Checking it Out
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- Apr 3, 2003
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Approved Maintenance Training
An essential step toward assuring safe aviation growth
By Brian Finnegan, President, Professional Aviation Maintenance Association
The Federal Aviation Administration (FAA) has ruled that pilots, flight engineers, flight attendants, and dispatchers must not only receive initial and recurrent training, but that their training programs must also be FAA approved. Given the flight safety critical tasks that each performs; the rule is valid. What is incredible is the exclusion of aviation maintenance technicians from those ranks.
While aviation maintenance training programs are required for FAR Part 121 and Part 135 operators, those programs do not include mandatory annual training and they do not need FAA approval.
To help right this wrong, on Feb. 17, 2004, PAMA again wrote a letter to FAA Administrator Marion C. Blakey urging the FAA to “require all air carrier, commuter, and on-demand operators to have and implement FAA-approved maintenance training programs.†On Feb. 26, 2004, the National Transportation Safety Board (NTSB) reached the same conclusion after completing its year-long investigation into the Air Midwest flight 5481 crash in Charlotte, North Carolina. Among its 21 safety recommendations to the FAA, the NTSB recommended that the FAA “require that all 14 CFR Part 121 air carrier maintenance programs be approved.â€
In a poll of PAMA’s Chapter leaders, the most desired advancement for maintenance technicians is the requirement for mandatory training. Second is the development of an advanced recognition program through which maintenance technicians can quantify the training they receive, set training milestones, and move toward future professional goals and personal growth. That is all part of a professional career and that is what PAMA is here to promote. We’re addressing both of these issues right now and will have an announcement on our recognition program in the near future.
Following my letter to Administrator Blakey and our subsequent press release, available on the PAMA web site www.pama.org, I have received feedback from several PAMA members. As might be expected in dealing with the many complexities and diverse interpretations of the FARs, there is much misinformation and misunderstanding. The contrary feedback was from members who felt the current wording for maintenance training in both Part 121 and Part 135 got the job done with respect to requiring training.
Unfortunately, those regulations actually do not require FAA-approved maintenance training programs. In both Part 121 and Part 135 for aircraft with 10 or more passengers, the maintenance training regulations are identical. (Part 135 businesses operating aircraft with less than 10 passengers have no additional training requirement at all!) And while the federal government is rarely succinct, in this case it did manage to convey the entire requirement in a total of 52 words:
Ҥ121.375 and §135.433 Maintenance and preventive maintenance training program: Each certificate holder or person performing maintenance or preventive maintenance functions for it shall have a training program to ensure that each person (including inspection personnel) who determines the adequacy of work done is fully informed about procedures and techniques and new equipment in use and is competent to perform his duties.â€
Notice the difference between the maintenance training statement above and the regulations for pilot and flight attendant training.
§135.341 Pilot and flight attendant crew member training programs: Each certificate holder, other than one who uses only one pilot in the certificate holder’s operations, shall establish and maintain an approved pilot training program, and each certificate holder who uses a flight attendant crew member shall establish and maintain an approved flight attendant training program, that is appropriate to the operations to which each pilot and flight attendant is to be assigned, and will ensure that they are adequately trained to meet the applicable knowledge and practical testing requirements of §135.293 through 135.301.
Or for even greater numbers of airmen in Part 121:
§121.401 Training program: General: (a) Each certificate holder shall: (1) Establish, obtain the appropriate initial and final approval of, and provide, a training program that meets the requirements of this subpart and appendixes E and F and that ensures that each crew member, aircraft dispatcher, flight instructor, and check airman, and each person assigned duties for the carriage and handling of dangerous articles and magnetized materials, is adequately trained to perform his assigned duties.
FAA officials tell me that if a rule does not specify a requirement be “approved,†then it is merely “accepted†by default. This means that an accepted maintenance training program need not specifically comply with a standard established by the FAA. Advisory Circular 120-16D and other guidelines do exist for the development of maintenance training programs, but they are not “standards†and noncompliance does not necessarily carry the threat of an FAA enforcement action. It is the FAA’s ability, or lack thereof, to bring enforcement action that drives all training initiatives or, for that matter, all regulatory requirements.
Those with years of experience tell me that having a training program that is merely accepted also means an operator can change the training plan without approval simply by submitting a letter notifying the FAA of the intent to make the change — and then proceeding with the change without further comment from the FAA. It is then up to the FAA to respond in the negative if it so chooses, which it usually does not.
This ability to reduce one’s training obligation without approval puts maintenance training programs squarely in the financial crosshairs of an organization hunting for savings opportunities to achieve projected revenue goals. To financially strapped companies and all of the aviation industry, I remind you that professional maintenance is an investment in your customers, your staff, your company, and in your bottom line. Future training will not bring back the crew and passengers aboard Air Midwest flight 5481, but it can prevent it from happening again. Imagine what damage an accident will do to your bottom line.
Every aviation operation is eagerly looking for new growth and industry expansion. The forecasters anticipate so much growth in numbers of aircraft and passengers flown that just maintaining the current accident rate will result in an air carrier hull loss every week. It is time for our industry to significantly invest in a safer future by preparing a highly skilled, professional, and growing aviation maintenance workforce. FAA-approved training is the first step on the road to assuring the strong maintenance infrastructure we will need to meet those future challenges.
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An essential step toward assuring safe aviation growth
By Brian Finnegan, President, Professional Aviation Maintenance Association
The Federal Aviation Administration (FAA) has ruled that pilots, flight engineers, flight attendants, and dispatchers must not only receive initial and recurrent training, but that their training programs must also be FAA approved. Given the flight safety critical tasks that each performs; the rule is valid. What is incredible is the exclusion of aviation maintenance technicians from those ranks.
While aviation maintenance training programs are required for FAR Part 121 and Part 135 operators, those programs do not include mandatory annual training and they do not need FAA approval.
To help right this wrong, on Feb. 17, 2004, PAMA again wrote a letter to FAA Administrator Marion C. Blakey urging the FAA to “require all air carrier, commuter, and on-demand operators to have and implement FAA-approved maintenance training programs.†On Feb. 26, 2004, the National Transportation Safety Board (NTSB) reached the same conclusion after completing its year-long investigation into the Air Midwest flight 5481 crash in Charlotte, North Carolina. Among its 21 safety recommendations to the FAA, the NTSB recommended that the FAA “require that all 14 CFR Part 121 air carrier maintenance programs be approved.â€
In a poll of PAMA’s Chapter leaders, the most desired advancement for maintenance technicians is the requirement for mandatory training. Second is the development of an advanced recognition program through which maintenance technicians can quantify the training they receive, set training milestones, and move toward future professional goals and personal growth. That is all part of a professional career and that is what PAMA is here to promote. We’re addressing both of these issues right now and will have an announcement on our recognition program in the near future.
Following my letter to Administrator Blakey and our subsequent press release, available on the PAMA web site www.pama.org, I have received feedback from several PAMA members. As might be expected in dealing with the many complexities and diverse interpretations of the FARs, there is much misinformation and misunderstanding. The contrary feedback was from members who felt the current wording for maintenance training in both Part 121 and Part 135 got the job done with respect to requiring training.
Unfortunately, those regulations actually do not require FAA-approved maintenance training programs. In both Part 121 and Part 135 for aircraft with 10 or more passengers, the maintenance training regulations are identical. (Part 135 businesses operating aircraft with less than 10 passengers have no additional training requirement at all!) And while the federal government is rarely succinct, in this case it did manage to convey the entire requirement in a total of 52 words:
Ҥ121.375 and §135.433 Maintenance and preventive maintenance training program: Each certificate holder or person performing maintenance or preventive maintenance functions for it shall have a training program to ensure that each person (including inspection personnel) who determines the adequacy of work done is fully informed about procedures and techniques and new equipment in use and is competent to perform his duties.â€
Notice the difference between the maintenance training statement above and the regulations for pilot and flight attendant training.
§135.341 Pilot and flight attendant crew member training programs: Each certificate holder, other than one who uses only one pilot in the certificate holder’s operations, shall establish and maintain an approved pilot training program, and each certificate holder who uses a flight attendant crew member shall establish and maintain an approved flight attendant training program, that is appropriate to the operations to which each pilot and flight attendant is to be assigned, and will ensure that they are adequately trained to meet the applicable knowledge and practical testing requirements of §135.293 through 135.301.
Or for even greater numbers of airmen in Part 121:
§121.401 Training program: General: (a) Each certificate holder shall: (1) Establish, obtain the appropriate initial and final approval of, and provide, a training program that meets the requirements of this subpart and appendixes E and F and that ensures that each crew member, aircraft dispatcher, flight instructor, and check airman, and each person assigned duties for the carriage and handling of dangerous articles and magnetized materials, is adequately trained to perform his assigned duties.
FAA officials tell me that if a rule does not specify a requirement be “approved,†then it is merely “accepted†by default. This means that an accepted maintenance training program need not specifically comply with a standard established by the FAA. Advisory Circular 120-16D and other guidelines do exist for the development of maintenance training programs, but they are not “standards†and noncompliance does not necessarily carry the threat of an FAA enforcement action. It is the FAA’s ability, or lack thereof, to bring enforcement action that drives all training initiatives or, for that matter, all regulatory requirements.
Those with years of experience tell me that having a training program that is merely accepted also means an operator can change the training plan without approval simply by submitting a letter notifying the FAA of the intent to make the change — and then proceeding with the change without further comment from the FAA. It is then up to the FAA to respond in the negative if it so chooses, which it usually does not.
This ability to reduce one’s training obligation without approval puts maintenance training programs squarely in the financial crosshairs of an organization hunting for savings opportunities to achieve projected revenue goals. To financially strapped companies and all of the aviation industry, I remind you that professional maintenance is an investment in your customers, your staff, your company, and in your bottom line. Future training will not bring back the crew and passengers aboard Air Midwest flight 5481, but it can prevent it from happening again. Imagine what damage an accident will do to your bottom line.
Every aviation operation is eagerly looking for new growth and industry expansion. The forecasters anticipate so much growth in numbers of aircraft and passengers flown that just maintaining the current accident rate will result in an air carrier hull loss every week. It is time for our industry to significantly invest in a safer future by preparing a highly skilled, professional, and growing aviation maintenance workforce. FAA-approved training is the first step on the road to assuring the strong maintenance infrastructure we will need to meet those future challenges.
Learn More
