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									                                                  Federal Aviation
        Repair Station                            Administration

       Training Program
   Richmond FSDO
 Repair Station Seminar
Presenter
Elwyn Jordan

Sponsored by
The Aviation Safety Program
Mike Alakszay, ASPM

Duane Hunter
Manager, Richmond Flight Standards District
Office

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               GUIDANCE MATERIALS

• AC 145-10, Date: 7/8/05, REPAIR
  STATION TRAINING PROGRAM

• AC 120-72 Date: 9/28/00, MAINTENANCE
  RESOURCE MANAGEMENT TRAINING

• http://hfskyway.faa.gov Human Factors in
  Aviation Maintenance (FAA Web Site)


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          GUIDANCE MATERIALS con’t.

• CAP 718      Human Factors in Aircraft
  Maintenance and Inspection (previously
  ICAO Digest No. 12) (internet)


• HBAW 05-03 7-11-05 Introduction to
  8300.10, V2, Chapter RSTP, Review and
  Approve a Part 145 Repair Station’s
  Training Program


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           TOPICS FOR DISCUSSION
• Purpose of a Training Program
• The Rules
• The Training Program
      ● Organization              ● Manual
      ● Records                   ● Needs Assessments
• Course Design
• Sample Programs
• What is the FAA looking for?

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                       WHY
                     SHOULD
                 A REPAIR STATION
                       HAVE
               A TRAINING PROGRAM
                         ?
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Worldwide Commercial Jet Accident Rates
             1965-1999

       Aircraft Design
           Airway System
               FAA Initiatives
                   Technology ( Radar, ILS,GPWS)
                         Qualifications/Certifications
                                 Crew Resource Management




       Accident Rate (accidents per million departures)     6
         Worldwide Departures 1965-1999
20
18
16
14
12
10                                      Annual Departures
                                        (millions)
 8
 6
 4
 2
 0
     1965 '70 '75 '80 '85 '90 '95 '99



                                                            7
                          Primary Cause of Hull Loss Accidents
                        Worldwide Commercial Jet Fleet (1990-1999)
                       Flight Crew                                     67
PRIMARY CAUSE FACTOR




                          Airplane           11

                       Maintenance       6                                  Maintenance is the
                                                                            Primary Cause in
                          Weather        7                                  6% of Hull Losses
                       Airport/ATC       4

                       MISC/Other        4

                                     0            10     20       30        40     50      60        70      80
                                                  % of Total Accidents with KNOWN Primary Cause Factor
                                                                                                             8
                                                                                                (Boeing, 2000)
How Significant are Maintenance Factors?




               Studies found that:
• Maintenance contributed to 15% of commercial
   jet accidents (Boeing, 1995)
•Maintenance was the 2nd greatest contributor to
  fatalities, following CFIT (CAA, 1992)           9
General Aviation Stats.




                          10
                            The Heinrich Ratio



                                    Fatal Accident 1

                                  Non-fatal accidents 10

                             Reportable incidents 30

                                     Unsafe acts 600
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               PURPOSE OF A TRAINING
                    PROGRAM
• To ensure that every employee performing
  maintenance, preventive maintenance, and
  alteration, is capable of performing the
  tasks assigned (that’s the rule)
• A repair station should ensure that its
  employees are capable of performing the
  work skillfully, intelligently, efficiently,
  safely, and according to its procedures



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                     THE RULES


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        14 CFR PART 145.51 TRAINING
              REQUIREMENTS

 • An applicant for a repair station
   certificate must submit a training
   program for approval to the FAA
   as required by 145.51(a)(7).



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 14 CFR PART 145.163 TRAINING
        REQUIREMENTS
• A certificated repair station must
  have an employee training
  program approved by the FAA
  that consists of initial and
  recurrent training. For purposes
  of meeting this paragraph,
  beginning April 6, 2006,
  145.163(a).
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   14 CFR PART 145.163 TRAINING
    REQUIREMENTS CONTINUED
   • A repair station certificated before
     that date must submit its training
     program to the FAA for approval by
     the last day of the month in which its
     repair station certificate was issued,
     145.163(a)(2).


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     14 CFR PART 145.163 TRAINING
     REQUIREMENTS CONTINUED

   • Example dates for the training program to
     be submitted to the FAA:
          If your certificate was issued May 12, 1995 then
           your program must be submitted by May 31, 2006.
          If your certificate was issued January 12, 2002
           then your program is due January 31, 2007.
          If your certificate was issued April 1, 2001 then
           your program is due April 30, 2006.



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                   14 CFR PART 145.163
                   TRAINING PROGRAM
• The training program must ensure each
  employee assigned to perform
  maintenance, preventive maintenance, or
  alterations, and inspection functions is
  capable of performing the assigned task
  [145.163(b)].




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                   14 CFR PART 145.163
                   TRAINING RECORDS
  • A certificated repair station must
    document, in a format acceptable to the
    FAA, the individual employee training
    required under paragraph 145.163(c).
  • Employee training records must be
    retained for a minimum of 2 years.




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  14 CFR PART 145.163 TRAINING
      PROGRAM REVISIONS
• A certificated repair station must submit
  revisions to its training program to its
  certificate holding district office in
  accordance with the procedures required by
  145.209(e) (Revising and submitting for
  training programs for FAA approval)
• After FAA approval of the training program,
  the repair station may begin following their
  new/revised training program procedures.

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  Other Rules that INDICATE the need
            for TRAINING:
• 14 CFR Part 145, Section 145.151(a) requires
  WB to provide qualified personnel to plan,
  supervise, perform, and approve for return
  to service the aviation work that it does.

• §145.151(b) Requires a sufficient number of
  employees with the training or knowledge
  and experience to perform the aviation
  maintenance and alteration.



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   More Rules that INDICATE the need
            for TRAINING:

• §145.155 Requires repair station managers to
  ensure that inspectors are thoroughly familiar with
  the applicable regulations under 14 CFR and with
  the inspection methods, techniques, practices,
  aids, equipment, and tools used to determine
  airworthiness of the article being work on and
  proficient in using the various types of inspection
  equipment and visual inspection aids appropriate
  for the article being inspected.


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   More Rules that INDICATE the need
            for TRAINING:

• §145.207(a) Requires repair station
  personnel to follow the Repair Station
  Manual.


• §145.211(b) Requires repair station
  personnel to follow the Repair Station’s
  Quality Control System.


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           THE TRAINING PROGRAM




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        ORGANIZATION FOR TRAINING

                                                 •The Boss




             •Production                         •Training                •Quality
               •Manager                          Manager                 Assurance




                              •Authorized                •Training Record
                                  •Instructors               •Keeper


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        ORGANIZATION FOR TRAINING
Who (by title)
• Manages the training program
• Controls the program document
• Approves specific courses
• Approves Employees to be instructors
• Keeps training program files including general and
  individual assessments
• Keeps personnel training records
• Plans for future training needs & recurrent training
• Determines the need for remedial training
• Reassesses the training program periodically


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    TRAINING PROGRAM MANUAL
           STRUCTURE
• May be in the Repair Station Manual
  and subject to revision according to
  the manual,
            or
• A separate document (requires a
  procedure for revising and submitting
  for CHDO approval)

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     THE SCOPE OF THE TRAINING
            PROGRAM
• Each repair station’s training program will
  be unique and based on its individual
  operation and needs.
• The AC is not the only means to develop a
  Training Program.
• AC 145-10 Appendix 1 & 2 Provide sample
  Training Programs for Large/Medium and
  Small Repair Stations.


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            TRAINING COURSES AND
                 CATEGORIES




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              TRAINING CATEGORIES
     Initial General (indoctrination) training for
      new employees covering the repair station’s
      operations.
     Initial technical training to provide new &
      existing employees taking on new job
      functions with the appropriate technical
      skills.
     Recurrent training to ensure all employees
      remain current & qualified


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                  TRAINING CATEGORIES
                                  CONTINUED


      Specialized training that may require
       special skills or a task that may have
       complex assembly operations.
      Remedial technical training to correct
       an employee’s demonstrated lack of
       knowledge or skill deficiency.


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                    TRAINING COURSES
                   Indoctrination Training
         Title 14 CFR 145 and other
          regulatory requirements
         Company manuals, policies,
          procedures, and practices
         OSHA, HAZMAT, EPA



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               TRAINING COURSES
           Indoctrination Training (cont’)
      Human Factors
      Computer systems and software
       (as applicable)
      Facility security
      Repair Station Capabilities
      Quality control processes

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     TRAINING COURSES CONTINUED
        Initial Technical Training:

        May be separate and distinct from
         Indoctrination training
        Should be based on skill level of
         individuals
        May include Ground Support
         equipment

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     TRAINING COURSES CONTINUED
            Initial Technical Training (cont’):

      Tools, Test equipment
      Materials and parts,
      Records and recordkeeping
      Shop safety
      Specific-job task training


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     TRAINING COURSES CONTINUED
            Initial Technical Training (cont’):
• Some familiar criteria…

• §65.81 General privileges and limitations.

• §65.83 Recent experience requirements




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TRAINING COURSES CONTINUED
                    Recurrent Training
      Includes training commonly known as
       refresher training and could also include
       training for new policies (one-time),
       procedures, etc.
      Procedures to determine type and frequency
       of recurrent training.
      Recurrent training may be based on the
       repair station size, capabilities, employee
       tasks, customer requirements, etc.
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   TRAINING COURSES CONTINUED
                    Specialized Training:
      May include flame and/or plasma spray
       operations, special inspection or test
       techniques, special machining operations,
       complex welding operations, aircraft
       inspection techniques or complex assembly
       operations.
      May be part of Initial and Recurrent training


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     TRAINING COURSES CONTINUED
                        Remedial training:
      Administered to rectify an employee’s
       demonstrated lack of knowledge or skill by
       providing a corrective action as soon as
       possible.
      May only require a review of procedures with
       the employee through on-the-job training
       (OJT).
      Should include what happened, why it
       happened and how to prevent it from
       happening again in a positive manner

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                         TRAINING NEEDS
                          ASSESSMENT




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TRAINING NEEDS ASSESSMENTS
     TWO KINDS
 GENERAL: The repair station’s process to
  identify (overall repair station) training
  requirements and assessing employee
  capabilities.
 INDIVIDUAL: The repair station’s procedures
  should evaluate the current capability of its
  repair station employees.


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                 TRAINING NEEDS
               ASSESSMENTS continued
       Continuing Assessment by managers and
        supervisors to ensure competent employees perform
        the work of the repair station

       Reassessment when changes arise or are planned

       Corrective Action Assessment Procedures must
        consider whether remedial training is an appropriate
        remedy for deficiencies identified by audits,
        voluntary disclosures, and repair station rework after
        delivery.


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            COURSE DESIGN
                AREAS OF STUDY
               TRAINING METHODS
              SOURCES OF TRAINING




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 AREAS OF STUDY AND COURSE
         DEFINITION
•      The repair station can develop its own
       areas of study or provide acceptable
       courses or lessons to its employees.

•      If the repair station chooses to develop
       areas of study, each area should include
       objectives, desired outcome and a list of
       available courses/lessons.


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   AREA OF STUDY AND COURSE
           DEFINITION
• The FAA inspector will assess whether the
  repair station is following its own method of
  developing and maintaining areas of study,
  courses, lessons, instructor lists, and other
  records required by the approved training
  program.




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   AREA OF STUDY AND COURSE
           DEFINITION
The FAA will not approve the areas of
 study, courses, lessons or outlines,
 time of instruction, or the material
 taught in each course.




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 TRAINING PROGRAM METHODS

• Classroom
• On the Job Training (OJT)
• Computer-based Training
  (CBT)



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       TRAINING PROGRAM METHODS

• Distance learning
• Embedded Training
• Other Methods, Include Self-
  Study, Case Study and
  Seminars


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  TRAINING PROGRAM SOURCES

• Original Equipment Manufacturers (OEM).
• Aircraft Maintenance Technicians Schools
  (AMTS).
• Operators or other Repair Stations,




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       TRAINING PROGRAM SOURCES

• Government Agencies.
• Trade Associations.
• Other sources




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                   SAMPLE TRAINING
                     PROGRAMS



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  SAMPLE TRAINING PROGRAMS

• AC 145-10 Appendix 1 & 2:
       Appendix 1 Large /Medium Repair Station
       Appendix 2 Small Repair Stations under 10
        employees (part 91)
       Elements parallel with exception of work performed
        under section 145.205 and their complexity.




Repair Station Training Program              Federal Aviation   52
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  SAMPLE TRAINING PROGRAMS
          CONTINUED
• The sample training program emphasizes
  the process, procedures, and standards that
  a repair station may use to ensure
  compliance with the regulations.
• One-man shops may require additional or
  different information not included in the AC.
• These samples may be tailored to fit the
  size and complexity of the repair station.


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               FAA INSPECTORS ARE
                 LOOKING FOR…
                        ?




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                                  HBAW 05-03

• Inspectors Guidance:
       Defines the purpose of the training program
       Explains what procedures should be addressed in
        the repair station manual
       Explains the review and approval process of a
        training program

       http://www.faa.gov/avr/afs/faa/8300/




Repair Station Training Program                Federal Aviation   55
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                            ASI CHECKLIST
• A minimum standard to assist the PI in the
  Training Program approval process.
• The elements identified on the checklist are
  derived from regulatory requirements and
  accepted industry practices.
• The checklist may be altered or modified to
  fit a wide range of applications.
• Recommended that this form or a similar
  form used by the approving official be
  retained by the CHDO.

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        ASI CHECKLIST CONTINUED
    Is the manual identified with Company name,
     address, certificate number, and other contact
     information appropriate to this manual (Phone, fax
     email, etc.)?
    Does the manual have a control system?
    Does the control system include a distribution list
     identifying a particular manual to a person or
     location?
    Does the manual contain an adequate revision
     system to allow an easy determination of currency
     and person(s) responsible for inserting the revision?
Repair Station Training Program            Federal Aviation   57
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       ASI CHECKLIST CONTINUED
       Is there a procedure for submitting revisions to
        the CHDO for approval and retaining records for a
        2-year minimum?
       Does the training program have provisions for
        initial and recurrent training?
       Does the training program adequately identify
        task requirements for the performance of
        maintenance or inspection functions?
       Does the training program adequately ensure that
        each person or position performing a
        maintenance or inspection function is capable of
        performing the assigned task?

Repair Station Training Program            Federal Aviation   58
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       ASI CHECKLIST CONTINUED

          Are individual training requirements identified
           and documented in an acceptable manner?
          Is there a method of measure or test to ensure
           the training is effective?
          Has the Advisory Circular and Handbook
           guidance been reviewed to ensure that issues
           particular to this training program have been
           addressed?
          Does the training manual qualify for FAA
           Approval?

Repair Station Training Program               Federal Aviation   59
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      EASA-ACCEPTED OR OTHER
         FOREIGN FACILITIES
• Repair Stations who hold approval under an EASA
  or other Foreign authority may already have a
  training program. However, those Training
  Programs must meet the requirements of 145.163.
  Any additional requirements imposed by the
  Foreign Authority will not interfere with an FAA
  approval.
• They must also be FAA approved, or approved in
  accordance with the procedures of an International
  Agreement.


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                                  REVIEW

• 14 CFR 145.163 Requires a training
  program.
• It should be developed based to fit specific
  Repair Station needs.
• Available guidance: the Repair Station
  Training Program Advisory Circular and
  FAA Inspector guidance, FAA Order
  8300.10.


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                                  HANDOUTS




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                                  QUESTIONS

• There are no stupid questions!

• We may not have answered all of your
  questions or alleviated all confusion;

• We hope However that at least now you are
  confused at a higher level and about more
  important things.


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                                  THANK YOU



• Elwyn.Jordan@faa.gov

• 804-222-7494 x207




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