Repair Station Training Program Richmond FSDO Repair Station Seminar

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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
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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 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

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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 C
rew Resource Management
Accident Rate (accidents per million departures)
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Worldwide Departures 1965-1999
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Primary Cause of Hull Loss Accidents Worldwide
Commercial Jet Fleet (1990-1999)
(Boeing, 2000)
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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)

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General Aviation Stats.
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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 (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

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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 Stations Quality Control
  System.

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THE TRAINING PROGRAM
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ORGANIZATION FOR TRAINING
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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 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.

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TRAINING COURSES AND CATEGORIES
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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

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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
  employees 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 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

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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

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TRAINING NEEDS ASSESSMENT
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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.

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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 DESIGNAREAS OF STUDYTRAINING
METHODSSOURCES 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.

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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/

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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?

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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?

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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?

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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_at_faa.gov
• 804-222-7494 x207