Last year I was in California giving a series of seminars on the new Part 145 rule, when during a break I overheard a less than happy mechanic utter these immortal words: “Just when you have a chance at winning the rat race, they bring in new rats!”
Keeping in mind the quote, here is some help to identify the new rats. I call it an overview of the repair station training program requirements.
But before we enter the maze, I want to tell you that I found it easy to mistake the words “training manual” for “training program.” They are not the same. So let’s define the term. A training program describes what training is needed and how that training will be conducted based on a needs assessment of the repair station and employees. It might help if you think of the training program as a planning document to develop a training manual.
I have divided this article into five sub-sections:
general, needs assessment of the repair station, kinds of training, needs assessment of the employees, and development of the training program.
For Part 145 repair station operators, April 6, 2006 is the effective date when your repair station must have a training program as required by 14CFR Part 145, section 145.163. But the rule does give some repair stations a little wiggle room on the actual date the training program is due. How so? Your repair station’s training program due date depends on the month your repair station was originally certificated. The program’s due date could be as soon as April 30, 2006 or as late as March 31, 2007.
Confused? Let me explain. Since April 6, 2006 is the effective date of the rule, any repair station certificated in the months April through December must have its training program submitted to its local FSDO for approval by the last day of that corresponding month in 2006. Note: that I said submitted for approval, not “approved” by that date. If your repair station was certificated in January, February, or March, your program is due on the last day of the corresponding month in 2007. However, if you are a first-time applicant for a Part 145 repair station, then your training program is due the same time as your repair station manual.
Another point that you must understand is your Part 145 repair station manual is “accepted” by the FAA, but your new training program must be “approved” by the FAA. Without asking for a Supreme Court ruling on the difference between the two words, the major difference, as far as the FAA inspector is concerned, is the difference between buying (accepting) a new truck, or being run over by one (approving it). Therefore, I recommend that your “approved training program” should be kept separated from your “accepted” repair station manual just to avoid confusion.
Since there is a greater scrutiny of your training program on the FAA’s part, I strongly recommend reading Advisory Circular 145.10 Repair Station Training Program and FAR 145.163. I also strongly recommend that you follow the directions in the AC, especially those paragraphs that use the word “should” and follow those directions without deviation.
While the AC gives you the content requirements for FAA approval, the rule permits the FAA inspector to “accept” the format of the training program so you can use any format that your organization is used to.
Another item we should cover before we get in to developing a training program is the difference between the words: “capability” and “competency.” To avoid a snit between the FAA and the European Aviation Safety Agency wordsmiths, it was agreed that both words mean the same thing: “To describe the knowledge and skills required to accomplish assigned tasks.” So you can use either word in developing your training program.
Needs Assessment of the Repair Station
Editor’s Note: In the February issue Bill O’Brien began a discussion on the new regulations for the Part 145 manual requirements.
Does one size fit all?
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