Appendix 3 APPENDIX 3. FREQUENTLY ASKED QUESTIONS (FAQ)
REGARDING AMTS CERTIFICATION AND OPERATION
1. Question : How should I include additional items in my curriculum that are above and beyond the subject areas included in part 147?
Answer: You have two options. You can make it part of your curriculum or you can make it a separate class. Subjects may be taught to a higher level in the curriculum than required by part 147 appendixes, but if they are taught to a higher level, the school must include them as part of the approved curriculum.
2. Question : What is an exemption from part 147? For which type of items can I request an exemption from part 147 and how does this process work?
Answer: An exemption is a request to the FAA to allow a school to deviate from existing regulations.
NOTE: There are no provisions for waivers.
A school can apply for an exemption for any items governed by part 147.
The process for requesting an exemption is detailed in 14 CFR part 11, General Rulemaking Procedures. The school must submit a request that:
Clearly defines and specifies the exemption requested.
Explains why the school is requesting the exemption.
Explains why it is in the public interest for the exemption to be granted.
Explains how, if the exemption is granted, public safety would not be affected.
Also, refer to the FAA Web site, http://aes.faa.gov/, enter “147” into the “Regulation” field, and select “Search” to see examples of past regulatory clarification requests by schools, as well as the FAA responses.
3. Question : Does the rule establish a standardized method of proof of student time and attendance?
Answer: No, neither the regulation nor FAA policy established standardized procedures to record student time and attendance. Each school must develop and have approved by their Flight Standards District Office (FSDO) a method of taking time and attendance for each student.
4. Question : Are the actual student tests required to be kept for 2 years, or only the results of those tests (grades)?
Answer: According to AC 147-3, Paragraph 26a, only the test grades must be kept for 2 years. By extension, completed laboratory project sheets do not need to be kept for 2 years.
As with tests, only laboratory project grades must be retained for that period of time. The generic project sheet or test is a part of the curriculum/and kept with the curriculum.
Appendix 3
5. Question : Do we keep time and attendance records for students’ individual projects or for the block of time required for the subject area?
Answer: There is no need or requirement for time and attendance to be maintained on an individual project basis.
Time and attendance can be documented on a “subject area” basis, recording only the students’ attendance in the subject area.
A school’s curriculum should specify total hours for the subject area, the amount of time that is dedicated to classroom, the amount of time that is dedicated to laboratory, and the total number of required projects for that subject area.
NOTE: If a school, in its approved curriculum, specifies hours assigned to individual projects, then time and attendance must be kept on that basis.
6. Question : What guidelines should we use as the basis for writing the part 147 operations manual?
Answer: Guidelines can be found in AC 147–3, as amended, 14 CFR, and the Northwestern University’s Job Task Analysis of the Aviation Maintenance Technician.
This last document can be found on the following FAA Web site:
http://www.faa.gov/avr/afs/ .
7. Question : Do the scope and details of the lesson plans have to be included in the AMTS curriculum?
Answer: A school’s lesson plans are recommended for availability, but not required to be part of the approved curriculum. Lesson plans are not required to show compliance with the regulations, and they are not to be part of the approved operations’ manual. Lesson plans should be available upon the request of the FAA certificating office and school officials.
8. Question : What is the rationale for not allowing students enrolled in the general curriculum to be administered the general computer test upon completion of that course? I have contacted several part 147 schools/colleges and have found that approximately 50 percent of those queried give general computer tests upon completion of the general course.
Answer: Title 14 CFR part 65, section 65.77 specifies tests for ratings, not the program, in which the student is enrolled. As a result, if a student completes all the general portion hours and completes the airframe, powerplant, or A&P rating and the school issues a certificate of completion for a rating, then the student may take the general test. In other words, to take the general test, the student must have completed a rating plus all the general material and been issued a certificate of completion by the school for at least one rating.
Appendix 3
9. Hypothetical Scenario: During a recent inspection, the FAA commented that to be in compliance, training aids must be available and in working order even if the subject is not being taught at the time. The same training aids are used in subjects requiring troubleshooting. If a subject being taught requires a teardown, the school should not be cited for non-compliance.
Response: Training aids/devices that are required and on the current school equipment list should be in good working order for the course(s) of instruction they are identified and intended to support. Multiple use or different use of training equipment is acceptable as long as the unit is available for each project individually and is not being used for multiple projects at the same time. Some exceptions to this will exist, such as using a complete aircraft for propeller removal while simultaneously checking control surface travel. For such exceptions, the AMTS should ensure the objective of each project is being met and safety is not compromised.
10. Hypothetical Scenario: During a recent inspection, a comment was made that a complaint had been filed and the FAA was required to inspect the facilities. Regulations state that the school is to receive a copy of the complaint listing, the nature of the complaint, and all parties involved. The school had to request a copy of the complaint. We received a notice that we could request a copy from the Freedom of Information Act and pay a fee for the report.
Response: The FAA is not required by regulation to supply any information contained in a complaint filed against a part 147 school. In many cases, the FAA does discuss the nature and content of a complaint with school administrators, but the decision to do so is up to the FAA and is based on the nature and implications of the allegations contained in the document.
11. Question : Section 147.31(a) states a “school may not require any student to attend classes of instruction more than 8 hours in any day . . . .” For schools that have both day and night shift classes, may a school permit a student to attend both classes when the student requests to do so?
Answer: Not normally, but there are exceptions. An exception must be approved by the school’s principal maintenance inspector (PMI) on a case-by-case basis. The FAA/ATEC panel believes that a blanket form of approval could compromise the integrity of the quality of instruction. This would allow for special exceptions that the school and student find themselves involved with such as sickness, illness, accidents, family problems, weather, or any other special circumstances.
Appendix 3
12. Question : What authority does the FAA have pertaining to the buildings that hold our classrooms and laboratories? I once had an inspector who walked into my hangar and stated that I had to increase the lighting in the area for the students. This was based on his opinion;
no measuring equipment was used to check the actual lumens. Section 147.15 states that facilities must be “. . . properly heated, lighted, and ventilated . . . as are appropriate to the rating” sought. Who is he to determine how many lumens or BTUs we use in our buildings?
If we meet the local building codes and Occupational Safety and Health Administration safety regulations, are we not meeting the standard?
Answer: What would a reasonable person expect to find in a normal classroom and laboratory environment? It would be apparent if there were a woeful lack of heat or light in the school, but at the same time, the PMI is not trained as a building inspector. What would be more critical to the school would be the school meeting the codes of the city and the state that it operates within. The school should be able to show the PMI that it has met the standards by displaying or showing, on request, building permits, building inspections, and any other safety inspection documentation from local fire departments, health agencies, and other regulatory agencies.
13. Question : The FAA/ATEC panel needs to clarify the use of intimidation and ultimatum with the use of ACs and handbooks to enforce “rules.” We find that inspectors tend to deviate from the rule and try to make ACs “regulatory,” rather than useful as suggestions or guidance in the process of working with schools. This tends to give each inspector the space needed to bring individual “causes” into the process and make them appear to have the force of law. One example is the use of AC 147-3 as the standard that will be used rather than the regulation being the standard and the AC being helpful in that process.
Answer: AC 147-3, as amended, was developed to clarify Part 147. It is to be used as a guideline. It is not regulatory.
14. Question : There needs to be some clarification regarding the use of military surplus aircraft in performing practical projects. While AC 147-3 states that the use of such aircraft is acceptable as long as the model is eligible for an FAA type-certificate, our inspector is telling us that no military surplus aircraft will be used. In our case, we have two twin bonanzas and one Sabreliner that we use as part of our program. Both are aircraft that are TC’d in civilian use; they are not made differently (as would be a fighter aircraft, for example), and should be acceptable to use. In addition, what difference does it make regarding systems work, such as brake replacement, whether it is certificated or not? We do recognize that, for example, while a sheet metal repair to industry standards would be a completely different issue, it should not make any difference on systems training as noted.
Answer: There is nothing in the rules that prohibits the use of military aircraft for training at a Part 147 AMTS, provided the school has at least one complete aircraft of a type eligible for FAA type certification.
It is reasonable to assume that systems training in many areas such as brakes, landing gear, hydraulics, and many others, is no different on military than on civilian aircraft. Schools are cautioned that there are subjects where differences exist, such that military aircraft may not be adequate or applicable trainers, for example, documentation research including airworthiness directive compliance and type certification. This is particularly true for aircraft without a civilian counterpart, for example, fighters.
Appendix 3
15. Question : AC 147-3 was last issued in 1991, and it put great emphasis on the Allen Study and how schools may use it to assist in the establishment of their curriculum. Again, this is a suggestion rather than the rule, and if a curriculum meets the FAA regulatory requirement, the Allen Study should not be used instead of the rule to say that the curriculums do not meet the requirements. Is there a more recent guideline, such as the Air Transportation Association of America (ATA) 104 Training Standard, in use that would be more current in its guidelines than the now quite old Allen Study?
Answer: Schools may choose to use the more current Job Task Analysis of the Aviation Maintenance Technician Northwestern University to help develop or update their curriculum. This is available at http://hfskyway.faa.gov. Select “Documents,” and under “Publications,” select “Bibliography of Publications 1989-1998,” then enter “job task analysis” into the search field. However, schools should be sure to meet the requirements of part 147.
16. Question : In the curriculum in Appendix C to part 147, under Airframe Systems and Components, Cabin Atmospheric Control Systems, items C34 and C35 have always presented a challenge for us. Both seem to be the same with the exception of item C33 mentioning air cycle machines. So, under item C33, we cover cabin atmospheric control systems for both large turbine engine aircraft with air cycle machines as well as smaller reciprocal engine aircraft that are supercharged/turbocharged along with combustion heaters. We suggest item C34 be deleted.
Answer: The redundancy has been previously identified. This will be addressed by the FAA at the next revision of the rule.
17. Question : Is 1,900 hours a minimum or maximum number of hours permitted under part 147?
Answer: One thousand nine hundred (1,900) hours is the minimum an AMTS must offer for a combined A&P curriculum. A school may provide additional hours at its discretion to meet institutional program objectives or align with specific industry needs.
18. Question : The FAA has the responsibility to enforce the content in a school’s Part 147 curriculum. Can the following items be omitted from the curriculum and kept on file at the school?
List of instructors.
Equipment list.
Forms created and used by the school.
Answer: The curriculum is the official document of the school.
The curriculum should reference the instructor list and where it is kept at the school. Upon request, the school should be able to provide the PMI a current list to the instructional staff. The curriculum should discuss the lesson plans and where they would be kept for availability to the PMI on an inspection visit.
The equipment list should be discussed in the curriculum, and should be kept current and available to the PMI upon his or her request. The student manuals Page 5
Appendix 3 should not be included as part of the curriculum. The methods of recording and tracking time and attendance should be in the curriculum, but the actual records should be kept separate.
The curriculum should also address the procedures for meeting the requirements of part 147. It should not include other student policies such as financial aid processing, add-drop policies, or other school activities.
19. Question : If a school and its PMI disagree on the interpretation/enforcement of a particular Part 147 regulation, will the part 147 FAA/ATEC panel resolve it?
Answer: No. All attempts should be made to resolve a disagreement at the local/regional level. The school should contact the local FSDO office manager or, if the dispute continues, contact FAA headquarters, Aircraft Maintenance Division (AFS), for additional guidance on application of the regulations. Some of the other clarifications in this document will be helpful in resolving a school PMI disagreement. The current FAA/ATEC panel may be brought together periodically to help clarify particular issues; it is an ad hoc advisory group.
The FAA Aircraft Maintenance Division will make all final determinations.
20. Question : Can the PMI be a member of the school’s advisory board?
Answer: The PMI may not be a member of the advisory board of a school. However, the school may invite the PMI to attend these meetings as a guest with no voting rights.
21. Question : When an inspector came in, he inspected our school as if we were a repair station returning everything to service. All of our gauges, the battery charger, torque wrenches, measuring instruments, and measuring tools are required to be calibrated. We are a school, not a repair station. All the gauges located on hydraulic boards must be calibrated. They are not required to be there, but if they are, they must be calibrated. Reciprocating engine overhaul is level 2. We overhaul the engine and operate it (not at all airworthy), but the gauges on the test stand must be calibrated. These additional costs and time-consuming activities make it very difficult to operate efficiently. Gauges and measuring instruments should be operational, but not necessarily calibrated at a school.
Clarification is needed regarding the use of precision tooling and its calibration requirements. All schools are learning institutions, and the student environment does not easily lend itself to keeping tools that require calibration. Students damage these types of tools without being responsible for them, in some cases. Clarification is needed as to exactly when, where, and what the specifics are regarding the use of these tools other than a simple statement in the AC or handbook stating that a calibrated tool procedure is a requirement; there is no mention in the rule regarding this.
Answer: Some level of calibration is necessary, depending on what level of simulated return to service is being taught. It is up to the school and FAA inspector to determine what these areas of instruction are. It is not mandatory for all tools/gauges to be calibrated.
Appendix 3
22. Question : Our school’s class schedule is based on a clock hour, which must be at least 50 minutes in length. In January 2001, the school requested approval to change the class schedule to 4 days per week, 30 hours per week.
During a recent inspection in July 2001, the FAA stated that approval was not given and stated the school must reverse the schedule. To do so would be an extreme hardship on students who have set work schedules by the new schedule as well as the school, which took a financial hit to start the schedule in January. After several discussions with the FAA, the decision regarding the 50-minute hour rule is under review by the FAA. The school did remain on the 4-day week, but adjusted the class schedule (which has been very inconvenient for many students) until an interpretation of the regulation can be made.
Answer: The 50-minute hour is based on the Carnegie rule of instruction that a 50-minute instructional period may be combined with a 10-minute break time to equate to an hour of instruction. The question relates to two items: the interpretation of the 50-minute hour and the approval of schedule change. Historically, the 50-minute hour must be tied to the 10-minute break time. An AMTS is not able to bank the break time and offer longer breaks at a greater time interval. A school may offer a 50-minute educational period with a 10-minute break time and then take a second 10-minute break time with the next 50 minutes of instruction tied to the second break time.
The second part of the question is based on approval of change. The school has a responsibility to request a change far enough in advance to allow the FSDO to research the request and then make a decision and convey it to the school with proper justification for the approval or disapproval. The request and approval must be in writing for the benefit of both parties and to avoid confusion and/or misunderstanding.
23. Question : An FSDO stated, one of our schools must graduate a student when he or she has completed the part 147 program, even though the student has not met his financial obligations to the school. The school’s catalog states that in addition to meeting all academic and administrative requirements for graduation, the student must satisfy all financial obligations to the school. Should the FSDO dictate policy that interferes with the administrative and financial operation of a school as long as the school is operating in compliance with part 147?
Answer: A school may require students to meet certain requirements and/or obligations before issuing a graduation certificate, diploma, or degree.
A common example is that many schools require that all financial obligations of a student be met before issuing transcripts of completion certificates, diplomas, or degrees.
However, those administrative requirements of the school may be in conflict with the regulation. The regulation is clear on this issue: section 147.35(a) states that, upon request, an AMTS must provide a transcript of student grades to a student who graduates or leaves the AMTS before graduation.
Appendix 3
24. Question : Course testing (not FAA exams), including preparation and post-test reviews, is an important part of the learning process. Are these activities part of the minimum 1,900 hours?
Answer: Yes. This is very clear. Reference AC 147-3, Paragraph 12g(3) and FAA Order 8300.10 Airworthiness Inspector’s Handbook, volume 2, Chapter 187, Paragraph 7. The rule states, however, that time spent to prepare or review for the FAA general, airframe, or powerplant test may not be included as part of the hours to satisfy a school’s approved curriculum requirements.
Appendix 4 APPENDIX 4. OPTIONAL AMT CURRICULUM This optional curriculum is based on the curriculum guidelines in appendixes B through D to Part 147. This suggested curriculum may be adopted partially or in whole as a means of compliance with Part 147. The number in parentheses indicates the level of proficiency at which a particular element must be taught. Items in italics indicate additions to what is currently found in appendixes B through D to Part 147.
Area of Study Subject Description Teaching Level General Curriculum Subjects
a. Basic electricity An AMTS may choose to incorporate training on circuits and devices for complex aircraft. The AMTS may choose to incorporate these subjects into the six subject areas of this section or add them as separate subjects.
1. Calculate and measure capacitance and inductance.................... (2)
2. Calculate and measure electrical power. ..................................... (2)
3. Measure voltage, current, resistance, and continuity. ................. (3)
4. Determine the relationship of voltage, current, and resistance in electrical circuits. .................................................................... (3)
5. Read and interpret aircraft electrical circuit diagrams, including solid-state devices and logic functions........................ (3)
6. Inspect and service batteries........................................................ (3)
b. Aircraft drawings An AMTS may reduce the overall complexity of this subject. An AMTS may teach this subject only to the proficiency required to perform normal aircraft inspection and typical repairs and alterations. For example, interpretation of drawings needed to perform an actual or simulated accomplishment of an airworthiness directive.
7. Use aircraft drawings, symbols, and system schematics............. (2)
8. Draw sketches of repairs and alterations..................................... (3)
9. Use blueprint information. .......................................................... (3)
10. Use graphs and charts.................................................................. (3)
c. Weight and balance An AMTS may place emphasis on out-of-center-of-gravity conditions and load calculations.
11. Weigh aircraft.............................................................................. (2)
12. Perform complete weight-and-balance check and record data.... (3)
d. Fluid lines and fittings An AMTS may choose to focus on fabricating rigid lines because most flexible fluid lines are purchased. Students should be instructed in the inspection of flexible lines.
13. Fabricate and install rigid and flexible fluid lines and fittings.... (3) Page 1
Appendix 4 Area of Study Subject Description Teaching Level
e. Materials and processes
14. Identify and select appropriate nondestructive testing methods. (1)
15. Perform dye penetrant, eddy current, ultrasonic, and magnetic particle inspections...................................................................... (2)
16. Familiarize students with basic heat-treating processes.............. (1)
17. Identify and select aircraft hardware, composites, and materials. ..................................................................................... (3)
18. Inspect and check welds. Familiarize students with welding and soldering processes through shop visits, demonstrations, and/or classroom instruction. ..................................................... (3)
19. Perform precision measurements. ............................................... (3)
f. Ground operation and servicing
20. Start, ground operate, move, service, and secure aircraft and identify typical ground operation hazards. An AMTS may use high fidelity simulators to duplicate ground operations in place of actual aircraft................................................................ (2)
21. Identify and select fuels from among the common types of aircraft fuels in current use......................................................... (2)
g. Cleaning and corrosion control
22. Identify and select cleaning materials and perform aircraft cleaning. ...................................................................................... (3)
23.a. Inspect for aircraft corrosion. .................................................. (3)
23.b. Identify, remove, and treat aircraft corrosion.......................... (3)
h. Mathematics An AMTS may elect to test students out of mathematics without teaching it as part of its AMT curriculum. (See section 147.31(c)(4).)
24. Extract roots and raise numbers to a given power....................... (3)
25. Determine areas and volumes of various geometric shapes........ (3)
26. Solve ratio, proportion, and percentage problems....................... (3)
27. Perform algebraic operations involving addition, subtraction, multiplication, and division of positive and negative numbers... (3) Page 2
Appendix 4 Area of Study Subject Description Teaching Level
i. Maintenance forms and records
28. Write descriptions of work performed, including aircraft discrepancies and corrective actions, using typical aircraft maintenance records.................................................................... (3)
29. Complete required maintenance forms, records, and inspection reports. ....................................................................... (3)
j. Basic physics An AMTS may elect to test students out of basic physics without teaching it as part of its AMT curriculum. (See section 147.31(c)(4).)
30. Use and understand the principles of simple machines; sound, fluid, and heat dynamics; basic aerodynamics; aircraft structures; and theory of flight. ................................................... (2)
k. Maintenance publications
31. Demonstrate ability to read, comprehend, and apply information contained in FAA and manufacturers’ aircraft maintenance specifications, ATA codes, air carrier background elements, minimum equipment lists, configuration deviation lists, data sheets, manuals, publications, and related Federal Aviation Regulations, AD, and advisory material. ........ (3)
32. Read technical data...................................................................... (3)
l. Mechanic privileges and limitations An AMTS may familiarize students with related regulations to include Parts 21, 23, 25, 43, 121, 135, and 145.
33. Exercise mechanic privileges within the limitations prescribed by Part 65 of this chapter. .......................................................... (3)
m. Human factors/ maintenance resource management (MRM) Human factors and MRM may be taught as a separate subject and/or incorporated throughout the curriculum. Emphasis should be placed on error management/mitigation and situational awareness.
34. Conduct a short computer-assisted instruction course in basic MRM principles followed by integrated applications................. (1) Page 3
Appendix 4 Area of Study Subject Description Teaching Level
n. Aircraft electrical introduction
35. Teach basic concepts of aircraft electronics, including digital electronics and operational principles. ........................................ (1)
o. Fire protection systems An AMTS may teach this subject in the general curriculum, instead of separately in the A&P curriculums, to avoid teaching the subjects twice. This may only be accomplished by a school teaching a combined A&P curriculum. A school teaching only airframe or powerplant as separate ratings may not follow this approach.
36. Inspect, check, and service smoke and carbon monoxide detection systems......................................................................... (1)
37. Inspect, check, service, troubleshoot, and repair aircraft fire detection and extinguishing systems. .......................................... (3)
p. General aircraft inspection principles
38. Perform a capstone inspection module. This module should include research into regulations, maintenance manuals, and other relevant documentation encountered during a normal inspection. Students should become familiarized with applications of TCDS, illustrated parts catalogs, structural repair manuals, AD, and similar documentation. Additional focus may be placed on human factors principles, such as norms, shift turnovers, situational awareness, and inspection integrity. Students may also receive initial training in principles of visual inspection, including defect recognition, detection, and classification........................................................ (2) or (3) Page 4