Appendix 3 Answer: Schools may choose to use the more current JTA 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 part 147 Appendix C, 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 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 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.
Appendix 3
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 (HQ), Aircraft Maintenance Division (AFS-300), 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. AFS-300 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.
Answer: Some level of calibration may be necessary, depending on what level of simulated RTS is being taught. It is up to the school and FAA inspector to determine what these areas of instruction are. However, it is not mandatory for all tools/gauges to be calibrated.
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 an 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
Appendix 3 Page 7 (and 8) 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: § 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.
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: No, Reference AC 147-3, Chapter 2, and FAA Order 8900.1, Volume 2, Chapter 12, Section 2. 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. FREQUENTLY ASKED QUESTIONS (FAQ) REGARDING AMTS
OPERATING SPECIFICATIONS
1. Question: What are Operations Specifications (OpSpecs)?
Answer: OpSpecs are approved documents identified by OpSpec paragraphs containing the authorizations, limitations, and certain procedures under which each kind of operation is to be conducted. Operational variables such as: multiple ratings, management and designated personnel, affiliated Designated Mechanic Examiners (DME), exemptions, authorization/limitations, and approved manual systems are identified in applicable OpSpec paragraphs and approved through the issuance of those OpSpec paragraphs. OpSpecs are maintained in an internet accessible program known as Web based Operations Safety System (WebOPSS).
2. Question: Who originates the OpSpecs for a particular Aviation Maintenance Technician School (AMTS)?
Answer: The OpSpecs for an AMTS are prepared by the Flight Standards District Office (FSDO) using standard templates, known as paragraphs, and an automated system called the WebOPSS. In some cases, data for OpSpec fields will come out of an FAA database, Program Tracking and Reporting Subsystem (PTRS). The AMTS however, may need to provide the FSDO with some of the information that is required to prepare an OpSpec that is not currently in the database. This information should be readily available by the AMTS and would include:
• AMTS primary points of contact and their contact information.
• AMTS management personnel and their contact information.
• Identification of person(s) at the AMTS designated to receive OpSpecs.
• Location of the AMTSs recordkeeping system.
3. Question: Will incorporating OpSpecs into an AMTS require a curriculum change?
Answer: The initial set of OpSpecs that will be issued to AMTSs mirror the existing part 147 rule. This includes the curriculum requirements found in Appendices B, C, and D. An AMTS will therefore not need to change its curriculum to incorporate the OpSpecs.
4. Question: What OpSpecs would an AMTS be issued?
Answer: Some OpSpec are mandatory and others are optional. All AMTSs would be issued a set of mandatory OpSpecs consisting of the following:
• A001, Issuance and Applicability (Mandatory).
• A002, Definitions and Abbreviations (Mandatory).
• A003, Rating(s) (Mandatory).
• A004, Summary of Special Authorizations and Limitations (Mandatory).
• A006, Management Personnel (Mandatory).
• A007, Designated Persons (Mandatory).
• A013, Instructors (Mandatory).
Appendix 4
• A025, Recordkeeping System (Mandatory).
• B002, Required Minimum Curriculum for General (Part 147 Appendix B) (Mandatory). This B002 AMTS OpSpec is issued to all certificated AMTS(s) regardless of ratings issued.
NOTE: Some AMTS will also be issued one or more optional OpSpecs depending on their applicability.
The optional OpSpecs consist of the following:
• A005 Exemptions (Optional).
• A012, Affiliated Designated Mechanic Examiners (DME) (Optional).
• A026, Authorizations/Limitations (Optional).
• B003, Required Minimum Curriculum for Airframe (Part 147 Appendix C) (Optional). This OpSpec is issued only if the AMTS holds an airframe, and/or airframe and powerplant rating.
• B004, Required Minimum Curriculum for Powerplant (Part 147 Appendix D) (Optional). This OpSpec is issued only if the AMTS holds a powerplant, and/or airframe and powerplant rating.
5. Question: Who at the AMTS is authorized to receive OpSpecs?
Answer: The AMTS must have one or more persons identified in paragraph A007 of the OpSpecs as a designated person authorized to receive OpSpecs. When the AMTS receives an OpSpec, an authorized designated person will sign and date the OpSpec at the bottom of the page after the statement “I hereby accept and receive the operations specifications in this paragraph.” The signed OpSpec(s) would then be incorporated into the AMTSs manual, superseding the now outdated paragraph.
6. Question: Who develops the OpSpecs?
Answer: Standard templates are developed by Flight Standards Service, Aircraft Maintenance Division (AFS-300), FAA Headquarters (HQ), Washington DC. The process used at HQ for developing standard templates ensures appropriate coordination with regional flight standards personnel and with other FAA services and offices that could be affected.
The process also ensures that before the standard templates are finalized, appropriate coordination is accomplished with affected industry groups. Since standard templates specify limitations, conditions, and other provisions which operators must comply with, coordination with industry is essential to a mutual and clear understanding of the effect they will have on industry. After appropriate coordination with the Technical Programs Branch (AFS-260) has been completed, drafts of the new standard paragraphs/templates, or revisions to existing paragraphs/templates are finalized and incorporated into the WebOPSS.
Appendix 5 APPENDIX 5. OPTIONAL AMT CURRICULUM The following optional curriculum may be used by an AMTS and is based on the regulatory requirements listed in part 147 appendices B through D. The optional curriculum may be adopted as a means of compliance for only one section such as appendix C (Airframe), or it can be utilized for the General, Airframe and/or Powerplant (appendices B, C, and D). 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 part 147 Appendices B through D.
NOTE: The term “capstone” is a term utilized to reference topics and/or areas of study recommended as important final or closing subject matter that would be suitable to be taught.
Appendix › Teaching Area of Study Subject Description Level General Curriculum Subjects
a. Basic An AMTS may choose to incorporate training on circuits and devices for electricity 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. 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 An AMTS may choose (with FAA approval) to teach the subject only to the drawings proficiency required to perform normal aircraft inspections or typical repairs or alterations. For example, interpretation of drawings required to perform an actual or simulated airworthiness directive (AD).
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 An AMTS may place emphasis on out-of-center-of-gravity balance conditions and load calculations to ensure any alterations that would affect forward or aft center of gravity are recorded property.
11. Weigh aircraft.. (2)
12. Perform complete weight-and-balance check and record data... (3)
d. Fluid lines An AMTS may choose to focus on fabricating rigid lines because and fittings 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)
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. ()
17. Identify and select aircraft hardware, composites, and materials. ...... ... (3)
18. Inspect and check welds. Familiarize students with inspecting and checking welds created by the student using visual, nondestructive, and other NDI technologies.. . (3) Page 2
Appendix 5 Area of Study Subject Description Teaching Level
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. For aircraft starting and ground movement operations, a high fidelity simulator may be used with prior FAA approval... .... (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) 23a. Inspect for aircraft corrosion. (3) 23b. 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 § 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)
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 § 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 Page 3
Appendix 5 Area of Study Subject Description Teaching Level 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...
32. Read technical data.. (3)
1. Mechanic An AMTS may provide level 1 teaching to students on related privileges and regulations to include Parts 21, 23, 25, 43, 121, 135, and 145.
limitations
33. Exercise mechanic privileges within the limitations prescribed by Part 65 of this chapter. ... (3)
m. Human Human factors principals are encouraged and may be taught as factors/ a separate subject and'or incorporated throughout the maintenance curriculum. Emphasis should be placed on common maintenance resource problems such as failure to follow procedures and situational management awareness.
(MRM)
34. Provide instruction on Human Factors by implementing basic human factors techniques and applications... .. (1)
n. Aircraft electrical introduction
35. Teach basic concepts of aircraft electronics, including digital electronics and operational principles. ....
o. Fire An AMTS may teach this subject in the general curriculum, protection instead of separately in the A&P curriculums, to avoid teaching systems 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. … (I)
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 Type Certificate Data Sheet (TCDS), Page 4
Appendix 5 Area of Study Subject Description Teaching Level Illustrated Parts Catalogs (IPC), Structural Repair Manuals (SRM), Service Difficulty Reporting (SDR), 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) Airframe Curriculum Subjects I. Airframe Structures
a. Wood An AMTS may focus on only familiarization with the basic structures concepts of this subject.
1. Service and repair wood structures. ()
2. Identify wood defects. … (1)
3. Inspect wood structures. ... (
b. Aircraft An AMTS may focus on familiarization with the concepts of this covering
4. Select and apply fabric and fiberglass covering materials. - ()
5. Inspect, test, and repair fabric and fiberglass.... ... (1)
c. Aircraft finishes
6. Apply trim, letters, and touchup paint..
7. Identify and select aircraft finishing materials. (2)
8. Apply finishing materials. An AMTS may primarily focus on application of corrosion prevention materials. (2)
9. Inspect finishes and identify defects. ... (2)
d. Sheet metal and nonmetallic structures
10. Select, install, and remove special fasteners for metallic, bonded, and composite structures (2)
11. Inspect bonded structures... ... (2)
12. Inspect, test, and repair fiberglass, plastics, honeycomb, composite, and laminated primary and secondary structures, and focus on the detection and inspection of defects and the repair of damage, using manufacturer's structural repair manual guidelines.. ... (2)
13. Inspect, check, service, and repair windows, doors, and interior furnishings. .. (2)
14. Inspect and repair sheet metal structures... - (3)
15. Install conventional rivets. ... (3) Page 5
Appendix 5 Area of Study Subject Description Teaching Level
16. Form, lay out, and bend sheet metal. (3)
e. Welding
17. Weld magnesium and titanium.
18. Solder stainless steel. (1)
19. Fabricate tubular structures (1) To encourage the understanding of and preparation for material identification, filler materials, compatible alloys, gas welding system setup, and methods associated with welding safety.
20. Solder, braze, gas-weld, and arc-weld steel. (2)
21. Weld aluminum and stainless steel. ()
f. Assembly and rigging
22. Rig rotary-wing aircraft. (1)
23. Rig fixed-wing aircraft. (2)
24. Check alignment of structures (2)
25. Assemble aircraft components, including flight control surfaces.. (3)
26. Balance, rig, and inspect movable primary and secondary flight control surfaces. An AMTS may elect to focus specifically on FAA-required inspection items. (3)
27. Jack aircraft. ...... (3)
g. Airframe An AMTS may move this subject to the end of the airframe inspection curriculum, combine it with other elements, and teach it as a capstone inspection project.
28. Perform airframe conformity and airworthiness inspections.... - (3) II. Airframe Systems and Components
a. Aircraft landing gear systems
29. Inspect, check, service, and repair landing gear, retraction systems, shock struts, brakes, wheels, tires, and steering systems... (3)
b. Hydraulic and pneumatic power systems
30. Repair hydraulic and pneumatic power systems components.... (2)
31. Identify and select hydraulic fluids... .. (3)
32. Inspect, check, service, troubleshoot, and repair hydraulic and pneumatic power systems... ... (3) Page 6