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;
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• MEL and the proper procedures on how to defer an MEL item, including special procedures; and
• Configuration Deviation List (CDL) and the proper procedures on how to defer a CDL item, including special procedures.
2. At the completion of line and base maintenance training, personnel should be able to:
• Perform system, engine, component, operational, and/or functional checks, as specified in the maintenance manual;
• Correlate information for the purpose of making decisions with respect to fault diagnosis and rectification to maintenance manual level; and
• Describe procedures for replacing components unique to aircraft types.
4.4.2.2 Structural and Special Process Repair Training. This type of training includes maintenance, repair, and fabrication of aircraft structural members, sheet metal, and stress panels. Also included is the identification, use, and maintenance of common, special, and precision tools. This type of training may include courses on:
1. Fabricating aircraft and related sheet metal parts and assemblies, which may include:
• Making layouts on sheet metal for parts fabrication in accordance with instructions from applicable technical orders;
• Cutting and trimming metal parts using snips, powered and non-powered shears, and saws;
• Drilling and punching holes using hand and pneumatic drills, drill presses, and rotary punches;
• Forming sheet metal parts (using bending, shrinking, and stretching machines and hand-forming techniques) and assembling and fastening parts using solid rivets, blind rivets, and special fasteners; and
• Proper use and referencing of the Structural Repair Manual (SRM) and Aircraft Maintenance Manual (AMM), including all other approved repair data.
2. Repairing and modifying aircraft metal structures, which may include:
• Inspecting aircraft metal structures to determine repair procedures necessary to restore original strength and contour;
• Repairing damaged aircraft structure;
• Removing and/or replacing aircraft structural parts for repair or modification; and
• Modifying aircraft structural parts as specified by technical orders.
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3. Repairing special composition aircraft structures, which may include identifying and inspecting plastic, fiberglass, honeycomb, and composite bonded structures.
4. Using special aircraft hardware, which may include installing specialty fasteners, determining working length, cuts, swage terminals, and testing aircraft control cables, and cutting to length.
4.4.2.3 Avionics Maintenance Training. Avionics maintenance training includes inspecting, servicing, maintaining, troubleshooting, and repairing avionics systems that perform communications, navigation, collision avoidance, and automatic flight-control functions. The training may include courses on the following:
1. Preventive maintenance on mechanical/avionics instruments systems, which may include:
• Troubleshooting, adjusting, bench checking, and performing operational checks on electromechanical devices;
• Barometric flight instruments;
• Engine and temperature instruments;
• Pressure, position, and liquid level indicating systems;
• Integrated flight and navigational instruments;
• Electronic compass systems;
• Autopilot;
• Flight director systems; and
• Global Positioning Systems (GPS) through proper use of technical order procedures.
2. Operation and use of test equipment, which may include:
• Performing operational checks;
• Calibrating and troubleshooting mechanical/avionics instruments and component parts using test equipment and special test sets, such as vacuum/pressure-operated barometers and manometers; electronic compass compensators; capacitance type fuel quantity testers;
multimeters, tachometers, and thermometer testers; attitude gyro testers; flight director system testers; dead weight; and auto synchro and fuel flowmeter testers; and
• Swinging and compensating magnetic and electronic compass systems.
4.4.2.4 Mechanical and Electrical Maintenance Training. Training in this area includes inspecting, servicing, maintaining, troubleshooting, and repairing aircraft batteries, AC and DC power generation, conversion, and distribution
4-10 systems, as well as the electrical control and indication functions of all airframe systems, including hydraulic, flight control, landing gear, fuel, environmental control, powerplant, drivetrain, anti-ice, and fire detection systems. The objective of this training is for employees to have a working knowledge of mechanical, electrical, and powerplant systems. Courses associated with this training could include:
1. A review of the aircraft systems component locations;
2. Servicing;
3. Minor and major maintenance;
4. Troubleshooting; and
5. Ramp maintenance and the associated safety precautions, such as:
• Engine and auxiliary power unit intake and exhaust areas,
• Inadvertent control surface operation and thrust reversers,
• Transmitting radio frequency energy during refueling and maintenance activities,
• Cautions and hazard avoidance associated with systems servicing during in-transit maintenance, and
• Precautions during towing, taxiing, push-back operations, and docking.
4.4.2.5 Other Component Maintenance Training. Component maintenance training includes inspecting, servicing, maintaining, troubleshooting, and repairing a subassembly of an aircraft that is usually removable in one piece and interchangeable with other standard components, such as engines and engine parts. The objective of this training is for the employee to have working knowledge of operations procedures, equipment, and the tools necessary for various maintenance specialties; special reference documents; and engineering data and media pertinent to appropriate tasks for the various specialties. This training may include courses on:
• Engine and engine components,
• Hydraulic system components,
• Associated engine and accessory overhaul,
• Hydrostatic testing,
• Equipment and furnishings, and
• Evacuation emergency equipment.
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4.4.2.6 Engine Run and Taxi Training. This type of training includes the policies/procedures for the engine run and taxi process, including runway incursion precautions and preventions.
4.4.2.7 High-Load Events and Lightning Strike Training. This type of training involves the specialized policies and structural inspection procedures that must be followed after a lightning strike or high-load event, such as a hard landing, turbulence, or excessive airframe loads associated with abnormal flight operations occur.
5-1 CHAPTER 5 CONTRACT MAINTENANCE TRAINING
5.1 Contract Maintenance Oversite. An air carrier/program manager may arrange with another person to perform maintenance, preventive maintenance, and alterations.
However, the air carriers/program managers are always primarily responsible for the airworthiness of its aircraft, as stated in §§ 91.1413, 121.363, and 135.413. This responsibility may not be delegated.
Note: Safety Management Systems (SMS) a nd Continuing Analysis and Surveillance Systems (CASS) must provide adequate oversite of contract maintenance to reduce the risk of returning aircraft to service that are not airworthy.
5.1.1 Aircraft accident reports identify failure to maintain sufficient oversight and control over contract maintenance and Required Inspection Item (RII) procedures as a contributing factor in the probable cause of some accidents that resulted in loss of life. A contributing factor to this loss of control is the natural interface that exists between a CAMP organization and contract maintenance. Due to the separation between the contracting operator and its contracted maintenance provider, it is important to mention the additional FAA regulatory controls within part 121 (§ 121.368) and part 135 (§ 135.426). Wh ile these regulations do not apply to part 91K operations, the expectations are the same.
These requirements are overarching in regards to each element of a CAMP and apply indirectly to contract maintenance provider training. FAA regulatory controls within §§ 121.368 and 135.426 provide these definitions.
1. A maintenance provider is any person who performs maintenance, preventive ma intenance, or an alteration for a certificate holder (CH) other than a person who is trained by and employed directly by that CH.
2. Covered work means any of the following:
• Essential maintenance that could result in a failure, malfunction, or defect endangering the safe operation of an aircraft if not performed properly or if improper parts or materials are used;
• Regularly scheduled maintenance; or
• An RII on an aircraft.
3. Directly in charge means having responsibility for covered work performed by a maintenance provider. A representative of the CH directly in charge of covered work does not need to physically observe and direct each maintenance provider constantly, but must be available for consultation on matters requiring instruction or decision.
5.1.2 The above regulations use these definitions to require part 121 and 135 CHs to be directly in charge of all covered work done for them by a maintenance provider. They require the maintenance provider to perform all work per the CH’s manual and restrict maintenance providers from performing covered work unless that work is carried out under the supervision and control of the CH.