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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
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 part 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 responsible Flight Standards office. 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
Appendix 1 ensure employees are capable of performing assigned tasks in accordance with the procedures set forth in their manual.
NOTE: The repair station should set forth its method of documenting the annual review and for ensuring any changes to the training program are accomplished.
2. Individual Needs Assessment.
ABC has established skill levels and qualifications for each job position based upon technical functions and tasks. In addition, ABC has developed methods to evaluate an individual to determine what knowledge, experience, or training establishes capability to properly perform the work.
Whenever ABC hires a new employee or transfers an employee to a new job position, the employee’s new supervisor will assess the individual’s skill level and qualifications against the requirements for the assigned functions or tasks. The supervisor and the Training Department determine what training is necessary and ensure the individual’s training record is updated to reflect the assessment and training requirements. The supervisor will also work with the Training Department to ensure the individual receives the necessary training in the appropriate timeframe.
SECTION 3. COURSE DEFINITION The Training Department will develop and revise areas of study, courses, and/or lessons based on the results of a training needs assessment.
1. An area of study will be developed to identify the entire scope of training available for a broad area of knowledge and skill requirements. It will include the appropriate number and level of courses or lessons to accomplish the defined objective. The areas of study will define the initial and recurrent requirements for the associated courses and lessons.
Initial training will be provided to an employee for the first time.
Recurrent training will be information that supports, expands, or refreshes initial training areas of study, courses/lessons, or other requirements.
Remedial training will be assigned to ensure an employee who lacks demonstrated knowledge and has been provided the information necessary to accomplish assigned maintenance or alteration tasks properly.
a. Total required course of study hours or performance outcome.
b. Staffing category.
c. Job function.
2. All courses/lessons shall be recorded by developing the following information as necessary to capture the required knowledge or skill:
Appendix 1
• Course/lesson title;
• Objectives;
• Prerequisites;
• Course outline;
• Required hours or performance outcome for each topic or lesson;
• Training material including handouts, regulations, manuals, tools, or equipment used;
• Training source(s);
• Training method(s);
• Instructor(s);
• Instructor qualifications;
• Method(s) of evaluation; and
• Other supporting information, as available such as instructor guides and courseware.
The information required by this section shall be developed for all areas of study and/or courses/lessons made available to employees. This includes training provided by the on-the-job methodology.
The information on courses and lessons from outside sources will be evaluated to ensure the availability of enough information to determine its capability to impart the information required by the repair station’s needs assessment for the company or for the particular employee.
SECTION 4. SELECTION OF TRAINING METHODS AND SOURCES Using the information developed during the course definition phase, ABC will evaluate training method(s), source(s), and instructor(s) to determine whether the appropriate and necessary knowledge or skill will be transferred to employees.
1. Training Methods.
The material to be presented, the level of personnel receiving the training, and alternatives available will be used to establish training methods for areas of study and/or courses/lessons.
ABC uses various methods to train its employees including:
• Formal classroom training;
• On-the-job training (OJT);
• Self-study;
• Case study;
• Computer-based training (CBT);
• Distance learning;
• Embedded training; and
• External classes and courses.
The company will use all available resources to provide the appropriate training. Many areas of study, courses, and lessons will be provided by more than one method. All methods will have a documented method of determining the amount of information that must be exchanged.
Generally, this will be accomplished by completing the information required by Section 3 of this
Appendix 1 training manual. However, the validity of any particular method can be established by an evaluation of the employee’s capabilities.
2. Training Sources.
Sources available for training will be continually monitored to ensure ABC is aware of its alternatives. When a new or revised training need is identified, the available options will be reviewed. This process may include consultation with the FAA principal inspector (PI), other repair stations, manufacturers, and local colleges for available training.
If the training will be conducted by an outside vendor, an audit will be conducted to ensure it provides appropriate information. The audit may include an observation of training, a review of course outlines and materials, contact with previous training customers, and a review of instructor qualifications and experience. The extent of the audit will be based on an informal risk assessment related to the criticality of the training and the ability of the repair station to assess the information imparted.
NOTE: The repair station should set forth its method of tracking audits.
3. Training Instructors.
Instructors shall be qualified based upon subject matter knowledge and teaching ability. Subject matter expertise may be established by experience, demonstrated knowledge, and/or certification. The ability to impart information can be determined by observation, demonstration, or experience. The evaluation of in-house instructors shall be documented in the course description.
SECTION 5. TRAINING DOCUMENTATION The Director of Training is responsible for establishing the standards for the creation and retention of training records for all ABC employees that perform maintenance (including inspection), preventative maintenance, and alteration tasks. The company maintains an electronic summary of all training provided. Each electronic report includes the employee’s name and job function; the needs assessment findings; a list of FAA certifications; other applicable certifications and degrees; ABC qualifications and authorizations (such as Required Inspection Items (RII) for a given customer); and for each course completed, the total time credited; the date provided; the instructor; the location; and the results of any associated examination. ABC will make the training records of employees performing maintenance (including inspection), preventative maintenance, and alteration tasks available to the FAA for review upon request.
The company maintains the individual training records for as long as an employee is employed at ABC and for 2 years thereafter.