EASA Standardisation...15 March 2016 EASA Standardisation 5 0 2 4 6 8 10 12 14 0 2 4 6 8 10 12 14 Type training, Exam Standard 66-App III Basic Examination Standard 66-App II Instructional

EASA Standardisation What do you get out of EASA visits & other issues

Bram van Driel Airworthiness Standardisation Team Leader 15 March 2016

Subjects

EASA Standardisation Planning

Results

Part-147 Undertakings

findings

NAA

Issues brought forward by you 1. How can industry help standardisation?

2. Practical type training B1+B2 combined courses

3. Fuel Tank Safety Continuation Training

4. Change instructor if personality clashes

5. Helping to improve… vs punitive system

6. NAA inspectors could serve in industry

7. Second sites approvals

8. Authortity-subsidiary conducting examinations.

9. Practical type-training split

10.Practical type-training om other type

11.Differentiating B1 and B2 tasks

12.Audit interval applicable to individual articles

15 March 2016 EASA Standardisation 3


Planning 2016

Poland

Switzerland*

Greece*

Poland**

Slovakia

United Kingdom**

Slovenia

Austria**

Sweden

Austria

Ireland

Lithuania*

Bulgaria*

Malta

Germany

Denmark *) Focussed

**) also BASA

Results (1)


0 2 4 6 8 10 12 14

0 2 4 6 8 10 12 14

Type training, Exam Standard 66-App III

Basic Examination Standard 66-App II

Instructional equipment 147.A.115

Basic practical assessment 147.A.210

Tyoe exams, task assessments 147.A.305

Aircraft type/task training 147.A.300

Records of staff 147.A.110

Maintenance training material 147.A.120

Examinations 147.A.135

The approved basic training course 147.A.200

Facility requirements 147.A.100

Privileges of the organisation 147.A.145

MTOE 147.A.140

Basic knowledge examinations 147.A.205

Training procedures, quality system 147.A.130

Personnel requirements 147.A.105

Part-147 Undertaking non-compliances

2015 2014

Results – Summary issues in 147


1. Staff qualification OK –> make requirements S.M.A.R.T. and monitor /document assessment

2. Examinations –> structure independent verification of questions in question bank

3. Auditing often weak –> Use audits for structured improvements and to verify adequacy of all procedures.

4. Security of exams –> refreshment, access, unauthorised persons.

5. Expositions weak –> should assist the organisation to comply and to systematically apply process same way.

Results – Summary issues in 147 (2)


6. Privileges –> clear CoRs

7. Classrooms OK –> improve content of shops and library

8. Training material weaknesses -> validate that it is adequate and up to date

9. Basic Training OK –> detail & manage subcontractors

10. Basic examination –> allocation of questions

11. TNAs acceptable -> align course and TNA

Results (2)


0 5 10 15 20 25

0 5 10 15 20 25

Record-keeping 147.B.20

Revocation & Suspension 147.B.200

147 - Appendix II (147.B added for app)

Approval Certificate 147.B.125

Authority findings 147.B.130

Initial approval / Changes 147.B.110

Competent Authority 147.B.10

Oversight 147.B.120

Standardisation findings authority 2015

2014 C

2014 D

2015 C

2015 D

8th Standardisation meeting

Results – Frequent issues authorities


24 x quality system

16x exposition incomplete or not followed

13 x personnel qualification & training

6x full audit in 24 month

5 x independent audit quality system

4x sampling courses and exams

3x closure of findings

Results (3)


0 5 10

0 5 10

66 - Appendix VI

66.1 Transfer of AML

66.B.25 Basic Knowledge

66.B.115 Change

66.B.500 Revocation & Suspension

66.B.305 Conversion

66.B.120 Renewal

66.B.125 Conversion new group-ratings

66.B.130 Direct Approval Type-training

66.B.200 Authority Examinations

66.B.20 Privileges

66.B.10 Competent Authority

66.B.100 Issue of a Licence

Part-66 findings

2015 C

2015 D

2014 C

2014 D


Subjects raised

1. How can industry help standardisation

2. Practical type training B1+B2 combined courses:

3. Fuel Tank Safety Continuation Training every two years.


5. Helping to improve vs punitive system

6. NAA inspectors could serve in industry

7. Second sites approvals

8. CA subsidiary conducting examinations.


10. Practical type-training om other type

11. Differentiating B1 and B2 tasks

12. Audit interval applicable to individual articles


1.Can industry help standardisation?

EAMTC meetings

EAMTC instructor seminars

Communicate, Share information, Cooperate

Mutual model for question distribution

EASA review and working groups Comment on proposed rule changes & AMC/GM

Review of 147 (RMT.0544) 66 (RMT.0255)

Report unfair competitions

Push EASA with good suggestions

Promote central question bank

Promote the Certification Specification for OSD


2. practical type training for B1+B2

Part-147 to decide what is necessary

TNA -> theoretical or practical, CBT etc

If one course combines B1 and B2:

Practical training meets both B1 and B2 requirements

Minimum for combined unchanged (2 weeks)

147 justifies course content and duration

Odd case of < 2 w requires authority approval.

EASA welcomes proposals combined and difference courses (RMT.0255)


3. Fuel tank safety continuation training

Skipped if there are no new techniques/developments?

Recurrent and continuation training - no definition:

Refresh knowledge

Remain current, remain competent

Update (Technology, skills, HF, techniques)

Old and new knowledge, skills and attitude

FTS training specific subject continuation training

App IV to AMC 145.A.30(e)

Staff that is 100% up-to-date do not need training



Comparable to flight instructors…

Support concept (when feasible)

One to one situation e.g. OJT & Practical training

No intention to change rule


5. Continuous improving vs punitive

System not punitive

Penalties & fines only in case of serious misconduct

Just culture -> not punitive (Pre-amble (EC) 216/2008)

Good findings assist to improve NAA and 147

Verify effectiveness regulations (EASA)

Verify effectiveness procedures (NAA & 147)

Progressing to performance based oversight & SMS (ARO.GEN.305)


6. NAA inspectors serve in Industry?

Good idea!

Safety conference Luxembourg (2015)

Partnership NAA-Industry

NAA inspectors have > 5 years experience

Industry

Authority

Complications

Confidentiality

Time /cost


7. Approval of multiple sites

Concept:

Principal place of business

principal financial functions and operational control

Multiple locations

Permanently staffed

Incidentally staffed

Type training

Examinations


7. Approval of multiple sites (2)

Standardisation insists:

All locations are contained in audit plan

Part-147 organisation

Permanently used locations; audited at least every cycle

Incidentally used locations; depending on importance and experience

NAA

Main location; audited every cycle

Other permanent locations; depending on risks, scope, importance and experience

Incidentally used locations; depending on risks, scope, importance and experience


7. Approval of multiple sites (3)

Exposition

Approved location (1.6) fully controlled, audited etc.

Facilities & systems under control

Incidentally used location (2.8, 2.16) ad-hoc base

Facilities & systems not under control, but ad-hoc verified

Different procedures

Opinion 07-2015 no confidence basic knowledge exams-> stopped

Audit all to verify effectiveness of all procedures


8. CA subsidiary examinations

Part-66 examinations:

Authority (Inspected by EASA)

procedures, staff, exams & records

Independence = advantage

Part-147 (Inspected by NAA)

procedures, staff, exams & records

Side activity

Central Examination Question Bank


8. CA subsidiary examinations (2)

No level playing field

Some authority tasks performed by industry

Alleviation of NAA

E.g. Licence preparation & ARCs

Expensive licences vs free licences

Examiners

Knowledgeable when preparing questions

Not knowledgeable when invigilating

Trained and appointed as examiner



Type-training course = theoretical + practical

Analysis (TNA)

Complementary

Splitting possible (but not recommended)

Theoretical and practical in different 147

Avionics/Electrics or Engines in different 147

Beware of interfaces -> provide details to CA’s

Coordination – exchange of information

Content & Length satisfies licensing authority

Clear details on CoR


10. Practical type-training on other type

Possible only for identical tasks

Ensure tasks are identical & representative

Use only in exceptional cases

Document it


11. Differentiating B1 and B2 tasks

B1 is skilled in tasks mechanical or electrical nature.

B2 is skilled in tasks electrical and avionic nature

Define in task card

Mutual assistance

Future only combined? (Miscellaneous Part-66)


12. Audit interval for to individual articles

Theory - regulation

147 checks all aspects at least every 12 month (AMC)

CA completely audit organisation within 24 month

Implying to check individual article again without exceeding the cycle

Practical advice

Plan for the standard

Deviate if necessary

In accordance with deviation procedure

Justify and document deviation

Ensure deviation not to big

Ensure deviation not accumulative


Thank you for your attention


Thank you for listening

any questions or remarks

?

Documents

EASA Standardisation...15 March 2016 EASA Standardisation 5 0 2 4 6 8 10 12 14 0 2 4 6 8 10 12 14 Type training, Exam Standard 66-App III Basic Examination Standard 66-App II Instructional