Sofema Aviation Services www.sassofia.com looks at several Organisational Challenges related to the Management of on the Job Training within an EASA Part 145 Environment
Regulatory Background
Driven by changes in EASA regulations in accordance with EC 1149/2011 EASA introduced unique terms for Practical Training which is the responsibility of the 147 Organisation and āOn the Job Training (OJT) which typically sits with the 145 organisation.
Note 2 ā Whilst EASA Part 147 Contains multiple references to roles and responsibilities in respect of the role of Practical Assessor and Practical Trainer ā There is an absence of guidance within EASA Part 145 – Clearly this is a challenge.
EASA References within Part 66 provide for very limited guidance material related to 145 ā ref appendices to annex III
Appendix III – 4.2 Point 6 On the Job Training (OJT) shall be approved by the competent authority who has issued the licence.
It shall be conducted at and under the control of a maintenance organisation appropriately approved for the maintenance of the particular aircraft type and shall be assessed by designated assessors appropriately qualified.
So the issue is that the 145 organisation is deemed to be responsible without be provided with example guidance material. (EASA has tasked the Competent Authority CA) with the responsibility to locally approve
Related to 145 OJT – Each task shall be signed off by the student and countersigned by a designated supervisor. The tasks listed shall refer to an actual job card/work sheet, etc.
The final assessment of the completed OJT is mandatory and shall be performed by a designated assessor appropriately qualified.
Important Note related to the source criteria for assessors in both 145 & 147 jurisdictions
The provided guidance for OJT Assessor basic criteria is the same for both the 147 and 145 environment ā means a commonality of approach is implied – Further guidance about the assessment and the designated assessors is provided in Appendix III to AMC to EASA Part 66.
Regarding the day-to-day supervision of the OJT programme in the approved maintenance organisation and the role of the supervisor(s), the following should be considered:
It is sufficient that the completion ohf individual OJT tasks is confirmed by the direct supervisor(s), without being necessary the direct evaluation of the assessor.
During the day-to-day OJT performance, the supervision aims at overseeing the complete process, including task completion, use of manuals and procedures, observance of safety measures, warnings and recommendations and adequate behaviour in the maintenance environment.
The supervisor(s) should personally observe the work being performed to ensure the safe completeness and should be readily available for consultation, if needed during the OJT performance.
The supervisor(s) should countersign the tasks and release the maintenance tasks as the trainee is still not qualified to do so.
Note ā This point shows that the trainee should be signing against the task as the āmechanicā ā means full involvement in the task personally overseen by the supervisor.
The supervisor(s) should therefore:
have certifying staff or support staff privileges relevant to the OJE tasks;
be competent for the selected tasks;
be safety-orientated;
be capable to coach (setting objectives, giving training, performing supervision, evaluating, handling traineeās reactions and cultural issues, managing objectively and positively debriefing sessions, determining the need for extra training or reorientate the training, reporting, etc.); be designated by the approved maintenance organisation to carry out the
supervision.
Note – This point shows the need for a formal process to provide training and approval to the task supervisors as well as āformalā authorisation
Regarding the assessor, the following should be considered:
This assessment should include confirmation of the completion of the required diversity and quantity of OJT and should be based on the supervisor(s) reports and feedback.
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