6-1 CHAPTER 6 ADMINISTRATIVE INFORMATION
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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.
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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
Appendix A A-5 mechanics, or mechanics with previous experience. They also could include instructors from a manufacturer or other outside agency. To qualify for this position, the individual—
a. Must have performed the task to the satisfaction of their supervisor.
b. Must be able to transfer skills, knowledge, and techniques to students and determine their performance level.
c. Must be able to assign a maintenance task and ensure that task was properly completed using acceptable reference material and maintenance procedures.
5. Practical Examiner. This classification is for employees authorized to administer practical exams, such as those for an engine run and taxi practical.
VIII. Training Courses Each ABC Air training course contains a course description and syllabus that describes the content of the course, the objective of the course, type of training, length of course, and student grading standards, if applicable. The course description, syllabus, and hours for each course are on file in the training department. At the end of each course, each student will be provided an end-of-course evaluation. The manager of training will review this evaluation and results, or comments will be discussed with the instructors.
All training received must be documented on the appropriate form and forwarded to the training department for inclusion in the employee’s training file.
ABC Air provides the following training:
Indoctrination Training All ABC Air maintenance personnel must complete ABC Air maintenance indoctrination training. This type of training includes, but is not limited, to the following:
1. Company organization;
2. The General Maintenance Manual (GMM);
3. Professional responsibilities of technician and maintenance management;
4. Inspection systems and Required Inspection Items (RII);
5. Maintenance records and forms;
6. Safety;
7. Airworthiness release authority;
8. Minimum equipment list (MEL) policies and procedures;
9. Logbook procedures;
10. General familiarization of each aircraft type and use of manufacturer’s technical data;
11. Familiarization with selected state and Federal rules;
Appendix A A-6
12. Human factors overview;
13. Configuration Deviation List (CDL) policies and procedures; and
14. Company procedures on the use of parts, manufacturer parts identification and numbering, and the recognition of suspected unapproved parts.
Initial Training This training consists of formal classroom instruction on ABC Air’s airframes, engines, and avionics systems. The initial training will be conducted through classroom instruction by ABC Air, the aircraft manufacturer, or an appropriate training facility approved by the manager of training. Initial training includes the following types of training, determined by aircraft primarily worked on:
1. Line maintenance by each aircraft type.
2. Heavy maintenance by aircraft type primarily worked on (additional training when reassigned to different aircraft type).
3. Shop or special skills appropriate for an individual’s assigned duties.
A nontechnical initial course may be given for each fleet type operated by ABC Air and is designed for nontechnical personnel within ABC Air. This course does not take the place of the above-listed training and is not designed for mechanics. No test will be given for nontechnical courses.
Recurrent Training This training is provided to reinforce previous training and cover aircraft system upgrades and/or changes. Recurrent training will be conducted annually and includes changes in company policy or equipment and CASS recommendations. Courses are developed on various aircraft systems and subsystems. Recurrent training can be formal classroom, poster, video presentation, self-study, computer-based training (CBT), and OJT. Appropriate testing and grading of students will be accomplished, if applicable. The recurrent training process should capture the reasons why recurrent training was required. An effort should be made to identify and rectify unusual recurrence requirements.
Requalification Training Requalification training will be conducted on an as-needed basis, specifically to restore a previously qualified employee to a qualified status. To be eligible for training in a requalification curriculum, the employee must have been previously qualified and have subsequently lost that qualification. Employees meet requalification training objectives by completing requalification curriculum segments. The reasons for, and the length of, the employee’s unqualified status will determine the training and qualification curriculum segments needed for maintenance personnel requalification.
The requalification of an employee may be as simple as re-accomplishing the currency events in which the maintenance personnel is deficient. On the other hand, requalification may be as complex as the employee having to accomplish the events in the initial equipment category of
Appendix A A-7 training when they have been unqualified for an extended period of time. The requalification training process should capture the reasons why requalification training was required. An effort should be made to identify and rectify unusual requalification requirements.
Engine Run and Taxi Training ABC Air designed the engine run and taxi program to ensure maintenance personnel required to run-up or taxi the company aircraft are properly trained, qualified, and authorized. The maintenance training department authorizes the examiners and administers this program.
Engine run and taxi procedures will be taught hands-on and may be given by the following personnel:
1. Maintenance training technical instructors.
2. Maintenance personnel who hold current ABC Air engine run and taxi authorization for the type aircraft involved.
3. ABC Air flightcrew members type rated in the aircraft.
4. Trained personnel from the factory or other approved training facilities.
5. Contracted instructors authorized by the maintenance training technical instructor based on previous aircraft training and experience or successful completion of ABC Air’s engine run and taxi authorization training.
Engine run and taxi training will be conducted only on aircraft that have no open maintenance discrepancies that may affect the safe ground operation of the aircraft. The manager of training will keep a current list of authorized instructors on file electronically.
Maintenance personnel are required to meet the following criteria to possess an engine run and taxi authorization:
1. Possession of a valid Airframe and Powerplant (A&P) certificate.
2. Employment with the company for at least 6 months.
3. Completion of the engine run and taxi familiarization class (first-time applicants only) before initial engine run and taxi authorization and a score of 85 percent or better on the engine run and taxi written examination. Training will include aircraft cockpit and checklist procedures, marshalling, towing and taxi procedures, airport operations familiarization, radio communication procedures, and runway incursion prevention.
4. Completion of a minimum of four hours of hands-on instruction in engine run and taxi training on an actual aircraft and/or simulator, including but not limited to limitations, normal and emergency procedures, and engine and aircraft operation.
5. Successfully passing an initial checkride or reauthorization by passing the 12-month recurrent checkride at the appropriate time for that specific aircraft.
ABC Air may give maintenance personnel authorization to perform engine run and taxi of the aircraft if they have held such authorizations at a previous company on the same specific
Appendix A A-8 aircraft and have supplied ABC Air with the basic class training documentation from the previous experience. The manager of training will review and approve these authorizations.
The instructor providing the training sessions will record all training on the appropriate form.
When the instructor feels confident that the student has mastered the engine run and taxi procedures, they will inform the supervisor, and set up an engine run and taxi checkride for the student. If the instructor understands that the student requires additional training, the instructor will annotate the additional training on the appropriate form.
After the student successfully completes the checkride, the training department will issue an engine run and taxi authorization, which will be good for one year. Individuals holding engine run and taxi authorizations will receive an annual proficiency check covering equipment operation, limitations, emergency procedures, and engine run and taxi radio communication procedures for each aircraft type. Proficiency checks must include operation of the aircraft type for recertification. Aircraft simulator time is recognized as aircraft operation. Maintenance personnel must renew their engine run and taxi authorizations within 2 months after the expiration date for each aircraft rating to be considered for recurrent renewal. Failure to meet this renewal requirement will require the authorization holder to meet initial minimum eligibility requirements as outlined in this section.
After a practical examiner gives an engine run and taxi checkride, they will complete the appropriate form and forward it to the maintenance training department, where it will be included in the employee’s file. A copy of the engine run and taxi checkride form may be given to the student as proof of the qualification until they receive their authorization card.
Human Factors Training Program Maintenance human factors training is part of a total system in managing human error designed to discourage procedural violations in maintenance. It is an essential part of this system aimed at individuals engaged in hands-on maintenance. Human factors training covers basic safety principles and practices already incorporated in ABC Air’s safety management and quality system to ensure the work is carried out in a professional manner such that aircraft are released to service in a safe and airworthy condition.
The objective of ABC Air’s human factors training is to provide human factors principles and techniques that will help the employee do a better job by—
1. Improving safety.
2. Decreasing organizational exposure to risk.
3. Capturing and reducing errors.
Instructors should understand the aspects of human factors by embedding it into all the training curricula. To accomplish this, instructors must—
1. Have credibility in their understanding of fundamental human factors principles and the maintenance work environment.
Appendix A A-9
2. Have excellent communication and motivational skills and be able to effect attitude changes as well as impart knowledge.
3. Be aware that the instructor’s attitude and behavior carry over to the students.
4. Always follow the procedures and have them in hand.
5. Discuss personal feelings and/or needs with the students. For example, let the students know if you are feeling tired, distracted, overwhelmed, etc., and ask them to watch out for your well-being. This will demonstrate how the instructor and student can help each other avoid errors.
6. Remind students of the dollars they are responsible for. For example, taxiing a $130 million aircraft or replacing a $200,000 part.
7. Point out personal injury potentials associated with your subject matter.
8. Point out the environmental hazards you will encounter during this training. For example, wet/slick taxiways/parking spots, poor visibility, cold/hot, power on/off, etc.
Ask your students to identify “safety nets” for these conditions.
9. Use industry “lessons learned” relative to the subject matter; include associated costs and personnel injuries.
10. Debrief students after practical examinations and openly discuss mistakes and potential ramifications and how to avoid these traps on the job.
11. Advocate the training department’s knowledge, experience, and lessons learned to other departments.
As part of the human factors training, instructors should consider a reference to the Dirty Dozen relative to situations.
The Dirty Dozen are as follows:
1. Lack of C ommunication. The exchange of information that conveys meaning between two or more people. Lack of communication often leads to misunderstandings and the results could be catastrophic.
2. Complacency. Self -satisfaction accomplished by a loss of awareness of the dangers.
This often happens when doing familiar, repetitive work.
3. Lack of K nowledge. Insufficient experience or training in the task at hand. It is easy to see how lack of knowledge could lead to an error or an accident. Often lack of assertiveness plays a part because people do not like to admit they do not know something.
4. Distraction. One’s attention is drawn away; mental or emotional confusion or disturbance occurs. When working among many people, when the work is constantly interrupted, or when coping with stress, it is easy to become distracted.
5. Lack of Teamwork. Failing to work together to achieve a common goal. Lack of teamwork creates an unhealthy environment in terms of personal dissatisfaction and group disconnect.
Appendix A A-10
6. Fatigue. Weariness from labor or exertion, nervous exhaustion, temporary loss of power to respond. Shift work can have an enormous physical impact, but there are ways to combat fatigue. Examples include sleep and exercise regularly, avoid complex tasks at the bottom of the circadian rhythm, and ask others to check the work.
7. Lack of R esources. Failing to use or acquire the appropriate tools, equipment, information, or procedures for the task at hand. Lack of resources or misusing resources has been linked to many accidents or incidents.
8. Pressure. Pushing for something in spite of opposing odds or creating a sense of urgency or haste. This factor is most prevalent when deadlines approach or when trying to meet a schedule.
9. Lack of A ssertiveness. Failing to behave in a self-confident manner. Lack of assertiveness has been identified as a link in the chain of events for many accidents.
10. Stress. Mental, emotional, or physical tension, strain, or distress. Stress is not good or bad; it is how it is handled that determines its impact on the individual.
11. Lack of Awareness. Failing to be alert or vigilant in observing. Lack of awareness of the situation or your surroundings often results in error or injury to yourself or others.
12. Norms. Unwritten and, often, unspoken rules about how work is done. Always work according to the instructions or, if they are good norms, have the instructions changed to become a part of the approved procedures.
One important aspect of the human factors training program is disclosure. It is ABC Air’s policy to have maintenance personnel actively participate in the error investigation process and to reduce any anxieties maintenance personnel might have when participating in an error investigation. The purpose of the investigation is not to determine who made the error, but rather find out why the error occurred. Maintenance personnel should feel free to disclose any unintentional errors. Any good human factors program should include a company-wide, just culture without fear of punishment or retaliation.
Aircraft Fueling and Vendor Training This training course provides information to fueling vendors to obtain authorization for fueling ABC Air aircraft to meet the requirements of ABC Air’s fueling manual.
Unscheduled On-Call Maintenance Training This training provides information to on-call maintenance technicians who may be called upon to perform maintenance functions on ABC Air aircraft.
Borescope Qualification Process Borescope training is provided to individuals requesting level one or level two borescope qualifications. Training includes familiarization of various borescope equipment types, techniques, and return-to-service criteria.
Appendix A A-11 IX. Instructional Methods ABC Air uses various instructional methods as part of its training program. It is the responsibility of the training department to periodically revise and update, as necessary, the approved instructional methods. Currently, ABC Air has the following approved instructional methods:
1. Classroom T raining. This method is usually conducted away from the production worksite in an academic classroom environment. It is appropriate for presenting new material, showing relationships between theory and practice, and teaching a skill. Only qualified maintenance instructors, contracted instructors, or designated maintenance instructors may teach classroom courses.
2. Practical Training. This method helps students gain confidence. It is prescheduled hands-on training conducted by a qualified instructor where students learn by doing, using training aids, mockups, or serviceable equipment. It is part of a planned course and does not result in actual servicing or repair.
3. On-the-Job Training (OJT). This method helps employees gain competence and may or may not use structured learning. It is task-specific training conducted at the worksite by an OJT instructor that involves actual work performance. Technical documents used at the worksite must be used as a performance standard reference. See OJT program.
4. Computer-Based Training (CBT). This method is used to provide technical information to all maintenance department personnel. The content is of an advisory nature only and cannot be used as a reference for documenting maintenance action.
Examples of CBT use include the following:
a. Notices regarding aircraft fleet differences.
b. Amplifying and clarifying existing instructions found in maintenance manuals.
c. Tips and hints on accomplishing specific maintenance tasks.
d. Clarification of methods, techniques, and practices unique to the company.
X. Training Devices To further enhance training, the training department must provide the appropriate training devices as part of the curriculum and courses it develops. These devices may include unserviceable parts. The training department will maintain an inventory of all aircraft parts used for training purposes. The manager of training is responsible for the acquisition and accountability of all training devices.
XI. On-the-Job Training (OJT) Program The training department will manage the OJT program to augment classroom training and provide documentation for experience or tasks that are best taught through actual work performance. OJT must be conducted by a qualified OJT instructor. Once the training is accomplished, that training will be documented with the appropriate OJT form. The completed form will be sent to the training department for insertion into the individual’s training file. Line