Par 401 Page 11 CHAPTER 4. TRAINING PROGRAM BASIC COMPONENTS
400. GENERAL.
a. An effective training program should contain the following elements.
(1) Needs Assessments. The repair station should have defined processes for objectively identifying its training requirements and assessing each individual’s capabilities.
(2) Area of Study and Course Definition. The training program should include the procedures used to design each area of study, and/or individual classes or lessons. This includes defining the specific purpose and objectives of a given area, any prerequisites, any required lessons, any time requirements, and the desired outcome—gained technical skill or knowledge.
The individual courses associated with a particular area of study should include a detailed description of the technical information or skill that will be taught, along with the referenced material, tools, equipment, or procedures that will be used, the methods and sources of training available, instructor qualifications, and method of recording employee accomplishment.
(3) Identification of Training Sources and Methods. The repair station should have a method to identify and select the sources and methods of training that will meet the regulations and its training objectives.
(4) Measurement of Effectiveness. To avoid the potential of assigning an unqualified person to maintenance or alteration tasks, the training program may include a process to continually measure the effectiveness of the overall training program and individual training courses.
(5) Training Documentation. The repair station must have procedures to document each individual’s training to ensure compliance with 14 CFR part 145, § 145.163. This includes defining the extent of training records and establishing a system for creating, accessing, and retaining training records for 2 years after the training is provided.
(6) Interfaces. The repair station should include a description of how its training program interacts with other repair station functions, particularly how the capabilities of employees are assessed prior to being assigned maintenance (including inspection), preventative maintenance, and alteration tasks.
b. Each repair station’s procedures addressing the suggested elements will vary in terms of complexity and scope to fit the repair station’s requirements. Ultimately, the training program must ensure each employee performing maintenance (including inspection), preventative maintenance, or alteration duties is capable of performing assigned tasks.
401. NEEDS ASSESSMENTS. The repair station’s needs-assessment procedures enable the repair station to identify its training requirements based on job positions, duties, and tasks. It also establishes an objective method for determining training standards, assessing the capability of its employees, and establishing training programs for its employees to fill the gap between position/duty/skill/task requirements and employee capabilities. Procedures associated with the repair station’s needs assessment will be based on its size; employee hiring; assignment and
Par 401 Page 12 training practices; customer base; and the complexity of its ratings and scope of operations. The repair station should establish the basic standard that identifies the individual employee’s training needs by assessing the job function and duties against the employee’s specific skills and knowledge. Training areas, programs, and lessons can then be assigned to fill any gaps between the skills and knowledge needed for the job tasks and the employee’s capabilities.
a. Repair Station Needs Assessment.
(1) The program description should include the processes the repair station will use to identify its training requirements for ensuring each individual assigned to perform maintenance (including inspection), preventative maintenance, and alterations tasks is capable of performing the job properly. If you are a single employee repair station, you must evaluate your capabilities and determine that your current training is adequate or if additional training is necessary to perform the task for which you are rated. The training needs assessment is a method of analyzing the job tasks associated with repair station’s maintenance and alteration positions. This entails identifying the knowledge and skills required to successfully fill positions that perform maintenance and alteration tasks. In addition, when determining its training requirements, a repair station should analyze the nature of its business structure and its customers.
(2) When identifying overall training needs, the repair station should consider:
(a) The tasks associated with each position responsible for performing maintenance, preventative maintenance, or alteration.
(b) The skills, experience, and training of new and current employees.
(c) How assessments will be made of employees being assigned new tasks.
(d) The return of an employee to tasks after an extended period.
(e) The introduction of new regulations, procedures, equipment, or recordkeeping requirements.
(f) Preparing for a change in the nature of basic repair station capability.
(3) The needs assessment reviews the repair station’s training requirements in the context of its existing staff’s capability and tasks associated with specific work assignments.
Based on the outcome of its training needs assessment, the repair station can develop and revise its areas of study and/or courses. The training needs assessment should identify the requirements for initial and recurrent training. Based on its needs assessment, the repair station will determine the type and extent of training needs for the company and for individual employees.
b. Employee Needs Assessment.
(1) The repair station’s procedure should evaluate the current capability of its employees, technical and nontechnical. Only those performing maintenance, preventative maintenance, or alteration tasks must be trained under part 145; however, the repair station may wish to include employees that support or manage technical personnel. The training program
Par 401 Page 13 should differentiate between those employees required to be trained under the program and those that will be trained in accordance with the procedures at the repair station’s discretion. Once a technical employee’s capabilities have been assessed, employee specific training needs will be identified. If you are a single employee repair station, you must evaluate your capabilities and determine that your current training is adequate or if additional training is necessary to perform the task for which you are rated. Your training accomplishments or certifications should be contained in a training record. The basis of your program would show how you intend to remain current and how you will receive initial and recurrent training in accordance with part 145, § 145.163(a). These procedures should be documented and form the basis of your specific training program. The FAA recognizes that training programs may vary depending on the size of the repair station, its capabilities, and the experience of its employee(s). A portion or all of the training requirements of part 145, § 145.163 may be met by attending trade or technical society seminars and through OJT. Some of the methods available to evaluate employee capability are listed in the following table.
TABLE 4-1. CAPABILITIES EVALUATION Method for Evaluation Capability Usefulness of Method Formal examination This may include development of formal written test procedures with pass/fail criteria. While it is an effective method for assessing knowledge, it does not necessarily determine whether an individual can apply the knowledge to the assigned tasks.
Certificate Possessing a certificate may be a prerequisite for some specialized positions, the certification of qualifications or education from a credible source can measure an individual’s knowledge. However, it does not necessarily assess the individual’s ability to apply that knowledge to assigned tasks.
Completion of a training course A review of the documentation or instruction provided can be used to establish an individual’s knowledge of a subject. Completion of training courses is most useful when there is some verification, through testing or demonstration, that the individual absorbed the course objectives. However, successful completion of a training course does not necessarily translate into the ability to accomplish a task.
Practical evaluation A practical evaluation permits the employee to demonstrate skills in a controlled environment that is similar to a situation, or part of a situation, encountered in real life. For example, such an evaluation might allow the reviewer to focus on the critical steps in a time-consuming process without actually going through the entire process. This can be an effective way to determine an individual’s capability; however, the assessment can depend on the skills of the individual designing the practical evaluation mechanism.
Par 401 Page 14 Method for Evaluation Capability Usefulness of Method Group exercise A properly designed group exercise can help demonstrate the understanding of a group that must work together on a project.
Where an employee’s understanding of his or her role in a larger scheme is important, a group exercise that tests that knowledge in an appropriate context can illuminate who within the group needs assistance and can illuminate human factors elements of the training issue that might be otherwise misunderstood by the students. It can also do so in a manner that lends itself well to immediate remedial training as well as reinforcement of the training given the other members of the group, where properly administered.
On-the-job assessment These types of assessments should be objectively based and judged by successful accomplishment of specified tasks. This is an effective way to determine an individual’s capability; however, the assessment can depend on the skills of the individual accomplishing the assessment unless objective criteria are established.
Oral examination in the working environment These types of assessments should be objectively based and judged by the proper response to a consistent set of questions. This is an effective way to assess an individual’s knowledge and ability to apply that knowledge. It is also a valid method of determining whether an inspector or supervisor is capable of reading, writing, and understanding the English language. However, it can depend on the skills of the individual conducting the examination unless objective criteria are established.
NOTE: This is a sample list of tools for assessing training success and should not be considered exhaustive. Unique instructional and teaching methods, for example, often give rise to unique evaluation mechanisms. The FAA encourages the use of novel techniques for conducting effective evaluations.
(2) When carrying out any assessment of an individual’s capabilities, the repair station’s process should be as objective as possible and structured to produce consistent results.
The repair station should establish the basic skill level and qualifications for assigned tasks under the job function or position, and then establish objective methods for comparing an individual’s capability to those established skill standards. It may be necessary for the repair station to use more than one method to adequately assess an individual’s capability. The repair station should also have procedures to accept prior experience, training, or education to establish an individual’s capability. For example, a repair station may accept graduation certificates from a part 147 school and/or an A&P certification as acceptable evidence of a basic knowledge and
Par 403 Page 15 skill level in a particular area. A repair station could also have procedures for accepting certificates from previous training by manufacturers or associations, or documented by military records. The repair station should have procedures to:
• Ensure the assessments are objectively based and consistent;
• Ensure the assessment is documented in the individual’s training records;
• Ensure the individual conducting the assessment is qualified to evaluate the results of the assessment; and
• Monitor the individual to ensure capability of performing the tasks consistently at an acceptable level and assigning recurrent or remedial training as necessary.
402. AREA OF STUDY AND COURSE DEFINITION. Once the repair station identifies its training requirements, including the type of training each individual needs, it can define the areas of study it needs, what subjects should be included in each area or what individual course/lesson it is going to make available, and what level of treatment is appropriate, such as introductory or advanced, initial, or recurrent for each course. The development will take into account the needs assessment of the job tasks and the level of experience of the individuals to be trained.
a. The repair station can develop its own areas of study or provide acceptable courses or lessons to its employees. If the repair station chooses to develop areas of study, each area should include objectives, desired outcome, and a list of available courses/lessons.
b. Each course or lesson under an area of study should include, as appropriate, the following:
(1) The prerequisites or minimum student qualifications prescribed by the regulations or required by the repair station for enrollment in the course, for example, the type of airman certificate; aircraft; product and/or article qualifications; previous training; experience with other operators; and recency-of-experience requirements.
(2) Instructional aids and course materials such as manuals, tooling, and equipment.
(3) The training methods, sources, and qualified instructors.
(4) A course outline. The outline should identify any individual lesson or modules.
(5) Anticipated time of instruction for completion, and/or the knowledge or skill requirements that must be demonstrated to obtain credit for the course/lesson.
(6) Training forms and records to be used for recording student progress and/or completion.
(7) Supporting information such as courseware, lesson plans, and instructor guides.
403. IDENTIFYING THE TRAINING METHOD.
a. Once the repair station defines its areas of study and individual courses/lessons, it can identify the methods available to deliver the training. There are many methods available to repair
Par 403 Page 16 stations for the development and delivery of training. Most repair station training requirements may be accomplished through existing courses conducted in-house, offered by local schools and colleges, or provided by manufacturers or other organizations. To control costs, repair stations could share the costs of in-house training with other similarly situated repair stations. These repair stations may also want to function as a training entity or work with an AMTS to develop courses. AMTSs and repair stations may enter into reciprocal agreements.
b. The following is a brief overview of the different training delivery methods currently available:
(1) Formal Classroom Instruction. Training can be provided as a formal course delivered by an instructor in a classroom setting. To ensure the effectiveness of this method of training, the courses should include: an objective; a course outline defining the subjects, topics, and expected outcome; a list of reference and/or course material used; the qualifications of the instructor; and a summary of the knowledge or skill that is to be obtained and the method used to ensure it was absorbed by the employee. The interaction of employees with their instructor is important for the information to be successfully transferred.
(2) On-the-Job Training (OJT). OJT is knowledge obtained while participating in accomplishing the task under the direction of a qualified person or watching another demonstrate a task or activity and then accomplishing the same action under supervision until satisfactory results are obtained. It is an effective method of training for subject matter and tasks that are difficult to understand if described or for which demonstration of capability is essential to correct completion. Practical skills may also be taught using OJT. To make this method of training most effective, the process for providing the information should be standardized by using, for a particular task, the approved data from the article’s maintenance manual, and the referenced tools and/or equipment. The process should document that the employee demonstrated the ability to accomplish the skill or task properly on the requisite OJT record. The same process can then be used to train other employees to the same task, activity, or skill. Even with a very capable instructor, the repair station should ensure any OJT is well structured by establishing that the same key elements are included each time.
(3) Computer-Based Training (CBT). Interactive CBT courses can be used to impart knowledge and teach practical skills at the correct pace for each employee. CBT can be accomplished at any location, at times that are convenient for each employee. To ensure the effectiveness of this type of training, the repair station should evaluate the information provided against its particular needs.
(4) Distance Learning. Distance learning applies to situations where the instructor and the employees are not in the same location. It can take the form of mail-based correspondence courses using written, videotaped, or CBT materials; videoconferencing, teleconferencing, or a combination of both–sometimes called “virtual” classrooms; or Internet- or intranet-based instruction that allows employees to interact with an instructor or with courseware similar to CBT. The advantage of this training method is that the courses can be tailored to a specific repair station’s need and an instructor can respond to individual questions.
The disadvantages are that the communications can be misinterpreted because of technical difficulties, and the interaction of an employee may be inhibited.
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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. TRAINING SOURCES.
a. There 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 Required Inspection Items (RII) and operator’s program training to specified repair station employees. 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. Regardless of the source of the 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:
• Appropriate 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.
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b. The repair station’s process to measure the effectiveness of training should be linked to the process for defining and updating training requirements.
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, RII personnel, and persons approving articles for return to service must be certificated under part 65).
(4) Other certifications, diplomas, and degrees.
(5) Authorizations and qualifications (if not covered by part 65 certificates).
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(6) Proof of training course completion, if determined applicable to capabilities.
(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 employee 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. Title 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 repair 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.
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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.
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 501 Page 22 CHAPTER 5. ADMINISTRATIVE INFORMATION
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.
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. See the FAA’s public website at https://www.faa.gov/.
501. REQUESTS FOR INFORMATION. For information concerning this AC, contact the General Aviation and Repair Station Branch at (202) 267-1675. Submit direct comments regarding this AC to:
U.S. Department of Transportation Federal Aviation Administration Aircraft Maintenance Division 800 Independence Avenue SW.
Washington, DC 20591