Transcript Diapositive 1 - European Aviation Safety Agency

European Aviation Safety Agency
5 July 2007
EASA Cologne
Slide 1
NPA 2007/07: Type training
Part 66 Annex III
Rulemaking task 66-011
EASA workshop
05 July 2007
[email protected]
5 July 2007
EASA
Cologne
European Aviation Safety Agency
66-011 Type training and
examination standard
A few pieces of information
affecting rulemaking task
66-011
 Amendment
n°167 ICAO Annex 1
 Rulemaking task 21-039
5 July 2007
EASA Cologne
Slide 3
European Aviation Safety Agency
ICAO Annex 1 Licensing
New amendment n°167 (Tenth Edition) effective
on July 2006, applicable on 23 November 2006
Training should be “competency” based.
It is flight operation orientated. No change for
chapter 4 of Annex 1 (licences and rating for
personnel other than flight crew members –
especially for aircraft maintenance) and for Doc
7192 Part D-1 (training manual for aircraft
maintenance)
3 phases of learning process:
1) Knowledge
 2) Skills
 3) Experience

5 July 2007
EASA Cologne
Slide 4
European Aviation Safety Agency
ICAO Annex 1 Licensing
Creation of Doc 9868 about training (first edition
February 2006) and associated to the ICAO annex 1
A methodology about ‘training” is given.
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5 July 2007
Objectives / justification of a training need
Task analysis and their formulation in an observable and measurable
fashion
Continuous evaluation process to ensure the effectiveness of training
Indicators for evaluation / Assessment, assessors, performance
oriented tests
Performance or Criteria to be considered by the examiner when
assessing each competency / Definition of competency: a
combination of skills, knowledge and attitude to perform a task to the
prescribed standard /The tolerances applicable to all competency
based tests
EASA Cologne
Slide 5
European Aviation Safety Agency
21.039 Additional airworthiness specifications
for a given type of aircraft and type of operation
Rulemaking task 21-039
Currently the following (for a given type of aircraft) are
approved by the NAA following a recommendation of the
Joint Operational Evaluation Board (JOEB / JAA times),
such as:

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the minimum syllabus of pilot type rating training
the MMEL …
Objective of task 21.039:
To create in Part 21 the appropriate provisions
describing how the Agency will approve the following
additional airworthiness specifications for a given
aircraft type, making them the minimum standard for all
aircraft registered in the EU or operator by a European
operator (lease in) to be used by the operators in order
to develop their own training programmes, minimum
equipment lists etc…
5 July 2007
EASA Cologne
Slide 6
European Aviation Safety Agency
21.039
additional airworthiness specifications
for a given type of aircraft and type of operation
The most likely option is the TC holder to provide
stakeholders with a minimum standard (approved by the
Agency) to be used by the operator / Training
organisation... This package could include:
- the need for a type rating
- minimum syllabus of maintenance certifying staff type rating,
21.039 is now under progress and the chairman of 66-011
has been selected as member of the group to ensure
coordination.
An advanced-NPA / NPA could be ready by end 2007 (to be
confirmed) in order to determine the best option (what we
expect to regulate) and the content of the selected option
will be drafted in 2008.
A workshop will be organised after summer 2007:
operators, training organisations, NAAs… will be invited;
monitor http://www.easa.eu.int/home/events_en.html
5 July 2007
EASA Cologne
Slide 7
European Aviation Safety Agency
66-011 rulemaking task
66-011 Type training and
examination standard
(Part66 – Appendix III)
5 July 2007
EASA Cologne
Slide 8
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Unfortunately, elements from 21-039 are
not available so far and are likely to be
required only for new brand aircraft.
From a standardization point of view, it is
observed that
There is significant variation in duration (for
example, duration of a type course for the same
type and model can vary between 100 and 200h )
Too much room for interpretation is left for the
content of the practical elements (no sufficient
guidance).
Therefore, unequal treatment is reported in
level, length and content
5 July 2007
EASA Cologne
Slide 9
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Some elements although quite
extensive do not seem to be detailed
enough to avoid too much significant
variation in content and in duration.
The duration for the practical elements
as specified in the current AMC (between
two weeks and four months, based on
the experience of the applicant) is not
uniformly implemented: tendency was to
limit the duration to two weeks,
whatever the experience of the applicant
was.
5 July 2007
EASA Cologne
Slide 10
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Current AMC 66.A.45(d)
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5 July 2007
The practical training must comprise a period
of 4 months for applicants with no recent
recorded previous practical experience of
aircraft of comparable construction and
systems, including the engines, but this can be
reduced to a minimum of two weeks for
applicant with such previous experience.
A programme of structured OJT may be
prepared to satisfy the practical training
requirement
The practical training should be supported by a
detailed syllabus showing its content and
duration (no existing guidance so far)
EASA Cologne
Slide 11
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
The OJT program was mis-implemented.
No cross reference to the practical
training elements and its objectives
Standardization aspect: throughout the
Member states.
The group was committed to fully review
paragraph 66.A.45 (c) &(d) as well as
Appendix III
5 July 2007
EASA Cologne
Slide 12
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
The term of reference was limited to large
aircraft plus all aircraft where type
training is required.
The group started to work in 2005 and 12
meeting were necessary:
Difficulties in solving the problems
No perfect solution
Areas of non-consensus or dissents
 The NPA was produced late behind the schedule.
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66-011 group was composed of engineer
association representative, industry and
NAAs members. EAMTC was consulted.
5 July 2007
EASA Cologne
Slide 13
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
These facts encourage the following
options:
Setting up a minimum duration for the
theoretical elements and updating the
current syllabus
Defining a guidance or a syllabus to be
adapted for the practical elements and/or
Replace duration of the practical training
(between two weeks and four months) by
a fixed content.
5 July 2007
EASA Cologne
Slide 14
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Making a difference between practical
training in a Part 147 environment and on
the job training in a maintenance
organisation environment (OJT)
On the job training for the first type
training within a sub-category to be
compelled in order to gain experience and
competency.
Examination and assessment.
5 July 2007
EASA Cologne
Slide 15
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Some basic questions
Do we need the pre-requisites (eligibility
requirement) of each individual applicant
to be systematically checked before an
applicant enters a training room in order
to adapt the syllabus to the competence
or experience of the trainee?

(Refer to point n°42 of the NPA where the opinion of the
stakeholders is sought)
Do we need to recommend a minimum
duration in hours for the theoretical
elements?
5 July 2007
EASA Cologne
Slide 16
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
What NPA 2007/07 (task 66011) will propose….
5 July 2007
EASA Cologne
Slide 17
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Theoretical training
Content has been re-organised: new table
available according to ATA chapter breakdown or
subjects (in line with EAMTC proposal).
Content has been updated to match new
technology and new systems
The concept of “minimum duration” is accepted
(see next slides)
It does not mean that all course duration should be at the
minimum: all course application must be supported by detailed
training needs analysis.
 Where the analysis shows that more hours are needed, course
lengths shall be longer that the minimum specified in the table.
 This training needs analysis will constitute a tool for the NAAs

5 July 2007
EASA Cologne
Slide 18
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Minimum duration of the theoretical
elements
It is not easy to establish different classes or
categories of aircraft that covers the wide range of
aircraft and technology, only generic classes will
be identified and “flexibility” should exist about
the variation of that duration.
Therefore a guidance about flexibility is given in
order to reduce the length of a training course
when needed: it should be based on justifications
(training need analysis – 1st step towards
“competency based training “) that have to be
accepted by the NAA.
5 July 2007
EASA Cologne
Slide 19
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Minimum duration of the theoretical elements (…/…)
Therefore, the group decided to remain
“generic” and only proposed three
categories:
Aeroplanes with a MTOM of more than 5700kg.
 Aeroplanes with a MTOM of 5700kg and below where type
training is required;
 Multi-engine helicopters and helicopters where type
training is required.

A proposed guidance material for a better
understanding…
5 July 2007
EASA Cologne
Slide 20
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Minimum duration of the theoretical elements (…/…)
… GM 66.A.45(g)(1) Type/task training and ratings
The minimum duration for type training has been determined
based on generic categories of aircraft and minimum standard
equipment fit.
Deviation below the minimum duration is only permissible in
exceptional circumstances. Training program reductions for a
particular aircraft type must be approved by the competent
authority on a case-by-case basis appropriate to the type. For
example, while it would be exceptional for a theoretical
knowledge course to be below the minimum duration shown
for a large transport category aircraft such as an A330 or
B757, it would not necessarily be exceptional in the case of a
General Aviation (GA) business aircraft such as a Learjet 45 or
similar. Typically the training needs analysis (TNA) for a GA
aircraft course will demonstrate that a course of a shorter
duration satisfies the requirement.
5 July 2007
EASA Cologne
Slide 21
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Aeroplanes with a maximum take-off mass of more than
5700kg:
 B1.1: 150h
 B1.2: 120h
 B2: 100h
 C: 25h
Aeroplanes of a maximum take-off mass of 5700kg and below,
where type training is required:
 B1.1: 120h
 B1.2: 100h
 B2: 100h
 C: 25h
Multi-engine helicopters and helicopters where type training is
required:
 B1.1: 120h
 B1.2: 100h
 B2: 100h
 C: 25h
5 July 2007
EASA Cologne
Slide 22
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
A better distinction between the
practical training and the OJT was
proposed
There will be no more duration
(“2weeks/4 months)
For both cases, assessors should
demonstrate training and experience on
the assessment process being undertaken
5 July 2007
EASA Cologne
Slide 23
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Practical training
A content or a table (list of tasks) is proposed
(everything is “mandatory”) and the practical
syllabus must be supported by either a detailed
syllabus or practical logbook or worksheets
showing content and duration

Location / functional or operational test / service and ground
handling / removal or installation / MEL / Trouble shooting
Shall be assessed by approved assessors
Demonstration of practical training must be
retained during 5 years by the approved
organisation
5 July 2007
EASA Cologne
Slide 24
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
The OJT
The OJT is mandatory for the first type training in
any subcategory (of the licence) (theoretical and
practical) in a sub-category and is optional for the
second or subsequent ones;
The OJT shall be conducted by an approved MRO
and approved by the NAA.
The OJT should cover at least 50% of the
Appendix II to AMCs (that has been updated)
The OJT should be recorded in a harmonized
manner
OJT shall be supervised (supervisor) and shall be
assessed by approved assessors (AMC: F4).
No pre-requisite management by Part 147
5 July 2007
EASA Cologne
Slide 25
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Why OJT in a maintenance environment?
It is commonly accepted that true experience is
mostly gained in an approved maintenance
organisation where an aircraft is likely to be more
available for training purposes.
Few Part 147 organisations have permanent access
to an aircraft and very few training organisations
will perform maintenance for training purposes on
an aircraft which is fit for fly because true trouble
shooting cannot be performed and de-installationre-installation could lead to a true failure.
5 July 2007
EASA Cologne
Slide 26
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Additional small amendments to fit
to the overall changes
Based on experience in the application of the
current requirements and feedback received, some
improvements have been taken into consideration:
The duration of type rating examination
questions has been changed from a
mixture of 75 and 120 seconds to 90
seconds for all levels in order to
standardise question generation.
5 July 2007
EASA Cologne
Slide 27
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Additional small amendments to fit
to the overall changes (…/…)
Changes to the number of questions per
chapter to simplify the system presently
in place.
Highlighting that examination question
level must be in proportion to the level of
training conducted.
Clarification on instructor requirements.
A form 4 should be filled in for every
assessor and proposed to the competent
authority.
5 July 2007
EASA Cologne
Slide 28
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Responsibilities of the NAA related to type
endorsement
Practical training and OJT, when conducted
by a maintenance organisation, shall be
assessed, approved and audited by the
competent authority.
When the type training is conducted in
different organisations (PART 147 and/or
approved maintenance organisations or
direct course approval) the authority shall
be satisfied that the interfaces are
appropriately handled.
5 July 2007
EASA Cologne
Slide 29
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Responsibilities of the NAA related to type
endorsement (…/…)
In the case of second or subsequent type
rating within a license sub-category the
aircraft type has to be granted based on a
Part-147 Certificate of Recognition in the
case all applicable elements (theoretical
and practical part) are performed within an
approved part-147 organisation. This point
has been raised because of a lack of mutual
recognition between Member States.
5 July 2007
EASA Cologne
Slide 30
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Differences training has been addressed
Some AMC are now binding (raised at the
level of the implementing rules)
Consistency with other rulemaking tasks
such as 66-006 (privileges of B1/B2 licences
engineers)
One member suggested that the engine
running practical task, presently optional
within Part-66 appendix III should be a
mandatory practical training task. Dissent
area (paragraph 42 to be commented)
5 July 2007
EASA Cologne
Slide 31
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
(SUM-UP)
IMPACT and TRANSITION PERIOD
5 July 2007
EASA Cologne
Slide 32
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
a) for Part-147 Maintenance Training
Organisations:
Amendment of MTOE
Generation of Training Needs Analysis
(TNA) for all courses
Develop and amend course material
Review of examination questions
Development of practical training
schedules
5 July 2007
EASA Cologne
Slide 33
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
b) for Part-145 / Part-M Maintenance
Organisations:
Amendment of MOE / MOM
Development of procedures for practical
training/ OJT
Training and appointment of practical
training/ OJT Assessors
Development of for practical training/ OJT
schedules
5 July 2007
EASA Cologne
Slide 34
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
C) for Competent Authorities:
Review of existing procedures
Develop new procedures for the oversight
of practical training/ OJT
Training of Surveyors/ Inspectors
5 July 2007
EASA Cologne
Slide 35
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
d) for students:
Formal use of logbook
Requirement for assessment of practical
training
5 July 2007
EASA Cologne
Slide 36
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Transition provisions / Entry
into force
(a) A period of 90 days has been proposed before
entry into force of this Regulation amendment.
(b) Applicants for an initial Part-147 maintenance
training organisation approval that are already
subject to the applicable investigation process on the
date of entry into force of this Regulation
amendment, are subject to the requirements
applicable prior to the entry into force of this
Regulation amendment.
…/…
5 July 2007
EASA Cologne
Slide 37
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Transition provisions / Entry
into force
…/…
(c) Part-147 approved maintenance training
organisations applying for approval of new type
courses may elect not to apply this Regulation
amendment until 15 months after the date of entry
into force of this Regulation amendment. Partial
implementation of selective items of this Regulation
amendment is not allowed.
(d) The provisions of paragraph 2(c) shall also apply
to organisations applying to the competent authority
for approval of type courses not imparted by Part147 approved maintenance training organisations.
…/…
5 July 2007
EASA Cologne
Slide 38
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Transition provisions / Entry
into force (…/…)
(e) Competent authorities shall accept and process
applications for type course approval submitted
under paragraphs 2(c) and 2(d).
(f) Type courses approved in accordance with the
requirements applicable prior to the entry into force
of this Regulation amendment can only be imparted
until 15 months after the date of entry into force of
this Regulation amendment. Certificates for those
type courses issued not later than 15 months after
the date of entry into force of this Regulation
amendment shall be considered as issued in
accordance with this Regulation amendment.
5 July 2007
EASA Cologne
Slide 39
European Aviation Safety Agency
66-011 Type training and
examination standard (App III)
Future of this rulemaking task
Bridge with rulemaking task 21-039 (some elements
have been already passed to this group) Consistency
between 66-011 and 21-039 will have to be and will
be enhanced
 21-039 will only give the minimum syllabus but it
will be responsibility of the training providers to
build a course IAW 66-011 guidelines /
recommendations
 It is unlikely that a catch up program will be
mandatory: “optional catch up programme” is more
likely to happen: the training syllabus IAW 66-011
will remain valid. In any case, transition period to
bridge will be proposed and the former training
certificates will remain valid.
 If something wrong happen with 21.039, 66-011 will
apply. Entry into force for 66-011 would be before
21-039.
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5 July 2007
EASA Cologne
Slide 40
European Aviation Safety Agency
www.easa.europa.eu
END
5 July 2007
EASA Cologne
Slide 41