Approved Training Organizations
By Tony Soulis
One of the key differences that distinguishes Canada's licensing system from that of other developed countries, is the unique role that an Approved Training Organization (ATO) plays in the regulatory process.
What are these organizations and how do they fit into the scheme of things? An ATO is an organization that has been approved by Transport Canada (TC) for the delivery of basic or aircraft type training programs that have been specifically designed to support the Canadian Aircraft Maintenance Engineer (AME) licensing system. In that regard, before approval, an applicant organization is subjected to rigorous regulatory evaluation against the applicable requirements detailed in STD 566, Division II. Thereafter, there is continuous monitoring for program quality and compliance against those same control standards. In addition to routine visits and inspections by TC personnel, an ATO will be subject to an in-depth audit on a two to three year frequency cycle.
Primarily, there are two types of ATOs: those that engage in the delivery of basic training programs at the primary or ab initio level (similar to the FAR Part 147 school approvals in the USA), and those responsible for aircraft type and systems training. In the first instance, these organizations are generally associated with community colleges or technical schools across Canada and the United States. In the later case, they are located at any number of facilities worldwide including: aircraft, engine, and other aeronautical product manufacturers; Air Operators; Approved Maintenance Organizations (AMO); Training Institutes; or in some instances, in partnership at two or more of the above.
An important point to remember about these facilities is that they may offer a wide range of training courses to the aviation industry in general. However, TC approval is only granted to a maintenance training program that has been specifically designed to support AME rating privileges. In all instances, the courses will be identified with a TC control number that coincides with the course approval basis. This number will also appear on a student's graduating certificate following successful course completion. In that regard, it provides confirmation to our Transport Canada Centres (TCC), that the AME has successfully completed an approved course, and is eligible for additional rating privileges.
Prior to program approval, both types of ATOs must document policies and procedures relating to systems management and program control in a Training Control Manual (TCM) as required by STD 566, Division II. In the case of a basic training institute, program approval is conditionally based upon TC acceptance of a course curriculum that supports licence rating. At the moment, these programs are limited to aircraft mechanical and electronics systems, but will be expanded in the near future to include airframe structures as well. Typically, these programs are of a fourteen to twenty month duration, delivered over a two to four year period, depending on program design and delivery methodology. Curricula and topic requirements are geared towards the particular licence rating that the program has been approved for. While there is some room for variance between course approvals, core training standards ensure that students receive training in a full and diverse subject matter, in preparation for licence application.
Following successful graduation from these institutes, and provided that other licensing experience requirements are met, a candidate may apply to sit the national AME examinations. Under the Canadian licensing system, successful completion of basic training is a mandatory requirement. Therefore, challenging the evaluation process as an alternative to formal training is not an option.
Once an individual qualifies for a basic AME licence, additional training becomes an on-going requirement to support additional ratings or privileges. As such, TC approves a second tier of training providers who deliver aircraft type and systems training for most of the aircraft and engine types operated on the Canadian registry. In many instances, an applicant AME may choose from among several courses and locations offered by Original Equipment Manufacturers, Air Operators, AMOs, or dedicated training providers.
As noted earlier, these organizations are located worldwide and may include multiple facilities to support a variety of product lines. TC approvals can be all-inclusive. That is, multiple locations under control of one document; or alternatively, approved on a stand-alone basis. For example, one well known Dallas-based training organization carries seven separate ATO approvals, with diverse programs located in Canada, Europe, and the United States. An advantage of the multiple-base approval option is that organizational control can be decentralized, while core training standards remain consistent system-wide. Also, in the event that document action is required at one location, it may not necessarily affect the other locations.
Earlier, I alluded to tight controls and standards that must be met prior to program approval. These additional requirements generally focus on instructor qualifications, professional development, internal self-audits, quality assurance, and expanded curricula addressing rating privileges. While it may be desirable, TC does not require an ATO to develop a stand-alone control manual (TCM). As such, where an organization so chooses, it may identify those elements of an existing program that apply to the TC approval. This approach avoids unnecessary duplication, while still maintaining program integrity. However, if this option is chosen, then the documented program must be laid out in a manner that allows for easy access by its users. This is important so that roles and responsibilities can be clearly understood by those engaged in the delivery of a TC program element. As well, it makes the auditor's job that much easier at time of review. This applies to both internal and external audit activities.
As new aeronautical products enter the marketplace, the number of ATOs will continue to grow, both in Canada and abroad. Check out the latest approved courses and ATO locations at our TC web site, under Aircraft Maintenance and Manufacturing, at: www.tc.gc.ca. The site can be especially valuable to those AMEs contemplating course attendance in support of additional licence ratings. To that end, it would be wise to check out TC approval status before committing funds or making your travel arrangements. Otherwise, from a regulatory perspective, while the knowledge gained may be useful — it may not be in your very best interest.