1. 5 July 2007
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2. NPA 2007/07: Type training Part 66 Annex III Rulemaking task 66-011
EASA workshop
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3. 66-011 Type training and examination standard
A few pieces of information affecting rulemaking task
Amendment n°167 ICAO Annex 1
Rulemaking task
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4. 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
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5. ICAO Annex 1 Licensing A methodology about ‘training” is given.
Creation of Doc 9868 about training (first edition February 2006) and associated to the ICAO annex 1
A methodology about ‘training” is given.
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
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6. 21.039 Additional airworthiness specifications for a given type of aircraft and type of operation
Rulemaking task
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:
the minimum syllabus of pilot type rating training
the MMEL …
Objective of task :
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…
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7. 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,
is now under progress and the chairman of 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
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8. 66-011 Type training and examination standard (Part66 – Appendix III)
rulemaking task
Type training and examination standard (Part66 – Appendix III)
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9. 66-011 Type training and examination standard (App III)
Unfortunately, elements from 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
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10. 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.
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11. 66-011 Type training and examination standard (App III)
Current AMC 66.A.45(d)
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)
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12. 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
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13. 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.
group was composed of engineer association representative, industry and NAAs members. EAMTC was consulted.
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14. 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.
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15. 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.
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16. 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?
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17. 66-011 Type training and examination standard (App III)
What NPA 2007/07 (task ) will propose….
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18. 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
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19. 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.
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20. 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…
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21. 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.
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22. 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
Multi-engine helicopters and helicopters where type training is required:
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23. 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
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24. 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
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25. 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
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26. 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-installation-re-installation could lead to a true failure.
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27. 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.
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28. 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.
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29. 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.
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30. 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.
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31. 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 (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)
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32. 66-011 Type training and examination standard (App III)
(SUM-UP)
IMPACT and TRANSITION PERIOD
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33. 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
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34. 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
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35. 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
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36. 66-011 Type training and examination standard (App III)
d) for students:
Formal use of logbook
Requirement for assessment of practical training
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37. 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.
…/…
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38. 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 Part-147 approved maintenance training organisations.
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39. 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.
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40. 66-011 Type training and examination standard (App III)
Future of this rulemaking task
Bridge with rulemaking task (some elements have been already passed to this group) Consistency between and will have to be and will be enhanced
will only give the minimum syllabus but it will be responsibility of the training providers to build a course IAW 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 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 , will apply. Entry into force for would be before
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41.
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