The Federal Aviation Administration (FAA) has significantly changed Title 14 Code of Federal Regulations (CFR) Part 145, which governs foreign and domestic repair stations. In particular, there is a new provision -- 14 CFR 145.163 -- that requires each repair station to submit a training program to the FAA for approval no later than April 6, 2005.
To assist industry and FAA inspectors in complying with this requirement, the FAA asked a research group to identify the current state of training to provide guidance. The group has made recommendations for establishing training programs at repair stations. This report will have an influence on FAA policies on training and affect the direction of the new Advisory Circular describing the approved repair station training program. Many of the same issues were addressed in the Part 66 rewrite that had many positive and negative comments to the final Notice of Proposed Rulemaking but did not become regulation. In the case of Part 145, regulations are already in place and the recommendations from the research group and upcoming Advisory Circular are one way but not the only way to comply with the regulation.
The research team reviewed the FAA's and other aviation authorities' requirements on repair station training and conducted interviews. The general consensus was that the FAA should specify hourly requirements as well as acceptable content and format for the training programs. Due to the diversity of the maintenance segment of the aviation industry, the challenge for the FAA is to create a reasonable compromise between an acceptable minimum of formalized training at smaller, less complex repair stations without reducing the training offered by the larger repair stations. Having very specific hour requirements for very specific categories may have interesting cost considerations.
Based on the 14 CFR 145.163 regulatory requirements, the current state of training at repair stations, and the interview results, the report offers guidance and recommendations on establishing an approved training program at repair stations. The report discusses the elements and functions that constitute an effective training program and the recommended number of hours and topics for training repair station mechanics, managers, supervisors, and inspectors. The research team recommended that the FAA build on existing tools to create an effective template for repair stations to design their training programs. This will allow repair stations to develop realistic training programs which build on current knowledge and skills. This comprehensive training plan is required to ensure that the training activity focuses on each organization's performance objectives and goals. And individual repair stations can use the plan and expand it to suit their needs.
The research team also suggests minimum basic hour requirements in repair station training programs with initial and recurrent training phases for each category of mechanics, managers, and inspectors. Repair stations should be allowed to conduct the recommended training in-house or to contract with an outside vendor or a 14 CFR Part 147 school. The FAA may establish a standard mechanism for tracking training in general and on-the-job training in particular.
Formal and hands-on training
The report states that most airframe and powerplant mechanics acquire their required skills through a combination of formal training and hands-on experience. Many mechanics obtain their formal training through maintenance training schools certificated under 14 CFR Part 147, which establishes minimum curriculum requirements and certain hour and level of instruction requirements.
The research report, in my opinion, does not fully address all issues related to repairmen and non-certificated personnel. A supervisor employed by the repair station inside the United States must be certified under Part 65. Each person authorized to return to service under the repair certificate and operations specification is certified under Part 65. Under both regulations there is no requirement for an individual to hold a mechanic certificate with an airframe and/or powerplant rating. Those with repairman certificates may perform these functions. The A&P certificate shows qualification but the person is the repair station not an individual.
There are many methods available to deliver training. Certain training methods are more appropriate than others for teaching specific types of skill and knowledge. These can be classified into the following categories:
- Classroom (formal)
- On-the-job training (OJT)
- Computer-based training (CBT)
- Distance learning
- Internet/intranet training
- Just-in-time/embedded training
Sometimes the distinctions between these training categories can become blurred. CBT may be used in a classroom setting for example. However, these categories are a useful framework for the discussion of training alternatives. The report addresses each method.
According to the research team some of the people interviewed were concerned about the economic effects the new requirements would have on their businesses, but the majority supported enhanced training of repair station personnel and provided constructive information. The FAA personnel expressed concern about the nature of the guidance and wanted it to provide adequate guidelines for their review and approval of programs.
Some respondents recommended that the FAA should issue clear guidelines for approved training programs that specify the types/requirements of training, the specific training the FAA would require, the minimum acceptable hourly requirements, the frequency of training, and how to quantify and qualify on-the-job training (OJT).
After the revisions to the rule, the requirements of 14 CFR 145.163 are in a general form and do not stipulate exactly what the training programs should include. Instead, the rule states that "a certificated repair station must have a training program approved by the FAA that includes initial and recurrent training." The rule further states that through this approved training program, repair stations must ensure that "each employee assigned to perform maintenance, preventive maintenance, or alterations, and inspection functions is capable of performing the assigned task." Repair stations are also required to document their training in an acceptable format and to retain these records for at least two years.
Standards of training
The standards of performance, detailed by the research team, would establish the minimum threshold criteria for all repair station training programs. They also provide a minimum acceptable level of performance that is achievable by this segment of the industry through initial and recurrent training. They stress that it is important that all repair station training remains current with technology and industry advancements.
Maintenance resource management
Maintenance resource management (MRM), or human factors, is part of the soft skills that have come to the forefront in the aviation maintenance business. MRM allows employees to better understand their role in the company's operation and its efforts to achieve a safe and error-free maintenance product. Over the past few years, research has proven the value of MRM in reducing maintenance errors. Many feel that human factors training for error reduction is an effective means of raising the standards. But selling the idea to mechanics can be tough. And the support of mechanics is essential to any successful human factors error-reduction program.
Recommendations of research team
The team suggests that in order to provide standardization and consistency, all advisory or guidance material published on the 14 CFR Part 145 approved training program should clearly identify the Federal Aviation Administration's (FAA) intended goals and objectives and provide a process to measure the training programs' effectiveness in a manner that can be used as a standard guide by both industry and regulators.
Most FAA-certificated repair stations have some form of training currently in place, although training may not be formally documented or conducted on a regularly scheduled basis. The FAA should build on existing tools to allow repair stations to develop realistic training programs that FAA aviation safety inspectors (ASI) will approve.
Based on this research and interviews, the following sample of minimum ranges for basic hour requirements in repair station training programs are recommended:
Repair stations should be allowed to conduct their own training in-house or to contract their training needs with an outside vendor or institution such as a 14 CFR Part 147 school.
The FAA may wish to establish a standard format for tracking training, in general, and on-the-job training (OJT), in particular. There seems to be a need in the industry to provide portability and consistency for mechanic training records.
The research team said that a justifiable duration for mechanic recurrent training hours appears to be the eight-hour minimum that is already established for IA renewal. It is reasonable to require at least that number of hours for all employees that are authorized to approve for return to service products at a repair station. A minimum value for initial training has less obvious parallels among existing requirements. It would be reasonable for it to exceed recurrent training periods or even double them based on the complexities of the maintenance performed by the repair station. This initial training period could be adjusted based on the level of experience a new employee brings.
However, there will always be areas such as company procedures and documentation that will be unique to the repair station and essential to the new employee's integration into the repair station work force. The structure of repair station programs should be based on existing requirements for 14 CFR Part 147 school curriculums, which are found in the appendices to 14 CFR Part 147, as well as the A&P certification requirements outlined in AC 65-2. These are well-established and have proved adequate for the formation of thousands of A&P mechanics. And, although the guidance material of the relevant International Civil Aviation Organization (ICAO) documents is general in nature, training program requirements should meet the intent of the ICAO standards and recommended practices.
The FAA should also take the opportunity of issuing concise guidance on repair station training programs to address some areas of concern in the industry, such as the standardization and portability of training records -- especially OJT records. The FAA should encourage this and provide avenues for mechanics to translate their increased training and skill sets into FAA awards or certificates.
During interviews some FAA personnel stated that it would be difficult, if not impossible, to create a generic training program that supports one-size-fits-all to apply to repair stations of all sizes and complexities. However, if the same building blocks are used for all programs and repair stations are given sufficient flexibility, it might work. The ASIs interviewed often see problems with regulatory compliance at repair stations that do not have training programs in place. No one that I have assisted has ever refused to do the training necessary to get the airplane or article safely back in the air. Training has value. All of us will be studying the Part 145 training guidance and advisory material very closely. Does one-size-fits-all training program really fit all? Keep 'em Flying!
This report is available at the Federal Aviation Administration William J. Hughes Technical Center's Full-Text Technical Reports page: actlibrary.tc.faa.gov in Adobe Acrobat portable document format (PDF).
Report No. DOT/FAA/AR-04/36, Title 14 Code of Federal Regulations Part 145 Approved Training Program -- Research and Recommendations, Final Report, Report Date - October 2004.
Fred Workley is the president of Workley Aircraft and Maintenance Inc. in Alexandria, VA, Indianapolis, IN, and San Jose, CA. He holds an A&P certificate with an Inspection Authorization, general radio telephone license, a technician plus license, ATP, FE, CFI-I, and advance and instrument ground instructor licenses.