147.A.145 Privileges of the maintenance training organisation

Distance training may also be delivered via URL addresses. When delivering distance training, the learning location is the responsibility of the student and need not be controlled by the training organisation. Refer to point 147.A.100(j). Knowledge examinations may also be conducted by accessing the examination questions via uniform resource locator (URL) addresses, provided the knowledge examination environment is under the control of the maintenance training organisation.

1.When training or examination is carried out under the sub-contract control system it means that for the duration of such training or examination, the Part-147 approval has been temporarily extended to include the sub-contractor. It therefore follows that those parts of the sub-contractor’s facilities, personnel and procedures involved with the Part-147 approved maintenance training organisation’s students should meet requirements of Part-147 for the duration of that training or examination and it remains the Part-147 organisation’s responsibility to ensure such requirements are satisfied.

2.The maintenance training organisation approved under Part-147 is not required to have complete facilities and personnel for training that it needs to sub-contract but it should have its own expertise to determine that the sub-contractor meets the Part-147 standards. Particular attention should be given to ensuring that the training that is delivered also meets the requirements of Part-66 and the aircraft technologies are appropriate.

3.The contract between the maintenance training organisation approved under Part-147 and the sub-contractor should contain: a provision for the Agency and the competent authority to have right of access to the sub-contractor; a provision for the sub-contractor to inform the Part-147 approved maintenance training organisation of any change that may affect its Part-147 approval, before any such change takes place.

1.The pre audit procedure should focus on establishing compliance with the training and examination standards set out in Part-147 and Part-66.

2.The fundamental reason for allowing a maintenance training organisation approved under Part-147 to sub-contract certain basic theoretical training courses is to permit the approval of maintenance training organisations, which may not have the capacity to conduct training courses on all Part-66 modules.

3.The reason for allowing the subcontracting of training modules 1 to 6 and 8 to 10 only is, most of the related subjects can generally also be taught by training organisations not specialised in aircraft maintenance and the practical training element as specified in 147.A.200 does not apply to them. On the contrary, training modules 7 and 11 to 17 are specific to aircraft maintenance and include the practical training element as specified in 147.A.200. The intent of the ‘limited subcontracting’ option as specified in 147.A.145 is to grant Part-147 approvals only to those organisations having themselves at least the capacity to teach on aircraft maintenance specific matters.

In the case of type training and examination, the reason for allowing only subcontracting to powerplant and avionic systems is that the related subjects can generally also be imparted by certain organisations specialised in these domains such as the Type Certificate Holder of the powerplant or the OEMs of these avionics systems. In such a case, the type training course should make clear how the interfaces with the airframe are addressed and by whom (the subcontracted organisation or the Part-147 organisation itself).

When an organisation approved to provide basic knowledge training or type training is also approved to provide type examination in the cases where type training is not required, appropriate procedures in the MTOE should be developed and approved, including: The development and the conduct of the type examination; The qualification of the examiners and their currency. In particular, emphasis should be put when such an examination is not regularly conducted or when the examiners are not normally involved in aircraft or activities with technology corresponding to the aircraft type subject to examination. An example would be the case of an organisation providing basic knowledge training only for the B1.1 license. This organisation should justify how they run type examinations for single piston-engine helicopters in the case of a B1.4 licence.