Recurrent Maintenance Training
Badly needed, often neglected
By Stephen P. Prentice
The accident was simple. The trainer's engine failed to produce sufficient power on takeoff and the instructor and student pilot were severely injured in the forced landing. The aircraft was totaled. In due course, the inevitable lawsuit ensued claiming damages for personal injury. The maintenance records were pawed over by the lawyers and the FAA looking for something to support the allegations of negligence and violations of the FARs.
Training records became the focus of the investigation because the aircraft was a new type. Although, no training discrepencies were found and the mechanics were cleared, the incident did serve as a reminder of the importance of training and of maintaining accurate training records.
Recurrent training is often overlooked or neglected at both repair stations and air carriers although it is mandated by the FARs. When an incident occurs, a question often asked is, "Were the technicians qualified to work on the aircraft?"
We all know a certified repair station has a training requirement mandated under FAR 145.2(a) where the repair facility does work on any air carrier aircraft. Although training is not specifically spelled out, the language states that stations supporting air carrier operations must comply with the carrier maintenance procedures. A repair facility that does not work on air carrier aircraft need not have a training program under the present regulation. But - and it's a big but - the person repairing an aircraft must still be "qualified" as indicated in FAR 65.81: General Privileges and Limitations:
"(a) A certificated mechanic-may not-approve and return to service, any aircraft-unless he has satisfactorily performed the work concerned at an earlier date. - (b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manual, for the specific operation concerned-"
FAR sections FAR 121.375 and 135.433 maintenance and preventative maintenance training programs would be of significance during an audit or other inquiry given this statement:
"Each certificate holder...or person performing maintenance for it, shall have a training program to insure that each person (including inspection personnel) who determines the adequacy of the work done is fully informed about procedures and techniques and new equipment in use and is competent to perform his duties."
Training records documented?
In the case of a certified repair station working on air carrier aircraft, the FAA inspector assigned to the facility should look at current training records. Further oversight should be accomplished by the air carriers technical representative on site. All employees should be listed and training history documented. When an employee leaves he or she should ask for a copy of these records to take to the new job.
A technician can build up a substantial training record based on his formal training, the aircraft he works on, and a description of the type of work performed. To make sure your training records are accurate, it would be wise for each individual technician to keep a log with his training record included. A personal journal listing each aircraft and specific work performed would be an excellent addition to your résumé. Canadian technicians (AMEs) are required to maintain a personal log of the work they perform.
The alternative to a detailed log is, of course, transcripts of previous training or school records. Note that FAR 65.81 requires that you be able to show that you have been taught to use and understand maintenance manuals of the manufacturer as well as the applicable Federal Aviation Regulations. This is clear-cut when you have transcripts of school records that contain the course description (keep your school catalogs) and hours devoted to the material.
When you attend a factory school, you should keep a detailed listing (curriculum) of the subject matter taught, the hours in attendance, and any diploma issued.
What do you do when the company gets a new aircraft or the maintenance facility is faced with working on a new (to the shop) aircraft? Does the company send some of the technicians to initial training on the aircraft?
Certainly, it would be prudent and in my opinion required by the FAR, that new equipment demands new training. If the company was to look closely at their overall insurance requirements, they may well find this spelled out someplace.
Part 121 and 135 air carriers are, as previously stated, required by FARs to provide initial and recurrent maintenance training. Likewise, where a repair facility does the work for an air carrier, the technicians must have initial (indoc) and recurrent training in accord with the air carrier's general operations manual and general maintenance manual. (Part 135 operators may not have a maintenance manual.) The form of the training can be varied and comprehensive - from in-house or on the job training, formal classroom training, or vendor-supplied training programs (i.e FlightSafety, SimuFlite etc.).
The proposed PART 145
As we all should know by now, there is published a Notice of Proposed Rulemaking (NPRM) dealing with FAR 145 repair stations.
A key change noted in the new proposed regulation is the addition of an enhanced training requirement that would include an FAA- approved training manual and program.
Proposed FAR 145.159 training requirements
(a) Each certificated repair station must have an employee training program that consists of initial and recurrent training and is approved by the Administrator.
(b) The training program must ensure that each employee assigned to perform maintenance, preventive maintenance, or alterations, and each employee assigned to perform inspection functions is capable of performing the assigned task.
(c) Each certificated repair station must document, in a form acceptable to the Administrator, programs pertaining to individual employee training. Individual training records for those employees who require training under the requirements of (b) must be retained for the duration of each individual's employment.
The proposed changes to Part 145 will clearly enhance aviation safety by ensuring that each employee who works for the station is capable of doing the work and would furthermore insure the same level of training required under Part 121 and Part 135.
Stay tuned to see if the proposed regulation becomes law.