147.A.145 Privileges of the maintenance training organisation Approved

147.A.145 Privileges of the maintenance training organisation Approved

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

CAP 468 BCARs Section L JAR-147/66 Part-147/66 3 147.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. 4 147.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. 5 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) 6 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

7 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 8 147.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. 9 147.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. 1. 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. 10 147.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. 11 147.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). 12 147.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.

13 147.A.100 - Facility requirements (i) A library shall be provided containing all technical material appropriate to the scope and level of training undertaken. 14

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. 15

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. 16 147.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). 17 147.A.135 Examinations (a) The examination staff shall ensure the

security of all questions. 18 147.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 onsite) 19 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. 20 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. 21 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. 22 ADDITIONAL CONSIDERATIONS

The MTO must also; be prepared to accept the additional costs of competent authority T&RE if they have remote siteactivity in their business model. 23 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 24 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. 25 Questions? 26

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