European shops prepare for human factors training rule
By September next year European aircraft maintenance providers will be obliged to have conducted approved human factors training for their staff. The requirement is included in Part 145 rules issued by the European Aviation Safety Agency (EASA), but national aviation authorities’ (NAAs) inconsistent implementation of the rule appears to be causing confusion for some European companies.
According to Harald Strehling, managing director of Austria-based training organization Link & Learn Aviation Training, NAAs have not been giving consistent guidance about what subjects the human factors course must cover.
Also, some have been requiring that students take an exam, while others have essentially allowed self-assessment. Strehling told AIN that the implementation of the requirement has not even been consistent among the regional offices of an NAA, such as Germany’s LBA agency.
In Strehling’s opinion, some companies have been delaying human factors training because they find the situation so confusing. But now they have barely 12 months to complete the task, in addition to standard JAR 66 maintenance training requirements.
Under the EASA Part 145 law, “all maintenance, management and quality audit personnel” are obliged to take the human factors training. The syllabus includes topics such as staff coordination and social and racial issues.
Companies are expected to follow up with recurrent training covering the human factors aspects of specific incidents that have occurred in the workplace. The requirement covers mechanics and technicians as well as staff such s store personnel, work planners and any contract workers.
Contrary to guidance from some NAAs, there is no requirement to take an exam. However, companies do need to be able to produce satisfactory “proof of attendance” documentation.
The EASA Part 145 rules state, “In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person’s function in the organization.”
The rules define human factors as “principles which apply to aeronautical design, certification, training, operations and maintenance which seek interface between the human and other system components by proper consideration of human performance, which means human capabilities and limitations which have an impact on the safety and efficiency of aeronautical operations.”
Link & Learn is now offering a Web-based training package to cover the human factors requirements of EASA Part 145 and complements its existing JAR 66 programs. According to the company, the online human factors training takes about five hours to complete. It estimates that most of its online training packages can be completed in about half the time the same program would take in a classroom. The online format also means that employees can complete the training during convenient gaps in their work schedule, so companies can avoid sending personnel away for training or scheduling time for a trainer to visit the company site.
The Link & Learn program includes a management system that records the training covered by each student. This also generates the proof of attendance record the authorities require. The package costs $300 (?250) per student; discounts are available to firms that have more than 10 employees who need to take the training.
According to Robert Spence, quality manager with UK business aviation services group Gama Aviation, the EASA Part 145 requirement for human factors training is generally a greater burden on maintenance firms than the national rules it replaces. In the UK at least, some aspects of human factors training were previously covered under continuation training, but the EASA requirement calls for some 65 different topics to be covered, including somewhat nebulous subjects such as stress, fatigue, attention and perception.
Spence told AIN that individual employees are now expected to take greater personal responsibility for all human factors issues in the workplace. “They need to speak out if there isn’t adequate lighting or access to do a particular task,” e explained.
Each maintenance organization is required to specify to its NAA how it has met the human factors training requirement, but Spence conceded that individual surveyors might assess firms’ training programs differently. He estimated that the typical cost of having a human factors trainer visit a company for a day-long session would be around $1,800 (?1,455).
The International Civil Aviation Organization has required human factors training since 1998. The EASA has formalized this requirement before the FAA, which has yet to introduce any such legislation.
More information about the EASA Part 145 rules is available in the maintenance section of the agency’s Web site, www.easa.eu.int.