Regulatory Report

Deadline Near for Part 145 Training Program

The FAA has finally released the advisory circular on how to set up a Part 145 repair station training program. AC 145-10 is available on the Aviation Maintenance Resource Archive at www.AviationMx.com. See also the file titled Part 145 Training Questions and Answers from the FAA, which elaborates on some specific issues related to the Part 145.163 training requirements.

The new AC is designed to help companies develop maintenance training programs to meet the requirements of 14CFR 145.163, which goes into effect April 6, 2006. The rule was supposed to become law early in 2005, two years after the new Part 145 regulations were enacted, but the FAA granted a one-year extension to give repair stations more time to comply and to help the short-handed FAA inspector force deal with all the training program approvals that need to take place.

The rule is short and to the point:

Sec. 145.163 Training requirements.
(a) 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 the requirements of this paragraph, beginning April 6, 2005—

(1) An applicant for a repair station certificate must submit a training program for approval by the FAA as required by Sec. 145.51(a)(7).
(2) 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.

(b) 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.
(c) A certificated repair station must document, in a format acceptable to the FAA, the individual employee training required under paragraph (a) of this section. These training records must be retained for a minimum of 2 years.
(d) A certificated repair station must submit revisions to its training program to its certificate holding district office in accordance with the procedures required by Sec. 145.209(e).

AC 145-10 is simply an advisory document that provides recommendations on how repair stations might comply with 145.163. Nothing in the AC is mandatory, and repair stations can choose whether or not to use it as a basis for preparing their own training program.

Note that the rule specifically requires that the training program be approved by the FAA. The actual training conducted under the program is not subject to approval. Indeed, it would be impossible for the FAA to provide enough inspectors to approve the training, and approval of the training program will have to suffice.

“The purpose of the repair station’s initial and recurrent training program,” the AC states, “is to ensure repair station employees performing maintenance (including inspection, preventive maintenance, and alteration) are capable of performing assigned tasks as required by section 145.163.

The specific requirement that personnel be trained so they are capable of performing assigned tasks may turn out to be problematical. The FAA defines a task as: “A piece of work to be done; an individual task that is part of the maintenance, preventive maintenance, and alterations required to return an article to service under the privileges of the repair station certificate and rating as assigned by appropriate management or supervisory personnel.”

Where this becomes sticky is figuring out how much training will be needed for the various tasks involved in maintaining various models of aircraft. At a maintenance provider that works on a large variety of aircraft models such as Banyan Air Service in Ft. Lauderdale, Florida, this could become a thorny issue.

“I’m struggling with [training for] multiple models,” said Walter Rittenhouse, Banyan’s vice president technical services. He wonders if detailed training will be required if a mechanic is assigned to do a similar job on a different aircraft, such as changing brakes or a rubber fuel cell. As an example, a Banyan mechanic spent 30 hours developing a comprehensive Microsoft PowerPoint class on Citation II fuel systems. Will such training be needed on every type of aircraft that Banyan maintains?

The FAA, answering a question about the specificity of required training, said that in the fuel bladder case, all that may be needed is differences training. How the individual FAA inspectors who approve training programs view this issue will be interesting and it’s likely that there will be different inspector interpretations, as is usually the case.

AC 145-10 outlines five different types of training that a repair station “should address” (remember, the AC is not mandatory): indoctrination for new and existing employees; initial technical requirements for new tasks; recurrent technical training; specialized technical training or advanced training; and remedial training needed to correct lack of skill or knowledge deficiencies.

The meat of this AC is a list of questions that FAA inspectors may choose to ask of their maintenance shop clients. These include:

• Is there clear responsibility and authority?
• Are there written procedures?
• Is there a measurement of effectiveness?
• Are there controls in place?
• Does the repair station identify and describe the interface between the training program and the individuals responsible for task assignments?
• Are there written procedures that require the repair station to maintain personnel training records for two years?
• Is the manual identified with applicable contact information?
• 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?
• Is there a procedure to submitting revisions to the FAA?
• Does the program have provisions for initial and recurrent training?
• Are individual training requirements identified and documented?

One more area of interest: the FAA states in the AC that human factors training might be a good idea, given the mandatory requirement for such training that exists in Europe. The FAA also suggests that companies consider training personnel in use of computer systems and on security issues. Don’t be surprised if these suggestions are strongly urged to be included by FAA inspectors.

AC 145-10 is full of useful information and recommendations and it includes two sample training program outlines, one for a large/medium repair station and one for a small repair station.

Training for mechanics is necessary, Rittenhouse said. “I think it’s something that’s needed. But we’re going to have to pass the costs on. It’s going to cost money.”