Training: Does one size fit all?

Does one size fit all?


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.

Conclusions

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.

One-size-fits-all programs

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!

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