About the author
Steven Bentley is an avionics licensed aircraft engineer who obtained his initial qualification in February 1976. With more than 40 years’ experience in commercial aviation and a deep understanding of practical considerations involved in Commercial Aircraft Maintenance. Steven is MD of Sofema Aviation Services a Regulatory training and Consulting Organisation which was founded in 2008
About the company
Sofema Aviation Services delivers regulatory training to the highest professional standards well known to EASA and UAE GCAA regulatory authorities, each year SAS delivers training to approximately 2000 Aviation personnel including maintenance and operational.
Currently more than 100 regulatory training courses are on offer: https://sassofia.com/regulatory-training-courses/
About this Document
To raise a number of issues related to aviation organisational Part 145 & Part M Training
The first is that EASA does not adequately identify the “TRUE” role of a 147 training organisation. In fact it is approved for specific activities “only” concerning Part 66 Maintenance engineers. Both BASIC training to obtain the aircraft maintenance engineers license (AMEL) and TYPE training to support the release of aircraft through attaining a Certificate of Release to Service Authority CRS .Its approval does not automatically cover it for other “ 145 or Part M related company specific training”
The second is that it is the fundamental obligation of both 145 and Part M organisations to manage competence in an effective way, moreover to be able to demonstrate this process to the satisfaction of the regulator.
NOTE 1
(Being a 147 organisation does NOT demonstrate that training meets the needs of the organisation)
The third is that the standard of Part 66 is clearly identified whereas in contrast organisational specific and related training is more subjective, with a need for the organisation to assess identify implement and measure the standard – this may be delivered using 145 internal instructors or from time to time involve external subcontract instructors.
The fourth point is that it should not be the role of the regulator to approve subcontract instructors or training material directly (In fact this is counterproductive as it undermines the internal competence management process)
The role of the regulator should be to ensure the organisation has the ability to “assess identify implement and measure the standard”
In this way it does not matter whether the training is connected with Human Factors, Fuel Tank Safety EWIS, Logistics, Reliability, Maintenance Planning or Production Planning the message is the same
a) How does the organisation assess the content of the training?
b) How does the organisation assess the standard of delivery of the training?
c) How does the organisation assess the effectiveness of the training?
NOTE 2
Please note the above comments ” a), b) & c) ” are a long way from “ticking the box” type training where a regulator insists for example that such a “sub contract” training must be delivered by a 147 organisation.
Comments for Consideration
1/ EASA Part 147 training organisations are approved to deliver training for Part 66 Basic or Part 66 type training. They have no regulatory remit to deliver any other training which may be required by either the Part 145 or Part M organisation
2/ EASA Part 147 Organisations do not automatically achieve competence to deliver EWIS training as a function of the “147” approval – for example the training of mechanics is not a standardized process – it should be developed in a way which demonstrates it meets the organisations needs.
3/ Within the EASA regulatory system it is the responsibility of the organisation to “manage” the competence of its Staff, its trainers and its Managers – moreover it is the responsibility of the organisation to demonstrate the competence management process to the regulator – means to the satisfaction of the regulator.
4/ Regulators outside of EASA who never the less profess to “follow” EASA regulations often fail to appreciate the significance of the competence oversight and assessment process – for example to “Require” an EWIS training organisation must also be 147 demonstrates a shortfall in appreciating the essential process of demonstrating effective management of competence.
5/ If we want to drive the safest system possible we need to identify the methodology used by an organisation to measure the effectiveness of its training processes.
6/ Organisations which over focus on the need to comply with regulatory requirements miss the fundamental point that regulatory compliance is in fact the minimum standard there is a lot more which can and should be done to raise standards and thereby reduce “risk & exposure” within the organisation – For example the decision taken by some organisations to provide inspection training for Zonal Inspection.
Using the example of EWIS to consider the challenge of effective organisation training
Part 66 Driven requirements
The following is the Part 66 requirement which a 147 organisation must ensure as part of the “basic” license training program. (Note that a 147 Type training organisation does not cover “AMC 20-22”
PART 66 Requirement – 7.7 Electrical Wiring Interconnection System (EWIS) Continuity, insulation and bonding techniques and testing; Use of crimp tools: hand and hydraulic operated; Testing of crimp joints; Connector pin removal and insertion; Co-axial cables: testing and installation precautions; Identification of wire types, their inspection criteria and damage tolerance. Wiring protection techniques: Cable looming and loom support, cable clamps, protective sleeving techniques including heat shrink wrapping, shielding; EWIS installations, inspection, repair, maintenance and cleanliness standards.
Now consider the training requirements driven by EASA AMC 20-22
The objective of this EWIS training programme is to give operators, holders of TC, holders of STC, maintenance organisations and persons performing field approval modifications or repairs a model for the development of their own EWIS training programme.
This will ensure that proper procedures, methods techniques, and practices are used when performing maintenance, preventive maintenance, inspection, alteration, and cleaning of EWIS. The training syllabus and curriculum for those personnel directly involved in the maintenance and inspection of EWIS, identified as Target Group 1 and 2, are in Appendix A and C to this AMC.
And the content of the training to comply with AMC 20-22
This is for persons who are required to either work on EWIS or Inspect EWIS
NOTE 3
PLEASE NOTE that this group of staff may in fact NOT always be licensed aircraft engineers – Means they can often be mechanics
A – GENERAL ELECTRICAL WIRING INTERCONNECTION SYSTEM PRACTICES Know or demonstrate safe handling of aeroplane electrical systems, line replaceable units (LRU), tooling, troubleshooting procedures, and electrical measurement.
1. Safety practices
2. Electrostatic discharge sensitive (ESDS) device handling and protection
3. Tools, special tools, and equipment
4. Verifying calibration/certification of instruments, tools, and equipment
5. Required wiring checks using the troubleshooting procedures and charts
6. Measurement and troubleshooting using meters
7. LRU replacement general practices
B – WIRING PRACTICES DOCUMENTATION Know or demonstrate the construction and navigation of the applicable aeroplane wiring system overhaul or practices manual.
8. Standard wiring practices manual structure/overview
9. Chapter cross-reference index
10. Important data and tables
11. Wiring diagram manuals
12. Other documentation as applicable
C – INSPECTION Know the different types of inspections, human factors in inspections, zonal areas and typical damages.
13. General visual inspection (GVI), detailed inspection (DET), special detailed inspection (SDI), and zonal inspection, and their criteria and standards
14. Human factors in inspection
15. Zonal areas of inspection
16. Wiring system damage
D – HOUSEKEEPING Know the contamination sources, materials, cleaning and procedures.
17. Aeroplane external contamination sources
18. Aeroplane internal contamination sources
19. Other contamination sources
20. Contamination protection planning
21. Protection during aeroplane maintenance and repair
22. Cleaning processes
E – WIRE Know or demonstrate the correct identification of different wire types, their inspection criteria and damage tolerance, repair and preventative maintenance procedures.
23. Wire identification, type and construction
24. Insulation qualities and damage limits
25. Inspection criteria and standards for wire and wire bundles
26. Wire bundle installation practices
27. Typical damage and areas found (aeroplane specific)
28. Maintenance and repair procedures
29. Sleeving
30. Unused wires – termination and storage
31. Electrical bonding and grounds
F – CONNECTIVE DEVICES Know or demonstrate the procedures to identify, inspect, and find the correct repair for typical types of connective devices found on the applicable aeroplane.
32. General connector types and identification
33. Cautions and protections
34. Visual inspection procedures
35. Typical damage found
36. Repair procedures
G – CONNECTIVE DEVICE REPAIR Demonstrate the procedures for replacement of all parts of typical types of connectors found on the applicable aeroplane.
37. Circular connectors
38. Rectangular connectors
39. Terminal blocks – modular
40. Terminal blocks – non-modular
41. Grounding modules
42. Pressure seals
Conclusions
1/ It should be noted that the content of the EWIS training requirement driven by AMC is at variance with that which is proscribed by Part 66. (The AMC is in far more detail)
2/ There is no conflict in item 1 above simply because it is the organisations responsibility to measure and manage the effectiveness of the training, simply put the Part 66 requirement is a step on the journey.
3/ Regulators who insist on “externally” attempting to manage what is in fact an “internal” competence driven training, run the risk of undermining the effectiveness of the training
4/ The strongest aviation system is found where the regulators understand the role of industry to manage its own competence in an effective way. The UAE Gulf Civil Aviation Authority is a typical example of a regulatory having a full understanding of how the regulations are “meant” to work as such the UAE aviation system is strong and effective.
5/ EASA has a role to play to communicate more effectively the true purpose of a part 147 organisation and the role of organisational competence management – unfortunately it sends out many mixed messages which cause some confusion.
Next Steps
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