2. Nick Leale Airworthiness Surveyor 8th December 2016
147.A.145 Privileges of the maintenance training organisation
Approved activities at ‘remote sites’
Nick Leale
Airworthiness Surveyor
8th December 2016

3. Historical background
CAP 468 – BCARs – Section L…
JAR-147/66…
Part-147/66…
From regulator through to compliance monitor.
MTOs tell us how they intend to conduct approved activities (MTOE & Procedures)
The Competent Authority then assess and approve the activities…
…the ball is definitely in your court

4. 147.A.145(b)
Training, knowledge examinations and practical assessments… may only be carried out at the locations identified in the approval certificate and/or at any location specified in the maintenance training organisation exposition.
There are only sites specified in the exposition or not.
SECOND – REMOTE etc
All approved addresses/sites must be audited by MTOs and CAA

5. 147.A.145(c)
By derogation to point (b), the maintenance training organisation may only conduct training, knowledge examinations and practical assessments in locations different from the point (b) locations in accordance with a control procedure specified in the maintenance training organisation exposition.
‘Control procedure’ is exactly that. It is not just a brief entry in an exposition. The use of the word ‘specified’ indicates that specifics and detail is required. Generics will not be acceptable to a competent authority as they will attract standardisation findings from EASA.

6. AMC 147.A.140(c)
MTOE Content…
…10. the maintenance training organisation's control procedure, as required by 147.A.145(c), when authorised to conduct training, examination and assessments in locations different from those specified in point 147.A.145(b)…
This is AMC so an MTOE does not have to contain the control procedure but it should be referenced in the MTOE if it exists or designated as Not Applicable.

7. TRAINING AND EXAMINATION PROCEDURES
AMC to Part-147: Appendix I: Maintenance training organisation exposition (MTOE)
PART 2
TRAINING AND EXAMINATION PROCEDURES
…2.8. Training at locations not listed in paragraph 1.6…
…2.16. Examinations at locations not listed in paragraph 1.6…
cross-referenced to a separate procedure preferred.

8. Things to be addressed;
CONTROL PROCEDURE
Things to be addressed;
147.A.100 Facility requirements
147.A.115 Instructional equipment
147.A.120 Maintenance training material
147.A.130 Training procedures and quality system
147.A.135 Examinations
But not exclusive, everything that is carried out

9. 147.A.100 - Facility requirements
(a) The size and structure of facilities shall ensure protection from the prevailing weather elements and proper operation of all planned training and examination on any particular day.
Not your facility so you will have to demonstrate how you will ensure compliance

10. 147.A.100 - Facility requirements
(b) Fully enclosed appropriate accommodation separate from other facilities shall be provided for the instruction of theory and the conduct of knowledge examinations.
The maximum number of students undergoing knowledge training during any training course shall not exceed 28.
2. The size of accommodation for examination purposes shall be such that no student can read the paperwork or computer screen of any other student from his/her position during examinations.
‘Separate’ may need clarification.
Different exam papers not allowed for.
Acetate sheets example

11. 147.A.100 - Facility requirements
(c) The accommodation environment shall be maintained such that students are able to concentrate on their studies or examination as appropriate, without undue distraction or discomfort.
Again, this is for the MTO to demonstrate…
…glass walls in open office environment…
Internet access…
SEP training…

12. 147.A.100 - Facility requirements
(e) In the case of an aircraft type/task training course access, shall be provided to appropriate facilities containing examples of aircraft type as specified in point 147.A.115(d).
Still a requirement so must be satisfied.
‘Course’ may be challenged.

13. 147.A.100 - Facility requirements
(f) The maximum number of students undergoing practical training during any training course shall not exceed 15 per instructor or assessor.
If for example an MTO divides courses into two groups with a single instructor, how long will the course duration be?

14. 147.A.100 - Facility requirements
(i) A library shall be provided containing all technical material appropriate to the scope and level of training undertaken.
The MEL despite being an Ops publication contains maintenance actions and forms a constituent part of troubleshooting.
Other considerations;
TSM/FIM
AMM
SRM
ITEM
WDM
SPM

15. 147.A.100 - Facility requirements
With the exception of student delegate numbers the procedure should address exactly how the MTO will ensure that the facilities are compliant before the course commences.
Note: With the exception of student delegate numbers the procedure should address exactly how the MTO will ensure that the facilities are compliant before the course commences. This is usually done by asking the facility custodian to complete a checklist type audit and sending it to the MTO supported by digital images. This is often backed up by an on-site audit by the MTO’s instructional staff.
Expecting an instructor to audit immediately prior to course delivery is not enough as commercial pressure will overrule NCs. This option is a useful back-up but should not be considered enough on its own.

16. 147.A.115 - Instructional equipment
(a) Each classroom shall have appropriate Presentation equipment of a standard that ensures students can easily read presentation text/drawings/diagrams and figures from any position in the classroom.
Note: This is more often than not simply a Multi Media projector (MMP) and screen, a flip-chart and white board. Very often Flight Deck Panel posters are also displayed. Either way the MTO should detail how compliance will be achieved and demonstrated.
The provision of PEDs to all delegates does not remove this requirement as the instructor may support training material with diagrams and/or additional material.

17. 147.A.120 Maintenance training material
(b) ) Students shall have access to examples of maintenance documentation and technical information of the library as specified in point 147.A.100(i). 
A library shall be provided containing all technical material appropriate to the scope and level of training undertaken.
Maintenance documentation is often ignored by MTOs as they usually rely upon the training material alone. This is not compliant and access to AMMs, IPCs, FIM/TSM MEL ‘shall’ be available.

18. 147.A.135 Examinations
(a) The examination staff shall ensure the security of all questions.  
Good luck with this!
A robust procedure must be developed and processes must follow the procedure.

19. 147.A.135 Examinations
This could be a procedure all of its own. The MTO should describe how examinations are transported and retained securely on-site prior to the examination/s, used securely during the examination/s and then returned to the MTO securely after the examination/s. Among considerations are, but not limited to;
Controlling access to exam material prior to use
Preventing unauthorised copying via Personal Electronic Devices (PEDs)
Ensuring all exam material is counted out and back
Ensuring the invigilation/examining process is clearly defined
Ensuring marking is conducted appropriately (Usually not on-site)
This becomes even more complex in situations where the host organisation’s staff are designated to assist the MTO with training/examination tasks and must be clearly described in the procedure.

20. ADDITIONAL CONSIDERATIONS
The MTO must also;
ensure that the quality system required of 147.A.130 also audits the procedure and includes product sample audits of the training and examination/assessment processes conducted at remote sites.
147.A.130(b) – ‘independent’
The independence of the audit system should be established by always ensuring that audits are carried out by personnel not responsible for the function or procedure being checked.

21. ADDITIONAL CONSIDERATIONS
The MTO must also;
establish procedures and processes for the collation, return and retention of records of training. This often causes NCs as MTOs rely upon personnel not usually tasked with this and the establishment of identity and the completion of attendance registers is often less than effective.
Delegates completing attendance records and identity details is not appropriate - EXAMPLE

22. ADDITIONAL CONSIDERATIONS
The MTO must also;
understand that the competent authority must be able to access remote sites for audit purposes and this is usually agreed via a training agreement/contract with the facility custodian and/or training host organisation.
FCO guidance must also be applied for any approved activities in areas where safety/security concerns exist.
Approved training must not be conducted if FCO advises against all but essential travel and the exposition should make this clear.

23. ADDITIONAL CONSIDERATIONS
The MTO must also;
be prepared to accept the additional costs of competent authority T&RE if they have remote site-activity in their business model.
We will always use the HRG system as this ensures protocols with regard to extravagance and economy are applied.

24. ADDITIONAL CONSIDERATIONS
The MTO must also;
ensure that when they co-opt staff from their customers to conduct training delivery, examination/assessment, those staff are appropriately qualified iaw 147.A.105(f) and CAA Standards Document 46 and detailed iaw 147.A.140
147.A.105(h) - Instructors and knowledge examiners shall undergo updating training at least every 24 months relevant to current technology, practical skills, human factors and the latest training techniques appropriate to the knowledge being trained or examined.
147.A.140(a) - The organisation shall provide an exposition for use by the organisation describing the organisation and its procedures and containing the following information:
…5. a list of the training instructors, knowledge examiners and practical assessors…
AMC to Part-147: Appendix I: MTOE
2. Whilst this format is recommended, it is not mandatory to assemble the MTOE in this manner as long as a cross-reference index is included in the MTOE as an Appendix and the Part 1 items remain in Part 1…
…1.5. List of instructional and examination staff. Note: A separate document may be referenced

25. ADDITIONAL CONSIDERATIONS
The MTO must also;
Ensure that they detail (Unless we mandate a process) how they will notify the competent authority of the intention to conduct approved activities away from the approved location/s.

26. Questions?