What Do the Regulations Mean?

We have been waiting for the new AC 145 – 10 Training Advisory Circular for a number of years and now it has arrived. The deadline for compliance will vary as per the advisory circular but April 6, 2006 is the first date that is in effect for the training requirement, less than five months away.

The advisory circular is a guide on how to develop and tailor a training program that is beneficial to individual repair stations. There are a lot of good ideas and examples on how this can be done. When you read through the advisory circular there are notes about FAA requirements and European Aviation Safety Agency (EASA) requirements. The FAA maintenance human factors training requirements are for managers and support staff who perform maintenance (including inspection), preventative maintenance, and alteration duties. If your shop is EASA approved, the bilateral agreement states that all staff including repair station owners need to participate in human factors workshops (initial and recurrent) every two years.

Benefits of Training

Training is a necessary component of our dynamic and ever-changing industry. Pilots have had mandatory initial and recurrent training for years.

How is it that maintenance technicians and managers have slipped through the cracks? Professionals in other occupations must take training to maintain their licenses to practice. Different professions have varying requirements for annual continuous education training measured in continuous education units (CEUs) based on the length of the actual training class.

We often see case studies of very successful airlines and repair stations that have proven that the investment they make in their employees by providing them with excellent training and support is worthwhile. Employee feedback and ideas pay back tenfold. The paradigm shift is to support their feedback and ideas. Invest in your employees and their careers then take a moment to step back, as there is nothing like seeing an educated and motivated technician succeed. Measurable benefits such as improved efficiency, reduction in errors, reduction in re-work, and improved communications are but a few of the benefits companies have realized.

I have just facilitated human factors training for an organization that has 70 employees. After the training was completed, I spoke with the director of maintenance who noted that its maintenance training budget increased from $0 to $250,000 in the last year. Since implementing the human factors training program, employee turnover has been reduced, morale is higher than ever before, and production has improved substantially. The bottom line: the profit margin has increased accordingly.

Despite the proven pay back for an investment in training, there are still shop owners who look for the easiest and cheapest way to comply with any regulatory requirements for training. In the case of human factors training, this mentality will not work. In order for human factors training to be effective, owners and senior managers must buy in to the program and give it the priority and budget necessary to implement an effective human factors program. If upper management does not create and support a corporate culture that fosters human factors awareness, the money invested toward human factors training will be spent in vain.

Human factors training for aviation maintenance managers and technicians is not only a requirement of the new advisory circular but it is also a critical element of a safety management program (which will be a requirement by the FAA in a few years and already is required in Canada).

Safety Management System

A safety management system (SMS) is a systematic business-like approach to organizational safety and a comprehensive process for the management of safety risks. Similar to all management systems, a SMS provides a framework for goal setting, planning, and measuring performance. A company’s SMS defines how it intends to manage a safety program and to be conducive as an integral part of the company’s business management activities. A SMS is woven into the fabric of an organization. It becomes part of the culture; the way people do their jobs.

The key to success of a SMS:

  • Create a plan with sufficient detail to secure a policy-level commitment from leadership with the work force buy-in to maintenance human factors training.
  • Write the policies and procedures needed to implement the event investigation process.

  • Select a manager/department to be responsible for the event investigation process, usually the quality assurance manager.

  • Review the investigation findings to select areas of improvement then ensure improvements are being made.
  • The purpose of an event investigation process is to manage the risks from events caused by human actions that may affect flight safety, personal injury, and equipment damage. Event investigation programs help to identify contributing factors to errors and violations and to create corrective actions to prevent future events. Examples include hard-to-understand procedures, time pressure, distractions, fatigue, poor communication, and a variety of additional workplace and life conditions.

    A well-thought-out and reasonable consistently applied company disciplinary policy is required to handle errors and violations. An error is a human action that unintentionally deviates from the required, intended, and expected action. A violation is a human action that intentionally deviates from company or regulatory policies or procedures.

    The operator’s manual for human factors in aviation maintenance (www.hf.faa.gov/opsmanual) outlines three benefits to human factors training:

    1. It is instrumental in fostering a positive safety culture.
    2. Human factors training for the work force, including for the leadership, is a critical and cost-effective first step in identifying methods to recognize, understand, and manage human performance issues.
    3. Effective human factors training not only improves work performance, but also promotes work force physical and psychological health.

    As leaders and technicians in sour industry we need to be proactive in 2006 and establish a successful training program for all to ensure we maintain our competitiveness in this dynamic aviation industry. We now have our guidelines, adopt them and give employees the training they need to excel. This not only makes good regulatory sense but good business sense.