Operational Airworthiness
Aircraft Maintenance Training Programs for Approved Maintenance Organizations
Purpose
The purpose of this notice is to provide Approved Maintenance Organizations (AMO) with some insight into Transport Canada (TC) training requirements as they apply to Canadian Aviation Regulation (CAR) Standard (STD) 573. In particular, it deals with the features, characteristics and requirements of an AMO environment as they relate to technical training programs. The contents are not intended to replace guidance material associated with course standards or curriculum development as those instruments serve other purposes and are available from industry sources.
Background
Over the years training programs have played a key role in supporting maintenance activities by ensuring that individuals exercising maintenance release privileges were properly qualified for their roles and responsibilities. Prior to the existing regulatory regime, Transport Canada took a hands-off approach with respect to formalizing training requirements by allowing individual organizations to set their own control standards. This was followed by a period wherein training became a recognized means of satisfying knowledge requirements for licence privilege.
Now, changes in regulatory requirements brought about through industry consultation have led TC to adopt more flexible policies relating to the control of maintenance training standards in an AMO. These newly developed performance-based requirements are addressed in the Canadian Aviation Regulations, providing the aviation community with a wide range of regulatory training options.
General
The Minister has an obligation to the Canadian flying public, and additional commitments internationally, to ensure that aircraft operating under the Minister's control are maintained in a manner that ensures aviation safety. One of these safeguards is the requirement that AMO technical personnel engaged in aircraft maintenance activities be properly trained. Depending on the scope of approval granted to an AMO, training requirements will vary from one program to another, based on the particulars of the approval. However, all training policies have a common objective:
To ensure that sufficient and adequate training requirements are built into management policy, thereby assuring that technical personnel engaged in maintenance activities are properly trained to support their area of responsibility.
Thus, all AMOs engaged in aircraft maintenance have an obligation to address this fundamental requirement in their respective programs. This assurance is confirmed at the local level by TC personnel at the time of program submission where it is measured for compliance against the approval basis of the AMO. In short, TC reviews AMO policy to ensure that each aircraft type or aeronautical product being maintained, is supported by a program that addresses both initial and up-date technical training.
Regulatory Requirement
In accordance with CAR573.06 each AMO is responsible for the development of a maintenance training program that supports the scope of authority issued to the organization by TC. The policy must be such that it addresses training needs for all technical personnel engaged in aircraft maintenance activities in line with their individual duties and responsibilities. The training program must include both initial and up-date (recurrent) training appropriate to each technical employee within the maintenance organization.
573.06 Training Program
An approved maintenance organization (AMO) certificate holder shall implement a training program to ensure that persons authorized to perform or supervise the performance of any function under this Subpart are trained in respect of the regulations, the standards and the AMO procedures applicable to that function.
The program required by subsection (1) shall include initial training, updating and other training necessary, within the meaning assigned to those terms in Section 573.06 of the Airworthiness Manual, to ensure continued qualification that is appropriate to the function to be performed or supervised.
Aircraft Certification Authority - ACA
Where aircraft are being released for return to service, only individuals who hold an appropriately rated Aircraft Maintenance Engineer (AME) Licence can exercise those privileges. In addition, where such an activity is under control of an Approved Maintenance Organization, additional training requirements must be met.
The CARs require that all individuals issuing a maintenance release on commercial aircraft, or in the case of specialized work - all aircraft, be identified by the maintenance organization. Essentially this means that, while the organization may have several appropriately rated AMEs engaged in aircraft maintenance activities, not all of them will necessarily receive maintenance release authority. Each organization is free to establish ACA issuance policy based on its own requirements so that qualification standards are tailored to operational need.
In all instances the maintenance department must maintain sufficient training records and other relevant rationale to support the granting of ACA. The file should provide evidence that an individual, in addition to satisfying technical training requirements, has also demonstrated familiarization with company policy and procedures that support maintenance release.
Shop Certification Authority - SCA
Another means of controlling quality within an organization is to nominate qualified individuals who can issue a maintenance release against off-aircraft aeronautical products. This process is usually referred to as Shop Certification Authority. The privilege differs from ACA in that the vested release authority is limited to "off-aircraft" aeronautical products and, unless the individual is otherwise qualified, does not include the release of on-aircraft work. Following certification, parts or components are generally returned to stores for future use, or alternatively, certified for installation on company or third party aircraft.
Training programs tailored for holders of SCA are generally more narrowly focused than those associated with full ACA. They reflect training outcomes that mirror shop specialization requirements geared to the specific nature of the SCA. For example, an individual responsible for maintenance certification of hydraulic actuators, or a particular line of avionics equipment will usually undergo technical training geared to those specific areas in greater depth than that associated with an ACA training program. The SCA candidate would not be expected to receive training in peripheral or collateral areas of aircraft systems as would an individual in an ACA training course. As a minimum, training programs supporting SCA must be equal to or greater than those supporting ACA for a particular on-aircraft functional area or system.
Commercial Environment - Typical Scenario
A typical example of how licensing privilege, working environment and requisite training come together is highlighted below and is provided as a general guide. Individual cases will vary depending on their own circumstances. However, it should provide some insight on how the separate, yet interrelated regulatory requirements interact.
Where an organization recruits an individual to issue a maintenance release against one or more of its aircraft or aeronautical products, a documented process must support that nomination process. In most instances, the in-briefing and the organization's hiring standards will establish a minimal bring factor. Hiring profiles other than regulatory requirements are not covered in this scenario. Nevertheless, where an individual joins the organization, an in-briefing will determine that he or she carries a valid AME licence with a rating applicable to the AMO's maintenance approval. Typically, this would be in one or more of the M1, M2, E, and S ratings, or grandfathered privileges associated with previous TC licensing standards.
573.05 Authorization to Sign a Maintenance Release
No approved maintenance organization (AMO) certificate holder shall authorize a person to sign a maintenance release unless the person meets the applicable requirements of Section 571.11 and has successfully completed the training required by Section 573.06.
Persons Who May Sign a Maintenance Release
Except as provided in subsections (2) and (4), no person other than the holder of an aircraft maintenance engineer (AME) licence issued pursuant to Part IV, specifying a rating appropriate to the aeronautical product being maintained, shall sign a maintenance release in accordance with Chapter 571 of the Airworthiness Manual.
Where off-aircraft privileges relating to the certification of components or appliances following maintenance apply, the organization should confirm that the individual possesses any trade qualifications applicable to the area of responsibility. Confirmation may be in the form of a certificate issued by a recognized trade school, institution, community college, or other forms of recognition that have been issued by a standards bearer against a national trade standard such as CAMC, CGSB, SAE, MIL, etc.
Once a new employee enters into the organization, the individual's maintenance experience and training records need to be measured against the requirements of the new organization. Regardless of what privileges the individual previously held with other organizations, it is incumbent on the new organization to review those personal qualifications before determining what course of action is needed. At this point, additional training and experience will be measured against past history and the immediate needs of the organization.
573.07 Personnel Records
An approved maintenance organization (AMO) certificate holder shall establish, maintain and retain for at least two years after an entry is made, for each affected person, a record of
- all personal qualifications in respect of appointments made pursuant to Section 573.03 and in respect of assignments of functions made pursuant to Section 573.04;
- all of the authorizations to sign a maintenance release pursuant to Section 573.05; and
- all of the training conducted pursuant to Section 573.06.
For example, an individual may have worked in the aviation industry for thirty years or more and have exercised maintenance release authority on identical aircraft to those operated by the new organization. Given the similarity of aircraft type, additional training may not be required. However, if that conclusion is reached, then it must be documented if Aircraft Certification Authority is to be based on that determination. Where the individual is providing proof of training from a TC Approved Training Organization (ATO), the certificate itself will attest to basic qualification. Training Certificates, previous ACA responsibility and historical records such as those issued by the Minister to confirm privileges previously held by the individual, also serve that purpose.
The manager responsible for maintenance should ensure that where an organization's fleet characteristics or aeronautical products differ appreciably from the individual's documented training and experience, that those differences are bridged with additional training. The amount of training can be covered with a differences course or, where feasible, a training module or session addressing the shortfall.
Under no circumstances can an individual enter into an organization and immediately release commercial aircraft based on his or her licence alone, as that would be in violation of the CARs. The ACA process must be respected and can not be circumvented in any manner.
Once the individual's "bring factor" has been documented, the organization is then in a position to move onto the next step in the process. That is, to identify for which aircraft or products the individual will be granted maintenance release authority. This may be the entire product, or alternatively the responsibility may be limited to a particular process, system, zonal area, or any other definition within the applicable rating privileges. Whichever approach is chosen, training and documentation must be in line with that authority. In addition to technical training requirements, the individual must also demonstrate an understanding of the organization's policies and procedures. Both of these requirements must be documented for audit purposes.
As alluded to earlier, the need to select and nominate a qualified AME for ACA in a commercial environment is a company requirement. Nevertheless, all AMOs must have ACA policy in place that respects the need to control aircraft maintenance release and off-aircraft release by utilizing ACA and SCA control. Based on the organization's control policy, an individual may exercises those privileges by issuing a release utilizing their AME licence number, or alternatively by using a company issued number for that purpose. Again, this is a company decision that would be reflected in the organization's policy manual.
Small Aircraft AMO
Where an individual is nominated by the organization to issue a maintenance release against normal category aircraft, training need not be as structured or formal. In most instances experience in this sector has been gained from a broad spectrum of small aircraft with similar maintenance characteristics and the need for a type training course is less important. However, the organization should have some form of documented process in place to describe the manner in which an AME is selected for ACA privileges, as the release of all commercial aircraft must be controlled through this medium. This may take the form of a documented on-job-training (OJT) program, or by some other combination of OJT and structured training. In any case, the organization must have policy that precludes individuals issuing a maintenance release without first having completed a mandatory evaluation process. This process will ensure that an individual has been properly assessed and nominated by the organization to exercise maintenance release privileges.
STD 573.06 requires that all technical personnel receive appropriate training in line with an individual's maintenance responsibilities. For the benefit of those companies maintaining small aircraft with one or two maintenance personnel, the training program does not have to be complex. But it does have to be sufficient to keep technical personnel abreast of changing technology and systems as it applies to maintenance activities within the small AMO. For example, over the past several years maintenance as well as regulatory requirements have undergone substantial change to mirror changes in management systems and technology. These changes and others effecting maintenance practices cause company operating procedures to be altered in line with new requirements. Accordingly, policy and procedures manuals are amended and these program changes need to be transmitted to maintenance personnel. This could be as a simple as calling a meeting to review regulatory changes, company procedures, or even a short review of technical information that affects the maintenance of the organization's aircraft. Often a simple event such as reviewing an Airworthiness Directive, Service Bulletin or other relevant document, will easily satisfy up-date training requirements, provided that the event is documented provided that the event is documented. An important point to remember is, the sessions need to be planned, attended and documented. If this approach is followed, the company will be in an excellent position to demonstrate that their training policy is effective, structured and meets regulatory requirements.
Another example might be where a supplier or technical representative visits a small operator to provide technical information on aircraft or systems changes. This could be as simple as a demonstration on the use of dynamic balancing and tracking equipment, the use of electronic weight and balance equipment, powerplant run-up and performance procedures, the application of non-destructive methods, and so on. Operators should take full advantage of these visits and include policy in their manuals that recognizes this type of information exchange in a formal manner. Maintenance symposia, where similar sessions address a whole manner of issues from regulatory information to technical subject matter, also qualify for up-date training when TC approved. These formal presentations should also form part of a small AMO's training policy.
All companies engaged in maintenance activities encounter some form of maintenance related problems during the course of routine operations. Where defect isolation has been problematic and a company has identified and resolved the problem, a review of that activity can also form part of the training program. In one way or another, most companies can relate to such a scenario and except for the lack of documentation, already meet an acceptable form of structured training.
Regardless of the size or complexity of the aircraft concerned, an AME rating, in itself, is not sufficient grounds to support maintenance release privileges in a commercial environment. ACA should only be granted after the organization has confirmed that the licence holder has undergone appropriate training on the aircraft, engine or system types to be released. For example, an individual whose background and experience has been solely on small piston fixed-wing aircraft will have to undergo some form of aircraft type training before moving to the release of more complex aircraft types. Some examples where additional training would logically apply include: small piston to small turboprop aeroplanes; small turbo-prop to small piston aeroplanes; small piston helicopters to small turbine helicopters; small piston helicopters to small aeroplanes; and non-pressurized to pressurized aircraft.
As well, AMO training policy should also include sufficient safeguards to ensure that individuals are properly trained in new technology where that is a factor affecting maintenance release privileges. Technology not previously experienced by the individual, such as glass cockpit; digital electronics; fly-by-wire; composite structures; autoflight and flight director type systems; on-board computer equipment affecting flight characteristics; and other such technology, need to be adequately addressed.
The variables that make up a small operator's training program are virtually unlimited and must be tailored to the type of operation. It should not be an off-the-shelf canned approach, put in place to satisfy some regulatory requirement, but fails to support the organization's maintenance program.
Maintenance Training Courses
For approval purposes, pursuant to STD 566, TC catalogues maintenance training courses as either Aircraft, Airframe, Engine, Systems or Process type training.
An Aircraft course is one that covers the entire aircraft including the airframe, engine and all of its related support systems. Unless otherwise noted, where an aircraft comes with optional engine packages, the course will be approved for a particular engine installation only.
Airframe courses include airframe and related systems content, but do not include detailed engine coverage. However, airframe and engine interface is a mandatory component of an Airframe course. In most instances airframe manufacturers who are TC approved generally exclude detailed engine coverage, focusing instead on the integration of the engine into the airframe.
Engine or powerplant training courses include a full range of engine topics and their supportive systems, but may not include airframe interface content. An engine course is generally a stand-alone presentation, geared to multiple users of the engine installation, fitted into a various aircraft types.
Propeller training may be included in the curriculum for either the airframe or engine courses. The course approval documentation and graduation certificates should make plain the extent to which propellers and associated systems are included.
Aircraft Process training course are those that deal with metal treatment, special repair processes and non-destructive inspection techniques. This training tends to be very broad based as learning outcomes gained from these courses are normally applied to a wide range of aeronautical products.
Course Input
Depending on the size and complexity of maintenance activities undertaken, input into training programs will vary according to reporting or trend monitoring systems supporting the maintenance planning and decision-making processes. Where possible, an organization should consider including a cross section of input from performance-based data. Feedback should include reports that identify recurring defects; maintenance anomalies; pilot and flight deck input; supplier feed-back and strip report data; delay and on-time departure performance; down time tracking; and human factors data related to poor maintenance practices.
Course Content
Depending on the training objective or outcome, it is important that course content include all topic areas relevant to the participant's area of responsibility as it relates to the issuance of a maintenance release. In the case of an organization that provides in-house training to meet its own operational needs, course content will be influenced by policies that control maintenance release qualification requirements. The extent to which an individual exercises licensing privileges will be directly proportional to the amount of training received to support that activity. For example, an individual exercising a narrow scope of responsibility will in all likelihood receive lesser training than one who has broader responsibilities. Course content will be adjusted to match the operational requirements of the position.
Alternatively, for those individuals exercising full or broader based privileges, course content will be more expansive, reflecting increased responsibility. Training must complement and support technical responsibility. It may be more than the individual requires, but it can not be less than that associated with the individual's technical responsibility.
Course Duration
For planning and management purposes, training courses have historically been defined in terms of days or hours. Unless content, maintenance operations, target population, delivery methodology and facilities are similar in nature, no two courses need be of the same duration. Regardless of topic or subject matter, each training course should be designed as a performance-based activity, so that achievement of the training outcome becomes key in establishing course duration. Good training programs should constantly evaluate delivery methodology to ensure that training is both effective and efficient.
With respect to course duration, in most instances the greatest influence is derived from the use of simulators or other methods utilizing interactive technology that reinforce learning objectives. Logically, where TC reviews course curricula or training standards with similar training outcomes, any variance in course length from the industry average, must be objectively supported by the ATO. In that regard, while training courses can vary in length to some degree due to content and delivery methodology, TC will look closely at course submissions that establish new benchmarks.
Course Prerequisites
Course prerequisites are a planned necessity for several reasons, one being that learning is always linked to previously held knowledge that was obtained in a formal manner, or gained through life experience. As such, a link to previous knowledge is important for participant success as well as for attainment of course objectives. Prerequisites should be established respecting known learning environment principals: that is, knowledge is transferred from simple to complex, small to large, concrete to abstract, theory to practice, and so forth. STD 566 requires that course prerequisites should always define the minimum bring factor for individuals attending technical courses at the initial, differences, update, and refresher delivery levels.
It follows then that, participants should not attend recurrent or update training sessions if they have not successfully completed an initial course on the related subject matter. Therefore, prerequisite policy should address this initial training requirement.
Initial Type Courses
Initial maintenance training courses are designed to support training requirements of individuals engaged in the release of aircraft or aircraft systems. Program content should reflect the basic information, familiarization and inspection procedures characteristic of that particular aircraft, engine, system or process. Bearing in mind the scope of privileges associated with the rating being addressed, courses should be designed to include all areas and levels of aircraft inspection undertaken by the individual.
Courses can be all inclusive, covering all areas of maintenance release authority. This will always be the case with respect to ATOs. However, for in-house programs that are designed to address the organization's own needs, courses may be limited in scope to address a major system, process or zonal area. In all instances course content must be equal to, or exceed areas of responsibility associated with maintenance release authority.
Differences Courses
Differences training courses are developed to bridge the gap between previously held technical knowledge on a family of aircraft, engines, systems or processes, and their derivatives. They are designed to build on the participant's base knowledge, addressing only the technical differences between the original subject matter and a derivative. It becomes necessary to include course screening, or prerequisite policy, so that only individuals who have successfully completed an initial course, on the basic product can be eligible. Examples of this would include individuals who are qualified on either a Boeing 757 or 767, Airbus 319 or 320, or Bell 206 Series types.
In certain instances,such as is the case with most electronic and appliance manufacturers, equipment changes and modifications are not always easily identifiable. In such cases, the AMO should clearly identify training policies that identify when additional training is required. For example, a policy statement such as:
"Whenever a manufacturer changes the model or part number, or modification status of a component, the AMO will review those changes to determine if any differences training is required prior to granting additional release authority to the holder of an ACA, or component certification privileges to the holder of SCA."
In all instances, the basis for course development should be predicated on the need to measure content against both principle and derivative initial courses. Where a differences course bridges between more than one initial course, then each course must be included in the review process. As is the case for initial type maintenance courses, course content should be consistent with the privileges of the rating being addressed.
Up-Date (Recurrent Training) Courses
The purpose of up-date training, often referred to as recurrent training, is to ensure that technical personnel are kept abreast of changes to the products, processes and systems for which they hold release privileges. As with differences training, up-date training modules must build on the content of relevant initial courses as a basis for developing or addressing new material.
Course content should be driven by historical performance related to maintenance operations. The effect and success of these courses should be immediate, as maintenance and inspection practices are modified in response to known problem areas. As trends develop, management policy should ensure that lines of communication are such that individuals responsible for course development or content, address known problem areas.
It is important that these courses provide feedback and information relating to successful practices adopted by the organization in response to previous, or known problem areas. In this manner technical personnel are also kept informed of positive program changes that have enhanced maintenance reliability. For training to be effective, course content must always be undergoing review and change in line with operational experience. Course loading should be limited to individuals who have successfully completed initial training for that particular topic area.
Delivery Methodology
If training analysis has been properly addressed, then delivery methodologies will be accurately reflected in the course standard that has been developed to support a particular outcome. Delivery methodology refers to the manner in which training is presented. This may include several teaching methods such as lecture, class room style, interactive, interview, computer based or assisted learning, Where possible, regardless of delivery methodology used, learning objectives should be reinforced by practical application. A good program that monitors program effectiveness will adjust delivery to meet redefined outcomes. What may have started out as a lecture method to support a given outcome, may end up as a self-paced learning module. These are issues that are normally determined by professional trainers who have insight into course design.
Training Standards
Just as maintenance quality is controlled and assured by adherence to clearly defined maintenance performance standards, training programs also require the same degree of qualitative definition. Training standards should define course objectives, delivery methodology, personnel qualifications, testing and evaluation criteria, facility and equipment requirements, as well as methods for student evaluation. The standard should also provide for methods to ensure that performance objectives are meeting defined standards and desired outcomes. The system should include pass/fail performance statistics that are recorded and reviewed for course effectiveness. Test maps should be used to track the effectiveness of individual test questions with respect to course delivery and instructor performance. Results should be recorded, kept on file and form part of the audit trail to support changes to specific evaluation instruments and to modify instructor performance.
To ensure that training standards are effective, programs should include random sampling, structured audits, and program review strategies that provide confirmation of quality delivery. A good training standard should measure up under independent evaluation and be responsive to client expectations.
Instructor Qualifications
Individuals directly engaged in the delivery of formal classroom instruction of technical subject matter should hold both technical credentials for their area of expertise, and qualifications in instructional techniques. In addition to initial training, ATO administrative policy should ensure that instructors are provided with periodic professional development to maintain industry currency and awareness in both areas. As well, where an instructor is responsible for the delivery of a complete maintenance course to support rating privilege, the individual should be the holder of an AME licence, or hold equivalent credentials in that rating. For small organizations who choose to use their own staff for course delivery, a three- to four-day instructional techniques course available from most community colleges, would be sufficient to address this requirement.
Note: For the provision of OJT, formal training in instructional techniques is not essential.
Approved Training Organization (ATO) Courses
Courses that are developed to meet the need of a specific organization or operation, will be assessed against the scope of maintenance authority held at the time of course content approval. Thereafter, content must be modified in line with changes in maintenance program scope and operational experience.
AMO courses approved for third party use must qualify for Approved Training Organization status. Technical course content for these courses will be measured against world-fleet maintenance training requirements. In this manner, approved training courses at these establishments will qualify for AMO use where the AMO is engaged in the maintenance of those aircraft or aeronautical product types. This would not preclude an organization from contracting services from a TC approved ATO, and in addition, establishing in-house courses to satisfy more specific technical requirements.
Conclusion
As indicated above, the success of a training program is linked to a number of key factors, not the least of which is the identification of sound training outcomes linked to operational experience and maintenance control requirements. Not all courses or training programs are the same, nor should they be. As delivery capability, content and facilities differ, so too will course length and design. In that regard, it is the responsibility of all engaged in the delivery of approved training, to ensure that training standards are maintained in a manner that compliment individual system requirements. By applying the guidelines contained in this advisory, an AMO will be better positioned to gain program approval and withstand regulatory evaluation.
Applicable References
CAR Subparts 403; 406; 571; 573; 604; 605; 706; their associated standards; and the Manual of Regulatory Audits.