145.A.30(e) Maintenance personnel qualification

COMPETENCY ASSESSMENT OBJECTIVES The procedure referred to in 145.A.30(e) should require amongst others that planners, mechanics, specialised services staff, supervisors, certifying staff and support staff, whether employed or contracted, are assessed for competency before unsupervised work commences and competency is controlled on a continuous basis. Competency should be assessed by the evaluation of: on-the-job performance and/or testing of knowledge by appropriately qualified personnel, and records for basic, organisational, or tasks training and/or product type and differences training, and experience records. Validation of the above could include a confirmation check with the organisation(s) that issued the document(s). For that purpose, experience/training may be recorded in a document such as a log book, or based on the suggested template in GM3 145.A.30(e). As a result of this assessment, an individual’s qualifications should determine: the scope of tasks this individual is authorised to perform and/or supervise and/or sign off (as applicable) or which level of ongoing supervision would be required; whether there is a need for additional training. A record should be kept of each individual’s qualifications and competency assessment (refer also to point 145.A.55(d)). This should include copies of all documents that attest to their qualifications, such as a licence and/or any authorisation held, as applicable. For a proper competency assessment of its personnel, the organisation should consider that:

1.In accordance with the job function, adequate initial and recurrent training has been received by the staff and recorded to ensure continued competency so that it is maintained throughout the duration of the employment/contract.

2.All staff should be able to demonstrate knowledge of, and compliance with, the maintenance organisation’s procedures, as applicable to their duties.

3.All staff should be able to demonstrate an understanding of the safety management principles, including human factors related to their job function, and be trained as per AMC4 145.A.30(e).

4.To assist in the assessment of competency and to establish the training needs analysis, job descriptions are recommended for each job function in the organisation. Job descriptions should contain sufficient criteria to enable the required competency assessment.

5.Criteria should allow the assessment to establish that, among other aspects (titles might be different in each organisation): Managers are able to properly manage the work output, processes, resources and priorities described in their assigned duties, accountabilities and responsibilities in accordance with the safety policy and objectives and in compliance with the applicable requirements. Planners are able to interpret maintenance requirements into maintenance tasks, and have an understanding that they have no authority to deviate from the maintenance data. They are able to organise maintenance activities in an effective manner and in consideration of human performance limitations. Supervisors are able to ensure that all the required maintenance tasks are carried out and, if they are not completed or it is evident that a particular maintenance task cannot be carried out according to the maintenance data, that these problems will be adequately addressed to eliminate the non-compliance, and reported through the internal safety reporting scheme to prevent their reoccurrence. In addition, for those supervisors, who also carry out maintenance tasks, the assessment should ensure that they understand that such tasks should not be undertaken if they are incompatible with their management responsibilities. Mechanics are able to carry out maintenance tasks to any standard specified in the maintenance data, and will notify their supervisors of any defects or mistakes requiring rectification to re-establish the required maintenance standards. Specialised services staff are able to carry out specialised maintenance tasks to the standard specified in the maintenance data. They should be able to communicate with their supervisors and report accurately when necessary. Support staff are able to determine that the relevant tasks or inspections have been carried out to the required standard. Certifying staff are able to determine when the aircraft or aircraft component maintenance is ready to be released to service and when it should not be released to service. Compliance monitoring staff are able to monitor compliance with this Regulation and to identify non-compliances in an effective and timely manner so that the organisation may remain in compliance with this Regulation. Staff who have safety management responsibilities are familiar with the relevant processes in terms of hazard identification, risk management, and the monitoring of safety performance. All staff are familiar with the safety policy and the procedures and tools that can be used for internal safety reporting. The competency assessment should be based upon the procedure specified in GM2 145.A.30(e).

COMPETENCY ASSESSMENT PROCEDURE

(a)The organisation should develop a procedure that describes the process for conducting competency assessments of personnel. The procedure should specify:

(1)the persons who are responsible for this process;

(2)when the assessments should take place;

(3)how to give credit from previous assessments;

(4)how to validate qualification records;

(5)the means and methods to be used for the initial assessment;

(6)the means and methods to be used for the continuous control of competency, including how to gather feedback on the performance of personnel;

(7)the aspects of competencies to be observed during the assessment in relation to each job function;

(8)the actions to be taken if the assessment is not satisfactory; and

(9)how to record the assessment results.

(b)Competency may be assessed by having the person work under the supervision of another qualified person for a sufficient time to arrive at a conclusion. Sufficient time could range from several days to several weeks depending on the complexity of the task(s) and the work exposure. The person need not be assessed against the complete spectrum of their intended duties. If the person has been recruited from another approved maintenance organisation, a written confirmation from the previous organisation could be taken into consideration to reduce the duration of the assessment.

(c)All prospective maintenance staff should be assessed for their competency related to their intended duties.

INITIAL AND RECURRENT TRAINING

(a)Adequate initial and recurrent training should be provided in relation to the job function to ensure that staff remain competent. Completion of such training should be recorded.

(b)Recurrent training should take into account the information reported through the internal safety reporting scheme (see point (c)(3) of AMC1 145.A.202).

(c)Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting, and recording.

SAFETY TRAINING (INCLUDING HUMAN FACTORS)

(a)With respect to the understanding of the application of safety management principles (including human factors), all maintenance organisation personnel should be assessed for the need to receive initial safety training. Personnel involved in the delivery of the basic maintenance service of the organisation should receive both initial and recurrent safety training, appropriate for their responsibilities. This should include at least the following staff members: Nominated persons, line managers, supervisors; Certifying staff, support staff and mechanics; Technical support personnel such as planners, engineers, technical record staff; Persons involved in compliance monitoring and/or safety management-related processes and tasks, including the application of human factors principles, internal investigations and safety training; Specialised services staff; Stores department staff, purchasing department staff; Ground equipment operators. The generic term ‘line managers’ refers to departmental heads or persons responsible for operational departments or functional units that are directly involved in the delivery of the basic maintenance services of the organisation.

(b)Initial safety training should cover all the topics of the training syllabus specified in GM1 145.A.30(e) either as a dedicated course or else integrated within other training. The syllabus may be adjusted to reflect the particular nature of the organisation. The syllabus may also be adjusted to suit the particular nature of work for each function within the organisation. For example: small organisations not working in shifts may cover in less depth subjects related to teamwork and communication; planners may cover in more depth the scheduling and planning objectives of the syllabus, and in less depth the objective of developing skills for shift working. All personnel identified in accordance with point (a) of this AMC, including personnel being recruited from any other organisation should receive initial safety training compliant with the organisation’s training standards prior to commencing the actual job function, unless their competency assessment justifies that there is no need for such training. New, directly employed personnel working under direct supervision may receive training within 6 months after joining the maintenance organisation.

(c)The purpose of recurrent safety training is primarily to ensure that staff remain current in terms of SMS principles and human factors and also to collect feedback on safety and human factors issues. Consideration should be given to involving compliance monitoring staff and the key safety management personnel in this training to provide a consistent presence and facilitate feedback. There should be a procedure to ensure that feedback is formally reported by the trainers through the internal safety reporting scheme to initiate action where necessary. Recurrent safety training should be delivered either as a dedicated course or integrated within other training. It should be of an appropriate duration in each 2-year period in relation to the relevant compliance monitoring audit findings and other internal/external sources of information available to the organisation on safety and human factors maintenance issues.

(d)Safety training may be conducted by the maintenance organisation itself, independent trainers, or any training organisations acceptable to the competent authority.

(e)The safety training procedures should be specified in the MOE.

OTHER TRAININGS

(a)The organisation should assess the need for particular trainings, for example with regard to the ‘Electrical Wiring Interconnection System’ (EWIS) or ‘Critical Design Configuration Control Limitations’ (CDCCL).

(b)Guidance on EWIS training programme for maintenance organisation personnel is provided in AMC 20-22.

(c)Guidance on fuel tank safety training is provided in ‘Appendix IV to AMC5 145.A.30(e) and AMC2 145.B.200(a)(3)’.

TRAINING SYLLABUS FOR INITIAL SAFETY TRAINING (INCLUDING HUMAN FACTORS) The training syllabus below identifies the topics and subtopics to be addressed during the safety training. The maintenance organisation may combine, divide, or change the order of any of the subjects in the syllabus to suit its own needs, as long as all the subjects are covered to a level of detail appropriate to the organisation and its personnel, including the varying level of seniority of that personnel. Some of the topics may be covered in separate training courses (e.g. health and safety, management, supervisory skills, etc.) in which case duplication of training is not necessary. Where possible, practical illustrations and examples should be used, especially accident and incident reports. Topics should be related to existing legislation, where relevant. Topics should be related to existing guidance/advisory material, where relevant (e.g. ICAO HF Digests and Training Manual). Topics should be related to the maintenance activities of the organisation to the greatest extent possible; too much unrelated theory should be avoided.

1.General/Introduction to safety management and human factors

1.1. Need to address safety management and human factors

1.2. Statistics

1.3. Incidents 1a. Safety risk management 1a.1. Hazard identification 1a.2. Safety risk assessment 1a.3. Risk mitigation and management 1a.4. Effectiveness of safety risk management

2.Safety Culture/Organisational factors

2.1 Justness/trust

2.2 Commitment to safety

2.3 Adaptability

2.4 Awareness

2.5 Behaviour

2.6 Information

3.Human Error

3.1. Error models and theories

3.2. Types of errors in maintenance tasks

3.3. Violations

3.4. Implications of errors

3.5. Avoiding and managing errors

3.6. Human reliability

4.Human performance & limitations

4.1. Vision

4.2. Hearing

4.3. Information-processing

4.4. Attention and perception

4.5. Situational awareness

4.6. Memory

4.7. Claustrophobia and physical access

4.8. Motivation

4.9. Fitness/health

4.10. Stress

4.11. Workload management

4.12. Fatigue

4.13. Alcohol, medication, drugs

4.14. Physical work

4.15. Repetitive tasks/complacency

5.Environment

5.1. Peer pressure

5.2. Stressors

5.3. Time pressure and deadlines

5.4. Workload

5.5. Shift work

5.6. Noise and fumes

5.7. Illumination

5.8. Climate and temperature

5.9. Motion and vibration

5.10. Complex systems

5.11. Other hazards in the workplace

5.12. Lack of manpower

5.13. Distractions and interruptions

6.Procedures, information, tools and practices

6.1. Visual inspection

6.2. Work logging and recording

6.3. Procedure - practice/mismatch/norms

6.4. Technical documentation - access and quality

6.5. Critical maintenance tasks and error-capturing methods (independent inspection, reinspection, etc.)

7.Communication

7.1. Shift/task handover

7.2. Dissemination of information

7.3. Cultural differences

8.Teamwork

8.1. Responsibility

8.2. Management, supervision and leadership

8.3. Decision-making

9.Professionalism and integrity

9.1. Keeping up to date; currency

9.2. Avoiding error-provoking behaviour

9.3. Assertiveness

10.Organisation’s safety programme

10.1. Safety policy and objectives, just culture principles

10.2. Reporting errors and hazards, internal safety reporting scheme

10.3. Investigation process

10.4. Action to address problems

10.5. Feedback and safety promotion

COMPETENCY ASSESSMENT ELEMENTS An example of elements that may be considered during a competency assessment according to the job functions and the scope, size and complexity of the organisation, is given in the following table (not exhaustive):

TEMPLATE FOR RECORDING EXPERIENCE/TRAINING The following template may be used to record the professional experience gained in an organisation and the training received and to be considered during the competency assessment of an individual in another organisation.

COMPETENCY OF THE SAFETY MANAGER The competency of a safety manager should include, but not be limited to, the following:

(a)knowledge of ICAO standards and European requirements on safety management;

(b)an understanding of management systems, including compliance monitoring systems;

(c)an understanding of risk management;

(d)an understanding of safety investigation techniques and root cause methodologies;

(e)an understanding of human factors;

(f)understanding and promotion of a positive safety culture;

(g)operational experience related to the activities of the organisation;

(h)safety management experience;

(i)interpersonal and leadership skills, and the ability to influence staff;

(j)oral and written communications skills;

(k)data management, analytical and problem-solving skills.

SAFETY TRAINING (INCLUDING HUMAN FACTORS)

(a)The scope of the safety training and the related training programme will vary significantly depending on the size and complexity of the organisation. Safety training should reflect the evolving management system, and the changing roles of the personnel who make it work.

(b)In recognition of this, training should be provided to management and staff at least:

(1)during the initial implementation of safety management processes;

(2)for all new staff or personnel recently allocated to safety management-related tasks;

(3)on a regular basis to refresh their knowledge and to understand changes to the management system;

(4)when changes in personnel affect safety management roles, and related accountabilities, responsibilities, and authorities; and NOTE: In the context of safety management, the term ‘authority’ is used in relation to the level of management in the organisation that is necessary to make decisions related to risk tolerability.

(5)when performing dedicated safety functions in domains such as safety risk management, compliance monitoring, and internal investigations.

(c)Safety training is subject to the record-keeping requirements in point 145.A.55(d).