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1.8.1 Basic Content of the Maintenance Manual. The emphasis and significance of your manual cannot be overstated. Your CAMP is unique to you, and therefore §§ 91.1023,
121.133, and 135.21, in conjunction with §§ 91.1437, 121.369, and 135.427, require you to produce a manual that reflects your design. Your manual provides personnel with your direction, procedures, instructions, guidance, and information that you require them to follow in order for you to meet your primary responsibility requirements and maintain safe operations. Therefore, an acceptable CAMP Training Program must derive its basic content and curriculum from your CAMP manual and will address the unique nature and requirements your CAMP requires. The FAA should be able to identify some form of introductory training that ensures each person knows how to access the CAMP manual part(s) that is relevant to them. The CAMP Maintenance and Preventive Maintenance Training Program must inform, teach, reinforce, and emphasize the methods, techniques, and practices of your CAMP manual.
1.8.2 Method to Ensure a Person is Fully Informed and Competent. A CAMP Training Program is your means to present, explain, and ensure maintenance personnel understand the methods, techniques, and practices defined in your manual. Your CAMP Training Program is your means to emphasize to those you employ, contract with, and authorize to perform maintenance (including inspection), preventive maintenance, and alterations that they must do so in accordance with your manual. Your CAMP Training Program is where you determine personnel are fully informed and competent based on your standards and expectations. The method you use to meet the requirements of §§ 91.1425,
121.367, and 135.425 to provide competent personnel must be documented in your CAMP manual per §§ 91.1427, 121.369, and 135.427.
1.8.3 Training Recordkeeping. The FAA expects your CAMP Training Program to gather, produce, and maintain training records of your employees and include a method that explains how you oversee and verify contractor employee records. Training records validate that personnel have a full understanding and are competent. These records should show that you or your contract provider have considered past and present training, experience, and certifications; compared them to the competency standards you have set in your manual; and provided additional training as required to fill any identified knowledge or competency gaps.
1.8.4 Contract Provider Training Programs. You should assess, accept, and authorize contractor maintenance training when you choose to use them. The regulations accommodate the significant safety benefits afforded by contract maintenance providers, especially in highly technical and specialized areas of maintenance; however, doing so induces risks that the CAMP operator needs to control and explain within its CAMP manual. The CAMP operator has overarching responsibility for training regardless of whose program it is or who is delivering it. Sections 91.1427, 121.368, 121.369(b)(10),
135.426, and 135.427(b)(10) require your manual to include your methods to evaluate maintenance provider training, supplement it as is necessary, accept its content and delivery methods, authorize its use through a maintenance provider agreement or method your manual describes, and continuously verify training performance and effectiveness.
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1.8.5 CASS Interface. Sections 91.1431, 121.373, and 135.431 require CHs t o 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 deficiency in those programs, regardless of whether those programs are carried out by the CH or by another person. Therefore, regardless of whether your CAMP Training Program is of your design or a contract maintenance provider training program you accept as part of your design, your CASS must be able to influence your training when it identifies or associates root cause deficiencies with your training program design or delivery of your maintenance training. You are responsible for ensuring that maintenance, preventive maintenance, and alterations performed by your maintenance employees, or by other persons for you, is performed in accordance with your manual.
1.9 Who Receives CAMP Training? The CAMP Training Program applies to your entire maintenance organization. Sections 91.1423, 121.365, and 135.423 require an organization to adequately perform maintenance, preventive maintenance, alterations, and required inspections. Sections 91.1427, 121.369, and 135.427 require you to place in your manual a chart or description of your organization and a list of the persons you have arranged with to perform any of your required inspections, other maintenance, preventive maintenance, or alterations. The performance of maintenance (including inspection), preventive maintenance, and alterations, followed by the article’s subsequent return to service, is an organizational responsibility with individual duties that are often divided and diverse. Each person performing functions such as manual management, maintenance control, records control, maintenance scheduling, assuring serviceability of parts, and maintaining your CASS has a role in determining the “adequacy of work.” As such, your CAMP Training Program, per §§ 91.1433, 121.375, and 135.433, should ensure each individual (within their respective organizational roles) is fully informed about procedures, techniques, and new equipment in use, and is competent to perform their duties as they relate to determining the adequacy of the work done under your CAMP authority.
1.9.1 Your CAMP Organizational Manag ement. The management-related provisions for part 91K for fractional ownership operations, and those in §§ 119.65 and 119.69 for parts 121 and 135 air carriers, require sufficient management and technical personnel who are qualified through training, experience, and expertise. AC 120-16, Air Carrier Maintenance Programs, explains these positions are necessary to perform, supervise, manage, and amend your CAMP; manage and guide your maintenance personnel; and provide the direction necessary to achieve your CAMP objectives defined in §§ 91.1425,
121.367, and 135.425. The duties, responsibilities, and authority of personnel that fill these required or approved positions must be as stated in the general policy provisions of the manual required by §§ 91.1023, 121.133, and 135.21. While you may hire individuals with the training, experience, and expertise you require, your CAMP Training Program should ensure the personnel you provide have a full understanding of their duties, authority, and responsibility. The CAMP Training Program empowers you to train and prepare your employees for management roles and responsibilities within your organization. To the extent of their responsibilities (per §§ 119.65 and 119.69), these individuals should fully understand:
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• Aviation safety standards and safe operating practices;
• Title 14 CFR Chapter I (Federal aviation regulations);
• Your OpSpecs;
• All appropriate maintenance and airworthiness requirements (e.g., 14 CFR parts 1, 21, 23, 25, 43, 45, 47, 65, 91, and 121); and
• Your manual required by §§ 91.1023, 121.133, and 135.21.
1.9.2 Those Who Perform Maintenance, Pr eventive Maintenance, and Alterations and Those Who Approve Work for Return to Service.
1.9.2.1 The training program must ensure that CAMP operator personnel, or the persons with whom the CAMP operator has arranged to perform the work, understand the policies, procedures, and instructions in their maintenance manual; are fully informed about procedures, techniques, and new equipment in use; and are competent to perform their duties. Sections 121.379 and
135.437 grant parts 121 and 135 CHs th e authority to perform maintenance, preventive maintenance, and alterations as provided in their maintenance manuals. In addition, they authorize those CHs to approve for return to service any airframe, aircraft engine, propeller, rotor (rotorcraft may be used in part 135, but not part 121), or appliance after performing that maintenance, preventive maintenance, or alteration. As part of the approval for return to service, §§ 121.709 and 135.443 restrict airworthiness releases, logbook entries, and approvals for return to service to only appropriately certificated persons.
1.9.2.2 Un like air carriers, part 91K operators are not maintenance entities. The performance of maintenance, preventive maintenance, and alterations, and the subsequent approval for return to service, must be by a certificated person authorized to do so under part 43. A part 91K program manager may perform and/or approve maintenance for return to service only if properly certificated.
However, the part 91K program manager still has the responsibility, with the Director of Maintenance (DOM), to ensure the personnel they employ or contract with are appropriately certificated, have a full understanding of the CAMP manual procedures and techniques, are fully informed of any new equipment in use, and are competent in accordance with their manual.
1.9.3 Required Inspection Personnel. Sections 91.1429, 121.371, and 135.429 provide that persons who perform required inspections for you must be appropriately certificated, properly trained, qualified, and authorized to do so, and must perform under the supervision and control of an inspection unit.
1.9.4 Contract Mai ntenance Personnel. It is common for persons performing maintenance, preventive maintenance, or alteration functions for you to have a training program of their own. When you arrange with others to perform work for you, your responsibility is to ensure these individuals are fully informed about your procedures, techniques, and new
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1.9.5 Individuals Who Perfo rm CASS Functions. Individuals who perform CASS functions must be able to validate your CAMP’s performance and assess its effectiveness. These individuals collectively determine the adequacy of all CAMP work; therefore, the CAMP Training Program is a method to ensure they are competent to do so.
1.9.6 Maintenance Department Employe es. Parts clerks, records clerks, and auditors may not need training under your CAMP Training Program; however, parts and records control, as well as complete and accurate audits, are essential to ensure airworthiness. Competent performance of these duties is expected, necessary, and may be required. Refer to §§ 91.1433, 121.375, and 135.433.
1.10 How Does Your CAMP Training Program Interface With Your Safety Management System? The Airline Safety and Federal Aviation Administration Extension Act of 2010 directed the FAA to “require all part 121 air carriers to implement a safety management system.” As a result, in 2015, the FAA published 14 CFR part 5, Safety Management Systems, applicable to air carriers conducting operations under part 121. Persons other than part 121 air carriers are encouraged to implement a Safety Management System (SMS) voluntarily. AC 120-92, Safety Management Systems for Aviation Service Providers, provides an acceptable means of complying with part 5. SMS is not a standalone program; rather it is a system that emphasizes safety and is integrated throughout all aviation-related facets of an organization. An SMS does not have to be extensive, expensive, or sophisticated to do what it is supposed to do. Part 121 air carriers and others with an FAA-accepted SMS should understand that developing and delivering any training (including maintenance training) is an opportunity to promote safety.
Because the performance and approval of maintenance is relative to your safety performance, your maintenance executives, managers, and other employees are all accountable for your safety performance (refer to § 5.23). Note that the requirements in § 5.91 (competencies and train ing) and § 5.93 (safety communication) apply for part 121 operators and should be considered in developing your CAMP Training Program. Note also that § 5.97(c) (SMS records) requires you to ma intain a record of all training provided under § 5.91 for each individual, and that those records must be retained for as long as the individual is employed by the operator. Additionally, § 5.97(d) requires part 121 operators to retain records of all communications provided under § 5.93 for a minimum of 24 consecutive calendar months.
1.10.1 Your CAMP Training Program May be a Mitigation Strategy. You may use a CAMP Training Program as a mitigation strategy to address the hazard/risk of a “nonproficient” employee or work unit.
1.10.2 Your CAMP Training Program is a Means to Gather Safety Data. E xisting programs, such as an Aviation Safety Action Program (ASAP), the CAMP Training Program, and the CASS, provide valuable data that you can integrate into an SMS. Feedback from these programs will “feed” your system, which may often identify underlying causes and identify additional hazards or increased risk.
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1.11 Is My Non-Extended Operations (ETOPS) CAMP Training Program Sufficient for ETOPS? No. A CH conducting ETOPS with two-engine airplanes must enhance its CAMP Training Program to comply with the ETOPS maintenance requirements as specified in §§ 121.374 and 135.411(d). An ETOPS CAMP has additional training requirements and expectations. In accordance with § 121.374(m) and part 135 appendix G, subparagraph G135.2.8(m ), for each airplane-engine combination, you must develop a maintenance training program that provides training adequate to support ETOPS. This may be a standalone program or an enhancement to your existing non-ETOPS CAMP Training Program. Either way you must ensure ETOPS-specific training for all persons involved in ETOPS maintenance, and this training must focus on the special nature of ETOPS. This training is in addition to your CAMP Training Program used to qualify individuals to perform work on specific airplanes and engines.
1.12 What Det ermines the Complexity and Scope of a CAMP Training Program? Your CAMP Training Program is unique to your organization. The complexity of your CAMP Training Program is proportional to the maintenance organization, the number of aircraft, aircraft make, aircraft model, and aircraft equipment configurations. The number of courses, content, time requirements, training methods, and sources within a CAMP will vary accordingly. For example, one maintenance organization may have separate indoctrination courses for technicians, inspectors, managers, and supervisors. Another maintenance organization may have only one indoctrination course appropriate for all of its employees, including temporary personnel. The FAA expects the CAMP Training Program, like the CAMP itself, to be sufficiently comprehensive in scope and detail to fulfill its responsibility to provide competent personnel and authorize inspection personnel to maintain the aircraft in an airworthy condition in accordance with the regulations. Competent individuals who perform the inspections and other maintenance, preventive maintenance, and alterations under the CAMP:
1. Understand and use the applicable portions of the CH’s/program manager’s manual to perform their assigned tasks;
2. Perform the work;
3. Determine the adequacy of the work;
4. Determine the adequacy of the work done under their supervision;
5. Accomplish the approval for return to service under §§ 91.1443, 121.709, and
135.443, as applicable, on behalf of the maintenance organization;
6. Identify Required Inspection It ems (RII) and ensure they are verified and that the required items are correct; and
7. Create complete and accurate maintenance record entries.
1.12.1 Persons tasked with reliability program or CASS data collection and analysis duties may require specialized training and technical backgrounds. It is your responsibility to ensure those who perform these duties are competent to do so. In general, these auditors and analysts should:
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1. Have a sufficient maintenance background applicable to your program.
2. Be familiar with your maintenance procedures, technical documents, and aircraft systems.
3. Be able to understand and interpret data to evaluate the facilities, equipment, and processes you use.
4. Have training and experience specific to their assigned functions and duties.
5. Have systems analytical skills.
6. Have skills in auditing techniques.
7. Be able to apply risk assessment and risk management (RM) techniques.
8. Be able to perform Root Cause Analysis (RCA).
9. Fully understand and consider human factors.
1.13 Which Regulations and Other Guidance Material are Related to This AC? For more information, consult the current editions of the following documents:
1.13.1 Title 14 CFRs .
1. Part 1, Definitions and Abbreviations. Part 1 contains the definitions of some of the words used in 14 CFR.
2. Part 5, Safety Management Systems: Subpart E—S afety Promotion.
3. Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration. Part 43 contains the rules for maintenance, preventive maintenance, rebuilding, and alteration.
4. Part 91, General Operating and Flight Rules: Subpart K—F ractional Ownership Operations.
5. Part 119, Certification: Air Carriers And Commercial Operators: Subpart C— Certification, Operations Specifications, and Certain Other Requirements for Operations Conducted Under Part 121 or Part 135 of This Chapter.
6. Part 121, Operating Requirements: Domestic, Flag, and Supplemental Operations:
Subpart L—Maintenance, Preventive Maintenance, and Alterations.
7. Part 135, Operating Requirements: Commuter and On- Demand Operations and Rules Governing Persons On Board Such Aircraft: Subpart J—Maintenance, Preventive Maintenance, and Alterations.
1.13.2 Advisory Circulars (AC).
1. AC 120-16, Air Carrier Maintenance Programs. T his AC describes a Continuous Airworthiness Maintenance Program (CAMP). It explains the background as well as the FAA’s regulatory requirements for these programs.
2. AC 120- 66, Aviation Safety Action Program. This AC provides information encouraging employees to voluntarily report safety information.
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3. AC 120-72, Maintenance Human Factors Training. This AC presents guidelines for developing, implementing, reinforcing, and assessing Maintenance Human Factors (MxHF) training programs for improving communication, effectiveness, and safety in maintenance operations.
4. AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals. This AC provides information on electronic recordkeeping.
5. AC 120-79, Developing and Implementing an Ai r Carrier Continuing Analysis and Surveillance System. This AC provides information on how to implement a CASS, which is required for CAMP operators.
6. AC 120-92, Safety Management Systems for Aviation Service Providers. T hi s AC provides information on how to develop an SMS.
1.13.3 Other Publications.
1. FAA Order 8900.1, Volume 3, Chapter 24, Evaluate 14 CFR Parts 91 Subpart K/121/135.411(a)(2) Maintenance Training Program Record. Section 1 provides guidance for training program evaluation and Section 2 provides guidance for evaluating and accepting a human factors training program.
2. The FAA Office of Aerospace Medicine (AAM) Op erator’s Manual: Human Factors in Aviation Maintenance. This manual is available at https://www.faa.gov/data_researc h/research/med_humanfacs/oamtechreports/2010s/2015/201502. As stated on FAA.gov, “This manual recognizes that readers already know the importance of human factors – a science that pays attention to physical, psychological, and other human attributes to ensure that we work safely and efficiently with minimal risk to others and equipment. The chapters discuss seven critical human factors topics that contribute to the goal of creating and reinforcing a safety culture where employees practice safe habits, both at work and at home:
1. Hazard Identification,
2.
Procedural Compliance and Documentation,
3. Human Factors Training – Evolution and Reinforcement,
4. Fatigue Risk Management,
5. Human Factors Health and Safety Program,
6. Considering Human Factors Issues in Design and Installation, and
7. Measuring Impact and Return on Investment.”
Note: A downloadable PDF is available at https://www.faa.gov/sites/faa.gov/files/ data_research/research/med_humanfacs/oamtechreports/201502.pdf.
3. Air Transport Association (ATA) Specification 104, Guidelines for Aircraft Maintenance Training, Washington, DC, Airlines for America (2017). The document provides guidance on training development including task analysis and
1-10 industry-defined training levels. This document is available at https://publications.airlines.org/CommerceProductDetail.aspx?Product=236.
4. International Civil Aviation Organization (ICAO) Doc 9683-AN/950, H uman Factors Training Manual (1998). This document provides overview information on training content for human factors programs.
5. European Union Aviation Safety Agen cy (EASA) Acceptable Means of Compliance (AMC) and Guidance Material (GM). This information may have value for those interested in the training design and maintenance certification guidance used by EASA. The information is available at https://www.easa.europa.eu/documentlibrary/acceptable-means-of-compliance-and-guidance-materials.
2-1 CHAPTER 2 TYPES OF TRAINING
2.1 Purpose of This Chapter.
2.1.1 The AC explains various types of training that you should consider in the following sections:
2.2 CAMP Indoctrination.
2.3 Code of Federal Regulations (CFR).
2.4 Maintenance Policies and Procedures Content and Usage.
2.5 Human Factors Training (Initial and Recurrent).
2.6 Initial Training.
2.7 On-the-Job Training (OJT).
2.8 Recurrent Training.
2.9 Requalification Training.
2.10 Remedial Training.
2.11 Aircraft/Airplane Equipment Specific Training.
2.12 Specialized Tasks.
2.13 Competency-B ased Training.
2.14 Maintenance Provider Training.
2.1.2 Your CAMP Training Program should be flexible enough to adjust as needs arise and include additional types of training as dictated by maintenance program assessments, changes in operations, and regulatory requirement changes.
2.2 CAMP Indoctrination.
2.2.1 Indoctrination training should introduce new employees to the organization and its operations and serve as core training for all employees. Indoctrination training usually is required only for new employees shortly after an employee is hired. The scope and depth of indoctrination training will vary based on the employee’s job function and the complexity of the organization. However, to establish a common company core of knowledge, indoctrination training should be similar for all employees.
2.2.2 Indoctrination training usually covers the following subject areas:
• The operator’s basic policies and procedures, company manuals, and organizational and administrative practices.
• Applicable sections of 14 CFR.
• Facility security.
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• Maintenance department and quality control policies, procedures, and practices;
maintenance manuals; and forms.
• Company and maintenance department computer systems and software training.
• Maintenance recordkeeping and documentation.
• Human factors and safety management procedures overview.
• Hazardous materials (HAZMAT), Environmental Protection Agency (EPA), and Occupational Safety and Health Administration (OSHA) regulations familiarization.
2.2.3 The maintenance training portion of the manual should contain the training program subject areas, define to whom and when indoctrination training is required, and define the timeframe for delivery (e.g., within 30 days of hiring).
2.3 Code of Federal Regulations (CFR).
2.3.1 All employees should receive a basic introduction to the 14 CFR and the applicable sections as described in the indoctrination training.
2.3.2 Many employees require a more detailed review of the applicable regulations as they apply directly to their specific job responsibilities. For example, inspectors and those with approval for return-to-service signature authority may require additional or an indepth review of the regulations as applied to their job responsibility.
2.3.3 A CAMP Training Program task analysis should determine and justify the amount of regulations training required beyond indoctrination training.
2.4 Maintenance Policies and Procedures Content and Usage.
2.4.1 Improper use of or failure to use documentation to follow established procedures is a leading contributing factor to human error in maintenance. Therefore, training for maintenance policies and procedures is important to all employees.
2.4.2 Training should ensure that it addresses the Continuing Analysis and Surveillance System (CASS) analysis and assessments, disclosure reporting, and regulatory noncompliance related to documentation and manual use.
2.4.3 Training for use of procedures should be matched to each employee’s job requirements.
This training should also be reinforced in the human factors training.
2.5 Human Factors Training (Initial and Recurrent).
2.5.1 FAA investigations and data analysis show that human factors have contributed to approximately 80 percent of all maintenance-related accidents and incidents. Research and experience show human factors training can address many issues that contribute to these maintenance events. Attention to maintenance human factors will raise efficiency, effectiveness, and safety in aviation environments. That translates to better expense control and long-term safety benefits.
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2.5.2 Training in maintenance human factors is an essential part of a maintenance training program. The CAMP Training Program, and any revision to it, should include human factors elements.
2.5.3 Many companies have European Union Aviation Safety Agency (EASA) certificates and have implemented training accordingly. This AC encourages CAMP Training Programs to conform to EASA’s suggestions for training content. However, the maintenance organization can base its human factors training on a training needs assessment that may not include all the EASA elements.
2.5.4 Human factors training can be delivered using multimedia, including web-based training.
However, the value of additional instructor-led discussion is extremely valuable.
2.5.5 When human factors training is provided by contracted providers, the manual should state the way the contracted program is evaluated and authorized to deliver this training.
2.5.6 The maintenance training portion of the manual should contain human factor subject areas, define how outside influences affect human behavior, provide human factor awareness training, and contain a student assessment evaluation concerning content and instructional delivery.
2.5.7 Maintenance human factors experts and other regulatory agencies, including EASA, have identified the following key topics to include in a training program.
1. General/introduction to human factors.
2. Safety culture/organizational factors.
3. Error (error principles, event investigation, and case studies).
4. Human performance and limitations.
5. Environment (physical and social).
6. Procedures, information, tools, and task signoff practices.
7. Planning of tasks, equipment, and spares.
8. Communication.
9. Teamwork and leadership.
10. Professionalism and integrity.
11. Shift and task turnover.
12. Undocumented maintenance.
13. Fatigue management/fitness for duty.
14. 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.)
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2.6 Initial Training.
2.6.1 Initial training is where you establish the minimum competency levels individuals must meet when performing their work assignments. It is here that you ensure personnel are fully informed about your procedures, techniques, and equipment. Individuals leave initial training knowing their duties and authorities and they are now fully aware of what you expect of them. Initial training enables individuals (at the level they are assigned) to determine the adequacy of the work they do (and if required) the work others do in accordance with your procedures. Through initial training, each individual understands their part in your overarching responsibility to ensure airworthiness.
2.6.2 Initial training may be tailored according to job functions and position. For example, initial training for maintenance technicians would be different than that for stockroom clerks. Initial training should be matched to the aircraft type(s) on which the employee is likely to work. Regardless of their work assignments, initial training is where you relate your methods, techniques, and practices defined in your manual as it applies to their duties and responsibilities.
2.6.3 Initial training based on CAMP competencies ensures each employee has a validated set of knowledge, skills, aptitude, and ability, and is not measured in course hours or time.
Initial training is your opportunity to evaluate each person’s skill level and assess how their skills meet your CAMP needs and expectations. This determination is based on each employee’s previous experience and demonstrated capabilities. It is best established through a needs assessment process (see paragraph 3.4). T his needs assessment is a critical part of establishing each individual’s training requirements. There could be different standards and program requirements depending on the measured skills and past experience of each maintenance employee. The following are some standards you could apply:
• Individuals with no prior expe rience,
• Individuals with prior experience on the same aircraft type,
• Individuals with prior experience not on the same aircraft type,
• Individuals with experience working under a CAMP organization,
• Individuals without experience working under a CAMP organization,
• Individuals with prior repair station experience, and/or
• Individuals with prior military experience.
2.6.4 Initial training could have minimum hour requirements; however, achieving individual competency must be the output of your CAMP Training Program. The CAMP Training Program portion of your manual will identify the minimum competency standards each employee must possess prior to being used in your maintenance organization. For example, the minimum initial training requirements for all maintenance technicians may be 40 hours, but maintenance technicians with no prior experience may require 80 hours or more in order to reach the competency level expected of them.