Regulation (EU) No 1321/2014
(a) The organisation shall appoint an accountable manager who has corporate authority for ensuring that all maintenance required by the customer can be financed and carried out to the standard required by this Part. The accountable manager shall:
- ensure that all necessary resources are available to accomplish maintenance in accordance with point 145.A.65(b) to support the organisation approval.
- establish and promote the safety and quality policy specified in point 145.A.65(a).
- demonstrate a basic understanding of this Annex (Part-145).
Regulation (EU) No 1321/2014
(b) The organisation shall nominate a person or group of persons, whose responsibilities include ensuring that the organisation complies with this Part. Such person(s) shall ultimately be responsible to the accountable manager.
- The person or persons nominated shall represent the maintenance management structure of the organisation and be responsible for all functions specified in this Part.
- The person or persons nominated shall be identified and their credentials submitted in a form and manner established by the competent authority.
- The person or persons nominated shall be able to demonstrate relevant knowledge, background and satisfactory experience related to aircraft or component maintenance and demonstrate a working knowledge of this Part.
- Procedures shall make clear who deputises for any particular person in the case of lengthy absence of the said person.
Regulation (EU) No 1321/2014
(c) The accountable manager under point (a) shall appoint a person with responsibility for monitoring the quality system, including the associated feedback system as required by point 145.A.65(c). The appointed person shall have direct access to the accountable manager to ensure that the accountable manager is kept properly informed on quality and compliance matters.
Regulation (EU) No 1321/2014
(d) The organisation shall have a maintenance man-hour plan showing that the organisation has sufficient staff to plan, perform, supervise, inspect and quality monitor the organisation in accordance with the approval. In addition the organisation shall have 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.
Regulation (EU) 2020/270
(e) The organisation shall establish and control the competence of personnel involved in any maintenance, airworthiness reviews, management and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority. In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person’s function in the organisation. ‘Human factors’ means principles which apply to aeronautical design, certification, training, operations and maintenance and which seek safe interface between the human and other system components by proper consideration of human performance. ‘Human performance’ means human capabilities and limitations which have an
impact on the safety and efficiency of aeronautical operations.
Regulation (EU) 2018/1142
(f) The organisation shall ensure that personnel who carry out or control a continued-airworthiness non-destructive test of aircraft structures or components, or both, are appropriately qualified for the particular non- destructive test in accordance with the European or equivalent standard recognised by the Agency. Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised standards. By derogation from this point, personnel referred to in point (g), points (h)(1) and (h)(2), qualified in category B1, B3 or L in accordance with Annex III (Part-66), may carry out and/or control colour contrast dye penetrant tests.
Regulation (EU) 2018/1142
(g) Any organisation maintaining aircraft, except where stated otherwise in point (j), shall in the case of aircraft line maintenance, have appropriate aircraft-rated certifying staff qualified as category B1, B2, B2L, B3 and L, as appropriate, in accordance with Annex III (Part-66) and point 145.A.35.
In addition such organisations may also use appropriately task-trained certifying staff holding the privileges set out in points 66.A.20(a)(1) and 66.A.20(a)(3)(ii) and qualified in accordance with Annex III (Part-66) and point 145.A.35 to carry out minor scheduled line maintenance and simple defect rectification. The availability of such certifying staff shall not replace the need for category B1, B2, B2L, B3 and L certifying staff, as appropriate.
Regulation (EU) 2018/1142
(h) Any organisation maintaining aircraft, except where stated otherwise in point (j), shall:
- in the case of base maintenance of complex motor-powered aircraft, have appropriate
aircraft-type-rated certifying staff, qualified as category C in accordance with Annex III (Part-66) and point 145.A.35. In addition, the organisation shall have sufficient aircrafttype-rated staff qualified as category B1 and B2, as appropriate, in accordance with Annex III (Part-66) and point 145.A.35 to support the category C certifying staff.
(i) Category B1 and B2 support staff shall ensure that all relevant tasks or inspections have been carried out to the required standard before the category C certifying staff issues the certificate of release to service.
(ii) The organisation shall maintain a register of any such category B1 and B2 support staff.
(iii) The category C certifying staff shall ensure that compliance with point (i) has been met and that all work required by the customer has been accomplished during the particular base maintenance check or work package, and shall also assess the impact of any work not carried out, with a view to either requiring its accomplishment or agreeing with the operator to defer such work to another
specified check or time limit. - in the case of base maintenance of aircraft other than complex motor-powered aircraft, have one of the following:
(i) appropriate aircraft-rated certifying staff, qualified as category B1, B2, B2L, B3 and L, as appropriate, in accordance with Annex III (Part-66) and point 145.A.35;
(ii) appropriate aircraft-rated certifying staff, qualified in category C and assisted by support staff, as set out in point 145.A.35(a)(i).
Regulation (EU) 2018/1142
(i) Component certifying staff shall be qualified in accordance with Article 5(6) and point 145.A.35.
Regulation (EU) 2015/1088
(j) By derogation to points (g) and (h), in relation to the obligation to comply with Annex III (Part66), the organisation may use certifying staff qualified in accordance with the following
provisions:
- For organisation facilities located outside the Community territory certifying staff may be qualified in accordance with the national aviation regulations of the State in which the organisation facility is registered subject to the conditions specified in Appendix IV to this Part.
- For line maintenance carried out at a line station of an organisation which is located outside the Community territory, the certifying staff may be qualified in accordance with the national aviation regulations of the State in which the line station is based, subject to the conditions specified in Appendix IV to this Part.
- For a repetitive pre-flight airworthiness directive which specifically states that the flight crew may carry out such airworthiness directive, the organisation may issue a limited certification authorisation to the aircraft commander and/or the flight engineer on the basis of the flight crew licence held. However, the organisation shall ensure that sufficient practical training has been carried out to ensure that such aircraft commander or flight engineer can accomplish the airworthiness directive to the required standard.
- In the case of aircraft operating away from a supported location the organisation may issue a limited certification authorisation to the commander and/or the flight engineer on the basis of the flight crew licence held subject to being satisfied that sufficient practical training has been carried out to ensure that the commander or flight engineer can accomplish the specified task to the required standard. The provisions of this point shall be detailed in an exposition procedure.
- In the following unforeseen cases, where an aircraft is grounded at a location other than the main base where no appropriate certifying staff are available, the organisation contracted to provide maintenance support may issue a one-off certification authorisation:
(i) to one of its employees holding equivalent type authorisations on aircraft of similar technology, construction and systems; or
(ii) to any person with not less than five years maintenance experience and holding a valid ICAO aircraft maintenance licence rated for the aircraft type requiring certification provided there is no organisation appropriately approved under this Part at that location and the contracted organisation obtains and holds on file evidence of the experience and the licence of that person.
All such cases as specified in this point must be reported to the competent authority within seven days after issuing such certification authorisation. The organisation issuing the one-off authorisation shall ensure that any such maintenance that could affect flight safety is rechecked by an appropriately approved organisation.
Regulation (EU) 2020/270
(k) If the organisation performs airworthiness reviews and issues the corresponding airworthiness review certificate in accordance with point ML.A.903 of Annex Vb (Part-ML), it shall have airworthiness review staff qualified and authorised and meeting all of the following requirements:
- shall hold a certifying staff authorisation for the corresponding aircraft;
- shall have at least three years of experience as certifying staff;
- shall be independent from the continuing airworthiness management process of the aircraft being reviewed or shall have overall authority on the continuing airworthiness management process of the complete aircraft being reviewed;
- shall have acquired knowledge of Subpart C of this Annex (Part-M) or Subpart C of Annex Vb (Part-ML);
- shall have acquired proven knowledge of the procedures of the maintenance
organisation relevant to the airworthiness review and issue of the airworthiness review certificate; - shall have been formally accepted by the competent authority after having performed an airworthiness review under the supervision of the competent authority or under the supervision of the organisation’s airworthiness review staff in accordance with a procedure approved by the competent authority;
- shall have performed at least one airworthiness review in the last twelve-month period.
AMC 145.A.30(a) Personnel requirements
ED Decision 2015/029/R
With regard to the accountable manager, it is normally intended to mean the chief executive officer of the approved maintenance organisation, who by virtue of position has overall (including in particular financial) responsibility for running the organisation. The accountable manager may be the accountable manager for more than one organisation and is not required to be necessarily knowledgeable on technical matters as the maintenance organisation exposition defines the maintenance standards. When the accountable manager is not the chief executive officer the competent authority will need to be assured that such an accountable manager has direct access to chief executive officer and has a sufficiency of ‘maintenance funding’ allocation.
AMC 145.A.30(b) Personnel requirements
ED Decision 2015/029/R
- Dependent upon the size of the organisation, the Part-145 functions may be subdivided under individual managers or combined in any number of ways.
- The organisation should have, dependent upon the extent of approval, a base maintenance manager, a line maintenance manager, a workshop manager and a quality manager, all of whom
should report to the accountable manager except in small Part-145 organisation where any one
manager may also be the accountable manager, as determined by the competent authority,
he/she may also be the line maintenance manager or the workshop manager. - The base maintenance manager is responsible for ensuring that all maintenance required to be
carried out in the hangar, plus any defect rectification carried out during base maintenance, is
carried out to the design and quality standards specified in 145.A.65(b). The base maintenance
manager is also responsible for any corrective action resulting from the quality compliance monitoring of 145.A.65(c). - The line maintenance manager is responsible for ensuring that all maintenance required to be
carried out on the line including line defect rectification is carried out to the standards specified
in 145.A.65(b) and also responsible for any corrective action resulting from the quality
compliance monitoring of 145.A.65(c). - The workshop manager is responsible for ensuring that all work on aircraft components is carried out to the standards specified in 145.A.65(b) and also responsible for any corrective action resulting from the quality compliance monitoring of 145.A.65(c).
- The quality manager’s responsibility is specified in 145.A.30(c).
- Notwithstanding the example sub-paragraphs 2 – 6 titles, the organisation may adopt any title for the foregoing managerial positions but should identify to the competent authority the titles and persons chosen to carry out these functions.
- Where an organisation chooses to appoint managers for all or any combination of the identified Part-145 functions because of the size of the undertaking, it is necessary that these managers report ultimately through either the base maintenance manager or line maintenance manager or workshop manager or quality manager, as appropriate, to the accountable manager.
NOTE: Certifying staff may report to any of the managers specified depending upon which type of control the approved maintenance organisation uses (for example licensed engineers/independent inspection/dual function supervisors etc.) so long as the quality compliance monitoring staff specified in 145.A.65(c)(1) remain independent.
AMC 145.A.30(c) Personnel requirements
ED Decision 2015/029/R
Monitoring the quality system includes requesting remedial action as necessary by the accountable manager and the nominated persons referred to in 145.A.30(b).
AMC 145.A.30(d) Personnel requirements
ED Decision 2020/002/R
- Has sufficient staff means that the organisation employs or contracts competent staff, as detailed in the man-hour plan, of which at least half the staff that perform maintenance in each workshop, hangar or flight line on any shift should be employed to ensure organisational stability. For the purpose of meeting a specific operational necessity, a temporary increase of the proportion of contracted staff may be permitted to the organisation by the competent authority, in accordance with an approved procedure which should describe the extent, specific duties, and responsibilities for ensuring adequate organisation stability. For the purpose of this subparagraph, employed means the person is directly employed as an individual by the maintenance organisation approved under Part-145, whereas contracted means the person is employed by another organisation and contracted by that organisation to the maintenance organisation approved under Part-145.
- The maintenance man-hour plan should take into account all maintenance activities carried out outside the scope of the Part-145 approval.
The planned absence (for training, vacations, etc.) should be considered when developing the man-hour plan. - The maintenance man-hour plan should relate to the anticipated maintenance work load except that when the organisation cannot predict such workload, due to the short term nature of its contracts, then such plan should be based upon the minimum maintenance workload needed for commercial viability. Maintenance work load includes all necessary work such as, but not limited to, planning, maintenance record checks, production of worksheets/cards in paper or electronic form, accomplishment of maintenance, inspection and the completion of maintenance records.
- In the case of aircraft base maintenance, the maintenance man-hour plan should relate to the aircraft hangar visit plan as specified in AMC 145.A.25(a).
- In the case of aircraft component maintenance, the maintenance man-hour plan should relate to the aircraft component planned maintenance as specified in 145.A.25(a)(2).
- The quality monitoring compliance function man-hours should be sufficient to meet the requirement of 145.A.65(c) which means taking into account AMC 145.A.65(c)(1). Where quality monitoring staff perform other functions, the time allocated to such functions needs to be taken into account in determining quality monitoring staff numbers.
- The maintenance man-hour plan should be reviewed at least every 3 months and updated when necessary.
- Significant deviation from the maintenance man-hour plan should be reported through the departmental manager to the quality manager and the accountable manager for review.
Significant deviation means more than a 25% shortfall in available man-hours during a calendar
month for any one of the functions specified in 145.A.30(d).
AMC1 145.A.30(e) Personnel requirements
ED Decision 2015/029/R
Competence should be defined as a measurable skill or standard of performance, knowledge and understanding, taking into consideration attitude and behaviour.
The referenced procedure requires amongst others that planners, mechanics, specialised services staff, supervisors, certifying staff and support staff, whether employed or contracted, are assessed for competence before unsupervised work commences and competence is controlled on a continuous basis.
Competence should be assessed by evaluation of:
— on-the-job performance and/or testing of knowledge by appropriately qualified personnel, and
— records for basic, organisational, and/or product type and differences training, and
— experience records.
Validation of the above could include a confirmation check with the organisation(s) that issued such
document(s). For that purpose, experience/training may be recorded in a document such as a log book
or based on the suggested template in GM3 145.A.30(e).
As a result of this assessment, an individual’s qualification should determine:
— which level of ongoing supervision would be required or whether unsupervised work could be
permitted.
— whether there is a need for additional training.
A record of such qualification and competence assessment should be kept.
This should include copies of all documents that attest to qualification, such as the licence and/or any
authorisation held, as applicable.
For a proper competence assessment of its personnel, the organisation should consider that:
- In accordance with the job function, adequate initial and recurrent training should be provided
and recorded to ensure continued competence so that it is maintained throughout the duration
of employment/contract. - All staff should be able to demonstrate knowledge of and compliance with the maintenance
organisation procedures, as applicable to their duties. - All staff should be able to demonstrate an understanding of human factors and human performance issues in relation with their job function and be trained as per AMC2 145.A.30(e).
- To assist in the assessment of competence and to establish the training needs analysis, job
descriptions are recommended for each job function in the organisation. Job descriptions
should contain sufficient criteria to enable the required competence assessment. - Criteria should allow the assessment to establish that, among others (titles might be different
in each organisation):
— Managers are able to properly manage the work output, processes, resources and priorities described in their assigned duties and responsibilities in a safe compliant manner in accordance with regulations and organisation procedures.
— Planners are able to interpret maintenance requirements into maintenance tasks, and have an understanding that they have no authority to deviate from the maintenance data.
— Supervisors are able to ensure that all required maintenance tasks are carried out and, where not completed or where it is evident that a particular maintenance task cannot be carried out to the maintenance data, then such problems will be reported to the 145.A.30(c) person for appropriate action. In addition, for those supervisors, who also carry out maintenance tasks, that they understand such tasks should not be undertaken when incompatible with their management responsibilities.
— Mechanics are able to carry out maintenance tasks to any standard specified in the maintenance data and will notify supervisors of defects or mistakes requiring rectification to re-establish required maintenance standards.
— Specialised services staff are able to carry out specialised maintenance tasks to the standard specified in the maintenance data. They should be able to communicate with supervisors and report accurately when necessary.
— Support staff are able to determine that relevant tasks or inspections have been carried out to the required standard.
— Certifying staff are able to determine when the aircraft or aircraft component is ready to release to service and when it should not be released to service.
— Quality audit staff are able to monitor compliance with Part-145 identifying noncompliance in an effective and timely manner so that the organisation may remain in compliance with Part-145.
Competence assessment should be based upon the procedure specified in GM2 145.A.30(e).
AMC2 145.A.30(e) Personnel requirements
ED Decision 2015/029/R
In respect to the understanding of the application of human factors and human performance issues, all maintenance organisation personnel should have received an initial and continuation human factors training. This should concern to a minimum:
— Post-holders, managers, supervisors;
— Certifying staff, support staff and mechanics;
— Technical support personnel such as planners, engineers, technical record staff;
— Quality control/assurance staff;
— Specialised services staff;
— Human factors staff/human factors trainers;
— Store department staff, purchasing department staff;
— Ground equipment operators.
- Initial human factors training should cover all the topics of the training syllabus specified in GM
145.A.30(e) either as a dedicated course or else integrated within other training. The syllabus may be adjusted to reflect the particular nature of the organisation. The syllabus may also be adjusted to meet the particular nature of work for each function within the organisation. For example:
— small organisations not working in shifts may cover in less depth subjects related to teamwork and communication;
— planners may cover in more depth the scheduling and planning objective of the syllabus and in less depth the objective of developing skills for shift working.
All personnel, including personnel being recruited from any other organisation should receive initial human factors training compliant with the organisation’s training standards prior to commencing actual job function, unless their competence assessment justifies that there is no need for such training. Newly directly employed personnel working under direct supervision may receive training within 6 months after joining the maintenance organisation. - The purpose of human factors continuation training is primarily to ensure that staff remain current in terms of human factors and also to collect feedback on human factors issues.
Consideration should be given to the possibility that such training has the involvement of the quality department. There should be a procedure to ensure that feedback is formally passed from the trainers to the quality department to initiate action where necessary.
Human factors continuation training should be of an appropriate duration in each two year period in relation to relevant quality audit findings and other internal/external sources of information on human errors in maintenance available to the organisation.
- Human factors training may be conducted by the maintenance organisation itself, or
independent trainers, or any training organisations acceptable to the competent authority. - The human factors training procedures should be specified in the maintenance organisation
exposition.
AMC3 145.A.30(e) Personnel requirements
ED Decision 2015/029/R
Additional training in fuel tank safety as well as associated inspection standards and maintenance procedures should be required for maintenance organisations’ technical personnel, especially technical personnel involved in the compliance of CDCCL tasks.
EASA guidance is provided for training to maintenance organisation personnel in Appendix IV to AMC 145.A.30(e) and 145.B.10(3).
AMC4 145.A.30(e) Personnel requirements
ED Decision 2015/029/R
Competence assessment should include the verification for the need of additional EWIS training when relevant.
EASA guidance is provided for EWIS training programme to maintenance organisation personnel in AMC 20-22.
GM1 145.A.30(e) Personnel requirements
ED Decision 2016/011/R
TRAINING SYLLABUS FOR INITIAL HUMAN FACTORS TRAINING
The training syllabus below identifies the topics and subtopics to be addressed during the human factors training.
The maintenance organisation may combine, divide, change the order of any subject of the syllabus to suit its own needs, as long as all subjects are covered to a level of detail appropriate to the organisation and its personnel.
Some of the topics may be covered in separate training (health and safety, management, supervisory skills, etc.) in which case duplication of training is not necessary.
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 existing guidance/advisory material, where relevant (e.g. ICAO HF Digests and Training Manual).
Topics should be related to maintenance engineering where possible; too much unrelated theory should be avoided.
- General/Introduction to human factors
1.1. Need to address human factors
1.2. Statistics
1.3. Incidents - Safety Culture/Organisational factors
- Human Error
3.1. Error models and theories
3.2. Types of errors in maintenance tasks
3.3. Violations
3.4. Implications of errors
3.5. Avoiding and managing errors
3.6. Human reliability - Human performance & limitations
4.1. Vision
4.2. Hearing
4.3. Information-processing
4.4. Attention and perception
4.5. Situational awareness
4.6. Memory
4.7. Claustrophobia and physical access
4.8. Motivation
4.9. Fitness/Health
4.10. Stress
4.11. Workload management
4.12. Fatigue
4.13. Alcohol, medication, drugs
4.14. Physical work
4.15. Repetitive tasks/complacency - Environment
5.1. Peer pressure
5.2. Stressors
5.3. Time pressure and deadlines
5.4. Workload
5.5. Shift Work
5.6. Noise and fumes
5.7. Illumination
5.8. Climate and temperature
5.9. Motion and vibration
5.10. Complex systems
5.11. Hazards in the workplace
5.12. Lack of manpower
5.13. Distractions and interruptions - Procedures, information, tools and practices
6.1. Visual Inspection
6.2. Work logging and recording
6.3. Procedure – practice/mismatch/norms
6.4. Technical documentation – access and quality
6.5. Critical maintenance tasks and error-capturing methods (independent inspection,
reinspection, etc.) - Communication
7.1. Shift/Task handover
7.2. Dissemination of information
7.3. Cultural differences - Teamwork
8.1. Responsibility
8.2. Management, supervision and leadership
8.3. Decision making - Professionalism and integrity
9.1. Keeping up to date; currency
9.2. Error provoking behaviour
9.3. Assertiveness - Organisation’s HF program
10.1. Reporting errors
10.2. Disciplinary policy
10.3. Error investigation
10.4. Action to address problems
10.5. Feedback
GM2 145.A.30(e) Competence assessment procedure
ED Decision 2016/011/R
The organisation should develop a procedure describing the process of competence assessment of
personnel. The procedure should specify:
— persons responsible for this process,
— when the assessment should take place,
— credits from previous assessments,
— validation of qualification records,
— means and methods for the initial assessment,
— means and methods for the continuous control of competence including feedback on personnel
performance,
— competences to be observed during the assessment in relation with each job function,
— actions to be taken when assessment is not satisfactory,
— recording of assessment results.
For example, according to the job functions and the scope, size and complexity of the organisation,
the assessment may consider the following (the table is not exhaustive):