Make them dynamic
By Tony Soulis
In Canada, two essential ingredients of an Approved Maintenance Organization's (AMO) documented program are maintenance release authority and a complementary training plan to support on-aircraft maintenance release privileges. The two go hand-in-hand and are mandatory requirements that must be in place at the time of program approval. Let's examine the how and why of these important program features to gain some insight into why effective training must be dynamic.
CAR 573 is the standard that details the requirements an applicant for an AMO certificate must meet to demonstrate that maintenance activities will be performed in a controlled environment. To achieve this, a candidate organization submits a documented program to the regulator, addressing the applicable elements of the standard to support the scope of authority being sought. Once accepted and followed, the approved program provides the regulator with a level of comfort that the controls in place are sufficient to ensure adequate maintenance performance standards.
One of those requirements has to do with the manner in which the organization identifies and controls qualified individuals to release aircraft to service. This is commonly referred to as the Aircraft Certifying Authority (ACA) control process. The way it works is like this: The organization must identify and document the qualified individuals who have been authorized to sign maintenance releases. To do this, the organization must first ensure that the individual is the holder of a valid and appropriately rated Aircraft Maintenance Engineer (AME) License; that he or she, has received initial aircraft type, system, or process training relevant to the organization's particular aircraft model, series, and type; and that upgrade training is provided, consistent with the type, model, and series of aircraft being released under the ACA. In all instances, initial and update training should provide both the organization and individual with sufficient confidence that maintenance releases are being issued by knowledgeable AMEs.
The criteria governing initial training requirements are very straight-forward. From a regulatory perspective, they must be driven by the privileges associated with the AME rating and ACA, as applicable. In that regard, an AME moving from one organization to another can expect to have his or her bring-factor assessed by the new organization to measure any differences between the newcomer's capabilities and the requirements of the new organization. For example, an individual may have received an aircraft type course from company A, which provided fleet or aircraft model training specifically designed to satisfy their particular fleet requirements. However, when measured against company B's fleet, the differences may be sufficient to require additional bridging, or differences training, to address the variance. That evaluation procedure must precede any ACA issuance in all instances. This is a controlled, documented process within the organization that must withstand regulatory scrutiny, from routine inspection to formal audit.
In the case of on-going, or update training, the criteria are less specific. However, STD 573 requires organizations to have a system in place to provide all technical personnel engaged in the release of aircraft with some degree of annual update training. What is this training supposed to achieve, and what constitutes sufficient training to satisfy this requirement? Don't look for a definitive number of hours, days, or any other tangible figure in the CARs — there aren't any. This AMO policy requirement was intentionally left open-ended by the regulator because of the many variables that can influence an effective update training program. For instance, how could you rationalize fixed content or terms for two different operators with similar fleet sizes but different histories?