JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3

Safety Regulation Group Personnel Licensing Department

Engineer Licensing JAR-147 Approval of Organisations to conduct Aircraft Type Training in Support of JAR-66 or BCAR Section L, Document 27, Version 3

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JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3

Introduction
JAR-66 represents the harmonisation of requirements within the Joint Aviation Authorities, of which the UK Civil Aviation Authority (CAA) is a member, for the qualification of personnel involved in the certification of maintenance. These require that an individual holds a JAR-66 licence which is validated for certain basic categories or sub-categories of aircraft with type ratings endorsed on the licence as appropriate to the activity and aircraft type concerned. Holders of the appropriately endorsed licences are then eligible to be issued with a certification authorisation under the auspices of a JAR-145 approved maintenance organisation. This allows the authorised individual to issue a Certificate of Release to Service in accordance with JAR145.50 for maintenance which has been carried out by the organisation. As part of the requirements to be satisfied before licence issue, JAR 66.45 requires that the licence holder undertakes a course of approved type training and has a minimum period of practical experience for specific aircraft types to qualify for a type endorsement. The initial issue of JAR-66, effective 1 June 1998, covers all aircraft above 5700 kgs maximum all up weight and approved training is required for such aircraft types. The content of the training course will be based upon the privileges appropriate to the basic licence category/subcategory held. The course is required to be developed in accordance with the detailed specifications laid out by the Air Transport Association in ATA Specification 104 Guidelines for Aircraft Maintenance Training at level 1 or 3 as appropriate to the licence endorsement sought. Level 1 is described as “general familiarisation” training whilst level 3 is classified as “line and base maintenance” training. This approved type training must be conducted by a suitably approved organisation. JAR-147 has been developed to provide and detail the requirements for the approval of organisations to conduct training to support JAR-66. There is provision within JAR-147 for organisations to conduct both basic and type training although this leaflet covers only the type training element. The approved course of training is then used in conjunction with a period of practical experience as the basis for licence endorsement with the appropriate type rating. This can be regarded as consolidation experience and is intended to ensure that the licence holder has a reasonable degree of exposure to aircraft maintenance and fault diagnosis and rectification on type. There is provision for the practical elements to be contracted out to JAR-145 organisations who provide maintenance for the particular type of aircraft being taught although many JAR-147 organisations will also be JAR-145 approval holders for the types on which training is being given. JAR-147 is intended to support JAR-66. The United Kingdom CAA intends however to use JAR-66 to replace its current engineer licensing requirement, British Civil Airworthiness Requirement Section L. This will take effect from the end of the transition period for JAR-66 which for aircraft above 5700 kgs is 1 June 2001. The UK also intends to use JAR-147 to cater for type training which is currently provided for under Airworthiness Notice No. 14 Supplement No. 1 (previously Supplement 1 to BCAR A8-13) and for recognised courses as provided for by BCAR Section L. Organisations will therefore be required to hold a JAR-147 approval to conduct aircraft type training after 1 June 2001.

Training Philosophy
During the development of JAR-66 the majority of the European States involved believed that all candidates for licences should have satisfactorily completed a course of approved maintenance type training. This is certainly the position for aircraft above 5700 kgs although approved type training may not be required for certain aircraft below this weight limit (JAR-66 is currently being developed to cover these other aircraft types). This is similar to the current UK situation although it has been implemented by using both recognised courses and training approvals as part of the BCAR A8-13 requirements. Both these systems had their weaknesses however and in many cases the ability of the organisations adequately to deliver the training required was not monitored. The application of JAR-147 to replace the current systems will allow the CAA to exercise a proper degree of monitoring of the training organisations and the standards of training being applied. This is particularly important since training carried out by a JAR-147 organisation in the UK will be equally valid for the endorsement of a JAR-66 licence by any of the JAA Member States. The CAA’s process of approving organisations will itself be subject to review by the Maintenance Standardisation (MAST) Teams from the JAA who will look at the implementation policy for JAR-66 and JAR-147 in the UK as well as sampling the organisations approved and their standards of training and facilities. The concept of approved training is straightforward. The CAA will establish the acceptability of an organisation, in terms of its structure and availability of facilities, to provide the training to be carried out. The course content itself is not strictly defined in detail. Organisations should however conduct training in accordance with the privileges appropriate to the basic category/sub-category of JAR-66 licence. The systems to be covered are readily identifiable from the syllabus defined in JAR-66 Appendix 1. Account should be taken of the different levels of knowledge and their application to the relevant course categories or sub-categories and this may mean different levels of training course for the same type.

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JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3 As noted above the subsequent additional practical experience which is expected to follow the approved course can be regarded as separate to the course and should be looked upon as consolidation, providing the student with additional maintenance exposure to aircraft systems, component replacement and function checks, inspection techniques and defect diagnosis techniques and rectification action. This will normally be undertaken under the supervision of a JAR-145 approved maintenance organisation in accordance with an agreed programme of on job training. Although it is highly likely that many course students will have ample type experience before joining the course, this will ensure that the individual receives a consistent overview or exposure to the aircraft. Where a JAR-147 organisation wishes to combine the approved course and the additional experience elements, the overall package must be subject to an appropriate level of management acceptable to the CAA. An approved organisation is expected to train its students. The approval process should not be seen as one where the student is taught only what he needs to know to pass the organisation’s examinations. The JAA member states acknowledge the benefits and improvement in maintenance standards which should result from formal training of the agreed syllabus leading to a high underpinning competence. The licence issued at the end of the process will entitle the holder to work anywhere within Europe. This means that more than ever before the UK licence and the abilities of the licence holder will be subject to external scrutiny. The UK should not therefore condone poor training which could compromise air safety or engender criticism from other states. Organisations approved in accordance with JAR-147 are therefore expected to show and exercise an appropriate degree of professionalism and integrity in their management and delivery of training. This suggests that the training programme needs to ensure a progressive delivery of instruction or tuition. It will of course be for the individual organisation to decide how to carry out the training but the CAA would expect the student to be supported throughout the course with continuous assessments of performance being made in addition to the formal phase examinations to ensure that the student is not left behind in the programme. The course should also have scope for retraining or additional ‘catch up’ training for those who need it. Clearly the more retraining a particular student requires calls into question their suitability for continuing the programme. The CAA will therefore expect organisations to remove candidates who quite clearly continue to struggle with the course content. It should be remembered by all that the purpose of the course is not to provide a short cut to the licence but to deliver the necessary skill, knowledge and experience for licence issue in a more timely and cost effective manner. The JAR-147 scope of approval will be defined by particular aircraft types within JAR-66 licence categories or sub-categories as appropriate and will allow the organisation to conduct the training required and the associated examinations. The JAR-147 training organisation may also be approved to conduct training to support the BCAR Section L LWTRs to cater for staff who are entitled to grandfather rights for certification purposes and who do not yet hold a full JAR-66 Category B1 or B2 licence eg Airframes only.

Organisation
There are likely to be two types of organisation which will seek approval under JAR-147: those organisations which have been established in the industry for a number of years to conduct type training under the provisions of BCAR A8-13 Supplement 1 or the equivalent in Airworthiness Notice No.14; the others are those organisations who are currently recognised in accordance with Section L to provide type training for aircraft type rating endorsement on a Section L licence. In each case it is possible that the organisation may not be able to satisfy all of the requirements itself but may seek alliances or contract certain activities, such as buying in additional instructor capability for certain types. Each case will be judged on its merits and subject to assessment by the Authority. However the CAA may decide that arrangements proposed are not adequate and seek additional assurances or insist on an in-house capability. The organisation itself will be headed by an Accountable Manager who will be a senior manager with full executive and budgetary powers to ensure that the needs of the organisation in respect of the requirements are provided for. Where the organisation is also approved in accordance with JAR-145 or other requirements there is no reason why the accountable manager cannot head both or all approvals. It is also acceptable for an organisation to set up a separate training arm and seek JAR-147 approval independent of any JAR-145 approval held. The organisational structure to support the training activities will obviously vary according to the size and scope of the training commitment. In the majority of cases it is envisaged that there will be a need for a training manager or equivalent to oversee the day to day management of the training programme and to ensure that the JAR-147 requirements are met. In line with other JARs the organisation is expected to set up certain elements with a degree of independence. These include, in particular, examination preparation and delivery and a Quality auditing function. Where the organisation is also a JAR-145 approval holder, there is no reason why the quality systems and staff should not be jointly applied.

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JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3

Facilities
The organisation will be required to have or, with the agreement of the CAA, have access to facilities appropriate to the training being conducted. This means classrooms for theoretical instruction and hangars or simulated maintenance environments to provide the exposure to aircraft type maintenance practices and system functions. Ideally this will include complete aircraft, or at least access to them, for familiarisation purposes. Where the organisation does not have the appropriate facilities the CAA may consider the organisation entering into a contracted arrangement with another organisation for their provision. Clearly such arrangements will need to be managed and overseen by the JAR-147 approval holder and included in the auditing programme for the organisation’s quality system. It should be noted that this familiarisation is part of the course not the practical exposure required for licence issue. Classrooms should be suitably equipped with presentation media appropriate to the method of delivery but as a minimum overhead projection equipment would be considered to be the norm. Many organisations may also wish to consider the use of Computer Aided Training (CAT) or Computer Based Training (CBT) as part of the training mechanism. Whilst such systems are likely to become more commonplace in the future, the CAA does not believe that delivery of training with little instructor involvement is wholly effective and a mix of instructional techniques may be necessary. However, where an organisation believes that they can apply such a system effectively the CAA will consider its submissions.

Courses
As noted above, the organisation will be approved to conduct certain courses of training under JAR-147. These courses in the main will align with the basic licence categories or sub-categories in JAR-66. These are as follows: Category A Line Maintenance Certifying Mechanic: Sub Sub Sub Sub Category Category Category Category A1 A2 A3 A4 Aeroplanes Turbine Aeroplanes Piston Helicopter Turbine Helicopter Piston

Category A type training is primarily aimed at task training accomplished through a programme of on job training of individual or collective tasks. It will in most cases be necessary for the JAR-145 organisation to provide some measure of aircraft type training for the Category A certifier to ensure that they are competent to perform some of the more general inspection tasks. This may include a course of general/familiarisation training at ATA level 1 and some detailed system training at ATA level 3 appropriate to the systems associated with the tasks to be authorised. Category B1 Line Maintenance Certifying Technician (Mechanical): Sub Sub Sub Sub Category Category Category Category B1.1 B1.2 B1.3 B1.4 Aeroplanes Turbine Aeroplanes Piston Helicopter Turbine Helicopter Piston

Approved type training in this case will consist of tuition covering airframes, engines, electrical power and distribution and avionic extension. Clearly, where an aircraft is fitted with two different engine types a different course is required. For example a course of Boeing 737-200 training includes the Pratt and Whitney JT-8 engine. It does not cover the Boeing 737-300/400/500 with CFM-56 engines. The training may however, combine two courses into one to provide for multiple ratings where the aircraft are variants of the same types. The training will be conducted in accordance with ATA specification 104 at level 3. Category B2 Line Maintenance Certifying Technician (Avionic): No sub categories are applicable. The Category B2 course will cover the avionic disciplines: electrical power and distribution, instruments, autopilot, radio communication / navigation and radar. It should be noted that training on an aircraft type will focus upon a particular equipment fit eg Collins integrated avionic installation. Where the same type is also available with an integrated fit from a different supplier eg King, a differences course will be required. The type rating endorsed on the licence may be endorsed to reflect this. Training organisations should therefore take care to cover the aircraft variants expected to be certified by the JAR-145 organisation for whom the training is being provided.

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JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3 The training should give adequate detailed theoretical knowledge of the aircraft, its main parts, systems (all existing systems in accordance with ATA 100, where appropriate), equipment, interior and applicable components. Relevant in-service problems, service bulletins and instructions should be covered, including training in the systems in use for technical manuals and maintenance procedures. Knowledge is also required of relevant inspections and limitations as applicable to the effects of environmental factors such as cold and hot climates, wind, moisture etc. Upon the completion of the course, the student should have demonstrated knowledge of this by examination. They should also be capable of ensuring the safe certification of line maintenance, inspections and routine work according to the maintenance manual and other relevant instructions and tasks as appropriate for the type of aircraft, for example trouble shooting, repairs, adjustments, replacements, rigging and functional checks such as engine run, etc., if required. JAR-147 does not specify a minimum course length for an aircraft type although there may be such provision in the future. It is clear however, that the course length between organisations for a specific aircraft type should be consistent and the CAA will seek to establish guidelines for minimum course lengths in conjunction with industry. (Such agreement will then be proposed to the JAA to establish comparability across the JAA member states). Organisations are expected therefore to prepare an analysis of how they intend to deliver the course based upon the available time and the knowledge requirements or syllabus as in JAR-66. The syllabus content varies in both scope and depth according to the licence to which the course is intended to lead. Due account of these variables will need to be made when preparing the analysis. The CAA would normally expect courses to be taught on a seven hour day, five day week basis. The CAA will consider alternative arrangements for training where appropriate and justified. In essence the organisation is expected to perform a training needs analysis for each course. The CAA will evaluate these in conjunction with the course notes and training aids and grant approval when satisfied that the conditions relating to the approval are met. Where the organisation can demonstrate an appropriate degree of competence and integrity the CAA may consider allowing the company to prepare other courses without further reference to the CAA subject to development being made in accordance with agreed procedures. Courses agreed as part of the JAR-147 approval must be supported by appropriate notes for the students. These should be comprehensive enough to provide a summary of the key elements of the subject, typical examples and installations and the associated maintenance practices. They should be up to date, at the time of the course and provision should be made for developing amendments and updating them. References to further reading material are acceptable but they should be for more detailed study and not in place of information in the notes. In particular where information is derived from textbooks or other material which is not readily available to students, the subject matter should be included in the notes. The CAA will also consider the approval of upgrade or conversion courses from a type rating issued under BCAR Section L or the equivalent authorisation under BCAR A8-13 or JAR-145, to those in JAR-66. A student may only be considered to have completed the approved course when he or she has satisfied all the elements of the approved course to the required standards of examination or assessment.

Instructors
Instructors used by the organisation to deliver the courses will need to be proven competent to do so by the organisation. The CAA is evaluating instructor qualification for this purpose but there are no aviation specific instructor qualifications available at this time. It may be that generic solutions are available which offer some benefit and the CAA intends to look at these in conjunction with potential JAR-147 organisations in the near future. In the absence of any formal qualification, the organisation must provide training in instructional techniques, on job training by observation, participation and assessment before being considered competent. The organisation will therefore be expected to include such procedures in their exposition along with other related issues such as initial and continuation training to support their instructional activities. Many instructors currently in training organisations are ex-service instructional personnel. Whilst the value of such persons cannot be discounted it is essential that they are given exposure to civil maintenance practices and access to current aircraft types and technologies in order that they can adequately deal with the subject matter to be taught. Clearly this suggests a programme of assignment to maintenance organisations for periods to observe maintenance tasks and gain an understanding of the maintenance and procedural systems in use. In all cases instructional staff are expected to have the required detailed knowledge of the aircraft type, maintenance practices and defects to enable them to conduct the course. The organisation may wish to consider the use of several instructors teaching the various elements of the type course rather than dependence upon only one.

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JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3

Aircraft
Approved type training will focus upon the delivery of theoretical system knowledge and related issues. In order to put this training into context access to representative examples of the subject aircraft should be available to the training organisation. This is primarily for familiarisation purposes and will consist of a few aircraft visits of short duration, typically an hour or two. It should not be confused with the requirement described in AMC 66.45(b) where the purpose is to ensure that a programme of structured on job training is prepared to satisfy the supporting practical experience on type and which is of longer duration. The training organisation may not have direct access to such aircraft and it will be acceptable to make arrangements with a suitable JAR-145 organisation to provide aircraft contact time. Where the visits are conducted away from the JAR-147 organisation the training course shall be adjusted accordingly to make time for the visits. Alternatively the organisation may wish to make some use of computer based packages of training (CAT or CBT) which will give the student an idea of the location and layout of components and systems. The use of fixed base maintenance simulators for defect diagnosis and system functioning and operation purposes is also acceptable but not mandatory. In both cases however, an actual aircraft visit is still necessary to give the training the proper feel. Where the organisation does not have access to suitable maintenance simulators to cover engine running etc., it may be necessary to secure access to real aircraft or flight simulators to complete the necessary training. If engine running is treated as a separate authorisation it may be covered by a separate course. The practical experience of four months or less, as determined by each individual student’s previous experience will ideally consist of on job training carried out under the supervision of a JAR-145 organisation. It is expected that the JAR-145 organisation will agree a structured programme covering the various requirements laid out in AMC 66.45(b)(4) to ensure that the individual is competent. Such programmes will be agreed by the CAA with the JAR-145 organisation concerned. An application for type endorsement of the JAR-66 licence will require two elements to be satisfied. The applicant will have satisfactorily completed an approved course of training on the specific aircraft type being applied for and conducted by a suitably approved JAR-147 organisation. The organisation may not necessarily be approved by the CAA providing it has been approved by a JAA full member state. The second element is the endorsement or countersigning of the application by a JAR-145 organisation verifying that the applicant has satisfactorily accomplished a programme of structured training agreed by the CAA. Where the programme has not been agreed, the applicant and the countersigning organisation must provide justification of the practical training as having satisfied the JAR-66 requirements. It should be noted that unless the CAA agrees otherwise the licence holder must have the type rating endorsed on their JAR-66 licence before the JAR-145 certification authorisation can be issued. This applies to all aircraft previously designated as falling within Paragraph 14 of Airworthiness Notice No. 10 in addition to those that were eligible for type ratings on the Section L licence. It should also be remembered that specific aircraft avionic type training is required for all aircraft above 5700 kgs before an authorisation can be granted.

Exposition and Procedures
The potential JAR-147 organisation is expected to have a quality system in place for both the management of the training and the quality audit function to ensure compliance with the requirements. A key issue is therefore the preparation of procedures to support the organisation’s activities. The topics to be covered will vary according to the way in which the organisation structures itself. It is not expected however, that procedures covering the purchase of toilet rolls would figure in the JAR-147 procedures. The information should be concise, relevant and workable. They should reflect the working practices used and not just be a token gesture to satisfy the CAA and the requirements. JAR-147 itself gives guidance on the typical contents of an exposition. The procedures also required by JAR147 may be included in the exposition or kept as a separate document providing there is a cross reference document available for auditing purposes. This is particularly relevant where the organisation uses the exposition to satisfy other approvals.

Examinations
A JAR-147 type training organisation is expected to carry out examinations of the various modules of theoretical knowledge and the associated practical assessments for those courses for which it is approved. The examinations have not yet been specified in the JAA Administrative and Guidance Material and is still under development (the CAA can advise on the current status of this material). In the meantime however, the examination standard will be determined by the CAA in conjunction with the training organisations concerned. Again the CAA will seek to establish common standards of examination and promote such standards across the JAA member states. The main examination mode is expected to be a multi-choice question format. JAR-147 organisations themselves will therefore have to prepare a number of question papers or a question database for examination purposes. The nominated examiner has an important role within the organisation as the examinations are being carried out on behalf of the Authority.

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JAR-147 Approval of Organisations to conduct Aircraft Type Training in support of JAR-66 or BCAR Section L, Document 27, V3 Examinations must be prepared and conducted in an appropriate manner with due consideration to the need for confidentiality. Clearly it is important that the questions are kept secure so that the examinations represent a fair attempt at assessing the students’ knowledge. A lack of confidentiality or security undermines the examination standards and could well lead to airworthiness being compromised by assisting candidates to pass examinations when they do not possess the requisite knowledge. Such practice will not be accepted under JAR147. Candidates must demonstrate their knowledge fairly: the licence must be earned.

Applications
The CAA will supply upon request an application form for JAR-147 approval. The example form shown in JAR147 itself will only be accepted as an interim measure. The prospective organisation will prepare an exposition and supporting procedures for submission to the CAA which will carry out an audit of the facilities, organisational structure, procedures, the course analysis and the examination process as part of the preapproval investigations. Deficiencies noted against the requirements of JAR-147 and JAR-66 will be defined as either level 1 or 2 findings, the level being indicative of the seriousness of the anomaly, and will be notified to the management of the organisation. These findings must be resolved before an approval will be issued. Organisations who have held BCAR A8-13 approvals or who have carried out recognised course training may have certain procedures in place which bear some similarity to those required by JAR-147. Credit will be given where possible but cannot be assumed. The JAR-147 approval attracts a fee for the investigation and grant of the approval and this is notified in Airworthiness Notice No. 25. The attention of prospective applicants is drawn to the provision for additional charges where the investigation proves particularly time consuming or for overseas organisations who wish to be approved. The CAA expects the organisation, as part of the proof of its ability, to develop the necessary submission with the minimum of CAA involvement. However, the CAA may be prepared to conduct a preapplication meeting with the organisation to discuss the approval requirements and the issues to be considered. Advice and guidance of a general nature will be provided as part of the approval process but the giving of detailed advice should not be expected. Any further queries on the issue of a JAR-147 approval in the UK should be addressed to: Civil Aviation Authority Personnel Licensing Department Aviation House Gatwick Airport South West Sussex RH6 0YR.

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