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Repair Station Training Program Richmond FSDO Repair Station Seminar

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Title: Repair Station Training Program Richmond FSDO Repair Station Seminar


1
Repair Station Training ProgramRichmond FSDO
Repair Station Seminar
Federal Aviation Administration
PresenterElwyn Jordan Sponsored by The Aviation
Safety Program Mike Alakszay, ASPM Duane
HunterManager, Richmond Flight Standards
District Office
2
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)

3
GUIDANCE MATERIALS cont.
  • 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 Stations Training Program

4
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?

5
  • WHY
  • SHOULD
  • A REPAIR STATION
  • HAVE
  • A TRAINING PROGRAM
  • ?

6
Worldwide Commercial Jet Accident Rates 1965-1999
Aircraft Design Airway System FAA
Initiatives Technology ( Radar,
ILS,GPWS) Qualifications/Certifications C
rew Resource Management
Accident Rate (accidents per million departures)
7
Worldwide Departures 1965-1999
8
Primary Cause of Hull Loss Accidents Worldwide
Commercial Jet Fleet (1990-1999)
(Boeing, 2000)
9
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)

10
General Aviation Stats.
11

The Heinrich Ratio
Fatal Accident 1
Non-fatal accidents 10
Reportable incidents 30
Unsafe acts 600
12
PURPOSE OF A TRAINING PROGRAM
  • To ensure that every employee performing
    maintenance, preventive maintenance, and
    alteration, is capable of performing the tasks
    assigned (thats 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

13
  • THE RULES

14
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).

15
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).

16
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).

17
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.

18
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).

19
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.

20
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.

21
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.

22
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.

23
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 Stations Quality Control
    System.

24
THE TRAINING PROGRAM
25
ORGANIZATION FOR TRAINING
26
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

27
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)

28
THE SCOPE OF THE TRAINING PROGRAM
  • Each repair stations 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.

29
TRAINING COURSES AND CATEGORIES
30
TRAINING CATEGORIES
  • Initial General (indoctrination) training for new
    employees covering the repair stations
    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

31
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
    employees demonstrated lack of knowledge or
    skill deficiency.

32
TRAINING COURSES Indoctrination Training
  • Title 14 CFR 145 and other regulatory
    requirements
  • Company manuals, policies, procedures, and
    practices
  • OSHA, HAZMAT, EPA

33
TRAINING COURSES Indoctrination Training (cont)
  • Human Factors
  • Computer systems and software (as applicable)
  • Facility security
  • Repair Station Capabilities
  • Quality control processes

34
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

35
TRAINING COURSES CONTINUED Initial Technical
Training (cont)
  • Tools, Test equipment
  • Materials and parts,
  • Records and recordkeeping
  • Shop safety
  • Specific-job task training

36
TRAINING COURSES CONTINUED Initial Technical
Training (cont)
  • Some familiar criteria
  • 65.81 General privileges and limitations.
  • 65.83 Recent experience requirements

37
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.

38
TRAINING COURSES CONTINUEDSpecialized 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

39
TRAINING COURSES CONTINUEDRemedial training
  • Administered to rectify an employees
    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

40
TRAINING NEEDS ASSESSMENT
41
TRAINING NEEDS ASSESSMENTS
  • TWO KINDS
  • GENERAL The repair stations process to identify
    (overall repair station) training requirements
    and assessing employee capabilities.
  • INDIVIDUAL The repair stations procedures
    should evaluate the current capability of its
    repair station employees.

42
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.

43
COURSE DESIGNAREAS OF STUDYTRAINING
METHODSSOURCES OF TRAINING
44
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.

45
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.

46
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.

47
TRAINING PROGRAM METHODS
  • Classroom
  • On the Job Training (OJT)
  • Computer-based Training (CBT)

48
TRAINING PROGRAM METHODS
  • Distance learning
  • Embedded Training
  • Other Methods, Include Self-Study, Case Study and
    Seminars

49
TRAINING PROGRAM SOURCES
  • Original Equipment Manufacturers (OEM).
  • Aircraft Maintenance Technicians Schools (AMTS).
  • Operators or other Repair Stations,

50
TRAINING PROGRAM SOURCES
  • Government Agencies.
  • Trade Associations.
  • Other sources

51
SAMPLE TRAINING PROGRAMS
52
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.

53
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.

54
FAA INSPECTORS ARE LOOKING FOR?
55
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/

56
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.

57
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?

58
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?

59
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?

60
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.

61
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.

62
HANDOUTS
63
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.

64
THANK YOU
  • Elwyn.Jordan_at_faa.gov
  • 804-222-7494 x207
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