December 06, 2024

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Sofema Aviation Services (SAS) www.sassofia.com considers key aspects related to the management of competence across the GACAR Part 145 & Part 43 Maintenance Organisation Approvals

Introduction

Managing competence across all business processes in compliance with GACAR Parts 43 and 145 involves developing a well-structured training program, ensuring ongoing evaluations and certifications, fostering a culture of safety, and Incorporating training & mentoring best practices throughout the business processes.

Personnel Competence Requirements – Training and Qualification:

  1. Initial and Recurrent Training: According to GACAR Part 145 (§145.67), it is mandatory for repair stations to implement a training program that ensures employees are both initially trained and regularly updated on skills, techniques, and procedures.
  2. A best practice is to incorporate competency-based training, where each individual’s job performance is evaluated against set competencies to identify gaps and provide targeted training.
  3. Hands-on and Simulation Training: Competence is best developed through practical experience. Incorporating simulation training or hands-on exercises using real-life scenarios can help employees understand how to apply theoretical knowledge in real maintenance situations.

>> In regulated environments, employees should practice handling real aircraft components or full systems under supervision.

>> On-the-Job Training (OJT): Especially for those who are new to the industry or gaining additional qualifications (e.g., moving from technician to inspector roles), OJT ensures competence development. OJT programs should be well-documented, with certified mentors evaluating progress at each step.

Certification of Personnel:

>> GACAR Part 145 mandates GACAR Part 66 licensing for those approving articles for return to service.

As a best practice, companies should maintain an updated certification matrix for all personnel, indicating current certifications, expiry dates, and required recertification or continuous education efforts.

Using digital platforms for managing and reminding employees of certification renewals is also effective.

Competence Assessment:

 >> While regulatory authorities administer tests to confirm competence for some roles (e.g., management personnel under §145.56), a best practice is to implement internal competency assessments that are conducted regularly by qualified supervisors or external auditors.

>> These can be practical tests, knowledge exams, or performance evaluations.

Supervisory Roles:

>> According to GACAR Part 145 (§145.57), repair stations must have enough supervisors to oversee personnel who may be unfamiliar with specific maintenance tasks.

A best practice here is to assign leadership training for supervisors that emphasizes both technical oversight and mentorship. Supervisors should not only manage tasks but also coach team members, ensuring that knowledge transfer occurs efficiently.

Competence in Maintenance Activities

Adherence to Approved Procedures:

>> Personnel must adhere to the methods and techniques outlined in the manufacturer’s maintenance manuals or other approved technical data as per GACAR Part 43 (§43.19).

>> A best practice is to integrate Standard Operating Procedures (SOPs) into daily activities and ensure all employees are trained in using the latest versions.

Conduct regular audits to ensure adherence to these procedures and swiftly correct deviations.

>> Use of Technology: Consider integrating digital maintenance platforms that give employees real-time access to technical manuals, updates, and checklists.

This reduces errors, ensures compliance with approved procedures, and boosts operational efficiency.

Inspections and Approvals:

Competence is critical for inspections. Inspectors must be proficient in using inspection equipment and identifying potential issues that could affect airworthiness.

A best practice is to implement continuous training and regular evaluations of inspectors. GACAR Part 145 (§145.59) emphasizes the need for inspectors to be familiar with applicable regulations, inspection methods, and tools, so providing regular updates on new regulations or emerging technologies is crucial.

Documentation and Record Keeping

Training Documentation:

GACAR Part 145 (§145.67) mandates maintaining training records for a minimum of two years.

>> Best practice extends this to digitalized, long-term records that track an employee’s entire career progress. This system should not only store completed training but also highlight upcoming training needs, certification renewals, and performance evaluations.

>> Compliance Audits: Regular internal audits of training documentation help ensure that employees’ competencies are continuously aligned with regulatory requirements. This is particularly important during external audits, where gaps in training documentation can result in non-compliance findings.

Maintenance Records:

Maintenance records must be accurate, complete, and accessible, as required by GACAR Part 43 (§43.11 and §43.15). Best practice includes implementing real-time electronic recordkeeping systems (such as a computerized maintenance management system or CMMS). These systems reduce the risk of human error and ensure that all records are securely stored and easily retrievable for both internal reviews and external audits.

>> Discrepancy Management: When discrepancies are found during inspections, it’s critical to document them thoroughly and communicate them to the relevant personnel. Implement a closed-loop feedback system that tracks the resolution of each discrepancy from detection through corrective action, ensuring no issue is overlooked.

Human Performance and Coordination – Human Factors Training:

Human factors training, as outlined in GACAR Part 145 (§145.67), is a key component of competence management. Best practice includes providing training on topics such as fatigue management, communication, and team coordination. Incorporating human performance elements into initial and recurrent training ensures that personnel can recognize and mitigate the human factors that could lead to errors.

>> Cross-Functional Team Training: Ensure that maintenance personnel, engineers, and flight crew regularly train together in simulated scenarios to foster better coordination, as human factors often arise from communication breakdowns between different teams.

Promoting a Safety Culture: Competence management should go hand in hand with fostering a strong safety culture. This includes encouraging employees to report near-misses or potential hazards without fear of repercussions. Regular safety meetings where incidents are openly discussed and analyzed for lessons learned is an essential best practice.

Quality Control and Continuous Improvement – Quality Control Systems:

Under GACAR Part 145 (§145.91), repair stations are required to implement a robust quality control system. Best practice includes developing a risk-based quality management system that regularly evaluates the effectiveness of maintenance processes, employee performance, and the adequacy of training programs. Quality control should extend beyond regulatory compliance to include continuous improvement initiatives aimed at enhancing competence and operational efficiency.

Root Cause Analysis: When issues arise, use root cause analysis to determine whether the issue stemmed from a lack of competence or procedural inadequacies. This analysis can help improve training programs or identify knowledge gaps in the workforce.

Capability Lists and Equipment:

As per GACAR Part 145 (§145.97), repair stations must maintain an accurate capability list that identifies the types of equipment and maintenance tasks the station is certified to perform. The best practice is to regularly review and update the capability list, ensuring that it reflects the most current technical capabilities and personnel competencies. This process should also involve evaluating new technologies and determining whether additional training is needed to maintain competence in emerging areas.

Ongoing Monitoring and Adaptation – Competence Reviews:

Continuous assessment is crucial for maintaining competence. Best practice includes regular skills assessments, refresher courses, and even peer reviews, where employees can learn from one another’s experiences. Annual performance reviews should include an evaluation of technical skills, problem-solving abilities, and adherence to safety protocols.

Adapting to New Regulations: The regulatory environment is continually evolving, especially with advancements in technology and changes in international standards. A best practice is to assign a dedicated team to monitor changes in GACAR regulations or international standards (e.g., ICAO), ensuring that all employees receive timely updates and training on new requirements.

Next Steps

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Sofema Aviation Services provides regulatory training compliant with GACAR Parts 43 and 145. For questions email team@sassofia.com.

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Human Factors Training, GACAR Part 145, GACAR Part 43, SAS blogs, Record-keeping, On the Job Training (OJT), Standard Operating Procedures (SOPs), Competence Considerations, Maintenance Activities, Quality Control Systems