Thu, Mar 31, 2005
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.
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