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
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