U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Repair Station Training Program Date: 7/5/12 AC No: 145-10 Initiated by: AFS-300 Change: 1
1. PURPOSE. This advisory circular (AC) provides information on developing the repair station employee training program required under Title 14 of the Code of Federal Regulations (14 CFR) part 145, § 145.163; categories of training; training program components; and sample training programs. This AC also provides an acceptable means, but not the only means, of showing compliance with § 145.163.
2. PRINCIPAL CHANGES. This change inserts a new Appendix 3, European Aviation Safety Agency Training Requirements, and a new Appendix 4, Related Correspondence.
PAGE CONTROL CHART Remove Pages Dated Insert Pages Dated Appendix 3 (pgs. 1 and 2) 7/8/05 Appendix 3 (pgs. 1 and 2) 7/5/12 Appendix 4 (pgs. 1 and 2) 7/5/12 John M. Allen Director, Flight Standards Service ORIGINAL SIGNED by /s/ Raymond Towels for
U.S. Department of Transportation Federal Aviation Administration Advisory Circular
Subject: Repair Station Training Programs Date: 7/8/05 AC No: 145-10 Initiated by: AFS-300
PREFACE This advisory circular (AC) provides information on developing the repair station employee training program required under Title 14 of the Code of Federal Regulations (14 CFR) part 145, § 145.163, categories of training, training program components, and sample training programs.
This AC also provides an acceptable means, but not the only means, of showing compliance with 14 CFR § 145.163. Neither of the sample programs described in Appendixes 1 and 2 of this AC need to be used; they only represent a possible way to structure a training program that meets the requirements of the regulations. Each person subject to 14 CFR part 145 should develop his/her own program tailored to his/her individual operations. Because this AC contains only guidance on developing a training program, the word “should” used herein applies only to an entity that chooses to follow a particular suggestion without deviation. The Federal Aviation Administration (FAA) uses the word “capability” to describe the knowledge and skills required to properly accomplish assigned tasks. The word “competency” is used by the European Aviation Safety Agency (EASA) and many repair stations located outside the United States. These terms should be considered synonymous for the purposes of the training program and as used in this AC. This AC contains additional governmental, mandatory and nonmandatory subjects not specifically required by 14 CFR part 145, § 145.163. The FAA is aware that the additional training outlined in this AC exceeds that required by 14 CFR part 145, § 145.163, but feel is necessary to provide these subject samples as a guide for a complete and comprehensive safety directed program. If the repair station chooses to develop a training program with the additional nonregulatory subjects, only those required by regulation would be subject to FAA approval. One means of developing this type of program could include a separation of the regulatory and nonregulatory training subjects within the training manual.
Page iii (and iv)
CONTENTS Paragraph Page CHAPTER 1. INTRODUCTION
100. Purpose1
CHAPTER 2. BACKGROUND ON REPAIR STATION TRAINING
200. G eneral3
201. R egulatory Requirements4
202. M anual Requirements4
203. P rogram Scope and Complexity4
CHAPTER 3. CATEGORIES OF TRAINING AND COURSES OF STUDY
300. G eneral7
301. Indoctrination (I nitial and Recurrent) Training7
302. T echnical Training8
303. R ecurrent Training10
304. S pecialized Training10
305. R emedial Training11
CHAPTER 4. TRAINING PROGRAM BASIC COMPONENTS
400. General13
401. Needs Assessments13
402. Area of Study and Course Definition17
403. Identifying the Training Method17
404. Training Sources19
405. Qualifying Instructors20
406. Measuring Training Effectiveness20
407. Training Documentation21
408. I
nterfaces with the Training Program22
409. Special Considerations for Repair Stations Located Outside the United States22
CHAPTER 5. ADMINISTRATIVE INFORMATION
500. How to Obtain Copies of Publications Referred to in This AC25
501. Requests for Information25
APPENDIX 1. SAMPLE TRAINING PROGRAM FOR A LARGE/MEDIUM REPAIR
STATION (8 pages)1
APPENDIX 2. SAMPLE TRAINING PROGRAM FOR A SMALL REPAIR STATION (UNDER 10 EMPLOYEES) THAT PERFORMS WORK SOLELY FOR
14 CFR PART 91 OWNER/OPERATORS (6 pages)1
APPENDIX 3. EUROPEAN AVIATION SAFETY AGENCY TRAINING
REQUIREMENTS (2 pages)1
APPENDIX 4. RELATED CORRESPONDENCE (2 pages)1
Par 100 Page 1 (and 2)
I NTRODUCTION
100. PURPOSE.
a. This AC provides information on developing the repair station employee training program required under 14 CFR part 145, § 145.163, categories of training, training program components, and sample training programs.
b. This AC provides an acceptable means, but not the only means, of showing compliance with 14 CFR part 145, § 145.163. Neither of the sample programs described in Appendices 1 and 2 of this AC need to be used; they represent only a possible way to structure a training program that meets the requirements of the regulations. Each person subject to 14 CFR part 145 should develop his or her own program tailored to individual operations. Because this AC contains only guidance on developing a training program, the word “should” used herein applies only to an entity that chooses to follow a particular suggestion without deviation.
c. The FAA uses the word “capability” to describe the knowledge and skills required to properly accomplish assigned tasks. The word “competency” is used by the European Aviation Safety Agency (EASA) and many repair stations located outside the United States. These terms should be considered synonymous for the purposes of the training program and as used in this AC.
d. Entities wishing to become certificated under 14 CFR part 145, and those 14 CFR part 145 repair stations certificated prior to April 6, 2006, whether located within or outside the United States, should use this AC to develop the training program required by 14 CFR part 145.
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BACKGROUND ON REPAIR STATION TRAINING
200. GENERAL.
a. B eginning April 6, 2006, persons applying for a repair station certificate under 14 CFR part 145 must submit a training program for FAA approval. Additionally, repair stations that were certificated prior to April 6, 2006, must submit a training program for approval by the last day of the month in which their 14 CFR part 145 certificate was originally issued. The program must ensure that individuals performing maintenance (including inspections), preventative maintenance, inspections, and alterations under the repair station certificate are capable of performing assigned tasks.
b. Though prior to the August 2001 rule change (No. 145–27, Repair Stations; Final Rule with Request for Comments and Direct Final Rule with Request for Comments (66 FR 41087, August 6, 2001)), 14 CFR part 145 did not include a specific requirement for a training program, the repair station needed to ensure persons were competent to perform assigned tasks. Only those repair stations performing maintenance or preventative maintenance functions for a 14 CFR part 121 or 14 CFR part 135 certificate holder were required to have a training program to ensure each person who determines the adequacy of the work performed is fully informed about the procedures, techniques, and new equipment in use and is able to perform all associated duties.
c. Mechanics may acquire their initial skill through formal training, such as 14 CFR part 147 Aviation Maintenance Technician Schools (AMTS) or hands-on experience working under FAA-certificated Airframe and Powerplant (A&P) mechanics or in the military. Once an individual obtains a certificate, acquired experience can vary substantially, as well as the type or level of training. Therefore, repair stations need proper initial and recurrent training to ensure persons are capable of performing assigned tasks, even when the majority of the workforce may be certificated under 14 CFR part 65.
d. There are numerous categories of personnel employed by 14 CFR part 145 repair stations, with a variety of specialties. Hiring practices vary widely among repair stations with some employees having direct relevant experience, certification, and training, while others do not. There are maintenance personnel who work for temporary placement organizations, which permit repair stations to meet peak workload demands. Therefore, all employees that are assigned tasks to perform maintenance (including inspection), preventive maintenance, or alteration must be included in the training program to ensure they are capable of performing the specific assigned tasks of the particular repair station.
e. Title 14 CFR part 145, § 145.163, promulgated in August 2001 under amendment No. 145–27, requires each repair station to establish a training program for employees who perform maintenance (including inspection), preventative maintenance, or alteration under the authority of the repair station’s certificate. This training program will enhance aviation safety by ensuring each maintenance employee is fully capable of performing assigned tasks. The FAA understands that repair stations vary in size; therefore, it expects each repair station to have a training program appropriate to its organization and the work it performs.
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f. The FAA notes that some 14 CFR part 145 repair stations have EASA certifications.
EASA Part-145 contains licensing and training requirements for Approved Maintenance Organizations (AMO) that perform maintenance on articles of those operators under the regulatory control of European Union (EU) Member States. These EASA Part-145 requirements can affect FAA part 145-approved repair stations that also have EASA approvals since EASA requires maintenance human factors training as part of the Bilateral Aviation Safety Agreement (BASA) and Maintenance Implementation Procedures (MIP) with the United States. The FAA training program may include the requirements of other civil aviation authorities as long as the 14 CFR part 145 requirements are also met.
201. RE GULATORY REQUIREMENTS. Beginning April 6, 2006, 14 CFR part 145 requires an applicant for certification and current FAA-certificated repair stations to submit a training program to the FAA for approval. The employee training program approved by the FAA must include initial and recurrent training requirements. The training program must ensure each employee assigned to a maintenance (including inspection), preventative maintenance, and alteration task is capable of performing the work. Upon training program approval by the FAA, the repair station will begin following its approved procedures. If a repair station accomplishes work for a 14 CFR parts 121, 125, 129, or a part 135 operator, its program must ensure any employee assigned to tasks for these referenced operators are trained in accordance with that operator’s requirements.
202. MANUAL REQUIREMENTS. The training program may be documented in the Repair Station Manual (RSM) or it may be in a separate manual. If the training program becomes part of the RSM, these procedures should distinguish between handling revisions to the approved training manual section from handling those revisions associated with the non-approved repair station manual. The procedures should also include how submitting revisions to the certificate-holding district office (CHDO) will be handled for the different types of manuals. If the training program is contained in a separate manual, that document may include the revision and notification provisions required by 14 CFR part 145, § 145.209(e).
203. PROGRAM SCOPE AND COMPLEXITY.
a. T he purpose of the repair station’s initial and recurrent training program is to ensure repair station employees performing maintenance (including inspection); preventative maintenance and alteration are capable of performing assigned tasks as required by 14 CFR, part 145, § 145.163.
b. Each repair station’s training program must be based on its individual operation and needs. When developing its training program, each repair station should consider its size, ratings, maintenance tasks associated with positions, and its employees’ experience and skill levels.
c. Each individual employed by a repair station should have training based on the tasks associated with the person’s job position. Therefore, each repair station should develop procedures for determining the training each employee requires. Also, not all repair station employees require the same level of training. To facilitate the development of the training requirements and courses of study, each repair station may wish to separate its staff into categories. Those persons that perform maintenance (including inspection), preventative
Par 203 Page 5 maintenance, or alteration tasks must be trained under the provisions of the approved training program required by 14 CFR part 145. Other employees may be trained under the 14 CFR part 145 training program, but their training should not be considered mandatory under the regulations. The following table shows two examples of types of categories a repair station might use:
TABLE 1. EXAMPLE REPAIR STATION CATEGORIES Type of Repair Station Example of Staffing Categories Small to medium (1) Technicians and inspectors that perform maintenance, preventative maintenance, and alteration duties (including inspection).
(2) Supervisors that perform maintenance, preventative maintenance, and alteration duties (including inspection).
(3) Managers and support staff that perform maintenance, preventative maintenance, and alteration duties (including inspection).
Larger (1) Technical personnel conducting maintenance, preventative maintenance, and alteration duties (including inspection) with authority for approval for return to service.
(2) Technical personnel conducting maintenance, preventative maintenance, and alteration duties (including inspection) without authority for approval for return to service.
(3) Inspection personnel.
(4) Supervisor personnel that perform maintenance, preventative maintenance, or alteration functions and duties.
d. Each repair station’s training program should address:
(1) Indoctrination (initial and recurrent) training for new and existing employees covering the regulations and the repair station’s operations, policies, and procedures (see paragraph 301);
(2) Initial technical requirements for new and existing employees taking on new tasks to ensure appropriate technical skills training is provided (see paragraph 302);
(3) Recurrent technical training for specific tasks or functions to ensure currency in existing or added capabilities (see paragraph 303);
(4) Specialized technical training or advanced training requirements for specific tasks or functions to ensure all employees accomplishing maintenance remain capable of performing assigned tasks (see paragraph 304); and
(5) Remedial technical training requirements to correct demonstrated lack of skill or knowledge deficiencies (see paragraph 305).
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e. Each repair station’s training program will vary in the number of courses, content, time requirements, training methods, and sources. One repair station may have separate indoctrination courses for technicians, inspectors, managers, and supervisors. Another repair station may have only one indoctrination course appropriate for all of its employees, including temporary personnel.
f. Consistent with its evolving systems safety certification and surveillance process, the FAA may ask the following questions to establish whether the training program meets the requirement for ensuring each employee performing maintenance, preventative maintenance, and/or alteration tasks is being trained or is capable of performing the assignment:
(1) Is there clear responsibility and authority? Did the repair station clearly identify the job title responsible for the different aspects of the training program? Did the repair station identify the job title with the authority to propose changes to the approved training manual?
(2) Are there written procedures? Are the repair station’s training program policies and procedures written in its training manual or program document?
(3) Is there a measurement of effectiveness? Is there a method of determining whether the employee is capable of performing assigned tasks?
(4) Are there controls in place? Does the repair station have adequate procedural controls to ensure that all applicable elements of the training program are carried out in specific situations?
(5) Does the repair station identify and describe the interface between the training program and the individuals responsible for task assignments?
(6) Are there written procedures that require the repair station to maintain personnel training records for 2 years?
(7) Is the manual identified with applicable contact information such as company name, address, certificate number, telephone, fax, email, etc.?
(8) Does the control system include a distribution list identifying a particular manual to a person or location?
(9) Does the manual contain an adequate revision system to allow an easy determination of currency?
(10) Is there a procedure for submitting revisions to the CHDO for approval?
(11) Does the training program have provisions for initial and recurrent training?
(12) Are individual training requirements identified and documented?