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(5) Embedded Training. Some equipment, particularly that which uses software for testing or to perform a maintenance function, has training embedded into the process.
Incorporating a tutorial or help menu are simple examples of how a software program can provide instruction as the user performs a specific task. Embedded training is most useful when:
• The employee already knows the underlying technical information related to the basic task and needs only to learn the details of the procedure.
• The procedure is straightforward and can be easily understood with a written explanation.
• The media and method in which training is embedded are part of the task or equipment to be learned.
• There is a method to assess the employee’s performance and to record that training has taken place.
(6) Other Methods Include Self-Study, Case Study, and Seminars. These methods of training or acquiring knowledge can be accepted by the repair station provided the information gained applies to the job function and skills required to perform the work capably. The repair station’s training program should ensure any processes used to impart information could be established by objective standards and requirements. Any class, course, or lesson should have a written objective, identified course material or tools/equipment, and an assessment of whether the knowledge was absorbed by the employee.
c. A repair station should pick the delivery method based on its assessment of the training needs. The repair station also should have a method to verify the training delivery technique it chooses is effective for the employee.
404. T RAINING SOURCES.
a. T here are a number of different sources for training, and the repair station should have a process for selecting a source that will satisfy its training requirements.
b. Some common training sources are:
(1) Original Equipment Manufacturers (OEM). OEMs may deliver technical information regarding maintenance or alteration on its articles by formal classroom instruction, OJT, distance learning, embedded technology, or CBT material. OEM instructors may come to a repair station to conduct training onsite or deliver the information during seminars, sessions, or extended study at other locations. OEM training onsite gives the repair station the opportunity to share the costs of the training with other local repair stations. If the repair station selects an OEM course, the repair station should ensure its employees have the prerequisite training and/or experience for the course to be most effective. Also, the repair station should verify that the area of study, course objective, material, and any instructors assigned by the OEM meet the repair station’s standards.
(2) AMTS. An AMTS approved under part 147 can be an effective source of training for repair stations, particularly for basic knowledge and skills. The training may need to be supplemented by information unique to the repair station’s tasks and equipment.
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(3) Operators or Other Repair Stations. Operators and other repair stations may have training programs they are willing to provide to others by contract. Operators may provide specified repair station employees required inspection items and operator’s program training.
The operator may also provide other general training, such as regulatory requirements.
(4) Government Agencies. Government agencies provide training on OSHA, EPA, and hazmat recognition and handling. They may also be a source of training related to maintenance human factors and general safety subjects.
(5) Trade Associations. Entities that represent certain segments of the aviation or business community offer training classes on technical and regulatory subjects. Again, the repair station must ensure the individual attending the training completed the course and acquired the requisite knowledge required by the particular repair station’s requirements.
(6) Other Sources. There are a variety of other training sources, which include, but are not limited to, independent seminars, product demonstrations, computer-based instructions, videos, and equipment manufacturers. All sources of information should be viewed as potential training sources. The repair station’s training program should have a method of incorporating training opportunities to ensure each employee is capable of performing its assigned task.
c. R egardless of the source of t he training, the repair station remains responsible for the administration, adequacy, and currency of its training program and for the maintenance of training records.
405. QUALIFYING INSTRUCTORS. The repair station may set basic standards for any instructor, whether a repair station employee, someone hired temporarily, or an instructor providing an outside training course/lesson. The repair station may have a procedure for evaluating and qualifying instructors. The following should be considered in verifying whether an instructor is appropriate:
• A ppropriate background for subject area (such as formal training and/or experience).
• Teaching ability (the ability to impart information on the particular subject matter).
406. MEASURING TRAINING EFFECTIVENESS.
a. To validate that a repair station’s employees are capable of performing assigned tasks, the training program should have a method to evaluate whether the training has been effective. This measurement has two parts. The first is a measure taken immediately after completion of the training to see if the training objectives have been met and the essential knowledge and skills have been transferred. The second is a measure of effectiveness in the application to the actual tasks. The repair station should measure this by evaluating the work and determining that the associated final products produced the learned capability in the actual work environment. The repair station may accomplish these objectives through testing upon completion of an area of study or course, or it may require a demonstration of capability by employees during the performance of the task.
b. The repair station’s process to measure the effectiveness of training should be linked to the process for defining and updating training requirements.
Par 406 Page 21
c. The following sources may be used as a tool by the repair station to measure training effectiveness:
(1) Review investigations into problems with the repair station’s work, as evidenced by complaints of customers and findings of inspectors when a product is to be approved for return to service, or other incidents.
(2) Voluntary disclosures with root causes of improper training or a lack of training.
(3) Audits that point to weaknesses in an employee’s capabilities that can be remedied by the training program.
(4) Complaints or suggestions from employees related to accomplishing work assignments or lack of training.
d. When it is determined that a training area, class, or lesson must be adjusted, the repair station should have a method of instituting the update and providing the additional information to its employees.
407. TRAINING DOCUMENTATION.
a. The repair station must document the required individual employee training in a format acceptable to the FAA. The capability of each employee depends on training, knowledge, and experience. Consequently, the determination by the repair station that an employee is able to perform the maintenance, preventative maintenance, or alteration assignment requires an analysis of the factors that contribute to the employee’s capability. The data to accomplish this analysis should be found in the employee’s training records if the principles of this AC are followed when the training program is developed.
b. The repair station may retain its training records electronically or in hard copy. In either case, the repair station should standardize the format and content for the training records based on individual job assignments. Each employee’s records should contain at least:
(1) The employee’s name and job position.
(2) Training requirements as determined by the needs assessment, including requirements for indoctrination (initial and recurrent), and other training required by areas and course titles.
(3) FAA certificates applicable to the qualifications (i.e., supervisors, Required Inspection Items (RII) personnel, and persons approving articles for return to service (RTS) must be certificated under part 65).
(4) Other certifications, diplomas, and degrees.
(5) Authorizations and qualifications (if not covered by part 65 certificates).
(6) Proof of training course completion, if determined applicable to capabilities.
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(7) List of accomplished training, to include enough information to determine whether it is applicable to the employee’s capability to perform assigned tasks:
• Course title or description,
• Course objective,
• Date completed,
• Test results,
• Total hours of training,
• Location of training,
• Name of instructor and/or instructor qualifications, and
• Signature of employee.
(8) Other documentation relevant to determining capability to perform tasks associated with assigned duties, such as past employment, written, oral and practical tests results, etc.
c. All records that are required by the training program to determine whether an emp loyee is capable of performing assigned tasks, as well as those that document training conducted by the repair station, should be considered those required by 14 CFR part 145, § 145.163. Therefore, these records should be detailed in the training program and retained for a minimum of 2 years. The repair station is encouraged to have procedures to regularly review all training records to ensure they comply with the requirements set forth in the training program manual .
408. INTERFACES WITH THE TRAINING PROGRAM. T itle 14 CFR part 145, § 145.163(b) requires that the repair station ensure that all of its employees performing maintenance (including inspection), preventative maintenance, or alteration tasks are capable of properly accomplishing that work. One of the measures for determining capability is the training an employee receives. When supervisors or managers assign tasks, they should have a procedure to verify the individual assigned has demonstrated the knowledge and skills necessary to properly accomplish the work. Consequently, the repair station should clearly define the interfaces between the employee’s individual capabilities, the training records, and the maintenance planning process in its description of the training program.
409. SPECIAL CONSIDERATIONS FOR REPAIR STATIONS LOCATED OUTSIDE THE UNITED STATES.
a. A rep air station located outside the United States is not required to have its personnel certificated under 14 CFR part 65. However, the technical knowledge, skills, and abilities should be no different for any individual performing maintenance (including inspection), preventative maintenance, or alteration tasks, regardless of where the repair station is located. Consequently, the FAA expects all repair stations to have training programs that include the basic elements set forth in this AC, including a comprehensive needs assessment requirement.
b. When conducting the training needs assessment, the repair station should place special emphasis on inspection and supervisory personnel’s ability to read, write, and understand the English language.
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c. Repair stations located outside the United States that hold an approval under another National Aviation Authority (NAA), may have a training program that satisfies the requirements of 14 CFR part 145. Different or additional requirements will not interfere with an FAA approval of the training program as long as the program meets all of the 14 CFR part 145 requirements.
Consequently, a repair station located outside the United States does not have to maintain multiple programs. However, the training program must be submitted to the FAA for approval as set forth in 14 CFR part 145, or in accordance with the procedures of an international agreement.
Par 500 Page 25 (and 26)
ADM INISTRATIVE INFOR MATION
500. HOW TO OBTAIN COPIES OF PUBLICATIONS REFERRED TO IN THIS AC.
a.
The CFRs and those ACs for which a fee is charged may be obtained from the Superintendent of Documents at the following address. A listing of the CFRs and current prices is located in AC 00-44, Status of Federal Aviation Regulations, and a listing of all ACs is located in AC 00-2, Advisory Circular Checklist:
Superintendent of Documents P.O. Box 371954 Pittsburgh, PA 15250-7954
b. To order free ACs, contact:
U.S. Department of Transportation Subsequent Distribution Office M-30 Ardmore East Business Center 3341Q 75th Avenue Landover, MD 20785
c. The FAA public Web site is located at http://www.faa.gov/.
501. REQUESTS FOR INFORMATION. For information concerning this AC, contact the General Aviation and Repair Station Branch (AFS-340) at (202) 267-3546. Submit direct comments regarding this AC to:
U.S. D epartment of Transportation Federal Aviation Administration Aircraft Maintenance Division, AFS-300 800 Independence Avenue SW.
Washington, DC 20591
Appendix 1 APPENDIX 1. SAMPLE TRAINING PROGRAM FOR A LARGE/MEDIUM
REPAIR STATION
INTRODUCTION This appendix provides a sample repair station training program for a large/medium size repair station performing work for air carriers or commercial operators under 14 CFR parts 121, 125, 129, or 135. This example is consistent with the guidance provided in this advisory circular (AC). This appendix also provides a sample training plan. The Federal Aviation Administration (FAA) must approve each training program. A repair station is not required have to follow this sample to have its training program approved. Individual repair station training programs may require different or additional information. Each program should be tailored to fit the size and complexity of the repair station. A large, complex repair station may have considerably more detail in its program description. This sample program emphasizes the process, procedures, and standards that a repair station should use to ensure compliance with the regulations. It does not set minimum limits or describe the details of the areas of study, courses, course outlines, or instructor qualifications.
In addition, the AC provides some information to help the repair station develop its training program that may not be included in the repair station’s written training program manual. The following sample training program contains notes for areas in which repair stations should provide further information.
Appendix 1
SAMPLE TRAINING PROGRAM MANUAL NOTE: The following example is for a large/medium size repair station doing business as ABC. ABC has a training department and director of training who reports directly to the accountable manager.
INTRODUCTION TO THE TRAINING PROGRAM This training program manual contains the policies and procedures ABC uses to determine its training requirements and to develop its training program. The training program ensures each repair station employee has the knowledge and skills to capably perform assigned maintenance, preventative maintenance, and alteration tasks. The training program content in this manual ensures ABC can respond to its employees’ changing training needs.
This manual sets forth the procedures for ABC to identify its training needs in a systematic manner, develop training and/or identify appropriate existing training, select the training methods, provide training, record training accomplishment, and measure the effectiveness of its training program.
ABC controls this document in accordance with the procedures for document control described in its Repair Station Manual (RSM). A copy of this document and all revisions are provided to ABC’s certificate-holding district office (CHDO). The procedures for revising this document and submitting revisions to the FAA for approval are described in this document and in the ABC RSM.
ABC uses a closed loop system to ensure that the training requirements for the company and employees are identified, training standards are established, training is provided, and the training program is revised as necessary. ABC’s training program consists of the following basic components:
• A training needs assessment to identify ABC’s overall training needs and individual employee training needs;
• The method for defining areas of study and/or courses/lessons made available to employees;
• The method for identifying training sources and methods available to employees for the areas of study, courses, and/or lessons;
• The method of documenting employee qualifications and training; and
• The methods used to measure the effectiveness of the training program and to make changes as necessary.
The director of training is responsible for ensuring ABC complies with all of the components of its training program.
The accountable manager (general manager) has the overall authority for ABC’s training program. Any changes to the training program will be coordinated with the accountable manager.
Appendix 1 SECTION 1. BACKGROUND Persons performing maintenance (including inspections), preventative maintenance, and alteration must be assessed and trained in accordance with the FAA-approved procedures set forth in this manual. All other employees may be trained in accordance with the approved procedures of this manual at management discretion.
ABC has an established training program that includes indoctrination (initial, recurrent), specialized, and remedial training areas of study for all of its employees. ABC has separate areas of study for the following staffing categories:
• Technicians and other individuals performing maintenance, preventative maintenance, or alteration tasks, such as:
• inspectors,
• supervisors, and
• managers.
• Support staff.
ABC further breaks down the training requirements for each staffing category based on job function requirements and experience levels. ABC has established minimum training standards for its job positions and methods to assess an individual’s skill level for each job function to determine training requirements.
The procedures in this manual enable ABC to revise its existing training program to ensure it continues to meet ABC’s needs and produce training consistent with all regulatory requirements.
SECTION 2. TRAINING NEEDS ASSESSMENT ABC’s needs assessment is a two--part process that determines ABC’s overall training requirements, as well as individual employee training requirements.
1. Overall Repair Station Needs.
To determine its overall training requirements, the Director of Training and the managers of each technical area must review ABC’s operations specifications (OpSpecs); capability list; job position duties and responsibilities listed in the repair station quality manual; technical job functions and tasks; customer requirements; past, current, and expected scope of work;
employment procedures for hiring; and current employee experience levels.
This needs assessment will result in a description of the knowledge and skill standards for each defined job position or function.
Employees will then be assessed against the standard established for the position and tasks assigned. If it is determined that an employee does not possess the capability to perform a maintenance (including inspection), preventative maintenance, or alteration task, appropriate training will be administered.
Appendix 1 The areas of study, individual courses/lessons, and instructors are developed or qualified in accordance with section 3.
ABC continuously evaluates its overall repair station training needs. However, ABC will specifically revise the training program when:
• It identifies additional training needs, and
• Changes to its ratings, facilities, equipment, or work scope require additional training areas, classes, or lessons.
a. Identification of Training Needs.
ABC may identify additional training needs through:
• The needs assessment outlined in this manual,
• FAA or other external agency oversight findings,
• Investigations that lead to voluntary disclosures,
• Routine or special quality assurance audits,
• Findings from the ABC Internal Evaluation Program (IEP),
• Feedback from employees, and
• The results from audits related to maintenance human factors.
The Director of Training ensures the Training Department regularly reviews the results and reports for additional training needs.
NOTE: The repair station should set forth its method for accomplishing the review and for identifying potential training needs.
b. Changes to Repair Station Work Scope.
Whenever ABC is planning to change its facilities, equipment, or scope of work as reflected in its OpSpecs or capability list, it will conduct a review of its current training program. The need for additional training will be based on an analysis of the new work to be performed, the capability of employees, and the availability of in-house training.
Appropriate changes will be made to initial, recurrent, and specialized training areas of study, including existing courses or the addition of new courses, positions, and individuals requiring the training, and when the new training needs to be implemented and completed.
c. Annual Training Program Review.
An annual review of the training program will verify if ABC has made any changes that might affect training and will analyze the measures of training effectiveness.
As a part of this annual review, ABC will analyze its job position duty and task assignments, its employee experience levels, and the method of delivery for various courses, new training techniques, or commercially available courses. It will make any changes that are required to