Group Cites Big Difference Between What Was Proposed And What Is To Be

The AEA doesn't like what it sees when it looks at the FAA's proposed final rule governing Part 145 repair station training programs. The Aircraft Electronics Association (AEA) has submitted comments on behalf of its membership to the FAA on the agency's proposed repair station training program:

"While the association supports the training and education of airmen, the repair station training program described in your draft AC 145-RSTP is completely unacceptable as written.

Fundamentally, there is little correlation between the proposed and final regulation mandating a limited repair station training program and the excessive, all-encompassing proposal contained in AC 145-RSTP.  In the August 6, 2001, Federal Register (Volume 66, Number 151)]: the FAA proposed to require each certificated repair station to establish a training program approved by the Administrator that consists of initial and recurrent training for employees assigned to perform maintenance, preventive maintenance, or alteration functions.

The AC clearly goes well beyond the scope of the regulation by recommending that "each individual employed by a repair station should have training based on the person's job function. Therefore, each repair station should develop procedures for determining which employees require what training. All repair station employees usually do not require the same level of training."  The inclusion of planners, production controllers, records personnel, and purchasing, supply, store personnel, support staff and other staff is well beyond the basic scope as proposed and accepted in the Part 145 NPRM.

The FAA stated it has determined that adoption of a training program for repair station employees would promote a level of safety equivalent to that of maintenance performed under part 121 or part 135.  And yet, the proposed repair station training program exceeds the criteria of parts 121 and 135 by a factor of 20 (or more).

Section 121.375 requires only that "Each certificate holder or person performing maintenance or preventive maintenance functions for it shall have a training program to ensure that each person (including inspection personnel) who determines the adequacy of work done is fully informed about procedures and techniques and new equipment in use and is competent to perform his duties."  The AC far exceeds this criterion in the application of the proposed training program with the inclusion of non-maintenance related training topics.  The criterion of Section 121.375 also does not mandate the burdensome training program that AC 145-RSTP proposes, especially as it applies to small businesses.

FMI: http://www.aea.net/ac145RSTPreview.pdf