“It doesn’t matter how small the operation, training is a key component to safety and success,” Sarah MacLeod, executive director of the Alexandria, Va.-based Aeronautical Repair Station Association (ARSA) told AIN. “Training for FAR Part 145 repair facilities has been an issue for the 17 years I’ve been in aviation, and even a lot longer before then. Shops that don’t recognize this deserve to go under.”
MacLeod said training is critical to “breeding” the next generation of maintenance personnel, and stressed that an initial and recurrent training program should be in place for all existing Part 145 operations, even though the regulations don’t specifically require them. “It shames me that the automotive and construction equipment industries are so far ahead of us when they don’t have the kind of legal responsibility we do,” she said.
According to MacLeod, there’s no room in the aircraft maintenance business for individuals who can’t do the job properly. “Train them; if they screw up, train them again; if they keep screwing up, fire them,” she said. “But how can you justify firing someone who doesn’t get the job done if you never took the time to train them properly in the first place?
“I’ve heard all the reasons for mechanics not getting recurrent training: ‘My company doesn’t pay for training,’ ‘My company doesn’t encourage me to get training,’ even ‘We don’t have the time or opportunity to go to training,’” she said. “The bottom line with today’s aircraft technology is that any individual who isn’t actively involved in a recurrent training program is irresponsible.”
The problem is that regulations don’t require mechanics at Part 145 shops to have an ongoing formal training program. According to FAR 145.39(e), “Each limited repair station shall have employees with detailed knowledge of the particular maintenance function or technique for which it is rated, based on attending a factory school or long experience with the product or technique involved.” There is no actual requirement for formal initial training, let alone recurrent. FAR 145.45(b) states, “…inspection personnel must be thoroughly familiar with all inspection methods, techniques and equipment used in their specialty to determine the quality or airworthiness of an article being maintained or altered.”
The new Part 145 that was released last month, a major rewrite of the regulation that’s been in the works for many years, contains provisions for FAA-approved training programs. The regulation has requirements for minimum initial and recurrent training hours and required training records, but until the new Part 145 is effective there aren’t any requirements, at least not in the U.S. Repair stations that work on European aircraft are already required under Joint Aviation Requirements (JAR) 145.30 to have a staff with an adequate understanding of what they’re doing and to receive “continuation training” in each two-year period.
Manual Is Important
One important area that should be covered by all repair stations is the inspection procedures manual. All personnel must understand how the facility goes about the business of doing maintenance. The manual should document what major repairs and alterations may be done, who is authorized to do them and who may return an aircraft to service. Other topics should include paperwork requirements, parts handling and the handling and documentation of precision measuring equipment. It is also important to have a clearly understood manual revision policy in place.
Aside from issues dealing with aircraft system knowledge and maintenance procedures, company employees must also be concerned about a host of complex, non-aviation regulations as well. Performing quality maintenance is no longer the only concern of maintenance personnel, and training must reflect the expanded concerns of the company.
Personnel working in the U.S. must also worry about compliance with EPA, OSHA, local airport regulations and the Americans with Disabilities Act. Add to that company policies and procedures, safety procedures, human-factors issues, company-provided computer systems and software, the use of various ground-support equipment, aircraft washing and waxing procedures and aircraft towing and taxiing, and the need for training becomes obvious.
“The absence of regulatory requirements doesn’t mean that operators shouldn’t be doing training,” MacLeod said. “All operators should put together a training manual so they can train their people as economically as possible, and then stick to it.”
She explained there are several key reasons for a training program. “Any repair facility that works on airliners is required to have a formal training program, but aside from that there are several good reasons for implementing such a program.” Some customers require maintenance providers to have a formal training program before they will consider using the facility.”
MacLeod also said training makes good business sense. “A formal training program goes a long way toward ensuring quality service. It also expands the operation’s capability and as a result its customer base.”
She stressed that training improves efficiencies and lowers production costs while reducing the risk of violations against the provider and its technical staff.
Developing a formal training program is not necessarily complicated, she said. There are initial and recurrent courses available through providers such as FlightSafety International and SimuFlite. Topics range from principles of advanced composite structures repair to aircraft type-specific maintenance courses. Most training providers offer the option of taking the course at their location or off site.
When developing a formal program, the operator can chose from a wide spectrum of options ranging from developing a total in-house program to relying solely on outsourced training, though the latter can be expensive. FlightSafety’s popular 2.5-day “Principles of Troubleshooting” course, for example, is available at several locations for $1,950 per student and at an off-site location for $1,450 per student, in addition to instructor expenses. FSI’s Falcon 900EX 10-day initial maintenance course runs $11,640 per student with a five-day, $4,290 refresher course recommended at 12- to 18-month intervals.
A less expensive in-house program might include computer-based instruction purchased off-the-shelf or locally developed, having an independent trainer come to one’s location, on-the-job training (OJT) or a combination of the above. “OJT can be a cost-effective training method if it is structured and given by a qualified instructor with defined objectives and standards,” MacLeod said. “All OJT training should be well documented, just like any other type of training.”
Even while touting the benefits of training, MacLeod is a pragmatist. “Let’s face it, there are negatives related to a formal training program,” she said. “There are the obvious direct costs of providing the training and the additional administrative tasks associated with it. There are also the increased opportunity costs. These are incurred when a newly trained individual sells his newfound worth to another company after you’ve increased his skills. On the whole, however, I firmly believe the benefits far outweigh the costs of training.”
Developing an In-house Program
“Developing a program isn’t as difficult as one might think,” MacLeod said. “First analyze training requirements.” She recommended inventorying the staff’s qualifications then matching projected business with the shop’s capabilities. It is also important to verify compliance with any existing regulations that pertain to the operation. “Aside from those issues, it is important to consider employee interests and potential,” she added. “Young, new employees are particularly interested in that because they want to have a say in their future.”
The second step in developing a training program is to identify a training source, and then decide whether the training should be done in-house or outsourced. Another concern is if factory or training center courses, pre-existing software, video or distance learning, simulation or computer-based instruction will be used. One option for an in-house program is to share the cost of instruction with other local shops.
The third step is to create a training budget that will become part of annual operating budget cycle. MacLeod suggested leaving some funds to take advantage of unplanned opportunities. She also stressed that the cost of training must also take into consideration the cost of personnel time, travel and potentially the cost to replace the trainee in the shop while away.
The fifth and final step is to have a management process in place. Someone will have to administer training, maintain the records, make schedule adjustments to meet training goals, match training and workload and take advantage of training opportunities as they arise.
ARSA has developed the “Generic Repair Station Training Manual.” According to MacLeod, it was developed to help the organization’s member repair stations reduce the “pain” associated with training. “We want our members to get the most out of the money and effort they put into developing their training programs,” she said. “It is designed so that the majority of their efforts and money can be spent on the training itself rather than organizing the training program and recording its results.”