AMC 145.A.35(d) Certifying staff and support staff    

CAA ORS9 Decision No. 1

1. Continuation training is a two way process to ensure that certifying staff remain current in terms of procedures, human factors and technical knowledge and that the organisation receives feedback on the adequacy of its procedures and maintenance instructions. Due to the interactive nature of this training, consideration should be given to the possibility that such training has the involvement of the quality department to ensure that feedback is actioned. Alternatively, there should be a procedure to ensure that feedback is formally passed from the training department to the quality department to initiate action.

2. Continuation training should cover changes in relevant requirements such as Part-145, changes in organisation procedures and the modification standard of the products being maintained plus human factor issues identified from any internal or external analysis of incidents. It should also address instances where staff failed to follow procedures and the reasons why particular procedures are not always followed. In many cases the continuation training will reinforce the need to follow procedures and ensure that incomplete or incorrect procedures are identified to the company in order that they can be corrected. This does not preclude the possible need to carry out a quality audit of such procedures.

3. Continuation training should be of sufficient duration in each 2 year period to meet the intent of 145.A.35(d) and may be split into a number of separate elements. 145.A.35(d) requires such training to keep certifying staff updated in terms of relevant technology, procedures and human factors issues which means it is one part of ensuring quality. Therefore sufficient duration should be related to relevant quality audit findings and other internal / external sources of information available to the organisation on human errors in maintenance. This means that in the case of an organisation that maintains aircraft with few relevant quality audit findings, continuation training could be limited to days rather than weeks, whereas a similar organisation with a number of relevant quality audit findings, such training may take several weeks. For an organisation that maintains aircraft components, the duration of continuation training would follow the same philosophy but should be scaled down to reflect the more limited nature of the activity. For example certifying staff who release hydraulic pumps may only require a few hours of continuation training whereas those who release turbine engine may only require a few days of such training. The content of continuation training should be related to relevant quality audit findings and it is recommended that such training is reviewed at least once in every 24 month period.

4. The method of training is intended to be a flexible process and could, for example, include a Part-147 continuation training course, aeronautical college courses, internal short duration courses, seminars, etc. The elements, general content and length of such training should be specified in the maintenance organisation exposition unless such training is undertaken by an organisation approved under Part-147 when such details may be specified under the approval and cross referenced in the maintenance organisation exposition.