AC 145-10

U.S.

Department of Transportation Federal Aviation Administration Advisory Circular Subject: Repair Station Training Program Date: 7/5/12 AC No: 145-10 Initiated by: AFS-300 Change: 1

1. PURPOSE. This advisory circular (AC) provides information on developing the repair station employee training program required under Title 14 of the Code of Federal Regulations (14 CFR) part 145, § 145.163; categories of training; training program components; and sample training programs. This AC also provides an acceptable means, but not the only means, of showing compliance with § 145.163.

2. PRINCIPAL CHANGES. This change inserts a new Appendix 3, European Aviation Safety Agency Training Requirements, and a new Appendix 4, Related Correspondence.

PAGE CONTROL CHART Remove Pages Dated Insert Pages Dated Appendix 3 (pgs. 1 and 2) 7/8/05 Appendix 3 (pgs. 1 and 2) 7/5/12 Appendix 4 (pgs. 1 and 2) 7/5/12 ORIGINAL SIGNED by /s/ Raymond Towles for John M. Allen Director, Flight Standards Service

U .S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Repair Station Training Programs Date: 7/8/05 AC No: 145-10 Initiated by: AFS-300 Change: 1

PREFACE This advisory circular (AC) provides information on developing the repair station employee training program required under Title 14 of the Code of Federal Regulations (14 CFR) part 145, § 145.163, categories of training, training program components, and sample training programs.

This AC also provides an acceptable means, but not the only means, of showing compliance with 14 CFR part 145, § 145.163. Neither of the sample programs described in Appendices 1 and 2 of this AC need to be used; they only represent a possible way to structure a training program that meets the requirements of the regulations. Each person subject to 14 CFR part 145 should develop his/her own program tailored to his/her individual operations. Because this AC contains only guidance on developing a training program, the word “should” used herein applies only to an entity that chooses to follow a particular suggestion without deviation. The Federal Aviation Administration (FAA) uses the word “capability” to describe the knowledge and skills required to properly accomplish assigned tasks. The word “competency” is used by the European Aviation Safety Agency (EASA) and many repair stations located outside the United States.

These terms should be considered synonymous for the purposes of the training program and as used in this AC. This AC contains additional governmental, mandatory, and nonmandatory subjects not specifically required by 14 CFR part 145, § 145.163. The FAA is aware that the additional training outlined in this AC exceeds that required by 14 CFR part 145, § 145.163, but feel it is necessary to provide these subject samples as a guide for a complete and comprehensive safety directed program. If the repair station chooses to develop a training program with the additional nonregulatory subjects, only those required by regulation would be subject to FAA approval. One means of developing this type of program could include a separation of the regulatory and nonregulatory training subjects within the training manual.

CONTENTS Paragraph Page

CHAPTER 1. INTRODUCTION1

100. PURPOSE1

CHAPTER 2. BACKGROUND ON REPAIR STATION TRAINING3

200. GENERAL3

201. REGULATORY REQUIREMENTS4

202. MANUAL REQUIREMENTS4

203. PROGRAM SCOPE AND COMPLEXITY4

TA BLE 2 -1. EXAMPLE REPAIR STATION CATEGORIES5

CHAPTER 3. CATEGORIES OF TRAINING AND COURSES OF STUDY7

300. GENERAL7

301. INDOCTRINATION (INITIAL AND RECURRENT) TRAINING7

302. TECHNICAL TRAINING8

303. RECURRENT TRAINING10

304. SPECIALIZED TRAINING10

305. REMEDIAL TRAINING11

CHAPTER 4. TRAINING PROGRAM BASIC COMPONENTS13

400. GENERAL13

401. NEEDS ASSESSMENTS13

TA BLE 4 -1. CAPABILITIES EVALUATION15

402. AREA OF STUDY AND COURSE DEFINITION17

403. IDENTIFYING THE TRAINING METHOD17

404. TRAINING SOURCES19

405. QUALIFYING INSTRUCTORS20

406. MEASURING TRAINING EFFECTIVENESS20

407. TRAINING DOCUMENTATION21

408. INTERFACES WITH THE TRAINING PROGRAM22

409. SPECIAL CONSIDERATIONS FOR REPAIR STATIONS LOCATED OUTSIDE

THE UNITED STATES22

CHAPTER 5. ADMINISTRATIVE INFORMATION25

500. HOW TO OBTAIN COPIES OF PUBLICATIONS REFERRED TO IN THIS AC25

501. REQUESTS FOR INFORMATION25

AP PENDIX 1. SAMPLE TRAINING PROGRAM F OR A LARGE/MEDIUM

REPAIR STATION (8 pages)1

APPENDIX 2. SAMPLE TRAINING PROGRAM For A SMALL REPAIR STATION ( UNDER 10 EMPLOYEES) THAT PERFORMS WORK SOLELY FOR

14 CFR PART 91 OWNER/OPERATORS (5 pages)1

APPENDIX 3. EUROPEAN AVIATION SAFETY AGENCY (EASA) TRAINING REQ

UIREMENTS (1 page)1

APPENDIX 4. RELATED CORRESPONDENCE (1 page)1

Par 100 Page 1 CHAPTER 1. INTRODUCTION

100. PURPOSE.

a. This AC provides information on developing the repair station employee training program required under 14 CFR part 145, § 145.163, categories of training, training program components, and sample training programs.

b. This AC provides an acceptable means, but not the only means, of showing compliance with 14 CFR part 145, § 145.163. Neither of the sample programs described in Appendices 1 and 2 of this AC need to be used; they represent only a possible way to structure a training program that meets the requirements of the regulations. Each person subject to 14 CFR part 145 should develop his or her own program tailored to individual operations. Because this AC contains only guidance on developing a training program, the word “should” used herein applies only to an entity that chooses to follow a particular suggestion without deviation.

c. The FAA uses the word “capability” to describe the knowledge and skills required to properly accomplish assigned tasks. The word “competency” is used by the European Aviation Safety Agency (EASA) and many repair stations located outside the United States. These terms should be considered synonymous for the purposes of the training program and as used in this AC.

d. Entities wishing to become certificated under 14 CFR part 145, and those 14 CFR part 145 repair stations certificated prior to April 6, 2006, whether located within or outside the United States, should use this AC to develop the training program required by 14 CFR part 145.

Par 200 Page 2 CHAPTER 2. BACKGROUND ON REPAIR STATION TRAINING

200. GENERAL.

a. Beginning April 6, 2006, persons applying for a repair station certificate under 14 CFR part 145 must submit a training program for FAA approval. Additionally, repair stations that were certificated prior to April 6, 2006, must submit a training program for approval by the last day of the month in which their 14 CFR part 145 certificate was originally issued. The program must ensure that individuals performing maintenance (including inspections), preventative maintenance, inspections, and alterations under the repair station certificate are capable of performing assigned tasks.

b. Though prior to the August 2001 rule change (No. 145-27, Repair Stations; Final Rule with Request for Comments and Direct Final Rule with Request for Comments (66 FR 41087, August 6, 2001)), 14 CFR part 145 did not include a specific requirement for a training program, the repair station needed to ensure persons were competent to perform assigned tasks. Only those repair stations performing maintenance or preventative maintenance functions for a 14 CFR part 121 or 135 certificate holder were required to have a training program to ensure each person who determines the adequacy of the work performed is fully informed about the procedures, techniques, and new equipment in use and is able to perform all associated duties.

c. Mechanics may acquire their initial skill through formal training, such as 14 CFR part 147 Aviation Maintenance Technician Schools (AMTS) or hands-on experience working under FAA-certificated Airframe and Powerplant (A&P) mechanics or in the military. Once an individual obtains a certificate, acquired experience can vary substantially, as well as the type or level of training. Therefore, repair stations need proper initial and recurrent training to ensure persons are capable of performing assigned tasks, even when the majority of the workforce may be certificated under 14 CFR part 65.

d. There are numerous categories of personnel employed by 14 CFR part 145 repair stations, with a variety of specialties. Hiring practices vary widely among repair stations with some employees having direct relevant experience, certification, and training, while others do not. There are maintenance personnel who work for temporary placement organizations, which permit repair stations to meet peak workload demands. Therefore, all employees that are assigned tasks to perform maintenance (including inspection), preventive maintenance, or alteration must be included in the training program to ensure they are capable of performing the specific assigned tasks of the particular repair station.

e. Title 14 CFR part 145, § 145.163, promulgated in August 2001 under amendment No. 145-27, requires each repair station to establish a training program for employees who perform maintenance (including inspection), preventative maintenance, or alteration under the authority of the repair station’s certificate. This training program will enhance aviation safety by ensuring each maintenance employee is fully capable of performing assigned tasks. The FAA understands that repair stations vary in size; therefore, it expects each repair station to have a training program appropriate to its organization and the work it performs.

Par 203 Page 3

f. The FAA notes that some 14 CFR part 145 repair stations have EASA certifications.

EASA Part-145 contains licensing and training requirements for Approved Maintenance Organizations (AMO) that perform maintenance on articles of those operators under the regulatory control of European Union (EU) Member States. These EASA Part-145 requirements can affect FAA part 145-approved repair stations that also have EASA approvals since EASA requires maintenance human factors training as part of the Bilateral Aviation Safety Agreement (BASA) and Maintenance Implementation Procedures (MIP) with the United States. The FAA training program may include the requirements of other civil aviation authorities (CAA) as long as the 14 CFR part 145 requirements are also met.

201. REGULATORY REQUIREMENTS. Beginning April 6, 2006, 14 CFR part 145 requires an applicant for certification and current FAA-certificated repair stations to submit a training program to the FAA for approval. The employee training program approved by the FAA must include initial and recurrent training requirements. The training program must ensure each employee assigned to a maintenance (including inspection), preventative maintenance, and alteration task is capable of performing the work. Upon training program approval by the FAA, the repair station will begin following its approved procedures. If a repair station accomplishes work for a 14 CFR part 121, 125, 129, or 135 operator, its program must ensure any employee assigned to tasks for these referenced operators are trained in accordance with that operator’s requirements.

202. MANUAL REQUIREMENTS. The training program may be documented in the Repair Station Manual (RSM), or it may be in a separate manual. If the training program becomes part of the RSM, these procedures should distinguish between handling revisions to the approved training manual section from handling those revisions associated with the non-approved repair station manual. The procedures should also include how submitting revisions to the responsible Flight Standards office will be handled for the different types of manuals. If the training program is contained in a separate manual, that document may include the revision and notification provisions required by 14 CFR part 145, § 145.209(e).

203. PROGRAM SCOPE AND COMPLEXITY.

a. The purpose of the repair station’s initial and recurrent training program is to ensure repair station employees performing maintenance (including inspection); preventative maintenance and alteration are capable of performing assigned tasks as required by 14 CFR, part 145, § 145.163.

b. Each repair station’s training program must be based on its individual operation and needs. When developing its training program, each repair station should consider its size, ratings, maintenance tasks associated with positions, and its employees’ experience and skill levels.

c. Each individual employed by a repair station should have training based on the tasks associated with the person’s job position. Therefore, each repair station should develop procedures for determining the training each employee requires. Also, not all repair station employees require the same level of training. To facilitate the development of the training requirements and courses of study, each repair station may wish to separate its staff into categories. Those persons that perform maintenance (including inspection), preventative

Par 203 Page 4 maintenance, or alteration tasks must be trained under the provisions of the approved training program required by 14 CFR part 145. Other employees may be trained under the 14 CFR part 145 training program, but their training should not be considered mandatory under the regulations. The following table shows two examples of types of categories a repair station might use:

TABLE 2-1. EXAMPLE REPAIR STATION CATEGORIES Type of Repair Station Example of Staffing Categories Small to medium (1) Technicians and inspectors that perform maintenance, preventative maintenance, and alteration duties (including inspection).

(2) Supervisors that perform maintenance, preventative maintenance, and alteration duties (including inspection).

(3) Managers and support staff that perform maintenance, preventative maintenance, and alteration duties (including inspection).

Larger (1) Technical personnel conducting maintenance, preventative maintenance, and alteration duties (including inspection) with authority for approval for return to service.

(2) Technical personnel conducting maintenance, preventative maintenance, and alteration duties (including inspection) without authority for approval for return to service.

(3) Inspection personnel.

(4) Supervisor personnel that perform maintenance, preventative maintenance, or alteration functions and duties.

d. Each repair station’s training program should address:

(1) Indoctrination (initial and recurrent) training for new and existing employees covering the regulations and the repair station’s operations, policies, and procedures (see paragraph 301);

(2) Initial technical requirements for new and existing employees taking on new tasks to ensure appropriate technical skills training is provided (see paragraph 302);

(3) Recurrent technical training for specific tasks or functions to ensure currency in existing or added capabilities (see paragraph 303);

(4) Specialized technical training or advanced training requirements for specific tasks or functions to ensure all employees accomplishing maintenance remain capable of performing assigned tasks (see paragraph 304); and

(5) Remedial technical training requirements to correct demonstrated lack of skill or knowledge deficiencies (see paragraph 305).

Par 203 Page 5

e. Each repair station’s training program will vary in the number of courses, content, time requirements, training methods, and sources. One repair station may have separate indoctrination courses for technicians, inspectors, managers, and supervisors. Another repair station may have only one indoctrination course appropriate for all of its employees, including temporary personnel.

f. Consistent with its evolving systems safety certification and surveillance process, the FAA may ask the following questions to establish whether the training program meets the requirement for ensuring each employee performing maintenance, preventative maintenance, and/or alteration tasks is being trained or is capable of performing the assignment:

(1) Is there clear responsibility and authority? Did the repair station clearly identify the job title responsible for the different aspects of the training program? Did the repair station identify the job title with the authority to propose changes to the approved training manual?

(2) Are there written procedures? Are the repair station’s training program policies and procedures written in its training manual or program document?

(3) Is there a measurement of effectiveness? Is there a method of determining whether the employee is capable of performing assigned tasks?

(4) Are there controls in place? Does the repair station have adequate procedural controls to ensure that all applicable elements of the training program are carried out in specific situations?

(5) Does the repair station identify and describe the interface between the training program and the individuals responsible for task assignments?

(6) Are there written procedures that require the repair station to maintain personnel training records for 2 years?

(7) Is the manual identified with applicable contact information such as company name, address, certificate number, telephone, fax, email, etc.?

(8) Does the control system include a distribution list identifying a particular manual to a person or location?

(9) Does the manual contain an adequate revision system to allow an easy determination of currency?

(10) Is there a procedure for submitting revisions to the responsible Flight Standards office for approval?

(11) Does the training program have provisions for initial and recurrent training?

(12) Are individual training requirements identified and documented?

Par 301 Page 6 CHAPTER 3. CATEGORIES OF TRAINING AND COURSES OF STUDY

300. GENERAL. As previously mentioned, a repair station may divide its initial and recurrent training into the following areas of study for each category of employee:

a. Initial, including:

• Indoctrination,

• Technical training, and

• Specialized technical training.

b. Recurrent.

c. Remedial, based on demonstrated need.

301. INDOCTRINATION (INITIAL AND RECURRENT) TRAINING.

a. This is core training for all repair station personnel. The scope and depth of indoctrination training may vary based on the individual’s assigned position. The repair station should determine the level of indoctrination training required for each job assignment, through its training needs assessment process described in paragraph 401.

b. The following subjects should be addressed in the training program, regardless of the repair station’s size or ratings:

(1) CFR requirements, particularly those associated with the repair station maintenance functions and authority as reflected on the certificate and operations specifications (OpSpecs).

(2) Company manuals, policies, procedures, and practices, including quality control (QC) processes, particularly those associated with ensuring compliance with maintenance (including inspection), preventative maintenance, and alteration procedures established to show compliance with 14 CFR part 145.

(3) Department of Transportation (DOT) hazardous material (HAZMAT) requirements, general Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and other local, State, and Federal laws requiring training for different categories of employees.

NOTE: Do not confuse employee HAZMAT familiarization and training with the regulatory requirement of DOT Title 49 of the Code of Federal Regulations (49 CFR) part 171, § 171.8 “HAZMAT employee/HAZMAT employer” training standards, which requires mandatory HAZMAT training for those personnel engaged in the shipping of hazardous materials.

(4) Maintenance human factors (if required). The FAA concurs with European authorities in that human factors training related to maintenance practices would provide an additional margin of safety to the repair industry. A human factors training program should be

Par 302 Page 7 related to maintenance practices where possible. The following are suggested human factors elements that may be included in a repair station training program:

• General/introduction to human factors,

• Statistics,

• Safety culture/organizational factors,

• Human error,

• Types of errors in maintenance task,

• Human reliability,

• Human performance and limitation,

• Vision,

• Hearing,

• Stress,

• Situational awareness (SA), and

• Workload management.

NOTE: Training in maintenance human factors may be required by a Bilateral Aviation Maintenance Agreement (BAMA). The repair station’s submitted training program and any revision thereto may include human factors elements. The human factors training procedures defined in the training program should be related to aviation maintenance, safety-related issues, existing legislation, where relevant, and/or some of the suggested elements below.

(5) Computer systems and software, as applicable to the repair station’s maintenance (including inspection), preventative maintenance, and alteration systems and procedures.

(6) Facility security.

NOTE: Some of the subjects listed above do not fall under the direct purview of the FAA or the Flight Standards Service (FS); however, the FAA recognizes that companies desire to have one training program for all employees. Repair stations are encouraged to distinguish between training required to comply with 14 CFR part 145 and other training that will be provided to employees in its training manual or program procedures.

302. TECHNICAL TRAINING.

a. The repair station’s technical training areas of study may be separate and distinct from indoctrination training and may apply to different categories of employees within a given job position. Technical training requirements should focus on providing employees with the appropriate skill or task training required to properly perform job position assignments.

b. The repair station should have procedures to determine the applicable scope and depth of initial and/or recurrent training based on each job assignment and each employee’s experience and capability established by the needs assessment (see paragraph 401). The needs

Par 302 Page 8 assessment is the basis for determining an individual’s initial and recurrent training requirements.

c. When developing the initial or recurrent training courses, the repair station may want to take into account that individuals will not have the same training, experience, and skill level.

For example, when developing its initial course of study for technicians, a repair station may want to have separate programs for:

(1) Individuals that hold an A&P certificate.

(2) Individuals with experience performing similar tasks at another repair station.

(3) Individuals with applicable military aviation maintenance experience.

(4) Individuals with no skills, experience, or knowledge.

d. A repair station may have more than one training course for its employees. For example, initial training for new repair station technicians with limited repair station experience may include the following in-depth courses:

(1) Maintenance human factors.

(2) Tools.

(3) Test equipment, including ground support equipment.

(4) Materials and parts.

(5) Records and recordkeeping.

(6) Specific HAZMAT, OSHA, and EPA requirements.

(7) Shop safety.

(8) Specific job or task training.

e. In contrast, initial training for new technicians with prior repair station experience may include a general review of the same subjects as necessary and detailed technical training only for specific job or task assignments. In all events, an individual’s specific training requirements should be established based on a needs assessment.

f. Additionally, whenever new information is introduced on the topics, the initial training requirements for new employees should be updated and existing employees should be provided abbreviated initial training on the new information. Alternatively, the additional information may be imparted to existing employees through the recurrent training requirements.

g. The time devoted to initial or recurrent training can vary depending on the level of experience of the individual and the skills and knowledge associated with the assigned job or tasks. However, the repair station should establish a basic minimum standard for all employees

Par 304 Page 9 in a specific job position, whether through training given by the repair station or knowledge acquired through other sources. For example, the repair station could establish minimum time requirements for training or alternatively could assess the need for training based upon skills and knowledge testing. In either event, the repair station training program must ensure that the employee is capable of properly performing assigned tasks.

303. RECURRENT TRAINING.

a. Recurrent maintenance training commonly includes training known as refresher training, to ensure that a repair station employee remains capable of properly performing the assigned job. The repair station’s program should define the terms initial and recurrent and identify the areas of study and/or courses/lessons that will be provided under the two definitions.

The definitions should be associated with either the person receiving the training, the training course, or the information being offered. The repair station should have procedures to determine the recurrent training requirements for each job assignment or employee. Not all job assignments will have the same recurrent training requirements. The repair station may also wish to provide a procedure for determining when training is not required to ensure an employee is capable of performing assigned tasks.

b. The repair station should have procedures to determine the type and frequency of recurrent training for each of its employees through the needs assessment. The repair station may define recurrent training that will be provided on a regular basis to address any subject provided in initial training. Alternatively, the repair station may provide new information on initial training requirements to existing employees under the recurrent training system. Its program procedures should set forth the two different types of recurrent training:

(1) That which updates the initial training requirements on a one-time basis.

(2) That conducted on a regular basis (refresher training).

c. Each repair station’s recurrent training program should differ since it should be based on the repair station’s needs assessment, which will take into account its size, employees, customers, and complexity of ratings and operations.

304. SPECIALIZED TRAINING. The repair station should have procedures to identify job assignments that will require special skills or have complexity that would require the development of specialized training to ensure capabilities. Some areas that may require specialized training include flame and/or plasma spray operations; special inspection or test techniques; special machining operations; complex welding operations; aircraft inspection techniques; or complex assembly operations. Individuals who attend specialized training and develop competency in a particular job assignment or task should be able to convey the information to other employees. The repair station’s training program should address the initial and recurrent training requirements for any task or assignment that it determines requires specialized training.