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Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting
6th Part-66 and Part-147 Meeting (13.10.2010)
Competency Based Training (Jean-Pierre Arnaud)
Issue 5 –Type training before issue of Part-66 AML (Peder Gernandt)
Issue 6 – Web Based Training (Luis Pires)
Issue 7 – GA Training and Examination (Sandbu Tore)
Qualification of Inspectors (Laurence Blasch-Roussel)
Questions & Answers (Luis Pires)
Closing (Mark Kieft)
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Cologne
Competency based training First approach from a regulatory point of view
Jean-Pierre ArnaudEASA Rulemaking Directorate
Part-66/147 standardisation meeting
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 3
Competency Based Training
Why something “new”?
A shortage of 400000 mechanics all over the world is expected for 2018 (100000 in Europe?)
Several task forces such as NGAP, ITQI… decided to approach the ICAO by suggesting the Competency Based Training concept for the maintenance staff and therefore to develop it.
NGAP: Next Generation of Aviation Professionals
ITQI: IATA Training and Qualification Initiative
The objectives are:To reduce the length of the training;To make the aeronautical field more attractive.
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 4
CBT (Competency based Training)
ICAO during summer 2010 has issued two State Letters for comments:
AN 12/1.1.15-10/52 – Proposal of amdt. of Annex I chapter 4 – introduction of CBT for MAINTENANCE
AN 12/48-10/50 - Proposal for the amdt. of PANS-TRG, Doc 9868 (initial edition - 2006) regarding “Training” - introduction of CBT
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 5
ICAO State letter 52
Draft for the amendment of ICAO Annex 1 (version 169-B):Revision of the definition of “approved training” and “approved training organization”;
Introduction of the CBT conducted within an approved-training organization;
Extension of human performance to the principle of threat and error management for the issue of the license;
Substitution (as an AMC) of the Maintenance Experience requirements with an approved training program imparted by an approved training organization, provided that the approved training organization demonstrates to the satisfaction of the Licensing Authority that this training provides a level of competency at least equivalent to that provided by the minimum experience requirements for personnel not receiving such approved training;
Use of “engine” or “engines” instead of “powerplant” or “powerplants”.
Applicability: 17 Nov 2011
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 6
ICAO State letter 52
According to ICAO Annex 1, the experience requirements (Annex I, chapter 4, §4.2.1.3 and 4.2.2.2 3)c) are only applicable:- for the issuance of the maintenance license (i.e.66.A.30) and/or before
the granting of the privileges as certifying staff;- for the certifying staff in order to maintain his/her privileges (recent
experience: 6 months during the preceding 24 months) (i.e. 66.A.20 b.2)
For that purpose, ICAO has developed a guidance material to better explain what CBT means: this is amdt. of PANS-TRG, Doc 9868 (State letter 50)
envisaged applicability for this amdt. is 10 February 2011
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 7
ICAO State letter 50 (CBT)
Applicability
1. Maintenance mechanics/technicians/engineers for:Aircraft and engine;Component;Structural repair
2. Line, base and workshop maintenance
3. Large aeroplanes (above 5.7T) powered by turbine engines and components thereof.
4. Any kind of training (basic knowledge, practical portion; experience requirements, TRTs, specialized training etc)
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 8
ICAO State letter 50 (CBT)
Aircraft systems maintenance personnel1. Perform fault isolation2. Perform maintenance practices3. Perform service4. Remove component/assembly5. Install component/assembly6. Adjust7. Test8. Inspect9. Check10. Clean11. Paint12. Repair13. Perform MEL and CDL/DDPB Procedures
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 9
ICAO State letter 50 (CBT)
Aircraft structure maintenance personnel1. Perform aircraft structural repair inspection2. Perform structural damage investigation, cleanup and
aerodynamic smoothness check3. Perform special process application4. Perform metal rework/testing5. Perform structural repair
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 10
ICAO State letter 50 (CBT)
Aircraft component maintenance personnel1. Perform testing fault isolation2. Perform disassembly3. Clean4. Perform inspection/check5. Repair6. Perform assembly7. Perform storage
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 11
Several international groups started to support the concept by producing several documents…
IATA Maintenance Personnel Selection Criteria Guidance Material
Before starting the training, analyze which competencies a person has to meet while performing intended maintenance tasks.
Select the person that has the potential to meet the requirements after successfully passing training activities.
Objective: eliminate drop-outs or failure-rate, but it reduces the likelihood of those substantially.
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 12
IATA Maintenance Personnel Selection Criteria Guidance Material
Basic-mental competencies like- following instructions
- verbal ability - numerical ability - abstract reasoning - spatial ability - mechanical reasoning - diagrammatic thinking - fault diagnosis - data checking
Managerial competencies like - leadership - concern for task - concern for people
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 13
IATA Maintenance Personnel Selection Criteria Guidance Material
Psycho-motor competencies like- aim - arm-hand steadiness - control precision - finger dexterity - manual dexterity - multi-limb coordination - rate control - reaction time - response orientation - speed of arm movement - wrist-finger speed
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 14
IATA Maintenance Personnel Selection Criteria Guidance Material
Personality profile including competencies and attitudes like:- stability - self-discipline - flexibility - team orientation - independence - adherence to procedures - helpfulness - ambition - openness - assertiveness - perseverance
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 15
Amendment of ATA 104 under progress
ATA Specification 104:Guidelines for airplane Maintenance TrainingRevision 2010 under progressMajor changes are:
Clearly identifies a set of objectives and competence (CBT)
Includes measurement of student performance and feedback (SMS?)
Uses a variety of methodologies as appropriate (blending teaching methods)
Short syllabus for: engine start, run-up and taxi Rigging Composite and metallic (damage assessment and repair) Fuelling Deice/anti-icing Component maintenance training
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 16
Competency based training for maintenance: Conclusions
1. The Agency is of opinion that this amendment to ICAO Annex I should be further evaluated in details in liaison with the Industry / the Member States and with the evaluation of State Letter AN 12/48-10/50 (Amendment of PANS-TRG, doc 9868), so that a new regulatory task relative to this amendment can be incorporated into the 2012-2015 rulemaking program.
2. No need for notifying differences to ICAO but a transition phase will be necessary:
to amend the regulatory framework in coordination with the stakeholders;for the Approved Trainings Maintenance Organizations to develop and implement competency-based training programs.
3. This alternative to the experience requirements, based on the CBT implies to complement existing rules EC N°2042/2003 and in particular Part-66, 147 and 145.
4. Additionally the concept might be evaluated for any type of experience required for the purpose of EC N°2042/2003.
5. Some debates may be re-opened …
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 17
Competency based training for maintenance: Conclusions
This will be a significant change and this will need time. For the sake of the demonstration, the following issues will have to be introduced in an appropriate manner:
course development methodology;population analysis;competency unit, competency element and performance criteria;assessment and examination process versus competence and training objectives;assessors and examiners: training and qualification;performance criteria;
evaluation of the effectiveness of the training.
European Aviation Safety Agency
13 October 2010 Part-66/147 Standardisation meeting13 October 2010 Part-66/147 Standardisation Meeting Slide 18
If you have any question on this presentation please contact:Jean-pierre.arnaud@easa.europa.eu
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Peder Gernandt Standardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Description of the problem Proposed conclusionHighlights of the relevant regulation Summary Discussion Final conclusion
Items
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Shall the successful completion of a Part-147 Type Training course by a person, not holding a Part-66 licence at the time (or with the relevant category), subsequently be accepted for addition of the type rating upon the initial issue of a Part-66 licence (or at a later request)?
Part-66 does not specifically address this situation.
Description of the problem
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Questions with regard to the level of previous knowledge and understanding needed in order to be able to assimilate the training:
• Must a person already have a Part-66 licence prior to the participation in a Type Training course in order for the Type Training to be acceptable as basis for type rating on the licence?
• Should it be required that an applicant, through completion of a Basic Training Course or by other means, meets the requirements for a Part-66 licence prior to participation in Type Training in order for the Type Training to be acceptable for addition of the type rating on the licence when issued?
Description of the problem
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
If a person successfully completes a Type Training course, it can be concluded that also the relevant general maintenance knowledge and understanding of that person is at an acceptable level.
It is therefore the opinion of EASA, and consequently the proposed conclusion, that the successful completion of a Part-147 Type Training course (when the relevant practical training also has been completed) shall be accepted for endorsement of the applicable type rating to a Part-66 licence, also when it was accomplished prior to the initial issue of the licence.
Proposed conclusion
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
66.A.45 (f) states that completion of approved aircraft type training shall be demonstrated by an examination conducted by a Part-147 training organisation, the training organisation approved to conduct the Type Training course or the competent authority.
Highlights of the relevant regulation
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Issue of an aircraft maintenance licence by the CA
• 66.B.100 (a): The CA shall, on receipt of EASA Form 19 and any supporting documentation, verify the form for completeness and ensure that the experience claimed meet this part.
• 66.B.100 (b): The CA shall verify the examination status.
• 66.B.100 (c): The CA shall, when satisfied that the applicant meets the standard of knowledge and experience required by Part-66, issue the relevant aircraft maintenance licence to the applicant.
Highlights of the relevant regulation
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Change of an aircraft maintenance licence by the CA to include an aircraft type
• 66.B.115 states that the CA shall, on receipt of a satisfactory EASA Form 19 and any supporting documentation demonstrating compliance with the applicable type rating requirements and the accompanying aircraft maintenance licence, either endorse the applicant's aircraft maintenance licence with the aircraft type or group or reissue the said licence to include the aircraft type.
Highlights of the relevant regulation
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Part-66 is currently not specific on the subject of possible limitations regarding when Part-147 Type Training may be taken in order to be recognised for a Part-66 licence.
EASA considers that there are no restrictions regarding the validity, and acceptance, of Type Training completed prior to holding a Part-66 licence.
Summary
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
DiscussionRELEVANT INFORMATION:
The pending amendment to Part-66 (CRD/NPA No 2007-02) will introduce a three year validity period (before applying for the licence) to comply with the theoretical and practical elements of a type training.
• It would ensure a good safety level
• It is consistent with Member State national systems in place prior to the JAA and (EC) Regulation 2042/2003.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 5: Acceptance of type training completed prior to the issue of a Part-66 licence
Final conclusionThe successful completion of a Part-147 Type
Training course MAY be accepted for endorsement of the applicable type rating to a Part-66 licence also when it was accomplished prior to the initial issue of the licence (or the addition of a category).
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
ISSUE 6: Part-147 Approval - use of Web Based Training (WBT)
Luis Pires Standardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Description of the problem Proposed conclusionHighlights of the relevant regulationsDiscussion Summary Final conclusion
Items
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Description of the problem (1)Some NAAs are being confronted with more and
more requests for Part-147 MTO basic training approval (initial or changes) using WBT;
The rule doesn’t cover such type of system to deliver training in accordance with the necessary basic knowledge requirements as per Appendix I;
Several NAAs requested the issue to be discussed during this meeting.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Description of the problem (2)After “googling” the internet it was possible to
detect several Part-147 organisations offering WBT in their Part-66 courses.
Example 1
Example 2
Example 3
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Proposed conclusion (1)
Web Based Training (WBT) as part of Basic Training or Type Training under Part-147 approval is not acceptable.
NAAs can only approve WBT by using the provisions given in Basic Regulation article 14 (6).
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Proposed conclusion (2)When applying for an Article 14 (6) NAAs should
take into account the following common sense items: Only certain modules can be covered by WBT; Not possible for level 2 and 3 knowledge;WBT should be seen as a complement to classroom
teaching instead of the other way around (split or percentage);
Control of training contents; Ensure proper learning sequence; Availability of an instructor on-line; All paragraphs of the rule to be taken into consideration
namely 147.A.100 (b) 1. The indicated duration of each basic training course
should not be changed
For type training apply the same principles.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Highlights of the Relevant Regulations (1)
As already stated both Part-66 and Part-147 rules do not address the use of WBT and generally speaking e-learning systems.
On item 147.A.115 the rule covers instructional equipment with regard to:
Classroom equipment, synthetic training devices;
Access to appropriate selection of aircraft, engines, parts and avionic equipment;
Access to appropriate aircraft type in case of type training.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Highlights of the Relevant Regulations (2)
On item 147.A.120 the rule refers to maintenance training material which shall be provided to the students and covers:
the basic knowledge syllabus specified in Part- 66 Appendix I for the relevant AML category;
the type course content required by Part-66 for the relevant aircraft type and AML category;
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Highlights of the Relevant Regulations (3)
Students shall have access to examples of mainte- nance documentation and technical information of the library as specified in 147.A.100(i).
The rule includes other requirements that might indirectly influence the use of WBT. For example: it limits the number of students (28) for each course
(147.A.100 (b)); training may only be carried out at the locations
identified in the approval certificate and/or in the maintenance training organisation exposition (147.A.145 (b)).
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
In the following slides a list of “common sense” statements are proposed for discussion:
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Discussion (1)
1. WBT can not be used in the training of certain modules. Examples:1. Module 6 – Materials and Hardware2. Module 7 – Maintenance Practices
2. WBT can not be used for teaching Level 2 and 3 knowledge as these levels implies knowledge of the practical elements of the subject.
3. WBT should be seen as a complement to classroom teaching. Not the other way around.
4. Availability of on-line instructor should be ensured.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Discussion (2)
5. Training contents and appropriate learning sequence in accordance with Appendix I to Part- 66 should be ensured.
6. Course duration as per Appendix I to Part-147 should be maintained.
7. Number of students per course should be in line with Part-147 regulation: maximum 28.
8. No web based examination allowed.
9. Type training to follow the same principles.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Summary
Taking into account all the factors associated with the issue and the fact that the rules were not meant to cope with the advent of the new technology, use of WBT for Part-147 approved courses is not acceptable;
Part-147 approved courses means the ones leading to the issue of a certificate of mutual recognition and thus benefiting from the reduced experience time;
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 6: Part-147 Approval - use of Web Based Training
Conclusion
Yes No
Item Agreed
1- Certain modules can’t use WBT
2- WBT not possible for level 2 and 3 knowledge
3- WBT as a complement of classroom teaching
4- On-line instructor always ensured
5- Training contents and sequence of learning ensured
6- Course duration as per Appendix I to Part-147
7- Number of students limited as per Part-147
8- No web examination allowed
9- Type training to follow the same principles
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
ISSUE 7: Part-147 GA aircraft Type Examination and Type Training
Tore Sandbu Standardisation Team Leader
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Description of the problem Proposed conclusionHighlights of the relevant regulations Summary Discussion Final conclusion
Agenda
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Description of the problem
Most Part-147 organisations are not involved in training and examinations for non-large/non- complex aircraft which creates a problem for the GA-environment when it comes to type examinations for these aircraft.
Approval of Type training on GA aircraft with no type training course previously established
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Proposed conclusion
A Part-147 organisation approved for type training, is adequately certified to also perform type examinations for other aircraft types for which type training is not required.
Part-147 organisations can develop type courses for aircraft types for which type training is not required.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Proposed conclusion
Currently regulation requires a Part-147 to create a type training course, even if not used, in order to perform type examination on an aircraft type where no type training is required. However:
There is a proposal to change 147.A.145 which, if accepted, may allow an organisation approved to provide basic knowledge training or type training also to be approved to provide type examination in the cases where type training is not required.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Proposed conclusion
Additionally, there is a proposal how to change the requirements for addition of type ratings on an AML for Group 2 and Group 3 aircraft:
Part-66 Licence
Group B1 B2 C
1 Training and Examination
Training and Examination
Training and Examination
2 Examination Experience Examination
3 Experience Experience Experience
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Highlights of the relevant regulations
147.A.305 Aircraft type examinations
A maintenance training organisation approved in accordance with 147.A.300 to conduct aircraft type training shall conduct the aircraft type examinations or aircraft task assessment specified in Part-66 subject to compliance with the aircraft type and/or task standard specified in Part- 66.A.45.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Highlights of the relevant regulations
147.A.105(c) Personnel requirements
The maintenance training organisation shall contract sufficient staff to plan/perform knowledge and practical training, conduct knowledge examinations and practical assessments in accordance with the approval
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Highlights of the relevant regulations
147.A.105(f) Personnel requirements
The experience and qualifications of instructors, knowledge examiners and practical assessors shall be established in accordance with criteria published or in accordance with a procedure and to a standard agreed by the competent authority
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Highlights of the relevant regulations
147.A.300 Aircraft type training
A maintenance training organisation shall be approved to carry out Part-66 aircraft type training and/or task training subject to compliance with the standard specified in 66.A.45.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Highlights of the relevant regulations
66.A.45(c) Type training
Except as otherwise stated in paragraph (h), ratings shall be granted following satisfactory completion of the relevant category B1, B2 or C aircraft training approved by the competent authority or conducted by an appropriately approved Part-147 maintenance training organisation.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Highlights of the relevant regulations
66.A.45(h) Type training
Notwithstanding paragraph (c), ratings on aircraft other than large aircraft may also be granted, subject to satisfactory completion of the relevant category B1, B2 or C aircraft type examination and demonstration of practical experience on the aircraft type, unless the Agency has determined that the aircraft is complex, where paragraph (c) approved type training is required.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Summary
Examiners shall fulfil experience and qualifications as prescribed in 147.A.105(f).
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Summary
Part-147 maintenance training organisations may develop type training courses also for aircraft types where type training is not required. These courses can be adapted to cover the defined request (from a few hours to some weeks) but no Certificate of Recognition for training can be issued since no type training is required.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Summary
The NAA can approve type training courses for new aircraft types where a type training is not required. When approving the course it should be taken into account requirements in Part 66A.45, the minimum hours required for the aircraft type and a training need analysis.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Questions / discussion
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Final conclusion
Current regulation requires a maintenance training organisation to be approved for type training in order to perform type examination
It is proposed that both Part-66 and Part-147 will be amended to make it possible to issue ratings for group 3 aircraft for B1, B2 and C licences holders based on documented experience. This will also be applicable to group 2 aircraft for B2 holders.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
ISSUE 7: Part 147 General Aviation training / Examination
Final conclusion
In addition, it is proposed that a maintenance training organisation approved to conduct type training might also be approved to conduct type examination on Group 2 aircraft.
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Qualification
CONTINUING QUALIFICATION
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
QualificationSome key figures
To be qualified
To remain qualified
Principle of e-learning recurrent training
Conclusions
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
QualificationSome key figures
To be qualified
To remain qualified
Principle of e-learning recurrent training
Conclusions
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Qualification of Team Members
We at EASA thank you for your contribution to standardisation in Europe.
The high level of contribution is reflected through the following figures
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
Some key figures170 Standardisation Inspections and visits
performed since the entry into force of EC Regulation 736/2006.
205 NAA participations
100 NAA seconded inspectors used
63 NAA seconded inspectors in EASA’s pool of inspectors, 55 of them being fully qualified
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
QualificationSome key figures
To be qualified
To remain qualified
Principle of e-learning recurrent training
Conclusions
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
To be qualifiedThe criteria are laid down in EASA Work
Instruction WI-STDST.0002:
Standardisation staff qualification criteria
Beside the technical knowledge, the main aspects with regard to practical experience are:ObserverInitial trainingTraineeTeam Member
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
To be qualified: initial process One-day training on the Standardisation Inspection
of competent authoritiesWithin 18 months of this training, participation in a
Standardisation Inspection. Before being appointed as Standardisation Team
Member, the candidate should have performed at least one Standardisation Inspection exercise as an observer
Followed by one exercise as a trainee team member. The trainee Standardisation Team Member’s
performance will be evaluated by the Team Leader Upon his recommendation the trainee Team Member
will then be fully qualified
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European Aviation Safety Agency
6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010
QualificationSome key figures
To be qualified
To remain qualified
Principle of e-learning recurrent training
Conclusions
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To remain qualified: continuing process
For further participation after the issuance of the qualification statement
At the date of the opening session, the qualified Standardisation Team Member shall have participated in at least one complete standardisation inspection within the preceding 24 months
AndAt the date of the opening session, he/she
shall have completed the Agency’s Standardisation Team Members’ recurrent training within the 24 preceding months.
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To remain qualified: continuing process
If the last participation in a complete Standardisation was between 2 and 4 years before the next planned, the initial training course has to be repeated
If the interval exceeds 4 years, the inspector shall be re-assessed as a trainee.
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QualificationSome key figures
To be qualified
To remain qualified
Principle of e-learning recurrent training
Conclusions
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Principles of recurrent training
Successful completion of the Agency’s web- based Standardisation Team Members’ Training is required for every Standardisation Team Member at intervals not exceeding 24 months
Pass mark of 75% to be introduced by means of an examination
In case of failure, recurrent training and examination can be retaken without limitation on the number of attempts.
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Principles of recurrent training
The purpose of the recurrent training is
to recall the most relevant elements of the current regulatory framework
To review the key points of the standardisation process
To refresh the working methods for Team members
Inform team members about new and/or updated guidance material
Provide easy access to:The most relevant documents (e.g. Regulation
736/2006, WI-STDST.0002)The conclusions of our Standardisation Meetings
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Functionalities of recurrent training
The team members will receive an alert sent by our Technical Training Department on the need for them to complete the web-based training
As of receipt of this invitation, they will have 3 months to go through the training and the examination
A certificate of completion will be issued by our Technical Training Department
In parallel, the Standardisation Department will be informed on the status of the recurrent training
The pool of inspectors will be updated accordingly
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QualificationSome key figures
To be qualified
To remain qualified
Principle of e-learning recurrent training
Conclusions
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Conclusions
EASA relies on your participation
To be qualified is the first step – To remain qualified is of the utmost importance for standardisation in Europe
Take some time and go through the recurrent training
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Don’t
Become
dis-qualified
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Questions and Answers
Questions & Answers
In the following slides a set of 5 common questions and the respective answer is presented for your peruse.
These questions are posed by NAAs and the respective answer has been coordinated between Rulemaking and Standardisation.
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Questions and Answers
1- Definition of Audit Period Start and End.2- Issuance of Basic Knowledge certificates in
case of failing Modules.3- Are examinations included in the course
duration?4- Is it possible for one NAA to perform the
type examination on behalf of another NAA?5- In order to stimulate TC Holders (especially
US TC Holders) to have courses approved is it acceptable to have an alleviated procedure for the approval of those courses?
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Questions and Answers
During the audit planning of the section Continuing Airworthiness Management Organisations various interpretations regarding the definition "audit period" has arisen. According regulation (EC) 2042/2003, each Part-147 organisation shall be completely audited at periods not exceeding 24 months.
Does this mean, between two periodical audits (for the purpose of continuation) must not be more than 24 months? Does "audit period" relates to the intervals which are maximum 24 months?There is an alternative interpretation of "audit period" which says, there are audit periods of 24 months and sometime within these 24 months of each period the regulatory audit can be performed. However, this could lead to longer intervals than 24 months between two periodical audits. In this case, an additional question is when does the audit period start. Initially from the certification date or from the audit date or from the issue date of the Form 13?
Question 1
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Questions and Answers
Basic criteria for audit planning, valid for Part-M, Part-145 and Part-147, are :
1. all areas relevant to the approval must be audited within a 24-month period;
2. the interval between two audits for a particular area must not exceed 24 months;
3. the audit period starts with the date of the first approval certificate granted to the organisation.
The determination of the number of audits and the individual scopes of each audit to be performed within each 24-month period should be based on a risk assessment for the organisation under consideration, which for existing approvals should take into account also past surveillance results.
EASA Answer
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Questions and Answers
Can an appropriately approved Part-147 organisation issue a "Certificate of Recognition" for a basic training course to a student that has passed all but one Part-66 modules during the basic training course ?
Question 2
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Questions and Answers
A certificate of recognition for a partial Part 147 course should not be issued as there is no room for interpretation in 147.A.145(a)4.
In the case where the candidate only failed one module, only basic examination certificates to the modules passed should be issued and the candidate will not be entitled for the maximum reduction of the 66.A.30 required experience.
However if later the candidate attend to a course covering both the theoretical and the practical portion of the missing module, the Part-147 could reissue a certificate of complete basic training course so that it will be fair for the applicant.
It should be noted that the 5 years limitation still applies as per Appendix II to Part-66.
EASA Answer
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Questions and Answers
Are examinations included in the duration of a basic training course or do we need to book additional time for the examinations?
Question 3
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Questions and Answers
The duration of examination represents between 0.6% and 1.2% of the training and remains “insignificant”. The assessment for the practical portion should be taken into account as well but as long as the order of magnitude remains low inclusion should be acceptable.
EASA Answer
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Questions and Answers
Is it possible for NAA 1 to perform type examination on behalf of another NAA 2?
Question 4
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Questions and Answers
EASA position is that this is possible. However, please note that because the exam will be performed on behalf of the NAA 2, the NAA 2 is still responsible for ensuring that the examination meets the requirements of the rule.
EASA Answer
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Questions and Answers
In order to stimulate TC Holders (especially US TC Holders) to have courses approved, it could be admitted that the Authority need not have in-depth review (in particular no on-site audits) to approve a course when this course is provided by the TC Holder: a syllabus with durations + a declaration of conformity to Part 66 Appendix 3 would be considered as sufficient.Would this approach be acceptable to EASA?
Question 5
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Questions and Answers
This option is not acceptable to EASA. The competent authority has to verify that the course complies with the appropriate standard. This will be further clarified in a new AMC 66.B.130 (refer to CRD2007-07):
The procedure for the direct approval of type training courses by the competent authority should require that the proposed course covers the following aspects are described:
·The content and the duration of the theoretical and/or practical elements, as applicable, in accordance with Appendix III to Part-66, including the Training Need Analysis.
·The teaching methods and instructional equipment.
·The material and documentation provided to the student.
EASA Answer
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Questions and Answers
· The qualification of instructors, examiners and/or assessors, as applicable.
The examination and/or assessment procedure, as applicable.
· The documentation and records to be provided to the student to justify the satisfactory completion of the training course and related examination/assessment. This should include not only a certificate of completion but enough documentation and records to justify that the content and duration approved has been met and that the examination/assessments has been successfully passed.
· The procedure should also indicate how the competent authority is going to audit the proper performance of the approved course.
6th Standardisation meeting Part-66/Part-147
Closing – Mark Kieft
12 and 13 October 2010
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Successful?
24 suggestions for topics for this meeting
13 suggestions covered in the topics we discussed
Remaining topics will be carried forward
43 participants from 29 NAAs
Good support from Rulemaking and other EASA departments
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Best practices forms
Good usage
Some of your points have been covered by previous standardisation meetings existing agreed practices – available on SINAPSE
All will be answered in the minutes
May lead to topics at future meetings
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Other AW standardisation meetings this year
M and 145 on 3/4 November21 POA on 2/3 December
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Topics to be discussed
Please propose new/old topics for next meetings
….but we can’t discuss them all
It is always possible to start a discussion with your peers on SINAPSE to share ideas
It is always possible to ask EASA for an interpretation
All discussed topics have been noted by R
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Thank you
We hope you found this meeting useful
Thank you for your active participation
Please complete feedback form – we want to improve!
MoM and ‘Conclusions’ document to follow
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Finally
Any questions?Feedback?Comments?
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