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;
4-6
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.
4-7
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;
4-8
• 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.
4-9
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.
4-11
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.
5-2
5.1.2.1 Each part 121 and 135 CH who contracts for maintenance, preventive maintenance, or alterations must develop and implement policies, procedures, methods, and instructions for the accomplishment of all contracted maintenance, preventive maintenance, and alterations. These policies, procedures, methods, and instructions must provide for the maintenance, preventive maintenance, and alterations to be performed in accordance with the CH’s maintenance program and maintenance manual.
5.1.2.2 Each part 121 and 135 CH who contracts for maintenance, preventive maintenance, or alterations must ensure that its system for the continuing analysis and surveillance of the maintenance, preventive maintenance, and alterations carried out by a maintenance provider contains procedures for the oversight of all contracted covered work. (Refer to § 121.373(a) or § 135.431(a).) All the policies, procedures, methods, and instructions f or the accomplishment of all contracted maintenance, preventive maintenance, and alterations (as well as the CASS procedures for oversight of all contracted work) must be acceptable to the FAA and included in the CH’s manual as required by either § 121.369(b)(10) or § 135.427(b)(10).
5.1.2.3 Finally, each CH who contracts for maintenance, preventive maintenance, or alterations must provide to its appropriate FAA office (in a format acceptable to the FAA) a list of its maintenance providers. The list must include the name of each maintenance provider, its physical (street) address(es) where the work is carried out, and a description of the type of maintenance, preventive maintenance, or alteration performed at each location. The CH must update this list with any changes, including additions or deletions, and provide it to the FAA in a format acceptable to the FAA by the last day of each calendar month.
5.1.3 Additional regulatory controls governing contract maintenance were not applied to part 91K operations; however, the responsibilities in § 91.1413 are equivalent. This regulation places primary responsibility on the CAMP program manager for:
1. Maintaining the airworthiness of all program aircraft, including airframes, aircraft engines, propellers, rotors, appliances, and parts;
2. Maintaining all program aircraft in accordance with the applicable regulatory requirements; and
3. Repairing defects that occur between regularly scheduled maintenance required under part 43.
5.1.3.1 Additionally, per § 91.1413(b), each CAMP program manager must employ a Director of Maintenance (DOM) or equivalent position. The DOM must be a certificated mechanic with Airframe and Powerplant (A&P) ratings and have responsibility for the maintenance program for all program aircraft maintained under a CAMP. This person may not also act as Chief Inspector. The program manager must also employ a Chief Inspector or equivalent position. The Chief
5-3 Inspector must be a certificated mechanic with A&P ratings and have overall responsibility for the inspection aspects of the CAMP. This person may not also act as the DOM.
5.1.3.2 Finally, per § 91.1413(c), the CAMP program manager must have the personnel to perform the maintenance of program aircraft, including airframes, aircraft engines, propellers, rotors, appliances, emergency equipment, and parts under its manual and the applicable regulations. The program manager may choose to make arrangements with another person for the performance of maintenance. However, the program manager must ensure that any maintenance, preventive maintenance, or alteration that is performed by another person is performed in accordance with the program manager’s operating manual and the applicable regulations.
5.1.3.3 Section 91.1437 allows a CAMP program manager to employ or make arrangements with other persons to perform maintenance and preventive maintenance as provided in its maintenance manual. Section 91.1435 requires that, except when maintenance, preventive maintenance, alterations, and required inspections are performed by FAA-certificated repair stations located outside the United States, each person who is directly in charge of maintenance, preventive maintenance, or alterations for a CAMP (and each person performing required inspections for a CAMP) must hold an appropriate airman certificate.
5.1.3.4 Se ction 91.1435 also explains that a person “directly in charge” is each person assigned to a position in which that person is responsible for the work of a shop or station that performs maintenance, preventive maintenance, alterations, or other functions affecting airworthiness. A person who is directly in charge need not physically observe and direct each worker constantly, but must be available for consultation and decisions on matters requiring instruction or decisions from a higher authority than that of the person performing the work.
5.1.3.5 Finally, § 91.1431 requires a program manager who maintains program aircraft under a CAMP to establish and maintain a system for the continuing analysis and surveillance of the performance and effectiveness of its inspection program and the program covering other maintenance, preventive maintenance, and alterations. This includes the correction of any deficiencies in those programs, regardless of whether those programs are carried out by employees of the program manager or by another person.
5.2 Basic Training Program Requirements.
5.2.1 CAMP Training Program. Sections 91.1433, 121.375, and 135.433 require those who maintain aircraft under a CAMP, or the persons performing maintenance or preventive maintenance functions for the aircraft, have a training program to ensure each person (including inspection personnel) who determines the adequacy of work done is fully
5-4 informed about procedures, techniques, and new equipment in use and is competent to perform that person’s duties.
5.2.2 Required Inspection Personnel.
5.2.2.1 Sections 91.1429, 121.371, and 135.429 require that persons who perform required inspections be appropriately certificated, properly trained, qualified, and authorized to do so. Each CAMP organization must maintain (or must ensure that each person with whom it arranges to perform required inspections maintains) a current listing of persons who have been trained, qualified, and authorized to conduct required inspections. A significant output of the CAMP Training Program is the ability of the CAMP organization to maintain (or determine each person with whom it arranges to perform required inspections maintains) a current listing of persons who have been trained, qualified, and authorized to conduct required inspections.
5.2.2.2 Pe r §§ 91.1429(d), 121.371(d), and 135.429(e), persons who perform required inspections must be identified by name, occupational title, and the inspections they are authorized to perform. The CAMP organization (or person who performs its required inspections) must give written information to each person authorized describing the extent of that person’s responsibilities, authorities, and inspectional limitations. This written information authorizing them is normally done as training is completed. They are placed on the list available for inspection by the FAA upon request.
5.2.3 Contract Maintenance Provider Training Programs.
5.2.3.1 Maintenance provider training should include function-specific training appropriate to each contract individual’s job assignment or area of responsibility. The CAMP maintenance organization does not need to provide training to maintenance provider personnel in areas that do not concern them.
For example, training on aircraft log procedures and minimum equipment list (MEL) procedures would not be required for technicians working in an aircraft overhaul setting, but would be required for maintenance personnel assigned to perform on-call maintenance.
5.2.3.2 If a maintenance provider has specific types of training for its personnel, CAMP operators do not need to duplicate that training for those individuals.
However, the CAMP operator must ensure that the training provided equates to maintenance provider personnel being competent to perform its maintenance program. The CAMP operator’s organization and CASS are responsible to review and accept outsource maintenance provider training programs. It is the CAMP operator’s responsibility to ensure that outsourced maintenance provider personnel receive training equivalent to its own. This responsibility includes ensuring that those personnel have a full understanding of the CAMP manual procedures and techniques, that they understand any
5-5 new equipment you have introduced, and that they are competent to perform their duties.
5.3 Subject Areas. Examples of subject areas typically provided to personnel at contract maintenance facilities include the following:
1. Company policies and procedures,
2. Logbook procedures,
3. MEL/Configuration Deviation List (CDL) procedures,
4. Airworthiness release procedures,
5. RIIs,
6. Parts tags,
7. Appropriate fleet training,
8. Line maintenance procedures,
9. Heavy maintenance procedures,
10. Component-level maintenance procedures,
11. Use of approved aircraft maintenance and illustrated parts manuals,
12. Working with the CAMP manual job procedure cards,
13. Proper documentation of work and turnover processes, and
14. Significant maintenance personnel contacts for guidance and direction.