Name: Mladen Hanževački

Title:

Continuing Airworthiness Rulemaking Officer

Date: 21/22 May 2013

Outline
Overview of pending rulemaking tasks RMT.0281 (MDM.082) New teaching methods and new training technologies

The workshop

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EAMTC Instructor Seminar – RMT.0281

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Outline
Overview of pending rulemaking tasks RMT.0281 (MDM.082) New teaching methods and new training technologies

The workshop

21/22 May 2013

EAMTC Instructor Seminar – RMT.0281

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Overview of pending rulemaking tasks (CAW)
RMT.0251 “SMS embodiment and alignment with AR/OR requirements”

• • •

ToR published in July 2011. Agency task. NPA 2013-01 cover Part-M & 145. (external consultation until 22 May 2013) 2nd NPA will address Part-66 & 147. (currently under development)

A conference took place on 13th December 2012 to explain the changes proposed to Part-M and 145.

RMT.0209 “Contracting of continuing airworthiness management activities”


• •

NPA 2010-09 published in July 2010.
200 comments received, proposal was considered too complex Workshop organised in summer 2012 with industry and NAA. Agreed to progress the task with a more simple proposal CRD + Opinion postponed to 2013.
EAMTC Instructor Seminar – RMT.0281 4


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Overview of pending rulemaking tasks (CAW)
RMT.0252 “Instructions for Continuing Airworthiness

• ToR published in July 2011. Agency task. • Coordination with FAA and TCCA • Status Report published on EASA website on the 22 Oct 2012 • New ToR to be issued in 3Q2013, detailing that the task will be splitted in
the several subtasks (5).

RMT.0276 “Technical records”

• The ToR was published in November 2011. Working group task.
• 6 meetings held up to date • NPA is foreseen for 4Q2013.

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Overview of pending rulemaking tasks (CAW)
RMT.0393 “Maintenance check flights”

• ToR published in July 2011. Agency task. • NPA 2012-08 consultation ended 30/10/2012. • 335 comments received • CRD planned for end 2013
RMT.0222 “Critical tasks”

• NPA 2010-09 published in July 2010.

• 193 comments received
• CRD + opinion to be published before summer 2013.

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Overview of pending rulemaking tasks (CAW)
RMT.0278 “Importing of aircraft from other regulatory systems and Part-21 Subpart H review”.

• Affects Part-M and Part-145 • Group task • ToR and GC published in 1Q2013.

• NPA foreseen 2Q2014
RMT.0093 “Control of suppliers for components, parts and appliances”

• NPA 2012-03 published in April 2012. • Review group meeting November 2012: Disagreement of the members on
specific issues.

• CRD planned for 2Q2013

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Overview of pending rulemaking tasks (CAW)
RMT.0097 “Functions and responsibilities of B1 and B2 support staff”

• ToR published in Nov 2011. Group task. • The objective is to clarify the authorising process to “sign-off” maintenance
task personnel and interface with certifying staff.

• NPA planned for 4Q2013.
RMT.0243 “The identification of existing defences in maintenance processes to detect major configuration differences”

• Affects Part-M and Part-145
• Agency task. Based on Safety recommendations. • ToR planned for 2Q2013

• NPA planned for 2Q2015

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Overview of pending rulemaking tasks (CAW)
RMT.0281 “New training methods or new teaching technologies (Part-66/Part-147)”

• ToR published in November 2012 • Working group task

• 2 group meetings already held
• NPA planned for 4Q2014 • CRD/Opinion planned for 1Q2016

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Overview of pending rulemaking tasks (CAW)
Other deliverables planned for publishing in 2013:

• NPA RMT.0096 Amendments (rule and AMC/GM) adapted to the process of
granting foreign Part-145 approvals – 2Q2013

• CRD + Decision RMT.0461 List of type ratings (Appendix I of AMC to Part66) – 3Q2013

• CRD RMT.0463, RMT.0547 Task force for the review of Part-M for General
Aviation - 3Q2013

• Opinion RMT.0463, RMT.0547 Task force for the review of Part-M for General
Aviation - 4Q2013

• CRD + Decision RMT.0239 Non binding guidance on TBO limits - 3Q2013

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Outline
Overview of pending rulemaking tasks RMT.0281 (MDM.082) New training methods and new teaching technologies

The workshop

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RMT.0281 New training methods and new teaching technologies
Working Group Members: BRUNEL, Jean Pierre BUDEANU, Dragos HOTHERSALL, Colin KLUG, Sebastian LEALE, Nicholas LOTTER, Hans-Joerg ASD/Airbus EASA Thomson Airways Ltd Austro Control (ACG) UK CAA infoWERK multimedia GmbH

MAYER, Hans MUR, Frederic UNGER, Carlos
Secretary: HANŽEVAČKI, Mladen

Lufthansa Technik AG EASA Embraer S.A.

EASA

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ToR RMT.0281 New training methods and new teaching technologies
The fact
Digital technology has fundamentally changed the way of:

• designing aircraft (with new aircraft types come also new
technologies);

• interacting with these new aircraft types, its components, • simulating the aircraft (virtual aircraft); • working (information dissemination technology); • teaching: tutorial and self-learning.

its tools, its documentation and, finally, maintaining them;

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ToR RMT.0281 New training methods and new teaching technologies
The current situation
In Appendix III to Part-66 point 3.1. Theoretical element of type training:

• (f) ‘Multimedia Based Training (MBT) methods may be

used to satisfy the theoretical training element either in the classroom or in a virtual controlled environment subject to the acceptance of the competent authority approving the training course. ‘

• No further guidance • No AMC/GM

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ToR RMT.0281 New training methods and new teaching technologies
The solution
Part-66 and Part-147 need to be amended to take into consideration the following issues: • Introduction of new teaching methods such as:


• • •

Distance Learning, e-learning, Web-Based Training (WBT), Multimedia-Based Training (MBT), Computer-Based Training (CBT), Simulation Training Devices (STDs), Virtual Aircraft, Mobile Learning (m-Learning), etc.;

• Recommendations for the use of blended teaching methods; • Potential impacts of these new teaching methods.

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ToR RMT.0281 New training methods and new teaching technologies
The objectives
The objectives of the regulatory task RMT.0281 (MDM.082) consist in:

• evaluating:
• the new technologies (digital aircraft, electronic engineering,
computers, Internet, etc.); staff’s training.

• the new teaching methods for the benefit of the maintenance

• modifying Part-66 and Part-147 wherever there are benefits
of introducing these technologies and teaching methods

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ToR RMT.0281 New training methods and new teaching technologies
The objectives
(continued): • giving a definition of these new methodologies • evaluating the advantages and disadvantages and then proposing mitigation of their drawback or restrictions • providing AMC or GM to the NAAs regarding the qualification of a computerised training programme • giving recommendations for, and use of, blended teaching methods • reflecting criteria addressing the course efficiency based on these methods

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ToR RMT.0281 New training methods and new teaching technologies
The objectives
(continued) • considering the potential impacts of these new teaching methods on the training in terms of: • content, • level, • duration, • learning objectives, • competence to be gained, • documentation, • assessment, • examination and examiners, • benefits and limits for the practical tasks

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ToR RMT.0281 New training methods and new teaching technologies
The considerations

• Simulation and e-learning have their limits. Poorly developed

and implemented e-learning courses would result in poor training. • Simulation and e-learning will probably never eliminate the need for well-qualified human instructors. • Good teaching will always depend on effective instructors and courses. • From a tutorial point of view, the use of technology and simulation in training is not intended to entirely replace teaching and substitute traditional classroom instruction.

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Appendix to ToR RMT.0281 (MDM.082)
A) Main objectives

After having given a definition and following evaluation of their pros and cons, the scope of application for the following new digital teaching methods should be defined: • e-learning or computer based training (CBT) or web based training (WBT) at the training facilities (tutor-aided); • e-distance learning (not tutor-aided or e-tutor available on line) away from the training facilities; • simulation or synthetic training devices or STDs (level, content, theoretical and practical tasks, assessment, criteria for qualification, etc.) • any other teaching methods deemed to be evaluated in the course of this rulemaking task.

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Appendix to ToR RMT.0281 (MDM.082)
A) Main objectives

• Criteria regarding the efficiency of every teaching method

should be given, • appropriate use and limits of these new teaching methods may be recommended, • as well as the appropriate balance when they are blended.

• Emphasis should be put on the use and the blending of

these teaching methods, so that the training is more engaging and efficient. Many pedagogic studies confirm that the more interactive and different teaching methods are used, the better the course is at maintaining the student’s attention and the more efficient the course is.

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Appendix to ToR RMT.0281 (MDM.082)
A) Main objectives

• A regulatory framework has to be given, so that it ensures:
1. the legitimacy of these methods:
• current 147.A.145 (b) states that training may only be carried out at
the locations identified in the approval certificate and/or in the maintenance training organization exposition – therefore it currently excludes distance learning.

• 147.A.115(a) and (d) allow the use of synthetic training devices when
they are considered beneficial for the training such as fault diagnostic purposes, but more guidance should be given;

• Appendix III to Part-66, point 3.(f) states that Multimedia Based

Training (MBT) methods may be used to satisfy the theoretical training element either in the classroom or in the virtual controlled environment, but further guidance and definition of the MBT and “virtual controlled environment” should be given;
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Appendix to ToR RMT.0281 (MDM.082)
A) Main objectives

• A regulatory framework has to be given, so that it ensures:
• the type or part of training that these teaching methods may address, i.e.:

• When, where, how and why Computer Based Training or STDs may

replace the practical portion of a type rating training course on a real aircraft? out in an actual maintenance working environment [AMC 147.A.200(d)], but no definition of “actual maintenance working environment” exists. necessary to address the fact that today’s traditional course notes / documentation given to the student is often replaced by the access to computerized documentation through DVDs, CDs, videos and web based addresses or Internet websites or hyperlinks on computers. In some cases the student today may receive a laptop or a tablet PC with Applications (Apps) as a pedagogical support during the training.

• 30% of the practical training of the basic knowledge should be carried • A review of 147.A.120 (maintenance training material) may be

• 2. A high level standard.
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Appendix to ToR RMT.0281 (MDM.082)
B) Detailed consequences
Wherever needed, but not limited to, the following aspects and their impact, should be further evaluated:
• • Level of training Content (ATA chapter concerned, limitation to modules for basic knowledge of Appendix I to Part 66 or to type rating training (TRT) chapters according to Appendix III to Part-66) Nature of training (basic knowledge, TRT, specialized training such as Human factors, Fuel Tank Safety, continuation training, etc.) Duration of training Documentation and records

• • •


Assistance or role of the instructor or e-tutor / On-line assistance or assistance at proximity
Examination, assessment / Qualification of examiners and assessors / Certificate of recognition to a course
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Appendix to ToR RMT.0281 (MDM.082)
B) Detailed consequences Wherever needed, but not limited to, the following aspects and their impact, should be further evaluated: (contd)

• Guidance, limitation and percentage of acceptable use of these new

teaching methods (theoretical and practical portion of the training), if appropriate: □ The extent to which experience and practical training can be replaced by an e-programme? □ Level of interactions between the (virtual) aircraft, its systems, the aircraft documentation, the database of the aircraft… □ Level of interactivity of the learners (active and passive role) with the systems / ability of the learners

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Appendix to ToR RMT.0281 (MDM.082)
B) Detailed consequences Wherever needed, but not limited to, the following aspects and their impact, should be further evaluated: (contd)

• Facilities (to be rethought), equipment and number of students per
classroom with the assistance of a computerized training program: □ synchronous e-learning - learners and instructors logging on to a virtual classroom simultaneously at a predetermined time at or from separate locations, □ asynchronous e-learning – completed independently by each learner at a time and location that is convenient (without direct contact to each other and to the instructor)

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Appendix to ToR RMT.0281 (MDM.082)
B) Detailed consequences Wherever needed, but not limited to, the following aspects and their impact, should be further evaluated: (contd)

• Instructional design: guidance could be developed on how to get the best
out of these new teaching methodologies (or how to avoid poorly designed training materials) and how to create effective training programs, in particular:

□ use of the ADDIE model (Analyse, Design, Develop, Implement and Evaluate) or other similar instructional design models, □ tools or instructional equipment (standard, qualification or evaluation), □ prerequisites for how to use the system and instructions for use,

□ logical sequences of training and identification of the learning objectives, evaluation at the end of each sequence including authentication of the learner, records,

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Appendix to ToR RMT.0281 (MDM.082)
B) Detailed consequences Wherever needed, but not limited to, the following aspects and their impact, should be further evaluated: (contd)
□ asynchronous e-learning –as the learners lose direct contact with their instructor, how to:

• ensure the motivation of the learners, • check the learner’s ability to use computers or the technologies, • ensure that the learning objectives are reached • management structure of the system: administrators, password and
secure access, appropriate

• protections, authentication, confidentiality and track changes when

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Appendix to ToR RMT.0281 (MDM.082)
B) Detailed consequences Wherever needed, but not limited to, the following aspects and their impact, should be further evaluated: (contd)

• Assistance to the Competent Authorities (how to allow or validate the use

of these training methods and tools– development of requirements in section B of EC n°2042/2003); development of AMCs and GMs to evaluate the new training devices, their simulation capabilities, their associated programmes and their limits teaching methods, like:

• Any other aspects that may mitigate or encourage the use of these
forum or chat between tutors and students, post comments to a forum for classmates and the instructor to review at a later stage, quality system (management system) and evaluation of the course; impact on the MTOE, privileges of the Part-147 organisation and the certificates of recognition, etc.

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mladen.hanzevacki@easa.europa.eu

Outline
Overview of pending rulemaking tasks

RMT.0281 (MDM.082)
New teaching methods and new training technologies The workshop

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Workshop: New training methods, new teaching technologies
• •

• • •

2 Houses – appoint a spokesperson for your house This house supports the freedom of the Part 147 AMTO to use new training methods and new teaching technologies in their courses - Facilitator – Ian Williams or This house supports conventional training methods and teaching technologies and does not want them diluted by synthetic means - Facilitator – Mladen Hanževački 20 minutes to develop your argument in your House 10 minutes each House to expose your argument to the whole chamber Vote

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