Avionics News February 2023 - 15

Avionics News has been an acceptable means
of recurrent training for mechanics with an
inspection authorization for more than a decade.
As such, Avionics News should be in every
member's training program.
" The repair station must determine the competency
of all uncertificated workers engaged in maintenance
operations under the terms of a repair station certificate.
Competency should be determined on the basis of
practical examination or authentic employment records. "
Further to the history of employee qualifications,
revision 1 (1963) to 14 CFR Part 145, the original
transition document, required that " the officials of the
station must carefully consider the qualifications and
abilities of their employees and shall determine the
abilities of its uncertificated employees performing
maintenance operations on the basis of practical tests
or employment records. The repair station is primarily
responsible for the satisfactory work of its employees. "
When I read the current regulations that require a repair
station to " ensure each employee assigned to perform
maintenance, preventive maintenance, or alterations, and
inspection functions is capable of performing the assigned
task, " this simply is an example of what is old will
become new again. If the qualification of technicians is
not new, then what is new?
The only thing that is new in the U.S. regulation was
the introduction of the requirement in 2001 to develop
and document the processes that the repair station
has used for a hundred years to qualify maintenance
technicians and supervisors. The FAA requires that " a
certificated repair station must have and use an employee
training program approved by the FAA that consists of
initial and recurrent training ... " (§ 145.163 (a) Training
requirements).
While the FAA proposed a broader training program
in 1999, the 2001 final rule trimmed the excesses
from the proposal. Unfortunately, many of the authors
of training materials, public communications, and
guidance have leveraged the proposed language rather
than the final requirements. In addition, both the
proposal as well as the final rule failed to recognize
that, for a hundred years, the repair station has been
responsible for the qualifications of employees and
overall aviation safety. The FAA is quoted in the
NPRM that " the proposed training program would
enhance aviation safety by ensuring that each employee
who works for the repair station is fully capable of
performing that work, and it would ensure a level of
safety equivalent to that of maintenance performed
under Part 121 or Part 135. " Although the basic
requirement to qualify employees has been in the
regulations since their inception, the qualifications of
individuals have not changed, only the requirement for
the documentation of the qualification process that the
repair station uses. This documentation is called the
Repair Station Training Program as required by 14 CFR
Part 145.163 (a).
Let's look at the logic of the training program. For the
U.S., we can review FAA Advisory Circular 145-10; for
EASA we can review EASA AMC 145. They both have
similar basics.
The AC states that " a repair station may divide its
initial and recurrent training into the following areas of
study for each category of employee:
A. Initial, including:
* Indoctrination.
* Technical training.
* Specialized technical training.
B. Recurrent.
C. Remedial, based on demonstrated need.
Initial training is core training. It may be basic training
or advanced training; it may be specialized training.
Regardless of the specific topic, the advisory circular has a
great descriptive process for initial training.
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avionics news * february 2023 15
Avionics News February 2023

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