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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
4-5 for reporting otherwise missed safety events. The overall objective of the ASAP is to encourage voluntarily reporting of safety information that may be critical to identifying potential precursors to accidents. The FAA has determined that identifying these precursors is essential to further reducing the already-low accident rate. For further information on the ASAP, refer to AC 120-66, Aviation Safety Action Program.
4.2.3 Human factors training should cover basic safety principles and practices as part of an organization’s safety management and quality systems. The training should ensure maintenance personnel carry out their work in a professional manner and aircraft are released into service in a safe and airworthy condition. The objectives of human factors training should be to:
• Improve safety;
• Decrease personnel and organizational exposure to risk;
• Capture and reduce errors; and
• Reduce the potential for incidents and accidents.
4.2.4 Human factors training objectives are achieved by:
• Imparting knowledge on human factors and safety;
• Identifying how the human factors training program works;
• Developing skills, where appropriate;
• Affecting people’s attitudes; and
• Affecting behavior.
4.2.5 Where possible, relate human factors training to maintenance practices. Give examples and scenarios. The following are suggested human factors elements for inclusion into the CAMP Training Program:
1. General/introduction to human factors;
2. Statistics;
3. Safety culture/organizational factors;
4. Contributing factors and human error;
5. Types of errors in maintenance tasks;
6. Human reliability;
7. Human performance and limitation;
8. Vision and hearing;
9. Stress and workload management;
10. Situational awareness;
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11. Error investigating process;
12. Personal error reduction strategies;
13. Environment;
14. Communication;
15. Procedures, information, tools, and task signoff practices;
16. Teamwork, professionalism, and integrity;
17. Shift and task turnover procedures;
18. Fatigue management and duty time limitations;
19. Undocumented maintenance; and
20. Introduction to the Dirty Dozen. (The Dirty Dozen refers to twelve of the most common human error preconditions, or conditions that can act as precursors, to accidents or incidents. Refer to AC 120-72, Maintenance Human Factors Training.)
Note: For additional information regarding human factors programs and training, refer to the FAA Operator’s Manual: Human Factors in Aviation Maintenance located at https://www.faa.gov/sites/faa.gov/files/data_research/research/med_hum anfacs/oamtechreports/201502.pdf.
4.3 Safety and Risk Management Subjects. As you develop your CAMP Training Program, application of the following Safety Management System (SMS) pillars will ensure your CAMP Training Program is designed well, performing as it should, and the maintenance you perform is done with the highest degree of safety.
4.3.1 Safety Policy. As you develop your CAMP Training Program, your policy will identify its role toward ensuring safety and will include individual accountability for its development, implementation, and continual improvement.
4.3.2 Safety Risk Management (S RM). Systematic review of maintenance organization deficiencies in relation to your CAMP Training Program will assist in identifying hazards and manage their associated risk. When you identify competency issues, you can improve training and/or establish controls to mitigate safety risks.
4.3.3 Safety Assurance (SA). S ystematically monitoring the competencies required of your maintenance organization in relation to your training program will produce data validating that your CAMP organization is competent, functioning as designed, and the work you and those you contract with is done with the highest degree of safety.
4.3.4 Safety Promotion. The C AMP Training Program is one of the means needed to ensure competency, apply training, and communicate information.
Note: For further information on an SMS, refer to AC 120-92, Safety Management Systems for Aviation Service Providers.
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4.4 Maintenance-Specific Courses.
4.4.1 A review of industry practices has shown Air Transport Association (ATA) codes in conjunction with aircraft make, model, and type are an effective means to organize training directly related to the performance of aircraft-related maintenance tasks.
Organizing training by ATA codes and aircraft make, model, and type can identify if a person’s experience and skills are adequate to perform the work they are expected to perform.
4.4.2 To meet the CAMP requirement to ensure competent personnel are provided to perform maintenance, a typical CAMP Training Program provides indoctrination courses that are broad in nature. As individuals work and authority becomes more defined, their education must continue. The subject matter must become more refined to their assignments and prepare them to perform competently. Additional training tools become more relevant and effective than structured classroom-type training. CBT courses, which could include technologies like YouTube and video recordings, are advanced training methods that combine visual with audio instruction. CBT courses are stored on the computer and can be accessed, scheduled, and performed by individuals as their time permits and as often as they feel the need to review the subject. OJT is a time-proven method that also provides direct one-on-one training around specific competencies that must be acquired and mastered by individuals new to the tasks at hand. The following are areas where subject matter would be more refined and offered on a continuing or recurrent basis.
4.4.2.1 Line and Base Maintenance Training.
1. Line maintenance is any unscheduled maintenance resulting from unforeseen events or scheduled checks that contain servicing and/or inspections that do not require specialized training, equipment, or facilities. Line and base maintenance training may include:
• Troubleshooting;
• Logbook discrepancies;
• Component replacement to include the use of external test equipment, up to and including components, such as engines and propellers;
• Scheduled maintenance and/or checks, including visual inspections that will detect obvious unsatisfactory conditions/discrepancies, but that do not require extensive indepth inspection;
• Internal structures, systems, and powerplant items visible through quick-opening access panels/doors;
• Minor repairs and modifications that do not require extensive disassembly and that can be accomplished by simple means;