusion of contract maintenance policies, methods, techniques, procedures, and instructions.
3. The CAMP organization:
a. The CAMP organizational structure, to include company rules and policies.
b. Separation of required inspections from maintenance.
c. Director of Maintenance (DOM) roles and responsibilities.
d. Chief Inspector roles and responsibilities.
e. Management personnel.
f. Technical personnel.
4. Accomplishment and approval of maintenance and alterations:
a. Maintenance procedures (e.g., manuals, on-the-job training (OJT), or job aides, such as YouTube or computer-based training (CBT)).
b. Airworthiness Directive (AD) management.
c. Major repairs and alterations.
d. Airworthiness Release Form or aircraft log entry and approval for return to service.
e. Scope of maintenance:
• Scheduled maintenance, to include part airworthiness, tagging, and identification.
• Unscheduled maintenance:
o Minimum equipment list (MEL) methods, policies, and procedures.
o Logbook procedures.
• Specific maintenance requirements for major components:
4-3 o Engine program.
o Propeller program.
o Emergency evacuation systems.
• Off-wing parts and appliances maintenance program.
5. The maintenance schedule:
a. Time limitations or standards for determining time limitations.
b. The FAA’s role.
c. Maintenance schedule task organization and content.
d. Standards that determine maintenance schedules.
6. Required Inspection Items (RII):
a. The RII list.
b. The RII procedures standards and limits.
c. RII inspector certification, qualification, training, and authorization, to include a list of authorized RII personnel.
7. The maintenance recordkeeping system:
a. The significance of making and keeping maintenance records as they relate to the U.S. Standard Airworthiness Certificate.
b. Title 14 CFR part 43 requirements.
c. Interfacing with and meeting 14 CFR part 145 certificated repair stations’ requirements, as applicable.
d. Making and keepi ng required records within the recordkeeping system:
• Familiarity and use.
• Record locations.
• AD status.
e. Required records. This includes accounting for and retrieval (e.g., total time in service, currents status of life-limited parts, time since last overhaul, current inspection status of aircraft, current status of ADs, current major alterations for the entire aircraft).
f. Maintenance log.
g. Airworthiness release.
h. Mechanical interruption reports.
i. Service Difficulty Reporting (SDR).
j. Reporting major repairs and alterations.
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8. Contract maintenance, to include scope and responsibility (see Chapter 5 for more information).
9. Continuing Analysis and Surveillance System (CASS):
a. Re port a program deficiency to CASS.
b. Specific training for CASS auditors and analysts.
4.2 Maintenance Human Factors Training.
4.2.1 The objectives of human factors training are to improve safety, decrease personnel and organizational exposure to risk, and capture and reduce errors. An important aspect of accident decline is the reduction of human errors generated during the maintenance of aircraft. An understanding of human limitations improves an individual’s ability to recognize situations that can lead to errors.
4.2.2 Although training is an important part of human factors, reducing human errors requires more than just training. It requires a total error reduction program involving maintenance personnel and their senior managers.
4.2.2.1 An effective human factors training program begins at the highest level of an organization. This is where an organization:
1. Defines the environment in which individuals conduct their tasks;
2. Defines the policies and procedures individuals must follow;
3. Allocates the resources individuals need to achieve safety and meet production goals; and
4. Investigates system failures and takes remedial action to avoid repetition.
4.2.2.2 Human factors training will have a maximum impact only if it is reinforced by other related program elements and a supportive corporate culture. In addition, consistent follow-through over time is required to encourage maintenance personnel support and participation. To promote this, the CAMP organization should establish a clear, fair, and consistently applied discipline policy that encourages maintenance personnel to provide critical data about the factors that caused the error. To achieve this goal, design your human factors training program with policy and practices that do not punish maintenance personnel for unintentional errors. Your policy and practices should encourage immediate notification, open information sharing, and honest accountability with the intent being to identify what caused the error to occur. It is essential for the causal factors to be shared with the CASS and Safety Management Programs in order to identify possible systemic problems that have resulted from weak or incorrect training.
4.2.2.3 The FAA encourages voluntary safety reporting systems, such as the Aviation Safety Action Program (ASAP) and Voluntary Disclosure Reporting Program (VDRP). A good human factors program should incorporate ASAP as a means