MRO 2005 Berlin

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Managing Maintenance Error A European and
International Regulatory Perspective
Jorge Leite TAP Maintenance Engineering Director
of Quality www.tapme.pt dleite_at_tap.pt
Aviation Weeks MRO Europe 2005 Berlin,
Germany October 19th, 2005
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Summary
Summary

• EASA Requirements
• FAA Requirements
• Adoption of a Human Factors program

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EASA
EC 2042
EC No 2042/2003
Part-145
AMC-145
GM-145

• Commission Regulation (EC) No 2042/2003
• (of 20 November 2003)
• Article 7 Entry into force
• This Regulation shall enter into force on the day
  following that of its publication in the Official
  Journal of the European Union (which was 28
  November 2003).
• 3.(c) By way of derogation from paragraph 1,
  Member States may elect not to apply, until 28
  September 2006, item 145.A.30(e), Human Factors
  elements.

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EASA
EC 2042
EASA Part-145
Part-145
AMC-145
GM-145

• 145.A.30(a),(b),(c) Personnel Requirements
• The organisation shall appoint
• An accountable manager with corporate authority
• A person or group of persons, whose
  responsibilities include ensuring the
  organisation complies with Part-145
• A person with responsibility for monitoring the
  quality system, including the associated feedback
  system.

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EASA
EC 2042
EASA Part-145
Part-145
AMC-145
GM-145

• 145.A.30(d) Personnel Requirements
• The organisation shall have
• A maintenance man-hour plan showing that it has
  sufficient staff to perform the work in
  accordance with the approval
• A procedure to reassess work intended to be
  carried out when actual staff availability is
  less than the planned staffing level for any
  particular work shift or period.

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EASA
EC 2042
EASA Part-145
Part-145
AMC-145
GM-145

• 145.A.30(e) Personnel Requirements
• The organisation shall
• Establish and control the competence of personnel
  involved in any maintenance, management and/or
  quality audits as agreed by the competent
  authority
• Ensure personnel have expertise related to the
  job function
• Ensure competence also includes an understanding
  of the application of Human Factors and Human
  Performance issues appropriate to the persons
  function in the organisation.

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EASA
EC 2042
EASA Part-145
Part-145
AMC-145
GM-145

• 145.A.30(e) Personnel Requirements
• Human Factors principles which seek safe
  interface between the human and other system
  components by proper consideration of human
  performance
• Human Performance human capabilities and
  limitations which have an impact on the safety
  and efficiency of aeronautical operations.

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EASA
EC 2042
EASA Part-145
Part-145
AMC-145
GM-145

• 145.A.35(d) Certifying staff and category B1
  and B2 support staff
• The organisation shall ensure that
• All certifying staff and category B1 and B2
  support staff receive sufficient continuation
  training in each 2 year period
• Such staff have up-to-date knowledge of relevant
  technology, organisation procedures and human
  factor issues.

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EASA
EC 2042
EASA AMC-145
Part-145
INITIAL TRAINING
AMC-145
GM-145

• AMC 145.A.30(e) Personnel Requirements
• Personnel should be assessed for the need to
  receive initial human factors training, but in
  any case should receive continuation training
• Initial training should be provided to personnel
  within 6 months of joining the maintenance
  organisation, or less in the case of temporary
  staff
• Personnel being recruited from other maintenance
  organisation approved under Part-145 should be
  assessed for the need to receive any additional
  human factors training.

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EASA
EC 2042
EASA AMC-145
Part-145
CONTINUATION TRAINING
AMC-145
GM-145

• AMC 145.A.30(e) Personnel Requirements
• The purpose of human factors continuation
  training is primarily to ensure that staff remain
  current and also to collect feedback on human
  factors issues (by the quality department)
• Human factors continuation training should be of
  an appropriate duration in each 2 year period
• Human factors training may be conducted by the
  maintenance organisation itself, or
  subcontracted
• The human factors training procedures should be
  specified in the maintenance organisation
  exposition (MOE) manual.

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EASA
EC 2042
EASA GM-145
Part-145
AMC-145
GM-145

• GM 145.A.30(e) Personnel Requirements
• (Training syllabus for initial human factors
  training)
• The maintenance organisation may combine, divide
  or change the order of any of the following
  subjects in the syllabus to suit its own needs
• Where possible, practical illustrations and
  examples should be used, especially accident and
  incident reports
• Topics should be related to existing legislation,
  where relevant
• Topics should be related to maintenance
  engineering where possible too much unrelated
  theory should be avoided.

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EASA
EC 2042
EASA GM-145
Part-145
AMC-145
GM-145
Training syllabus for initial human factors
training
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EASA
EC 2042
EASA GM-145
Part-145
AMC-145
GM-145
Training syllabus for initial human factors
training (cont.)
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EASA
EC 2042
EASA GM-145
Part-145
AMC-145
GM-145
Training syllabus for initial human factors
training (cont.)
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FAA
AC 145-10
AC 145-10
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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, dated July 8th, 2005
• Repair Station Training Program
• This advisory circular (AC) provides information
  on developing the repair station employee
  training program required under Title 14 of the
  Code of Federal Regulations (14 CFR) part 145,
  section 145.163, categories of training, training
  program components, and sample training programs
• Entities wishing to become certificated under
  part 145, and those part 145 repair stations
  certificated prior to April 6, 2006, whether
  located within or outside the United States,
  should use this AC to develop the training
  program required by part 145.

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 2, 200(a)
• Beginning April 6, 2006, persons applying for a
  repair station certificate under 14 CFR part 145
  must submit a training program for FAA approval
• Additionally, repair stations that were
  certificated prior to April 6, 2006, must submit
  a training program for approval by the last day
  of the month in which their 14 CFR part 145
  certificate was originally issued
• The program must ensure that individuals
  performing maintenance (including inspections),
  preventive maintenance, inspections, and
  alterations under the repair station certificate
  are capable of performing assigned tasks.

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 2, 200(f)
• EASA Part-145 requirements can affect FAA part
  145 approved repair stations that also have EASA
  approvals, since EASA requires maintenance human
  factors training as part of the Bilateral
  Aviation Safety Agreement (BASA) and Maintenance
  Implementation Procedures (MIP) with the United
  States
• The FAA training program may include the
  requirements of other civil aviation authorities
  as long as the part 145 requirements are also met.

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 2, 201
• The employee training program approved by the FAA
  must include initial and recurrent training
  requirements.
• FAA AC 145-10, Ch. 3
• Indoctrination (301) and technical (302)
  training program either initial and recurrent,
  regardless of the repair stations size or
  ratings, should include maintenance human
  factors, among other subjects.

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 3, 301(b)(4)
• NOTE
• Training in maintenance human factors is an
  essential part of an FAA-approved training
  program
• The repair stations submitted training program
  and any revision thereto must include human
  factors elements
• The human factors training procedures defined in
  the training program should be related to
  aviation maintenance, safety-related issues,
  existing legislation, where relevant, and/or some
  of the suggested elements below.

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 3, 301(c)
• The FAA concurs with European Authorities in that
  human factors training related to maintenance
  practices would provide an additional margin of
  safety to the repair industry
• A human factors training program should be
  related to maintenance practices where possible
• The following are suggested human factors
  elements for inclusion into a repair station
  training program

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 3, 301(c)

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FAA
AC 145-10
AC 145-10

• FAA AC 145-10, Ch. 3, 303(a) and (b)
• Recurrent maintenance training commonly includes
  training known as refresher training, to ensure
  that a repair station employee remains capable of
  properly performing the assigned job
• The repair stations program should define the
  terms for initial and recurrent training and
  identify the areas of study and/or
  courses/lessons that will be provided under the
  two definitions
• The repair station should have procedures to
  determine the type and frequency of recurrent
  training for each of its employees through a
  needs assessment.

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Program
TAP HF Program
INVESTIGATION
Human Factors
FREE REPORTING
TRAINING (Initial and Recurrent)
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Program
Preparation
TAP HF Program
Training
Reporting
Investigation

• Initial Contact and Training
• Quality Managers and Trainers
• Galaxy Scientific Corporation and Trinity College
  Dublin (STAMINA)
• Managers, Engineering and HF Team
• System Safety Services (Mr. Gordon Dupont) in
  Lisbon
• Maintenance technicians, certifying staff,
  managers, quality auditors, student technicians
• TAP/MTO - Maintenance Training in Lisbon

TAP HF Program
TAP HF Training Manual
EASA Part-145 Initial Certification of TAP by
Portugal NAA (May 30th, 2004)
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Program
Preparation
TAP HF Program
Training
Reporting
Investigation

• Initial HF Training
• To student technicians, as part of their Basic
  Training

• Initial HF Training to all
• Maintenance technicians
• Certifying Staff
• Managers
• Quality Auditors

2 DAYS

• HF Training Program
• As per EASA Part-66 Syllabus

• HF Training Program
• As per GM 145 Syllabus
• Theory behind HF Program
• Presentation of Dirty Dozen
• Discussion of Safety Nets
• Practical cases and analysis
• Work group sessions

Recurrent HF Training should follow 2 years after
initial training
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Program
Preparation
TAP HF Program
Training
Reporting
Investigation

• Incident and Accident Reporting
• Statement prepared by the CEO reminding each
  individuals role in the HF Program and the free
  from reprisal principle
• Reporting is voluntary and kept confidential,
  either verbal or delivered to the Quality Dept.
  in a closed envelope
• Usually a confidential interview follows between
  the HF Team (Quality Dept.) and the reporting
  person
• If deemed necessary, an initial investigation is
  launched by the Quality Dept.

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Program
Preparation
TAP HF Program
Training
Reporting
Investigation
Incident or Accident
Preliminary Report
HF Report
HF Team and Director of Quality
REPORT ANALYSIS
INITIAL INVESTIGATION
Quality Auditors
HF ?
Yes
HF INVESTIGATION
Final HF Report Free from reprisal
HF Team and Quality Auditors
Final Report Management Action Required
No
NORMAL INVESTIGATION
Quality Auditors
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Thank you ! Visit us at www.tapme.pt dleite_at_
tap.pt