Part 66 Appendix II Working Group (MASTER DOCUMENT) · licence (i.e. as applicable with EASA Part...

European Aviation Maintenance Training Committee

Part 66 Appendix II Working Group

(MASTER DOCUMENT)

EAMTC WORKING GROUP MASTER DOCUMENT

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TABLE OF CONTENTS

Table of Contents ........................................................................................................................ 2

1 DOCUMENT DESCRIPTION ............................................................................................. 3

1.1 Revision Record ........................................................................................................... 3

2 INTRODUCTION ................................................................................................................. 5

2.1 Working Group organisation ....................................................................................... 5

2.2 Abbreviations ................................................................................................................ 5

2.3 Introduction ................................................................................................................... 5

3 MEETING REPORT ............................................................................................................ 7

3.1 Attendance .................................................................................................................... 7

3.2 Organisation Categories .............................................................................................. 7

3.3 Organisational Representation ................................................................................... 8

3.4 Minutes of Previous Meetings ..................................................................................... 9

3.5 Project Status ............................................................................................................. 11

3.6 Background of working group....................................................................................... 12

3.7 Mission Statement ........................................................................................................ 12

3.8 Objective Statement ...................................................................................................... 12

3.9 Scope Statement ........................................................................................................... 12 4 Discussion ............................................................................................................................ 13

4.1 Basic / Self-starter comparison ...................................................................................... 13 4.2 Practical issues surrounding carrying out the current task list ........................................ 14 4.3 Considerations for the WG ............................................................................................ 14

5 Purpose of ojt ....................................................................................................................... 16 6 Competencies – discussion – investigation - considerations .................................................. 17 7 approach ............................................................................................................................... 18 8 Amount of practical experience ............................................................................................ 19 9 Type ..................................................................................................................................... 20 10 Next meeting focus ............................................................................................................... 21 11 Appendices ........................................................................................................................... 22


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1 DOCUMENT DESCRIPTION

Purpose: This document is issued by the EAMTC President when the WG is established further to a GA vote for the establishment of such a group. The document is used to report the results of the WG to the EAMTC President and the GA.

Distribution: Participants of the Group, people designated by the WG President and / or EAMTC President and the EAMTC web site

Maintenance: WG President or as assigned Usage: This document records the ongoing work of the WG. It is the report

document for the WG. It is to be used to communicate the WG recommendations established to the EAMTC President and GA

Control: The control of the issuance of the document to the WG President rests with the EAMTC President. Once issued, the control of the document rests with the WG President.

Version: The version number is established by re-issue Revised: Revision number established by minor updates and editorial changes Classification: Restricted to members use Valid from: Latest meeting minutes Software: The software used to edit this document is MS Word, Open Office (or

similar). The document is normally distributed in Adobe® PDF format.

1.1 Revision Record

Ver Date Author Revision Highlights

1 04/08/14 Don Dixon 0 1st issue

2

3

4

5

6

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10


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Ver Date Author Revision Highlights

11

12


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2 INTRODUCTION

2.1 Working Group organisation

President Valgeir Runarrson

Vice President W. N. Chung

Meeting Recorder Don Dixon

Working Group Members (as below)

2.2 Abbreviations

A/C Aircraft

ATA Air Transport Association

EAMTC European Aviation Maintenance Training Committee

EASA European Aviation Safety Agency

EASp European Aviation Safety Plan

GA General Assembly of the EAMTC

GR EAMTC Guidelines and Recommendations

MRO Maintenance and Repair Organisation

NAA National Airworthiness Authority

OEM Original Equipment Manufacturer

OJT On-the-Job-Training

WG Working Group

2.3 Introduction

Due to differences between NAAs and concerns with the inapplicability or unsuitability of tasks in the Part 66 Appendix II for Group 1 aircraft, a WG was proposed in order to improve the Appendix II.


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The WG was tasked by the GA - "To examine all aspects of the Appendix II to Part 66 List of OJT Tasks and related areas of Part 66 in order to recommend improvements"


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3 MEETING REPORT

3.1 Attendance

Meeting attendance is open to all nominated WG participants and any specialists that may be called, as needed, periodically by the WG President to provide particular support.

3.2 Organisation Categories

Members and Attendees are categorized by the organisation to which they belong.

Group Member Category - Company Location

Valgeir Runarrson Airline - Icelandair Iceland

Holger Westerveld Airline – Air Berlin Germany

Mohammed M. Shawkat Airline – Qatar Airways Qatar

W.N Chung MRO - HAECO Hong Kong

Serdar Gokmen MRO – Turkish Habom Turkey

Michael Toparkus Airline – Condor Germany

Ralph Petshcel MRO – Lufthansa Technk Germany

Don Dixon OEM – Bombardier Canada

Ram Naidoo Consultant – Ram Air Training UK


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3.3 Organisational Representation

The following table totals the represented category by organisation. Only Active members are included in the totals. Multiple members from the same organisation or observers do not influence the totals.

Category Numbers

Airline – country: Icelandair - Iceland 1

Airline – country: Air Berlin - Germany 1

Airline – country: Qatar Airways - Qatar 1

Airline – country: Condor - Germany 1

Airlines Total 4

Manufacturer – country: Bombardier - Canada 1

Original Equipment Manufacturers Total 1

MRO – country: HAECO – Hong Kong 1

MRO – country: Turkish Habom – Turkey 1

MRO – country: Lufthansa Technik – Germany 1

MROs Total 3

Training School – country: Icelandair - Iceland 1

Training School – country: Air Berlin - Germany 1

Training School – country: Condor - Germany 1

Training School – country: Bombardier - Canada 1

Training School – country: HAECO – Hong Kong 1

Training School – country: Turkish Habom - Turkey 1

Training Schools Total 6


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Consultant – country: Ram Air Training - UK 1

Consultants Total 1

3.4 Minutes of Previous Meetings

The minutes of the previous meetings, are held by the group’s President and Minutes Recorder. They can be accessed from the Members area of the web site with member held passwords.


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Past meeting minutes:

Place Date Minutes Filename

Remote meeting 05/05/14 Please see members area




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3.5 Project Status

Project Status for each deliverable:

Deliverable Status Person Responsible

GR open Valgeir Runarrson


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3.6 Background of working group Due to differences between NAAs and concerns with the inapplicability or unsuitability of tasks in the Part 66 Appendix II for Group 1 aircraft, a WG was proposed in order to improve the Appendix II.

3.7 Mission Statement "To examine all aspects of the Appendix II to Part 66 List of OJT Tasks and related areas of Part 66 in order to recommend improvements"

3.8 Objective Statement The group’s objective is to produce guidelines and to recommend areas and / or tasks in

order to: • Ensure operational safety • Ensure competence and experience of staff applying for the first type rating on their

licence (i.e. as applicable with EASA Part 66 requirements for the first type rating on a licence)

• Recommend areas of improvement to Part 66, as applicable

3.9 Scope Statement EASA Part 66 Appendix II (other appendices as appropriate) and the associated paragraphs of the regulations.


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4 DISCUSSION The EASp 2014-17 (page 10) notes that the training requirements for aviation personnel, although continuously amended, need to be adapted after careful evaluation of how far they are still adequate to enable aviation professionals to meet the challenge. Competence of personnel is one of the systemic issues addressed in the EASp (page 10). The issues highlighted in the WG discussion and in this Master Document focus on modernising training methods and competence provisions. Additionally and as noted in the EASp (page 9), Human Factors and human performance affect all the safety areas. It is important to recognise that addressing Human Factors will bring safety improvements. In the context of the scope and objectives of the WG the following have been discussed to date. A WG member had been in discussion with his (non-EASA) NAA with new ideas for OJT. The discussion referred to older versus newer aircraft technologies. EASA standardisation issues and the difficulties of mutual recognition between NAA’s regarding accepting OJT from other NAA / countries was discussed. WG members had shared a number of their company documents between them for discussion.

4.1 Basic / Self-starter comparison Discussion took place regarding:

• If OJT should only be applicable to those following the “self-starter” route. The safety check for these people today is:

o Module knowledge exams o 5 years experience (of a relatively unknown nature) o Type course knowledge exams o Type course practical training o Part 145 organisation dependent “competence” assessment

• Whether it was logical for OJT to be applicable for those completing the Part 147 Approved Basic Training Course(s). The safety check for these people today is:

o Module knowledge exams o Basic training course practical elements assessment (2400 hours where

50-65% is practical time which includes time in a Part 145 organisation) o Type course knowledge exams o Type course practical training o Part 145 organisation dependent “competence” assessment


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The above raises a question as to whether 5 years (unknown / un-assessed competence) is equivalent to the Approved Basic Training Course? It was noted that the EAMTC set forth a list similar to the Appendix II list for the Basic experience some time ago.

4.2 Practical issues surrounding carrying out the current task list • Many tasks can only accommodate 1-2 people

o others are watching and thus do not get the “hands-on” experience or gain any improvement in their competence

• Many items are only relevant to Group 2 a/c • Many items are only carried out at major checks (if ever) on Group 1 a/c • Many tasks are R & I and bring little additional operational experience • Opportunities are shift-pattern dependent and may never be available on the

Type sought • Difficulty to find / have all of the required tasks within one Part 145 organisation • Operational experience • Complexities of the current Part 66 Appendix III AMC for OJT supervisors /

assessors • One WG member organisation reviewed the OJT books shared by the WG

members and the EASA approved ones that they use. o The aircraft types included were MD11, B737, B747, B757, B767, B777,

A300, A320, A330, A340, A380. More than 3000 different tasks were found due to the differences in the design of the aircraft types.

o The common ones tasks were identified. It is believed that these could form the core tasks for an OJT logbook which may also be done by Line Maintenance engineers. Such a logbook could be in the form of: Core Task + Specific a/c Type Tasks

For the reasons above the WG determines that the Appendix II task list as it is today is impractical and is not an efficient way of addressing the competence or experience for those people seeking the first Type rating on their licence.

4.3 Considerations for the WG The WG may consider whether a list is appropriate and whether the objective of OJT, as stated in Part 66 Appendix III AMC, is better achieved in another way. As well as the practical issues of completing OJT as it is currently defined, the WG may consider whether an OJT timeframe is appropriate. In view of the difficulties to have all of the required tasks / experience in a single Part 145 organisation, the WG may consider options to make it acceptable to use other Part 145s. The WG may analyse the possibilities of a wide body list and a narrow body “list”.


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If a list is to be used the WG will aim to simplify it and provide options to use it on Base Maintenance as well as Line Maintenance. There may be a need to simplify some of the procedures for the OJT, Assessment, and possibly the performance of the OJT for Supervisors. The WG may look into simplifying the procedures for the OJT when the list of tasks has been reviewed. The feasibility to be allowed to work on other types within Group 1 may be considered. A Core Task + Specific a/c Type Tasks arrangement may be considered.


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5 PURPOSE OF OJT Part 66 Appendix III states that “the objective of OJT is to gain the required competence and experience in performing safe maintenance.”


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6 COMPETENCIES – DISCUSSION – INVESTIGATION - CONSIDERATIONS


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7 APPROACH


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8 AMOUNT OF PRACTICAL EXPERIENCE


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9 TYPE


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10 NEXT MEETING FOCUS As above


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11 APPENDICES


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