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• If, and under what circumstances, the school credits a student’s prior instruction or experience.
• How the school will determine the amount of credit to be given that ensures the student’s prior experience or training is equivalent to the curriculum for which the student is receiving credit.
2.5.5.1 Crediting Prior Instruction. The AMTS should only grant credit for previous instruction that has been satisfactorily completed at:
• An accredited university, college, community college, or junior college;
• An accredited vocational, technical, trade, or high school;
• A military technical school; or
• Another certificated AMTS.
2.5.5.2 Crediting Prior Experience. The AMTS should only credit previous maintenance experience after examining documents that verify that experience.
2.5.5.3 Determining Issuance of Credit. The AMTS should determine the amount of credit to be given as it relates to the training requirements provided in § 147.17. An AMTS should utilize the following methods:
• An evaluation of an authenticated transcript from the student’s former AMTS (applicable for prior instruction),
• A qualifying entrance test equal to one given to students who complete the corresponding curriculum content at the crediting AMTS (applicable to either prior instruction or prior experience), or
• Another method that verifies the student’s previous training or experience meets the crediting school’s curriculum requirements.
2.5.5.3.1 When basing credit on an evaluation of an authenticated transcript, the crediting AMTS should ensure the individual has completed training comparable (i.e., meets or exceeds the curriculum content) of that offered by the crediting school. The AMTS should be able to show documented evidence of the evaluation. Evaluation of a transcript could be based on a combination of the following:
• Detailed transcripts.
• The course catalog description of the course that was completed by the student.
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• Audits of the class for which the credit is to be based when crediting a specific course on a routine basis. In this circumstance, the AMTS should define its audit schedule within the QC procedures.
• Other documents showing the course content on which the credit is being based.
2.5.5.3.2 When using an entrance test to determine the credit to be granted, the test should be equal to one given to students who complete the corresponding curriculum content at the school. This is applicable to either prior instruction or prior experience. The entrance test should include both knowledge and skill components of the curriculum to which credit is being granted.
2.5.5.3.3 Generally, creditable previous mechanic experience should be aviation maintenance experience comparable to the required AMTS curriculum subject areas.
• Example 1: An individual with substantial powerplant experience (no airframe experience) gained while working in the military or at an airline should be considered as having previous experience only within powerplant subject areas.
• Example 2: An uncertificated mechanic working for an airline for 5 years only in the tire shop should not be considered to have experience relating to all airframe subjects.
2.5.5.4 Credit for the General Curriculum. A school may credit a student seeking an additional mechanic certificate rating with previous satisfactory completion of the general curriculum content. If an individual has obtained a mechanic certificate with either an airframe rating or a powerplant rating, that rating indicates the individual has met the knowledge requirements for issuance of a mechanic certificate, which includes knowledge and skills that would be required within the general portion of an AMTS curriculum. Therefore, a student who is seeking an added rating to their mechanic certificate may be issued graduation documentation by the AMTS upon completion of the applicable curriculum, even though the student did not complete the general portion of the AMTS curriculum.
2.5.5.5 Exceptions to Crediting Procedures.
• If an AMTS Air Agency Certificate has been suspended by the FAA, courses taught during the suspension period cannot be credited retroactively, even if the school becomes re-certificated later, because the AMTS would be operated in violation of § 147.7.
• An AMTS applicant may not teach students as an AMTS before receiving an FAA certificate and then give credit for that training after the school becomes certificated, because the AMTS would be operating in violation of § 147.3.
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2.5.6 Issuing of Final Course Grades. The AMTS QC system must include procedures that describe how the AMTS will issue final course grades. The procedures should describe the AMTS’s standards for passing grades to include:
• The minimum passing grade sufficient to achieve the required knowledge and skills of the school’s curriculum;
• How grade weighting (percentage) and/or grade averaging will be used to determine the final course grade, as applicable;
• Forms or samples of electronic records the AMTS will use for recording grades;
• Any other procedures the school uses to determine final course grades; and
• A description of any audit or verification procedures the AMTS will use to ensure accuracy of the final grade.
2.5.6.1 A common academic standard for passing is a minimum score of 70 percent, and the FAA written, oral, and practical tests have a 70 percent minimum passing standard in accordance with § 65.17. The AMTS should define its standard for a passing final course grade in its QC system procedures (refer to § 147.23(b)). However, it is recommended that the school does not implement a passing standard lower than 70 percent, to support the school in meeting the quality of instruction requirements of § 147.25.
2.5.6.2 Theoretical portions of the curriculum may have different grading standards from those required in laboratory and shop classes.
2.5.7 Attendance. The QC system must include attendance procedures. Procedures should include the following:
• The AMTS attendance policy for courses that are required for curriculum completion.
• How the AMTS will track student attendance when required by its attendance policy.
• Any limitations on student attendance or enrollment, such as limiting class hours in a day/week, or limiting enrollment in additional courses.
Note: Depending on the basis of the curriculum, attendance policies can vary greatly. For example, schools basing their curriculum on hours may have more strict or detailed attendance requirements than schools basing their curriculum on credit-hours or competency.
2.5.8 Ensuring Sufficient Number of Instructors. The school must have QC system procedures describing how the school will ensure it maintains a sufficient number of instructors to achieve the school’s training requirements. Procedures should include the following:
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• A description of how the AMTS will ensure the 25:1 student-to-instructor ratio required by § 147.19(c) is maintained.
• A description of any other requirements the AMTS is placing on student-to-instructor ratios for the purpose of achieving the school’s training requirements.
2.5.9 Granting of Graduation Documentation. The school must have QC system procedures describing how it grants graduation documentation under § 147.21 and completion documentation required for early testing under § 147.31.
2.5.9.1 Section 147.21, Certificate of Completion. Under § 147.21, when a student satisfactorily completes the required curriculum content for graduation, the school must issue an authenticated document to the graduating student. A graduation document may only be issued consistent with the school’s ratings.
The procedures for issuing the authenticated document should include the following:
2.5.9.1.1 A description of the document to be issued and what information will be included on the document. At a minimum, the following information should be included on the document in order to meet the requirements of § 147.21(a):
• Student name, indicating who the document was issued to.
• School name and Air Agency Certificate number, to indicate who issued the document and that the document was issued by an FAA-certificated AMTS.
• Authentication, using the method of authentication determined by the school to show the document was issued legitimately.
• The student’s date of graduation.
• The name of the curriculum completed by the student (i.e., either “Airframe”, “Powerplant”, or “Airframe and Powerplant”).
2.5.9.1.2 A description of the authentication process used by the school to ensure the document was legitimately issued by the school, and a description of designated school personnel authorized to authenticate the document. For example, schools may use a signature, an embossed seal, or some other method to indicate authentication, and may limit the performance of authentication to certain school officials.
2.5.9.1.3 The process used to verify the student has passed the curriculum based on the school’s standards for issuing final course grades, any attendance requirements, and/or crediting of the AMTS curriculum that was based on prior instruction or experience.
2.5.9.1.4 How the school ensures the student is eligible to receive the graduation certificate.
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2.5.9.2 Section 147.31. Under § 147.31, when a student satisfactorily completes the general portion of a school’s curriculum, the school may issue an authenticated document that demonstrates the student’s preparedness to take the FAA mechanic general written test in accordance with § 65.75(c). When a school intends to support the option of the early testing provision, the QC system procedures should include procedures describing how the school issues the required document that will allow early testing under § 65.75(c). At a minimum, the following information should be included on the document in order to meet the requirements of § 147.31:
• Student name, indicating who the document was issued to.
• School name and Air Agency Certificate number, to indicate who issued the document and that the document was issued by an FAA-certificated AMTS.
• Authentication, using the method of authentication determined by the school to show the document was issued legitimately.
• The student’s date of graduation.
• Indicate the document demonstrates completion of the general curriculum content of the school’s curriculum.
Note: Some schools incorporate the general curriculum content as a part of the Airframe and/or Powerplant curriculum content. Students may be issued a completion document as long as the school can identify and verify that the student has completed the general curriculum content requirements of the school.
2.5.9.3 Electronic Signatures. If the AMTS chooses to use electronic signatures on the authenticated document issued under § 147.21 or § 147.31, the school should describe its electronic signature procedures within its QC system. It is recommended that the school incorporate the guidelines put forth in AC 120-78 in developing its electronic signature procedures. The FAA will issue OpSpec A025, to authorize the AMTS use of electronic signatures.
2.5.10 Corrective Action for Addressing Deficiencies. The school must have QC system procedures which describe how the school will take corrective action for addressing deficiencies. The term “deficiencies” refers to deficiencies or defects within the school’s QC system. The procedures should include a description of the following:
• How the school will receive and record reports of deficiencies.
• How the school will determine the cause of the deficiency.
• How the school will develop, implement, and track correction of deficiencies.
• How the school will perform follow-up to ensure deficiencies have been adequately corrected.
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2.5.11 QC System Format. The AMTS should consolidate its QC system policy and procedures into a single manual/document because the entire QC system receives FAA approval through OpSpec A027. However, the OpSpec does allow the listing of multiple approved documents that make up the QC system, if applicable. The AMTS should not include procedures that are not specified by § 147.23(b) within the QC system documents being approved by the FAA, unless the additional procedures are clearly noted as being not a part of the FAA-approved QC system.
2.5.11.1 FAA approval of the QC system described under paragraphs 2.5.2 through 2.5.11 is provided by issuance of OpSpec A027, which indicates the revision level and date of the QC procedures currently approved by the FAA.
2.5.11.2 Because § 147.23 requires that a QC system be FAA approved, if a school revises the procedures of its QC system, the school must receive FAA approval of the revised system prior to implementing those changes. It is important that the AMTS have a means of maintaining revision control of its QC document(s). This provides a way for both the AMTS and the FAA to verify if the school is maintaining its compliance with the requirements of part 147. The following controls should be included in any manual or document system for revision control, as appropriate:
• Revision Procedures. Define in writing the revision procedures for its manuals/documents to ensure consistent and correct application.
• List of Effective Pages (LEP). The LEP shows the current active pages of the document, to include their date of revision and revision level.
• Record of Revisions. This page is a running list of the revisions that have been applied to the document historically, and includes the revision level and date of the revision.
• Highlights of Revision. This page is based on the current revision and briefly describes the changes that were implemented within the document.
The details should be described on a page-by-page level.
• Form Control. Forms should include a form-specific revision level identified on the form. Forms may be included within the document, within an appendix, or within a separate forms manual.
• Identify Revised Text. Revised text within the document should be identified. Vertical change bars adjacent to the revised text, highlighting text, or another method of identifying revised text could be used.
2.6 Other AMTS Procedures. All AMTS are encouraged to develop additional procedures regarding their training operations. The procedures should be directed at AMTS personnel and students to provide transparency in expectations. While additional procedures are encouraged, they should not be included in the FAA-approved portion of a school’s QC system. Doing so can create confusion when determining regulatory compliance with part 147. Certain additional AMTS procedures may be required by
2-15 regulation (e.g., some exemptions include a requirement for procedures), or may affect how the AMTS or students comply with a related regulation (e.g., testing under § 65.80).
Some examples of other policy and procedures that an AMTS is encouraged to develop are included below.
2.6.1 Safety Procedures. The aviation maintenance environment can be dangerous, especially to those who are not knowledgeable of its hazards and risk. To prevent serious injury or death to students and AMTS personnel, the FAA encourages the AMTS to develop clear policy and procedures to ensure the safety of its training operations and conform to local, state, and Federal regulations for workplace safety. The FAA highly recommends that AMTSs contemplate the mitigation of hazards associated with performing high risk training operations, using the following guidelines:
• Any training equipment used by the AMTS to include tools or other devices, with the capability to operate, actuate, or store energy, or that otherwise has the potential to expose a person to injury, should be evaluated by the AMTS for hazards and safety risk.
• The use of chemicals such as cleaners, lubricants, and flammable liquids (refer to material safety data sheets (MSDS)) during training operations should be evaluated by the AMTS for hazards and safety risk.
• The AMTS should develop safety policy and procedures that ensure the equipment or chemical’s safe use in all training scenarios, by mitigating risk to acceptable levels.
• Safety procedures should include checklists wherever applicable. Training should be provided, to AMTS personnel and students, on the checklists prior to their use.
• The school’s curriculum should include or reference briefings on all safety procedures appropriate to laboratory or shop practical projects. The briefings should be readily available to instructors and students and be used to increase safety awareness prior to high risk training operations.
2.6.2 AMTS Safety Programs. As FAA certificate holders, AMTSs may voluntarily disclose apparent violations of part 147 to the FAA under the Voluntary Disclosure Reporting Program (VDRP). Written procedures could provide expectations and guidance to AMTS personnel. The procedures should define who is responsible for making disclosures, describe internal AMTS procedures related to disclosures, and include or refer to the applicable procedures of AC 00-58, Voluntary Disclosure Reporting Program. The VDRP web page can be found at https://vdrp.faa.gov/.
2.6.3 Student Testing Under § 65.80. AMTS students may take their FAA oral and practical tests prior to taking their FAA written tests, when done in accordance with § 65.80.
Because § 65.80 contains certain requirements that must be met, AMTSs are encouraged to develop written procedures to ensure those requirements are met before the school authorizes the student to test under § 65.80 (i.e., by signing the appropriate blocks on FAA Form 8610-2, Airman Certificate and/or Rating Application). Having written procedures may streamline the FAA approval process for these test authorizations. The procedures should address the following:
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2.6.3.1 Determine the Student Has Met the § 65.80 Requirements. When an AMTS has determined that a student has met the requirements of § 65.80, the AMTS must sign the appropriate block of FAA Form 8610-2 to show the student is prepared to take the oral and practical tests prescribed by § 65.79.
The requirements are as follows:
• The AMTS must show to the FAA that the student has made satisfactory progress,
• The student is prepared to take the oral and practical tests prescribed by § 65.79, and
• The student is in the final subjects of training in the curriculum (i.e., the AMTS must be prepared to show the FAA that the student is in the final subjects of training in the curriculum).
2.6.3.2 AMTS Signature. The AMTS procedures should describe how it will ensure that each student applying to take the FAA oral and practical tests prior to taking the FAA written knowledge tests has met the § 65.80 requirements.
The procedures should include who (by title) is authorized to sign FAA Form 8610-2 on behalf of the AMTS and the timeframe for submitting the form to the FAA.
2.6.4 Exemptions. Many exemptions granted by the FAA have associated conditions or limitations which the exemption holder must meet to be in compliance with the exemption. The AMTSs are encouraged to develop written procedures to ensure compliance with the conditions and limitations of the exemption it intends to use, and thereby ensure continued regulatory compliance and safety.
2.6.5 Technical Data. The use of appropriate technical data is a cornerstone of aviation maintenance. Accordingly, the FAA recommends that AMTSs describe procedures for ensuring access to appropriate technical data applicable to the school’s rating(s), training equipment, and training materials, to include chemicals used during training.
2.6.6 Special Tools and Hand Tools. The AMTS should describe procedures for how it will ensure the maintenance of precision/special tools and hand tools. If the school has a student hand tool policy, such as a requirement that the student supply certain hand tools, this should also be described.
2.6.7 Procedures for FAA Certification of Students (e.g., Taking the FAA Written, Oral, and Practical Tests After Graduation). Since the main goal of most AMTS graduates is to obtain an FAA mechanic certificate, it is recommended the AMTS provides students with procedures describing how the student will move forward to the FAA testing process following graduation. The procedures should also describe how the AMTS graduation certificate, or other appropriate documentation, will provide eligibility towards FAA testing.
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2.6.8 Additional Administrative Procedures. The FAA recommends the AMTS provides whatever additional procedures it deems necessary to ensure its personnel are conducting operations in accordance with the expectations of the AMTS, and the requirements of part 147.
2.7 Curriculum/Training Requirements. Part 147 contains the following curriculum requirements:
• Curriculum description (application requirements), as required by § 147.5(b)(2). See paragraph 2.7.1 for additional discussion.
• Curriculum document and training requirements, as required by § 147.17(a)(1). See paragraph 2.7.2 for additional discussion.
2.7.1 Curriculum Description. The AMTS OpSpecs include a description of the manner in which the school’s curriculum will ensure the student has the knowledge and skills necessary for attaining a mechanic certificate and associated ratings under part 65 subpart D, and, therefore, the description must be included in the AMTS’s application for a certificate and rating, as required by § 147.5(b)(2). The FAA recognizes that there are many methods of instruction available in the education industry, and part 147 allows the school to decide the best method for the structure and delivery of its curriculum. The FAA will include the curriculum description in the AMTS OpSpec B001. The description should include discussion in the following areas, as applicable:
• Curriculum Basis,
• Curriculum Delivery Methods, and/or
• Curriculum Focus.
2.7.1.1 FAA Oversight. Pursuant to the FAA’s authority to conduct inspection (§ 147.27), the FAA’s oversight includes:
• Ensuring the AMTS is delivering its curriculum in the manner stated in the description. If the school were not following the described manner, it would be in violation of its OpSpecs (refer to § 147.3).
• Ensuring the curriculum basis, delivery methods, and any curriculum focus are achieving the standards of § 147.17(a)(2) and (3).
2.7.1.2 OpSpec Paragraph B001. The curriculum that an AMTS must provide in accordance with § 147.5(b)(2) will be included in the AMTS OpSpecs.
Additionally, because an AMTS may not operate in violation of its OpSpecs, pursuant to § 147.3, whenever the AMTS changes the description of its curriculum basis or delivery, it must provide those changes to the FAA for amendment of OpSpec B001. The description may be included in the OpSpecs by reference to a document provided by the AMTS, rather than by including the description directly into the body of the OpSpec. In these instances, the
2-18 document’s title, revision level, and revision date will be listed in the OpSpec, and the FAA will retain a copy of the document.
2.7.1.3 Curriculum Basis. The following are examples of a curriculum basis that may be used for AMTS curriculum. There may be other examples of a curriculum basis that are not discussed here. Appendix B, Related References (Current Editions), lists several references that may assist schools in determining and developing the curriculum basis.
2.7.1.3.1 Hours-Based Curriculum. An AMTS may choose to base its curriculum on requiring student completion of a defined number of curriculum hours. For example, the school could base its curriculum on curriculum hours defined by the school, for each of the school ratings:
• Airframe — 1,150 hours (400 hours of general content plus 750 hours of Airframe content).
• Powerplant — 1,150 hours (400 hours of general content plus 750 hours of Powerplant content).
• Combined Airframe and Powerplant — 1,900 hours (400 hours of general content plus 750 hours of Airframe and 750 hours of Powerplant content).
Note: Part 147 does not prescribe minimum curriculum hours.
2.7.1.3.2 Credit Hours-Based Curriculum. An AMTS may choose to base its curriculum on requiring student completion of a defined number of credit hours. Credit hours should be based on higher education criteria, such as the credit hour criteria of the school’s accrediting agency.
Note: Part 147 does not prescribe an amount of credit hours.
2.7.1.3.3 Competency-Based Training (CBT) Curriculum. An AMTS could choose to develop its curriculum using educational practices based on competency and assessment. A standard for CBT has been developed by the International Civil Aviation Organization (ICAO).
• ICAO Doc 9868, Procedures for Air Navigation Services—Training, defines CBT and assessment as: “Training and assessment that are characterized by a performance orientation, emphasis on standards of performance and their measurement, and the development of training to the specified performance standards.” The ICAO document describes and the training takes into account the competencies and behaviors that are considered fundamental for aircraft maintenance personnel.
• ICAO Doc 10098, Manual on Competency-Based Training and Assessment for Aircraft Maintenance Personnel, provides guidance on a new approach of applying competency-based training and assessment to
2-19 aircraft maintenance personnel in accordance with Part III of the PANS- TRG (Doc 9868).
Note: Part 147 does not prescribe CBT standards.
2.7.1.4 Curriculum Delivery Methods. The school must ensure that the curriculum delivery method used to teach the various knowledge and skills required to perform aircraft maintenance under 14 CFR will achieve the training requirements put forth in § 147.17. Additionally, the delivery method must ensure that each instructor is able to comply with the instructor requirement to teach in a manner that ensures positive educational outcomes are achieved (refer to § 147.19(a)).
Note: The FAA does not approve a school’s curriculum delivery method.
2.7.1.4.1 In-Person Delivery. Much of the knowledge and skill training relative to aircraft maintenance is suited to in-person delivery, where students can learn and experience aircraft maintenance in an environment that is similar to what individuals will experience as certificated mechanics.
2.7.1.4.2 Distance Learning Delivery. There are various methods a school could use to deliver curriculum content that enables access to learning when the source of information and the learners are separated physically by time or distance, or both. Schools should carefully consider what curriculum content is appropriate for distance delivery to ensure expected learning outcomes will be met.
2.7.1.4.3 Virtual Simulation. Many AMTS are incorporating virtual simulation for conducting practical application of certain skills. For example, virtual welding and virtual paint booths use simulation equipment and technology to provide near-real environments while minimizing the hazards associated with those activities. When virtual simulation is used, the school must ensure that the learning objectives for knowledge and skill are met, just as they would in real-world practical application. Additionally, while the simulated environment may reduce the hazards associated with the task, it is important that students are highly aware of hazards when conducting the real-world task, as well as how to mitigate those hazards, such as with personal protective equipment (PPE).
2.7.1.5 Curriculum Focus. An AMTS may enrich portions of its curriculum to develop graduates who are directed toward particular areas of the aviation industry. For example, schools may train graduates specifically for employment at commercial airlines, helicopter operations, repair stations, or agricultural aircraft operations. Schools must ensure that the curriculum does not omit content that is in the Mechanic ACS, as, pursuant to § 147.17(a),
2-20 curriculum must continually align with the Mechanic ACS (refer to paragraph 2.7.2). Examples of curriculum focus include:
2.7.1.5.1 Example 1. An AMTS in a rural area may wish to focus on preparing students for General Aviation (GA) and aircraft operations such as agricultural operations. In this case, airframe subjects such as wood, dope, fabric, welding, rigging, and corrosion control would be emphasized for these subjects.
Powerplant courses such as propellers and reciprocating powerplants, including radial and opposed, would also be emphasized in the same ways. On the other hand, turbine engines, electronics, and air conditioning may be deemphasized, while still ensuring all knowledge and skills required by the Mechanic ACS are taught in these areas.
2.7.1.5.2 Example 2. An AMTS in a metropolitan area may concentrate on preparing students for employment at major airlines. This AMTS would tend to emphasize areas such as turbine engines, nondestructive inspection (NDI), air conditioning systems, auto flight, electronics, and airline maintenance systems. This AMTS may want to de-emphasize its teaching of wood, dope, fabric, welding, and reciprocating engine subjects, while still ensuring all knowledge and skills required by the Mechanic ACS are taught in these areas.
2.7.2 Curriculum. An AMTS must establish, maintain, and utilize a curriculum designed to continually align with Mechanic ACS, as appropriate for the ratings held, pursuant to § 147.17. The “curriculum” refers to the curriculum document(s) that a school must develop, which must align with the Mechanic ACS, depending on the ratings issued to school under § 147.11. The school’s curriculum must be used at all training locations of the school (i.e., different locations may not use different curriculum). However, all or a portion of the curriculum may be taught at any of the school’s locations.
2.7.2.1 Mechanic ACS. The phrase “mechanic airman certification standards” in § 147.17(a)(1) refers to the standards that have been incorporated by reference in § 147.17(b). The Mechanic ACS contains several high-level subjects. For each subject, the ACS specifies the aeronautical knowledge, risk management, and skill standards that an applicant for a mechanic certificate must know. An AMTS curriculum is required to align with the subject areas and with each of the aeronautical knowledge, risk management, and skill standards included in the Mechanic ACS.
2.7.2.1.1 Because part 147 requires use of the Mechanic ACS, which was not already published in the CFR or another location that carries the full force and effect of the law, the FAA incorporated the Mechanic ACS by reference.
Incorporation by reference is a mechanism that allows Federal agencies to comply with the requirements of the Administrative Procedure Act (APA) to publish rules in the Federal Register (FR) and the CFR by referring to material published elsewhere. Material that is incorporated by reference has the same legal status as if it were published in full in the CFR.