Avionics News February 2023 - 14

In this monthly column, Ric Peri of the AEA's Washington, D.C., office, informs members of the latest regulatory updates.
B Y
R I C
P E R I
AE A VICE PRE SIDEN T OF GOVERNMEN T & INDUS TR Y AFFAIR S
Recurrent Training
T
raining is nothing new.
After spending the past few years as co-chair
of the Federal Aviation Administration's Part
145 ARAC working group and researching the origins of
the regulations, I am reminded of a quote by author Stephen
King: " Sooner or later, everything old is new again. " As the
new year begins, I would like this month's column to focus
on training, certification and qualifications.
Every approved maintenance organization has a
fundamental requirement to assure it has competent people
performing maintenance. The European Union Aviation
Safety Agency requires that " the organisation shall establish
and control the competence of personnel involved in any
maintenance, management and/or quality audits in accordance
with a procedure and to a standard agreed by the competent
authority " (EASA 145.A.30 (c)). The FAA requires that " 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 " (14 CFR 145.163 (b)). This sentiment is
repeated with every regulatory authority worldwide.
While it seems everyone shares a similar requirement,
the current regulations are worded in such a manner that
success is in the eye of the beholder. As my research into the
origins of many regulations took me, history tells us a bit of a
different story.
Starting with the basics, the early regulatory language simply
required that the " Applicant shall have adequate personnel
certificated as required by the civil air regulations and qualified
14 avionics news * february 2023
'The FAA anticipates that training
requirements may be met by attending
trade or technical society seminars and
through on-the-job training.'
to perform or supervise the type of work involved " (CAR
14 CFR Part 52.20 Personnel (1937)). An often-overlooked
element from this early regulation is that, from the very
beginning, the regulations made a clear distinction between
the person being certificated and their qualifications. Again,
from the origin, the regulations have made the repair station
responsible for " qualifying " the individual.
In the 1959 edition of the Civil Aeronautics Manual 52, the
civil aviation authority offered the following interpretations
regarding the repair station's responsibility to qualify
technicians.
" An objective of this part is to place a greater responsibility
for the repair station's performance on the responsible
managing official. To this end, it is essential that repair station
officials give careful consideration to the qualifications
and competency of individuals in the employ. The primary
responsibility for the satisfactory performance of a worker
will be the repair station's. "
The regulation further offered an interpretation for the
competency of nonsupervisory personnel.

Avionics News February 2023

Table of Contents for the Digital Edition of Avionics News February 2023