Ready or Not, 145 Training is the Law

Ready or Not, 145 Training is the Law

Training programs for those who work at 14 CFR Part 145 repair stations become mandatory on April 6, 2005. As of that date, most repair stations (depending on their date of certification) must have an FAA-approved training program in place. The program must include initial and recurrent training for employees. The regulation is 14 CFR 145.163.

There was plenty of warning for Part 145 repair stations; when the new Part 145 rules took effect two years ago, the rule requiring training programs was included. Some repair stations have delayed preparing training programs citing lack of FAA guidance. Indeed, the FAA only recently released a draft advisory circular that outlines some recommended procedures to creating training programs that will meet the requirements of the rule. Advisory circulars are merely recommendations, however, and there was nothing to prevent a repair station from working on training programs well before the deadline for the rule loomed.

The draft advisory circular (available at the Aviation Maintenance Resource Archive at www.aviationmx.com/reports/avmaintenance/papers/index.html) is just one way of complying with the rule. FAA inspectors may look more favorably on submitted training programs that take the AC into account, but repair stations are free to devise training programs of their own creation and that meet their own unique requirements.

It appears that the FAA writers who drafted the AC took into account a report issued in October 2004 that studied the Part 145 training program situation. The report, created by consultants F.J. Leonelli Group, was sponsored by the FAA's Office of Aviation Research (also available at the above website). "To assist industry and FAA inspectors in complying with this requirement," the report stated, "the FAA Flight Standards Aircraft Maintenance Division (AFS-300) requested theh Risk Analysis Branch (ATO-P) to research the current state of training and to provide guidance and recommendations for establishing training programs at repair stations."

The report's research team looked at FAA and other countries' aviation maintenance training requirements, plus spoke to FAA and industry personnel. "The general consensus," the report said, "was the FAA should specify hourly requirements as well as acceptable content and format for the training programs." The FAA was also urged to take into consideration the different sizes of repair stations and not apply a one-size-fits-all requirement.

Following are some of the major recommendations made by the research report and by those who were interviewed for the report:

• Performance-outcome-based curriculum with no mandated time per task.
• Employees can receive credit for tasks for which they can demonstrate an acceptable level of performance.
• Include general concepts such as safety, team building, human factors, and error analysis in training program.
• Create a system to monitor and assess employee progress and performance, including practical examinations, written, and oral testing.
• Teach the "most important areas in maintenance," inspection and troubleshooting.
• Teach a core set of instruction to include regulations, company indoctrination, workplace hazards (OSHA and EPA requirements, plus hazmat training), shop safety, and human factors.
• Allow repair stations to use on-thejob training or outside training vendors to meet the requirements.
• Part 147 schools should look at the training rules as an opportunity to create new training courses for Part 145 repair stations.
• The FAA might establish a standard training tracking format to aid with portability of training records.
• FAA airworthiness safety inspectors need to be trained so they can effectively guide, evaluate, and monitor Part 145 training programs.

The draft advisory circular is a useful document, because repair stations can use it to begin preparing their training programs for the April 6 mandate. The AC does include a section that provides some deadline relief for certain repair stations so that the FAA doesn't get flooded with training programs on April 6, but each repair station should confirm its own deadline before submitting its program.

The reason for the rule change and the new training requirement is safety, according to the AC. "If repair stations do not have proper initial and recurrent training," draft AC 145-RSTP stated, "the maintenance performed and, consequently, safety could be affected. This training program will enhance aviation safety by ensuring each employee who works for a repair station is fully capable of performing that work."

The rules that govern airlines and charter operators already require training in the air carrier's specific maintenance procedures (Part 121.375 and 135.433). The new rules will help balance the level of safety by bringing all repair stations up the maintenance training standards of Parts 121 and 135.

The first requirement to meet the training rule is to create a training manual. Two appendices in the AC provide sample training programs, one for large/mediumsize repair stations and one for small repair stations. A small repair station is one that might have a manager who is also the chief inspector and accountable manager working with two technicians and one support person. Of course, there are repair stations smaller than that, but this appendix should be applicable to those as well.

For repair stations that are still wondering how they are going to implement a training program by the deadline, they may want to consider just copying the applicable appendix and making necessary changes to adapt it to their operation. The FAA has done a lot of the work, and it's likely these appendices aren't going to change by the time the final AC is released.

The AC does recommend that repair stations develop a training manual separate from the repair station manual so that updates are easier to accomplish and approvals will be simpler because the training program must be approved while the repair station and quality control manuals do not.

There are five types of training that the manual should cover: indoctrination for new employees, initial technical training for technicians moving to new job functions, recurrent training, specialized or advanced training for specialized tasks, and remedial training to correct deficiencies.

The AC makes clear that the FAA is not going to require a minimum number of hours of study or even a list of courses, but the AC does provide a list of questions that should be answered by the training manual. Some of these include:

• "Is there a measurement of effectiveness?"
• "Are there written procedures for maintaining personnel training records?"
• "Does the training program adequately ensure that each person or position performing a maintenance or inspection function is capable of performing the assigned task?"

The new training rules give the FAA an opportunity to add some training requirements that the agency has never been able to mandate for the maintenance community, such as human factors, A portion of the template for Part 145 training programs in the advisory circular. Initial Hours Recurrent Hours Mechanics 8 to 16 8 to 16 Managers and Supervisors 10 to 20 8 to 16 Inspectors 10 to 20 8 to 16 ? ? 08 AM 0305 Industry.indd 36 2/15/05 12:04:41 PM occupational safety, hazardous materials, and facility security. Remember, these are all just recommendations in an advisory circular and carry no regulatory weight, but ACs have a way of becoming quasi-rules that tend to be referenced by regulators and those whom they regulate.

Chapter 4 is the meat of the AC and covers training program components. A significant element is going to be assessing the training requirements of the employees based on their capabilities. Such assessment could take the form of formal testing, outside certification such as NDT, welding, etc., training course completion, onthe- job assessment, or oral examination in the working environment.

Another important step is going to be identifying the training method. Suggested techniques include formal classroom instruction, on-the-job training, computer-based training, distance learning (whether computer-based or not), and embedded training. An example of embedded training might be a test box that walks the user through a tutorial before allowing the technician to perform the test.

The AC lists some possible training sources such as manufacturers, existing Part 147 A&P schools, aircraft operators and other repair stations, government agencies (the FAA has some training material online and does live seminars, too), and trade associations.

For training effectiveness, the AC suggests a few ideas. These include monitoring the quality of the product delivered to the customer, internal voluntary disclosures or complaints, and internal or external audits.

Documentation is an important issue, and the AC states that: "The repair station must document, in a format acceptable to the FAA, the individual employee training required..." These records must be retained for a minimum of two years.

Training is useless without ensuring that the trainee becomes qualified to do the work that he or she is assigned. The AC recommends that repair stations create a process to ensure that a person assigned to a task has received the proper training. This could be an opportunity for software providers to include some method for verifying training before a particular technician can be assigned to a task.

Significantly, the AC points out that repair stations outside the U.S. must have an FAA-approved training program that includes the same elements as those required for U.S. repair stations. Also, English is required, according to the AC: "When conducting the training needs assessment, the repair station should place special emphasis on an individual's ability to read, write, and understand the English language. All documents and records related to employee training must be in English."

The AC 145-RSTP draft advisory circular is comprehensive and full of useful information. It's too early to say what changes might result after it has been reviewed by the people in the industry who will be affected, but no matter how the AC turns out, the rules are the rules and the deadline date is approaching. - By Matt Thurber

Taking Charge of Inventory Control

Not so long ago, maintainers all over the world believed the best way to serve their customers was to keep a warehouse crammed with parts. It made sense at the time: in a pre-computer age, it could take weeks or even months to track down parts for a client's particular AOG needs. Far better to carry the cost of maintaining a huge inventory and serve customers quickly than keep costs down and not be able to serve them when they needed help. After all, if your MRO firm didn't have the part, someone else's might.

Today, the industry has changed, for the most part, although there are still holdouts for the old way of doing business. In the first category are computers, e-mail, and the web, all fast, efficient tools for locating, negotiating prices on, and obtaining needed parts. In the second category is the cost of maintaining a huge parts inventory; it's still too expensive for all but the deepestpocketed of MROs. Besides, keeping a lot of parts in stock can't help but raise the prices an MRO charges its customers. After all, someone has to pay for all that warehouse space.

Just-in-time parts, MRO-style

The concept of just-in-time ( JIT) parts acquisition isn't new. it's just a fancy term for waiting until your customer needs a specific part, then scrambling to find it for them. However, the advent of e-mail and the web married with e-commerce have turned JIT parts acquisition into a viable strategy for MROs, even when helping customers out of their AOG nightmares. The reason? Being able to search the web for the parts you need, then acquire them quickly by e-mail, allows MROs to enjoy JIT's costcutting benefits while still meeting their customers' needs.

To develop this model one step further, imagine what can happen if airlines and MROs interconnect their inventory databases, so that they can see what each other has on hand? What if they then formed a cooperative venture that allowed them to swap and sell these parts to each other, at prices below the usual going rate? The result would be lower per-company inventory costs-because each would be partners in a common virtual inventory-fast JIT responses to customer demands, lower parts costs, and thus lower prices to customers without hurting the MROs' profit margins. Supplement this with PMA parts-FAA-approved alternatives to OEM original parts with the same level of quality and functionality-and the result would be a powerful cost-cutting solution for inventory-savvy MROs.

This is precisely the logic behind AirLiance Materials (www.airliance.com). Founded in 1998 by Air Canada, Lufthansa Technik, and United Airlines, AirLiance provides its owners and customers with traceable, pedigreed aircraft parts at affordable prices. "Our goal is to sell aftermarket PMA parts at about 70 percent of what would be charged for new OEM parts," said David Sisson, AirLiance's president and CEO. In those instances where parts have to be sourced from an OEM, AirLiance's size and buying power allow it to negotiate with OEMs for lower prices.

In addition, AirLiance's members save money by searching each other's inventory for surplus new and reconditioned parts. "How we work is simple: if you need a part, you look to find it in my inventory," Sisson said. "If I need a part, I can find it in yours." AirLiance even buys surplus aircraft and has them disassembled for parts. "Parting out an aircraft this way creates a wealth of surplus parts where there were none before," he said. "Again, this saves our customers money without compromising airworthiness."

Lessons for the average MRO

Clearly, MROs can reduce inventory costs by working together with other MROs, airlines, and PMA parts suppliers to source and sell components to each other. As well, belonging to a Web-based parts location system-whether through AirLiance, an e-commerce exchange like Inventory Locator Service, PartsLogistics, or Partsbase.com, or something less formal created between MROs themselves-can provide customers with the JIT service they need and the JIT inventory benefits MROs want.

Another tactic is to get parts on consignment wherever possible, thus eliminating inventory costs entirely. Granted, it is unlikely that Pratt & Whitney will drop off a few engines for MROs to keep in stock. However, vendors such as ShelfPlus (www.shelfplus.com), WinWare, (www.wwga.com), and WebVend (www.webvend.net) are willing to provide small parts on consignment, by putting them in vending machines on the shop floor. "When a person needs a part, they go to the machine and input their badge bar code with a handheld scanner, " explained Tom Jameson, president of ShelfPlus. "Once their bar code has recognized as authorized, the employee uses a Windows-based touchscreen to specify the part they need. The vending machine releases it, the employee takes it, and then gets back to work."

The moral to this tale: today's MROs can keep customers happy while keeping inventories lean. Remember this the next time you restock your warehouse. - By James Careless

Kansas Touts Technical Training Initiative

The talk of a mechanic shortage came to an abrupt halt just after September 11, 2001. But prior to that the fear of a near-term shortage was very real. Although historical events have slowed the inevitable, the talk of a shortage is starting to rumble again, mostly in areas of the country that are considered by some less trendy or desirable.

In an effort to ensure that aircraft manufacturers in Kansas have the technical employees needed in the future, Kansas has established the Kansas Technical Training Initiative (KTTI). This effort is a public/private consortium with the mission of providing technical education to potential future employees of technical companies such as the aircraft manufacturers located in Wichita, Kansas.

Manufacturers and government leaders in Kansas formed KTTI in the late 1990s and worked to establish a technical education system that will funnel future employees into training. The aircraft manufacturers have supported the effort the most but other industries in the area are supportive as well, such as businesses needing welders and the healthcare industry. The major aircraft manufacturers in Wichita include Cessna, Raytheon, Bombardier, and Boeing.

A collaboration with Cowley County Community College was established and the KTTI resources were merged with CCCC to create an aviation technology center. The program officially opened, after some initial curriculum problems were corrected, in October, 2004. KTTI is leasing a building from Cessna, one of the many ways industry is supporting the effort.

The opening of Cessna's new gargantuan service center is fueling its support of the center. Cessna has had to lay off assembly line workers since September 11, 2001 but will need more employees in that huge new service center. Aircraft assembly line workers typically don't have A&P] certificates. But to work in the service center, an A & P is desirable, if not required. Manufacturers like Cessna are directing their laid-off assembly line workers to the KTTI initiative at Cowley County in an effort to encourage those individuals to gain their A&P certificate and then reapply for employment at the service center. "There are approximately 10,000 laid-off workers in the Wichita area since 9-11," said Noel Gary a retired FAA unit airworthiness supervisor and currently chief executive director of aviation programs at Cowley County. "We want to get workers the training they need to get back on the payroll and back paying their bills." Gary also said that although that is the motivating factor right now, "Eventually we will run out of laid-off people. Then we'll look to high school students, they're the future."

As a participant in the program, students can pursue not only an A&P certificate but also an associate degree. "This is an educational institute," Gary said. "It is just the beginning, but the college wants a world-class program." The program includes traditional training but also NDT, avionics, electronics, and computer training. "Another area we want to get into is composite structures. We are not ready for that yet, but graduates should know what they are talking about," he said. Cabin technologies and software loads are other areas the school will be attempting to prepare their students for, knowing they will be applying for jobs working on business jets equipped with the latest technologies.

The program's founders, under the nurturance of KTTI, hope to grow and are looking at a new facility in the future. The school is looking at building a $7 million training facility at Jabara Airport on the east side of Wichita, tentatively planned to be ready in three years. With or without that new facility, Gary said KTTI hopes to produce the caliber of mechanics needed to supply local businesses like the new Cessna Service Center. "We will try to instill professionalism in our students. When you leave here, you will have the building blocks to learn," said Gary. - By Joy Finnegan

Got Spares? Don't Scrap Them, Donate Them

If you think it's tough making ends meet in the aviation industry today, try running an aviation maintenance school. The rising cost of teachers, equipment, and training aids combined with the shrinking pool of prospective students is putting a real squeeze on aviation maintenance training institutions. But, as an OEM, MRO, or PMAer there is something you can do to help and it won't cost you a dime. In fact, it may well save you a tidy chunk on your taxes; all you have to do is donate your excess spare parts or scrap materials and equipment to your local school.

"The donations we have received from American Airlines, AirLiance, AAR Corporation, and others have really helped us keep our tuition prices down for our students," explained Craig Neville, vice president of academic affairs, Aviation Professional Education Center (APEC). Neville estimated that the donations from AirLiance alone have saved the school more than $5 million. "That's if we would have had to go out and buy this equipment new," he said. "We wouldn't have been able to do what we've done without the help and generosity of our industry partners."

Dr. James Mader, director of academic affairs for PIA School of Specialized Technology, echoed Neville's comments, and added. "It's quite an advantage to students to be able to put their hands on the same equipment they will see in the field. Unfortunately, without donations from the industry, we couldn't afford to provide this type of training. It's just too expensive."

Expensive indeed. Especially considering modern avionics, components, and jet engines. "One of the best donations that we ever got was a jet engine from Pratt & Whitney," he continued. "Before that our students were training on old ex-military equipment; now they can work on the same engine they will see if they go to work for a major airline."

Being able to train on the same equipment that they will see in the field isn't only a benefit to the student, it is a major plus for their future employers also. Stevens Aviation has been benefiting from this type of relationship with a local school for years. "Greenville Technical College is an excellent resource for finding and grooming good A&P talent," said Hiott Daves, director of military operations for Stevens Aviation. "We identify candidates while they are still students and plug them into our mentoring program. Quite a few have worked their way up into crew leader positions."

Stevens doesn't just offer job opportunities, it also generously donates time and equipment to Greenville Tech's program. Davis and other Stevens executives sit on the school's A&P program advisory committee. Stevens also is a regular contributor of surplus tooling, equipment, and parts to the college.

When it comes to deciding what to donate, most schools aren't too particular. As long as it's something that their students can work on to sharpen their skills, it's a win for the school. "From time to time our consigners choose to scrap materials that we are holding, usually because of low demand or if the parts are deemed to be beyond economic repair," explained AirLiance president and CEO David Sisson. "We probably scrap $20 million a year. It's not a specific type of part, it can be anything, and some of it is brand new but nobody wants it."

How should companies and schools go about developing this synergistic give-and-take relationship? The best first step is just to ask. "When the school [APEC] opened, their directors came to AirLiance to introduce the school," Sisson explained. "We employ A&P mechanics and are interested in their graduates as future employees. During the tour of our warehouse, one of their directors asked about our scrap. That started it all off. Now before we have the scrap sent to salvagers, we call the folks at APEC to see if they're interested."

"We've received all kinds of stuff from AirLiance," Neville said. "I have wing sections, ailerons, combustion chambers, avionics, you name it. All totaled it's probably eight to ten 52-foot semi trailers full of parts donated to the school."

And while you can never have too much of a good thing, there are times when APEC just has too many of a certain part or component. "We actually get rid of our excess parts," he continued. "We send them to an authorized scrap dealer where they are destroyed. What's nice is that the money then goes back into our program. It's a win/win for us."

We don't begrudge the school trying to make a little money selling their excess parts for scrap," Sisson said. "As long as they follow the same controlled scrapping procedures we do, it isn't an issue."

But still, having schools or other organizations resell donated parts is always a concern for aviation companies. "We've all heard stories of people donating stuff like engines and they later find their way back onto an aircraft," Neville said. "That's why we are so careful about how our parts are destroyed. If it's scrap, it's scrap."

"The liability issue can be a problem for a lot of companies who would like to donate parts and equipment," Sisson added. "But it's really not a major issue if you follow the right procedures, beginning with having your lawyer draw up a simple agreement between your company and the school spelling out the fact that it is not for resale.

"But I really don't see that being a deal-breaker," he said. "If you have excess parts around find a local school, high school, technical school, or trade school and see if their aviation program needs them. Instead of selling them as junk, find a school and donate them. It's a good way to help our industry while becoming part of the community and fulfilling the good neighbor idea." - By Dale Smith