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.
6-1 CHAPTER 6 ADMINISTRATIVE INFORMATION
6.1 Copies of This AC and Other FAA Publications. This AC and other FAA publications are available on the FAA website at https://www.faa.gov and DRS at https://drs.faa.gov.
6.2 Further Information on This AC. For information concerning this AC, contact the Flight Standards Directives Management Officer at 9-AWA-AFB-120-Directives@faa.gov.
6.3 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.
Appendix A A-1 APPENDIX A. SAMPLE TRAINING PROGRAM A.1 Introduction.
This appendix provides a sample training program. This example is consistent with the guidance provided in this AC. CAMP operators are not required to follow this sample to have an acceptable training program. Individual training programs may require different or additional information.
Each program should be tailored to fit the size and complexity of the CAMP organization and operation. For example, a larger 14 CFR part 121 air carrier will have considerably more detail in its program description than a 14 CFR part 135 (10 or more) operator with just a few aircraft. This sample program does not set minimum limits or describe the details of the areas of study, courses, course outlines, or instructor qualifications.
A.2 Sample Training Program. The following example is for a CAMP operator doing b usiness as ABC Air. ABC Air has a training department and manager of training who reports directly to the Director of Maintenance (DOM).
I. Introduction The purpose of this manual is to establish a maintenance training program. This program ensures all personnel who perform inspections, alterations, maintenance, or preventive maintenance functions on ABC Air aircraft are fully informed about procedures, techniques, and new equipment in use and are competent to perform their duties in accordance with 14 CFR part 43 and parts 121 a nd 135, as applicable.
The primary purpose of the maintenance training department is to use standardized teaching procedures, maintain maintenance personnel proficiency, improve maintenance personnel skills, and carry out the training program, as well as to remain in compliance with applicable laws and regulations. This manual also establishes the necessary training guidelines for ABC Air’s maintenance department personnel to improve workplace safety, product quality, and job performance.
II. Policies ABC Air is committed to providing safe and reliable services; and, to ensure that commitment, we provide only first-class training to all our maintenance personnel. We train and motivate our maintenance personnel for maximum achievement through the design and delivery of high quality, cost-effective skill enhancement programs.
Our maintenance training program is a standardized teaching process to inform maintenance personnel of procedures and techniques used in maintaining our equipment. Emphasis throughout the entire program must be on safety and airworthiness. The outcome of this program will be that each employee is competent to perform duties as assigned.
Appendix A A-2 It is our policy to ensure that only appropriately certificated, properly trained, qualified, and authorized employees are assigned the responsibility for maintenance, preventive maintenance, alteration, and inspection in determining the adequacy of any aircraft maintenance work accomplished.
Individuals selected for training will be notified in writing of the time and location of the training. This notification will be signed by the immediate supervisor, given to the employee for signature, and a copy returned to the training department for verification that the individual has been informed and will attend.
III. Training Department Duties and Responsibilities The duties and responsibilities of the manager of training include the following:
1. Determining maintenance training requirements and ensuring maintenance personnel are kept up to date on procedures, techniques, and new equipment.
2. Continually analyzing the training program to ensure this manual and training content is current.
3. Developing the courses that will satisfy all established training requirements as well as the course content and presentation quality.
4. Providing formal instruction covering maintenance and inspection of aircraft, systems, and equipment.
5. Providing formal/practical on-the-job training (OJT).
6. Arranging factory and vendor training for all maintenance personnel, as required.
7. Maintaining maintenance personnel training records, a reference library, checklists, and training aids.
8. Remaining current on the latest equipment updates and maintenance methods through factory school attendance, individual study, and attendance at industry training conferences and workshops.
9. Developing new training modules, as needed, to improve the operating efficiency of the maintenance department using published manufacturer’s documents.
10. Publishing a training schedule.
11. Providing training to on-call and third-party maintenance providers as required.
IV. Training Needs Assessment The needs assessment process consists of assessing and verifying training needs before the development of training courses. These activities include identifying subject matter experts to participate in the assessment, determining if a training gap exists, and developing objectives and methods for delivering the training. The need for training and qualification generally originates from seven sources:
Appendix A A-3
1. Hiring of new maintenance personnel.
2. Acquisition of new equipment or changes to existing equipment.
3. Implementation of specialized tests, inspections, or procedures.
4. Returning to a job that requires requalification.
5. Recurrent training.
6. A corrective action based on a deficiency found through the Continuing A nalysis and Surveillance System (CASS).
7. Corrective actions based on comprehensive fixes as identified in Voluntary Disclosure Reporting Programs (VDRP).
NOTE: The CAMP portion of the manual should set forth its method for accomplishing the review and for identifying potential training needs.
V. Prior Training or Experience Recognition Documentation of prior training will be collected by the manager of training during the new hire orientation. Documentation of such training will be entered into the individual’s training record and the manager of training or designee will establish what further training is necessary to meet improved training requirements.
ABC Air may formally accept prior experience or training and give equivalent credit toward an ABC Air training course in accordance with the following procedures:
1. The employee must present copies of all prior experience or training supporting documentation as evidence of satisfactory completion to the training department for evaluation. Acceptable documents are copies of certificates or statements from a part 121- or 135-certificated operator, 14 CFR part 145 repair station, aircraft airframe or component manufacturer, or accredited college or technical school that are signed by a staff member of the organization.
2. In determining if equivalent credit may be given for an ABC Air course, the training de partment must take into consideration the time elapsed since the training was received, the training provider accreditation, and depth and scope of the training received.
3. If the training department approves the previous training or experience, documentation of such training will be entered into the individual’s training record and the manager of training or designee will establish what further training is necessary to meet the training requirements.
VI. Contracted Training Instruction provided by an outside agency may be provided by another certificate holder for related equipment, a manufacturer of equipment used by ABC Air, or an approved training vendor.
Appendix A A-4 Training conducted by an outside agency must be performed in accordance with the training program. The manager of training or designee will investigate and evaluate the contractor’s training program and facilities. The program must include sufficient material, training aids, and details to provide the trainee with adequate working knowledge. Any training conducted by an outside agency will be approved as an acceptable replacement to any training course in this manual. This approval will be given on a case-by-case basis by the director of maintenance, the director of quality control, or the vice president of maintenance.
All training and subjects taught by an outside agency will be documented by the providing agency and signed by an authorized individual of the agency. A copy of the training certificate or document will be sent to the maintenance training department and recorded in the individual’s training record.
VII. Instructor Qualifications and Classification In selecting maintenance training instructors, consideration will be given to the experience level of the individual and the individual’s judgment, aptitude, knowledge, and performance within the maintenance group. Before an instructor is authorized to teach an in-house training course, the manager of training must interview that individual. During the interview, the prospective instructor’s qualifications are reviewed, including training certificates, experience level on equipment, and communication skills, to ensure they have the technical background and teaching skills necessary to effectively communicate the course material.
ABC Air classifies instructors as follows:
1. Maintenance Training Technical Instructors. These are full-time maintenance training department employees who have met the qualifications for this position in accordance with company policies. When a new course is developed, an instructor may be authorized to teach that course by accomplishing the appropriate research and having the manager of training review the material before the first class is taught.
2. Designated Company Instructors. These instructors may be used to teach various in-house courses and are designated to perform instructor duties on an as-needed basis.
They are designated by the manager of training and will be fully versed and knowledgeable in their specialty; however, these instructors must maintain the course training materials and must not alter them without approval from the maintenance manager. The manager of training authorizes the designated instructor by letter, which will be kept on file in the maintenance training department.
3. Contracted Instructor. These instructors are third-party training vendors who are contracted by ABC Air for the following situations:
a. To train ABC Air instructors as required.
b. To supplement the training program by developing and teaching courses.
These instructors must follow ABC Air’s established training procedures.
4. On-the-Job Training (OJT) Instructor. These are subject matter experts qualified by the nature of their past documented experience level, and can effectively teach specific skills and information to others on the job. OJT instructors include supervisors, lead