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.
Appendix 1 SECTION 6. MEASUREMENT OF TRAINING EFFECTIVENESS The Training Department will regularly evaluate each course for its content, time, quality of the training materials (courseware), training facilities, and instructor. This is accomplished through observation, examination results, and feedback.
The Director of Training will coordinate with the quality department to ensure ABC audits outside training vendors and in-house training courses. The quality manager will ensure the Director of Training is provided the results of these evaluations. The Director of Training will work with the quality manager to resolve any discrepancies.
The Director of Training will ensure the training program is reviewed on an annual basis as described in Section 2, subparagraph 1c.
During the course design, ABC developed a method to evaluate each employee’s performance.
This could include written or oral examinations or manipulative skill tests. The Training Department will analyze the results of all course examinations to determine if any changes are required to establish a basis for determining whether the course met its objectives and provided the information necessary to ensure the employee was capable of performing assigned tasks.
SECTION 7. REVISION PROCESS The process for submitting changes is described in ABC’s RSM.
NOTE: Alternatively, if the repair station wishes this training program to stand on its own, it may describe the method for changing this approved program in this section.
SECTION 8. WORK PERFORMED FOR PARTS 121, 125, 129, AND 135 OPERATORS ABC performs work for parts 121, 125, 129, and 135 operators. Individual operator training requirements (initial, recurrent, or specialized) are identified for each job function. The Director of Training will work with each operator to schedule ABC employees for operator training, as determined during the individual’s needs assessment.
SECTION 9. WORK PERFORMED BY INTERIM MAINTENANCE EMPLOYEES During periods of heavy workload, ABC may supplement its workforce with interim maintenance employees. Before these individuals begin work for ABC, they must undergo a needs assessment. The Training Department must coordinate with the manager of the area where the individuals will work to conduct the needs assessment and ensure all individuals are provided training appropriate to the particular assignment before they are required to begin work.
The Training Department must make and retain training records for all individuals performing maintenance (including inspection), preventative maintenance, and alteration tasks.
Appendix 2 APPENDIX 2. SAMPLE TRAINING PROGRAM FOR A SMALL REPAIR STATION (UNDER 10 EMPLOYEES) THAT PERFORMS WORK SOLELY FOR 14 CFR PART 91 OWNER/OPERATORS
INTRODUCTION This appendix provides an example of a repair station training program for a small repair station (under 10 employees performing maintenance (including inspection), preventative maintenance, or alteration tasks) that performs maintenance for general aviation or business operations under Title 14 of the Code of Federal Regulations (14 CFR) part 91. It anticipates that the repair station will have low employee turnover and that the work being performed is consistent with the experience of the current employees. Each training program, such as the example shown in this appendix, must be approved by the Federal Aviation Administration (FAA) in accordance with 14 CFR part 145, § 145.163.
A repair station is not required to follow this sample for FAA approval. Individual training programs may require additional information. Each program should be tailored to fit the size and complexity of the repair station. This sample program emphasizes the process, procedures, and standards that any repair station could use, and illustrates how all of these processes can be compatible with even a very small repair station. The following sample training program contains notes for areas in which repair stations should provide further information.
SAMPLE TRAINING PROGRAM MANUAL NOTE: The following example is for a very small repair station doing business as “ABC.” ABC has a manager who also serves as the chief inspector and the accountable manager. He also accomplishes basic maintenance work as necessary. In addition, there are two technicians and one support person.
INTRODUCTION TO THE TRAINING PROGRAM This training program document contains the policies and procedures ABC uses to determine its training requirements and develop its FAA-approved training program. ABC is responsible for ensuring each repair station employee performing maintenance (including inspection), preventative maintenance, and alteration is capable of performing assigned tasks. This plan identifies the procedures for ABC to identify an employee’s training needs in a systematic manner, develop training and/or identify appropriate existing training, select the training methods, provide training, and record the training accomplished.
ABC controls this document in accordance with the procedures for document and revision control described in its RSM. A copy of this document and all revisions are provided to ABC’s responsible Flight Standards office.
ABC’s training program consists of the following basic components:
• Assessment of training needs, to identify overall training needs and individual employee training needs;
Appendix 2
• Course definition to define specific courses of study and individual courses;
• Identification of training sources and methods to identify options and select how ABC will provide the training; and
• Documentation of training to ensure all employees’ training is documented, and records are retained.
SECTION 1. BACKGROUND ABC has an established training program that includes indoctrination (initial and recurrent), specialized, and remedial training for employees performing maintenance (including inspection), preventative maintenance, and alteration tasks. The procedures in this manual enable ABC to revise its existing training program to ensure it meets ABC’s needs and produces training consistent with all regulatory requirements.
All of the information pertaining to the current training records is available for review by the Principal Maintenance Inspector (PMI) at ABC’s facilities.
SECTION 2. TRAINING NEEDS ASSESSMENT ABC’s needs assessment is a two-part process that includes determining the overall training requirements as well as individual employee training requirements.
1. Overall Repair Station Needs Assessment.
To determine its overall training requirements, ABC will review the types of work being performed and planned, and identify and update the types of knowledge and skills that the repair station needs. This will include reviewing such items as the ABC operations specifications (OpSpecs); capability list; customer requirements; expected scope of work; and the relevant experience of each technician that will be assigned to perform maintenance, preventative maintenance, or alteration tasks.
This general needs assessment will result in a description of the knowledge and skill an employee must have to properly perform the tasks associated with the work assignment.
The results are recorded in a brief summary report establishing the type and level of training required for an indoctrination to company procedures if there is a new employee, initial training for a new type of equipment ABC will maintain or alter, and an appropriate level of recurrent training for the different responsibilities of the technical and support personnel. These basic training goals are documented in the training program files, but do not require FAA approval.
ABC reviews overall training requirements and the requirements of specific individuals in relation to specific tasks to be performed. ABC will provide training to employees:
• When individual employee knowledge or skill deficiencies are identified; or
• When significant changes are made to its work scope, or such changes are planned such that the knowledge, skills, or experience render the employee unable to perform work properly such as:
Appendix 2
• New regulatory requirements are introduced;
• New tools, equipment, or skills are required to perform the work properly; and
• Work is going to be performed for an air carrier or commercial operator under 14 CFR part 121, 125, 129, or 135.
a. Identification of Capability Deficiencies.
ABC may identify individual capability deficiencies through:
• FAA or other external agency oversight findings, and
• Investigations that lead to voluntary disclosures.
The accountable manager ensures the above programs are regularly reviewed to determine if any training deficiencies exist. The accountable manager will decide on the appropriate training after consulting with all of the technical staff. The accountable manager will also be responsible for ensuring that the work performed by the individual requiring additional training will not affect the quality of ABC’s work until the required training is successfully completed. This can be accomplished through additional supervision or by changing work assignment.
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, the accountable manager must ensure the employees are capable of performing the maintenance (including inspection), preventative maintenance, or alteration tasks or that training needs have been identified and met. For changes to ABC’s capability list, the accountable manager will review the results of the self-evaluation (required by §§ 145.209 and
145.215) and identify if changes in training needs are required.
2. Individual Needs Assessment.
Whenever ABC hires a new employee or transfers an employee to a new task assignment, an assessment of the individual’s skill level and qualifications will be documented. ABC may accept previous employer training records or certifications, use a formal written examination, an on-the-job assessment, or other appropriate means to determine if any training is required to perform the assigned tasks.
Appendix 2 SECTION 3. COURSE DEFINITION The accountable manager (or technical staff delegated by the accountable manager) will outline training requirements for the company and/or for the individual, based on the results of a training needs assessment.
While defining the course or lesson, the following information should be documented, as appropriate:
• Objectives and/or required performance outcome: define the knowledge or skill obtained or to be obtained from the course or lesson.
• Prerequisites: define any knowledge, skill, course, or lesson that needs to be known before the course or lesson can be given.
• Training sources: define any and all training sources available to the repair station for the course or lesson.
• Training methods: define any and all training methods that can be, will be, or were used to impart the information.
• Instructor qualifications: define the knowledge or skill level of the in-house instructor or the qualifications of the instructor that provided the information (if known).
• Other supporting information such as instructor guides, course material, tools, equipment, or any other aid or information provided during the instruction.
Documentation associated with any training accepted or given by the repair station shall be retained in the training program files or in the file of the individual employee assigned to perform maintenance (including inspection), preventative maintenance, or alterations under the repair station’s 14 CFR part 145 repair station certificate. Training will be provided on an initial and recurrent basis as required to ensure all employees performing maintenance (including inspection), preventative maintenance, and alteration tasks are capable of performing assignments.
SECTION 4. TRAINING METHODS AND SOURCES ABC company will use all training sources and methods available to provide employees with the information necessary for them to perform assigned maintenance (including inspection), preventative maintenance, and alterations tasks correctly.
The majority of the training provided by this repair station will use on-the-job training (OJT) methodology. The information required by section 3 will be developed for each lesson to ensure consistency among training providers.
SECTION 5. TRAINING DOCUMENTATION The accountable manager will ensure training records are generated and maintained for all ABC employees that establish each individual is capable of performing the maintenance (including inspection), preventative maintenance, and alteration tasks assigned. The records include FAA certifications, other applicable certifications and degrees, ABC or customer qualifications and
Appendix 2 authorizations, and for each course completed, the total time credited, the date, the instructor, the location, and the results of any associated examination.
All documents showing proof of any of the aforementioned training are maintained for as long as an individual is an ABC employee and for 2 years thereafter.
Any employee may review their training records to verify that they are complete and current. If an employee notes a discrepancy in the training record documentation, that employee will inform the accountable manager of the discrepancy. Any change necessary to update an employee’s training record must be approved by the accountable manager.
SECTION 6. REVISION PROCESS The process for submitting changes to the training program for FAA approval is described in ABC’s RSM.
NOTE: Alternatively, if the repair station wishes this training program to stand on its own, it may describe the method for changing this approved program in this section.
SECTION 7. WORK PERFORMED FOR PARTS 121, 125, 129, AND 135 OPERATORS ABC does not perform work for air carriers or commercial operators under part 121, 125, 129, or
135.
Before ABC would perform maintenance (including inspection), preventative maintenance, or alteration under its 14 CFR part 145 certificate for an air carrier or commercial operator it would conduct a training needs assessment in accordance with Section 2, paragraph 1, to determine if additional capabilities were needed for its employees.
SECTION 8. WORK PERFORMED BY INTERIM MAINTENANCE EMPLOYEES During periods of heavy workload, ABC may supplement its workforce with interim maintenance employees. Before these individuals begin work for ABC, they must undergo a needs assessment. The accountable manager must determine where the individuals will work to conduct the needs assessment and ensure all individuals are provided training appropriate to the particular assignment before they are required to begin work.
Appendix 3 APPENDIX 3. EUROPEAN AVIATION SAFETY AGENCY (EASA) TRAINING
REQUIREMENTS
1. TRAINING PROGRAM REQUIREMENTS UNDER THE U.S./EUROPEAN UNION (EU) AVIATION SAFETY AGREEMENT. Title 14 of the Code of Federal Regulations (14 CFR) part 145 repair stations holding EASA Part-145 approval should include human factors training and fuel tank safety (FTS) training, as applicable, in their FAA-approved repair station training programs.
2. BACKGROUND. On March 24, 2009, the Executive Director of the EASA determined that the human factor training and FTS training program contained in EASA Part-145 is acceptable guidance for repair stations to use as a basis in developing a training program for relevant repair station personnel.
3. HUMAN FACTORS TRAINING AND FTS TRAINING. Personnel at a repair station should know how to interface between maintenance, inspection, quality audit, and maintenance management. This training should center on the scope of work performed by the repair station.
The repair station should ensure the training program is controlled and developed per the FAA Repair Station Manual (RSM)/EASA Supplement.
4. ALTERNATIVES TO FAA-APPROVED TRAINING. Those FAA-approved repair stations holding applicable airframe ratings that want to develop their own FTS training program may do so by referencing EASA Part-145, appendix IV to AMC 145.A.30(e) and 145.B.10(3), Fuel Tank Safety Training.
5. REFERENCES. EASA acceptable means of compliance (AMC) and guidance material regarding human factors training and FTS training are provided in the current edition of EASA Part 145, appendix IV to AMC 145.A.30(e) and 145.B.10(3), which is found on the EASA’s website at https://easa.europa.eu/rulemaking/technical-publications.php. For information regarding the U.S./EU Aviation Safety Agreement, go to https://www.faa.gov/aircraft/repair.