New Rats: Repair Station Training Requirements Overview

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.

General Information

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

Since the overall purpose of a training program is to ensure that the product coming out of the repair station is airworthy, the first step should be to define the product(s) and each of the processes that you use to maintain it.

Caution! Many would-be-training program authors will give this step only a cursory peek. Why? They figure they have been doing the same work, in the same place, forever, and they don’t need any stinking assessment of what they do every day. They are wrong! It is very important that you take your time and get the true picture of your repair station products, and the work performed, so you can define the training needs based on the tasks performed.

Before I would start my actual walk around, I would first look in your repair station manual and find your repair station’s capability list (Ref: 145.215). This list identifies the products your repair station is allowed to sign off. Next, get down on the floor and identify the tasks for each of those products as well as those associated tasks to make it airworthy. This includes inspection, supervision, and recordkeeping tasks.

After you have performed your needs assessment of the repair station’s products and tasks, you should have a good idea on how your training program will be formatted. For example, the training program could be designed to address training by product line, or for individual shops within your repair station, or by the tasks performed by individual employees. This assessment should also identify which tasks would require more technical training based on complexity versus those tasks which require less. A smart person would document how the needs assessment was accomplished and put that in a chapter or section of the training program. Why? Well, first of all because it is required to be in the program and second, the next time a needs assessment must be performed you have a template to guide you.

Kinds of Training Required

AC 145.10 breaks up employee training into three categories. They are:

1. Initial training which includes:
indoctrination, technical, and specialized
2. Recurrent
3. Remedial, based on demonstrated need.

Indoctrination category forms the core training for all repair station personnel. This kind of training can vary based on the tasks the employee must perform or it can be one size fits all kinds of training. While not a FAA requirement, indoctrination training is a good place to explain the repair station’s goals, objectives, culture, and values.

Indoctrination/initial training must include the following:

a. Appropriate review of Federal Aviation Regulations, such as Part 1, Part 21, 39, 43, 91, 121, 135, and 145 and how the repair station complies with these regulations.
b. Use of repair station’s manuals, policies, procedures, and practices including quality control, processes, etc.
c. How the repair station complies with Department of Transportation hazardous materials requirements, OSHA, and EPA regulations, as well as any appropriate local, state, and federal laws requiring training for different employee job tasks. While it is a good idea to have all the required training in one place, I would put this “other agencies” required training in a separate chapter/section in the training program, and identify that chapter/section as not required by the FAA so that chapter/section does not have to be “approved.”
d. Training in human factors is required. See the list of required subjects in AC 145.10 page 10.
e. Training in computer systems and software applications that relate to the operation of the repair station are also required.
f. And in this day and age, you have to train your employees on how security is maintained in and around the repair station facility.

Technical training is next. With your list of each of your product’s maintenance tasks that you identified during your repair station’s needs assessment in your hot little hand, you can now develop the technical training that each employee may need to perform that task.

For example, using tasks associated with an engine overhaul, the repair station might determine that each employee must have factory training on engine overhaul procedures and practices, or the repair station might determine that in-house training reinforced with OJT performed by an experienced repair station employee or contractor is the right way to go.

The technical training requirements can also be tailored to fit the employee’s own level of skills. For example, if your new employee’s last name is Lycoming and he just moved in from Williamsport, PA, there is a good chance he might not need the same amount of training on a 0-320 engine overhaul as I would. But on the other hand, I can’t fault the one size fits all kind of training either. At least you know all the bases were covered.

Specialized training is perhaps the easiest kind of training to be identified. This training is almost always associated with performing a complex task, such as plasma welding, special machining operations, or nondestructive inspection techniques.

Recurrent training or as it is sometimes known as refresher training is a good time to take care of the fuzzy areas that develop in one’s memory synopsis over time, as well as include new information or procedures. Recurrent training can concentrate on a single task or all the tasks the employee must perform. The ideal is to schedule recurrent training at least once every 12 months but no longer than 18 months, but remember the operative word here is “scheduled.”

Remedial training is the best indicator that your training program is working or it’s a documented failure. Usually, the need for remedial training is identified by a need for rework of a repair station product, or the need could come from a quality control problem brought to light from an accident investigation. Remedial training should be designed to fix an immediate knowledge or skill deficiency and may focus on a group of employees or only one individual. If you find a great need for remedial training, revise your training program.

Needs Assessment of the Employees

The purpose of this assessment is to marry the task requirements to the employee’s training requirements. Remember, the repair station is only required to identify the training requirements of those individuals who perform maintenance, preventive maintenance, alterations, and tasks permitted under Part 145. The repair station may include in its training program support personnel or manage technical personnel; however, the program must be clear on which employees are required to be trained under Part 145 and those employees trained at the repair station’s discretion.

The first place I would look to start a needs assessment on each employee would be in his or her personnel file or training record if there is one. This would give me a snapshot of his or her training history. I would look for evidence of training in the form of number of training courses attended, or industry certificate of training such as in composites or NDT. An oral or written test or a practical test can be used to determine an employee’s level of knowledge and skill, or an on-the-job assessment can be performed. The choice is up to the repair station but whichever kind of needs assessment is chosen it should be identified in the training program. Now with the tasks identified and the employee’s training needs identified it is now time to write the training program.

Developing the Training Program

First, remember that I told you that the FAA inspector “approves” the training program. That is true; however, he only accepts the training courses identified in your program. This sounds a bit strange at first but the rule requires that your training program identify only the training needed and how it will be accomplished. Approving the course content is not a requirement of FAR 145.163. If that was the case, we would have to hire 50,000 new employees just to stamp “FAA approved” on all the OEM and industry-developed courses that are available.

The training program should describe what the training course should contain. The course should have at least the following: (Ref: AC 145.10, page 19.)

a. Minimum student qualifications prescribed by FAR, or by the repair station needed to take the course
b. Instructional aids, such as course manuals, tooling, equipment, etc.
c. Training methods, such as lecture, visual aids, computer based
d. Source of the training material and methods and instructor’s qualifications
e. Course outline — lesson or module format
f. Length of the course
g. Training forms and records to document student progress
h. Supporting information such as courseware, lesson plans, and instructor guides

Second, identify the training methods, (Ref: AC 145.10 page 20).

a. Formal training. This type is usually found in an AMT school. The course should include an objective course outline that describes the subject areas covered, expected outcome, list of reference materials, instructor qualifications, and how well the information was transferred to the student. This is a fancy way of saying some kind of a test is needed.
b. On-the-job training (OJT). This training method is perhaps the most used and least documented of all the methods out there. OJT is when an experienced individual explains to a student how a particular task is performed, shows how the task is performed, and then has the student perform the task without help. Your program should explain the process, identify the skill level needed, how that level of learning was achieved, and how OJT will be documented in the employee’s file.
c. Computer-based training. This method must be identified. Thankfully, most CB training I have taken has the course outline and objectives included in the training program itself.
d. Distance learning. This method includes Internet-based training but could include videotaped courses or correspondence courses.
e. Embedded training. This is another form of computer-based training that uses software for testing or learning how to perform a maintenance function.
f. Other methods such as seminars, self-study, and case studies.

The repair station can employ all of these employee training methods or just stick to one kind. The repair station, not the FAA, picks the method of employee training to be used.

What are some of the common forms of training available to repair stations? Well as I mentioned, we have OEM factory training, contractors, AMT schools, other repair stations, government agencies, trade associations, and any other source you have determined that meets your training needs.

Qualifying Instructors

This is important. The repair station may set the basic standards for any instructor. You can also have a procedure for evaluating an instructor, be the instructor a repair station employee, a contractor, or a federal employee. Set the standards you want the instructor to meet. You can require student evaluations of the instructor and course content if you want. If your standard’s bar is set too low, you will trip over it.

Measuring Training Effectiveness

This means that you must determine if the employee has internalized the training received. Usually this is done by practical exam or written exam or both. Whether the student passes the course or fails is a reflection on his or her abilities, the training program design and execution, and the instructor’s ability to transfer information.

Documentation

Last but not least, you have to explain in your program how you are going to document the employee’s training and state that the record of training would be kept for at least two years. Review AC-145-10, pages 23 and 24 for a good outline on what is required.

In closing, developing this training program is now a requirement to operate as a Part 145 repair station. The rule leaves you with two choices. You can choose to develop your training program to ensure a well-trained work force that is effective and efficient, and able to successfully compete in today’s worldwide marketplace. Or you can choose to let the rats win.

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