November 29, 2022


Training Needs Analysis (TNA) – Considerations by Sofema Aviation Services (SAS)

Reference point 3.1(d) of Appendix III to Part-66 ā€˜Aircraft Type Training (ED Decision 2016/011/R)

Training Needs Analysis for the Theoretical Element of the Aircraft Type Training:

  1. 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
  1. 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.
  • In the particular case of type training courses approved on the basis of the requirements valid before Regulation (EU) No 1149/2011 was applicable (1 August 2012) and having a duration for the theoretical element equal to or above the minimum duration contained in paragraph 3.1(c) of Appendix III to Part-66,

o It is acceptable that the TNA only covers the differences introduced by Regulation (EU) No 1149/2011 in paragraph 3.1(e) ā€˜Contentā€™ and the criteria introduced in paragraph 3.1(d) ā€˜Justification of course durationā€™ related to the minimum attendance and the maximum number of training hours per day.
o TNA may result in a change in the duration of the theoretical element.

  1. The content and the duration deriving from this TNA may be supported by an analysis from the Type Certificate holder.
  2. In order to approve a reduction of such minimum duration, the evaluation done by the competent authority should be performed on a case-by-case basis appropriate to the aircraft type.
  • For example, while it would be exceptional for a theoretical course for a transport category complex motor-powered aircraft such as an A330 or B757 to be below the minimum duration shown, it would not necessarily be exceptional in the case of a General Aviation (GA) business aircraft such as a Learjet 45 or similar.
  • Typically the TNA for a GA aircraft course would demonstrate that a course of a shorter duration satisfies the requirements.
  1. When developing the TNA the following should be considered:
  • The TNA should include an analysis identifying all the areas and elements where there is a need for training as well as the associated learning objectives, considering the design philosophy of the aircraft type, the operational environment, the type of operations and the operational experience.
  • This analysis should be written in a manner which provides a reasonable understanding of which areas and elements constitute the course in order to meet the learning objectives.
  • As a minimum, the Training Need Analysis (TNA) should take into account all the applicable elements contained in paragraph 3.1 of Part-66 Appendix III and associated AMCs.

(c) The TNA should set-up the course content considering the Appendix III objectives for each level of training and the prescribed topics in the theoretical element table contained in paragraph 3.1 of Part-66 Appendix III.

(d) For each chapter described in the theoretical element table contained in paragraph 3.1 of Part-66 Appendix III, the corresponding training time should be recorded.

(e) Typical documents to be used in order to identify the areas and elements where there is a need for training typically include, among others,

  • The Aircraft Maintenance Manual,
  • MRB report,
  • CMRs,
  • Airworthiness limitations,
  • Troubleshooting Manual,
  • Structural Repair Manual,
  • Illustrated Parts Catalogue,
  • Airworthiness Directives and
  • Service Bulletins.

(f) During the analysis of these documents:

  • Consideration should be given to the following typical activities:
  • Activation/reactivation;
  • Removal/Installation;
  • Testing;
  • Servicing;
  • Inspection, check and repairs;
  • Troubleshooting / diagnosis.

Note – For the purpose of identifying the specific elements constituting the training course, it is acceptable to use a filtering method based on criteria such as:

  • Frequency of the task;
  • Human factor issues associated to the task;
  • Difficulty of the task;
  • Criticality and safety impact of the task;
  • In-service experience;
  • Novel or unusual design features (not covered by Part-66 Appendix I);
  • Similarities with other aircraft types;
  • Special tests and tools/equipment.
  • It is acceptable to follow an approach based on:
  • Tasks or groups of tasks, or
  • Systems or subsystems or components

(g) The TNA should:

  • Identify the learning objectives for each task, group of tasks, system, subsystem or component;
  • Associate the identified tasks to be trained to the regulatory requirements (table in Paragraph 3.1 of Appendix III to Part-66);
  • Organise the training into modules in a logical sequence (adequate combination of chapters as defined in Appendix III of Part-66);
  • Determine the sequence of learning (within a lesson and for the whole syllabus);
  • Identify the scope of information and level of detail with regard the minimum standard to which the topics of the TNA should be taught according to the set-up objectives.
  • Address the following:

o Description of each system/component including the structure (where applicable);
o System/component operation taking into account:

  • Ā Complexity of the system (e.g. the need of further break down into subsystems, etc.);
  • Design specifics which may require more detailed presentation or may contribute to maintenance errors;
  • Normal and emergency functioning;
  • Ā Troubleshooting;
  • Interpretation of indications and malfunctions;
  • Use of maintenance publications;
  • Identification of special tools and equipment required for servicing and maintaining the aircraft;

(h) Maintenance Practices;

(i) Routine inspections, functional or operational tests, rigging/adjustment, etc.

Describe the following:

  • The instructional methods and equipment, teaching methods and blending of the teaching methods in order to ensure the effectiveness of the training;
  • The maintenance training documentation/material to be delivered to the student;
  • Facilitated discussions, questioning session, additional practiced-oriented training, etc.;
  • The homework, if developed;
  • The training providerā€™s resources available to the learner.

Additional Notes

  • It is acceptable to differentiate between issues which have to be led by an instructor and issues which may be delivered through interactive simulation training devices and/or covered by web based elements. Overall time of the course will be allocated accordingly.
  • The maximum number of training hours per day for the theoretical element of type training should not be more than 6 hours. A training hour means 60 minutes of tuition excluding any breaks, examination, revision, preparation and aircraft visit. In exceptional cases, the competent authority may allow deviation from this standard when it is properly justified that the proposed number of hours follows pedagogical and human factors principles.
  • These principles are especially important in those cases where:

o Theoretical and practical training are performed at the same time;
o Training and normal maintenance duty/apprenticeship are performed at the same time.

  • The minimum participation time for the trainee in order to meet the objectives of the course should not be less than 90 % of the tuition hours of the theoretical training course.
  • Additional training may be provided by the training organisation in order to meet the minimum participation time.
  • If the minimum participation defined for the course is not met, a certificate of recognition should not be issued.

The TNA is a living process and should be reviewed/updated based on:

  • Operation feedback,
  • Maintenance occurrences,
  • Airworthiness directives,
  • Major service bulletins impacting maintenance activities or requiring new competencies for mechanics,
  • Alert service bulletins,
  • Feedback from trainees or customer satisfaction,
  • Evolution of the maintenance documentation such as MRBs, MPDs, MMs, etc.

The frequency at which the TNA should be reviewed/updated is left to the discretion of the organisation conducting the course.

Note:Ā The examination is not part of the TNA. However, it should be prepared in accordance with the learning objectives described in the TNA.

Next Steps

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Sofema Aviation Services ( offers Regulatory Compliant training related to the development of an EASA Part 147 Training Needs Assessments (TNA) please see the following courseĀ or emailĀ


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