Avionics News February 2021 - 15

Simply, the repair station training program is the
documented process that you use to show compliance with
the requirements of 14 CFR Part 145, Subpart D - Personnel.
It is your process that you use to assure that the technician
that you send out to work on your customer's 'pride
and joy' is qualified and capable of performing the task
the customer requests.

this " training program must ensure that each person
who determines the adequacy of work performed is
fully informed about procedures, techniques, and new
equipment in use, and is able to perform all associated
duties. " So, the FAA proposed the repair station
training program.
Under this proposal, 14 CFR 145.159, which
changed to 145.163 in the final rule, would require
each repair station to establish and maintain a
documented training program for all employees who
perform work under the repair station's ratings and
classes. The proposed training program would enhance
aviation safety by ensuring that each employee
who works for the repair station is fully capable of
performing that work, and it would ensure a level of
safety equivalent to that of maintenance performed
under Part 121 or Part 135. It is important to note that
the basic requirement for qualifications and abilities
of the repair station's employees did not change. And
citing the FAA's notice of proposed rulemaking, " The
proposed training would be required to consist of
initial and recurrent training for aviation maintenance
personnel, be based on each individual's assignment,
and ensure that each individual is capable of
performing the assigned task. "
There are several important comments submitted
that the FAA responded to in its 2001 final rule (66 FR
41087). The following is from the FAA's response to
the NPRM comments:
" The FAA has determined that adoption of a
training program for repair station employees who

perform maintenance, preventive maintenance,
or alterations would enhance aviation safety by
helping to ensure that those employees are fully
capable of performing the work. "
Here, the FAA establishes the scope of its intent:
" Employees who perform maintenance, preventive
maintenance, or alterations. "
" The FAA recognizes that the training programs
may vary depending on the size of the repair
station and the nature of the work performed.
Therefore, the FAA is not prescribing specific
training requirements but will approve
individual training programs submitted by
repair stations. "
The FAA was clear that a one-size-fits-all approach
was not the intent of the regulations. As such, the FAA
would approve the overarching program but not the
specific curricula. This approach is consistent with the
earliest of personnel qualification requirements where
" officials of the station must carefully consider the
qualifications and abilities of their employees and shall
determine the abilities of its uncertificated employees
performing maintenance operations on the basis of
practical tests or employment records. "
One area of controversy is in the record-keeping
requirements. In the original NPRM, the FAA proposed
that a repair station keep the records showing each
employee is capable of performing their assigned task
for the duration of each individual's employment.
Continued on page 31
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february

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Avionics News February 2021

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