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.)
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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