EASA Part 147 implementing rules and shows the relationship to requirements for Training Needs Assessment (TNA) – review by Sofema Aviation Services (SAS) www.sassofia.com
147.1 – Competent Authority for EU & EASA is the Competent Authority for Third Countries.
147.A.05 Scope Compliance Criteria is specified in Annex III (Part-66).
147.A.10 General – Must be an organisation or part thereof.
147.A.15 Application to and acceptable by the authority.
- the registered name and address of the applicant;
- the address of the organisation requiring the approval or change to the approval;
- the intended scope of approval or change to the scope of approval;
- the name and signature of the accountable manager;
- the date of application.
147.A.100 Facility requirements
Appropriate Facilities for training & examination (separate from other facilities) – allow students to concentrate.
- Max Students shall not exceed 28. (Practical 15 / supervisor or accessor)
- Students not able to see or copy
- basic training workshops and/or maintenance facilities separate from training classrooms (or use another organisation – contract)
- The competent authority shall require access to any such contracted organisation and the written agreement shall specify this access
- Office Accom for instructors assessors etc.
- Type training access to relevant aircraft for practical (147.A.115(d))
- Secure Storage for examination papers and training records. (147.A.125)
- A library reference scope and level of training undertaken
147.A.105 Personnel requirements
- Accountable Manager – Corporate Authority (May be QM – If not Nominated PH)
- Nominated PH (May be AM – Not Quality)
- Sufficient Staff to Manage the Org
- May Contract another organisation for Practical
- Multiple Roles (instructor, examiner, and assessor) subject to compliance with experience criteria requirement
- examiners and practical assessors specified in the organisation exposition
- updating training at least every 24 months relevant to current technology, practical skills, human factors, and the latest training techniques appropriate to the knowledge being trained or examined
147.A.110 Records of instructors, examiners, and assessors
- Record of all instructors, knowledge examiners, and practical assessors
- Terms of reference shall be drawn up for all instructors, knowledge examiners, and practical assessors
147.A.115 Instructional equipment
- appropriate presentation equipment of a standard that ensures students can easily read presentation text/drawings/diagrams
- Presentation equipment shall include representative synthetic training devices to assist students in their understanding of the particular subject matter where such devices are considered beneficial for such purposes
- Basic Training – Tools & Equip to support Scope (selection of aircraft / Engines / Parts & Avionic Equip
- Synthetic training devices may be used when such synthetic training devices ensure adequate training standards
147.A.120 Maintenance training material – To meet requirements of Annex III (Part-66)
- Students have access to maintenance documentation and technical information
147.A.125 Records – student training, examination, and assessment records for an unlimited period.
147.A.130 Training procedures and Quality System
- Procedures acceptable to the competent authority to ensure proper training standards and compliance with all relevant requirements in this Part.
- quality system including:
o Independent audit function to monitor training standards,
o Integrity of knowledge examinations and practical assessments,
o Compliance with and adequacy of the procedures, and
o A feedback system of audit findings to AM.
147.A.135 Examinations – Must Ensure Security of Questions
- Cheating – Disqualified & Banned for 12 months
- CA Notified
- Examiner providing questions – Exam void CA Notified
147.A.140 Maintenance training organisation exposition
- Signed Statement by AM
- Nominated Persons, Instructors & Examiners & Organogram
- Demonstrate compliance with the Regulations & Amendment Process
- Details of Facilities
- Scope of Approval
- Training Procedures
- Control Process to Manage Training & Assessments away from home base
- Minor amendments to the exposition may be approved through an exposition procedure (hereinafter called indirect approval).
147.A.145 Privileges of the maintenance training organisation (Regulation (EU) 2018/1142)
Subject to scope of approval (Annex III (Part-66))
- Basic Training & / or Type/task training courses
- Examination of students (on-site training & examination only)
- If the exam location is not identified in the approval certificate
o Either Questions from European Central Question Bank (ECQB), or
o In the absence of an ECQB, the competent authority selects the questions for the examination;
- Issue of certificates in accordance with Appendix III following successful completion of training & examinations.
- Training, knowledge examinations, and practical assessments may only be carried out at the locations identified in the approval certificate and/or at any location specified in the maintenance training organisation exposition. (control procedure required for other locations).
- Subcontracting under the control of the Quality System.
- Basic Training subcontracting limited to Annex III (Part-66), Appendix I, Modules 1, 2, 3, 4, 5, 6, 8, 9, and 10.
- The subcontracting of type training and examination is limited to powerplant and avionics systems.
- Only full approval may conduct exams however Basic Knowledge schools may also be approved to provide type examination in the cases where type training is not required.
147.A.150 Changes to the maintenance training organisation
- Organisation required to inform CA before the change (failure to do so can lead to suspension)
- CA will advise if any additional steps or requirements
- Unlimited Duration Approval
- CA granted full access
- Upon Surrender – Return to CA
147.A.160 Findings
- Level 1 significant non-compliance
- Level 2 finding other than level 1 findings
- After receipt of notification of findings – define Corrective Action Plan
147. A.200 The approved basic training course
- Consists of knowledge training & examination, practical training, and assessment.
- Subject matter ref. Annex III (Part-66).
- The knowledge examination element shall cover a representative cross-section.
- The practical training element shall cover the practical use of common tooling/equipment, the disassembly/assembly of a representative selection of aircraft parts, and the participation in representative maintenance activities being carried out relevant to the particular Part-66 complete module.
- The practical assessment element shall cover the practical training and determine whether the student is competent at using tools and equipment and working in accordance with maintenance manuals.
- Duration as per Appendix I (Conversion Course determined through an assessment of the basic training syllabus and the related practical training needs.)
147.A.205 Basic knowledge examinations
- No Training notes -standard ref Annex III (Part-66).
- cross section of in accordance with Annex III (Part-66).
147.A.210 Basic practical assessment
- Basic practical assessments carried out by the nominated practical assessors at the completion of each visiting period to the practical workshops/maintenance facility.
- The student shall achieve an assessed pass with respect to point 147.A.200(e).
147.A.300 Aircraft type/task training
- A maintenance training organisation shall be approved to carry out Annex III (Part-66) aircraft type and/or task training subject to compliance with the standard specified in point 66.A.45.
147.A.305 Aircraft Type Examinations and Task Assessments
- An MTOA approved in accordance with point 147.A.300 able to conduct aircraft type training shall conduct the aircraft type examinations or aircraft task assessments specified in Annex III (Part-66) subject to compliance with the aircraft type and/or task standard specified in point 66.A.45 of Annex III (Part-66).
Note Concerning the Requirement to Develop Training Needs Analysis (TNA)
The TNA is NOT directly driven by a specific Part 147 requirement rather it is required to show compliance with AMC to point 3.1(d) of Appendix III to Part-66 ‘Aircraft Type Training and Examination Standard. On-the-Job Training (ED Decision 2016/011/R).
Training Needs Analysis for the Theoretical Element of the Aircraft Type Training.
- The minimum duration for the theoretical element of the type rating training course, as described in Appendix III to Part-66, has been determined based on:
− generic categories of aircraft and minimum standard equipment fit
− the estimated average duration of standard courses imparted in Europe
- The purpose of the Training Needs Analysis (TNA) is to adapt and justify the duration of the course for a specific aircraft type. This means that the TNA is the main driver for determining the duration of the course, regardless of whether it is above or below the minimum duration described in Appendix III to Part-66.
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Tags:
Aviation Quality System, EASA, EASA Part 66, Quality System, EASA Part 147, Regulation (EU) No 1321/2014, Commission Regulation (EU) No 1321/2014, SAS blogs, Training Needs Assessment (TNA), ECQB, Regulation (EU) 2018/1142
