Index. CAP1528 Issue 05

Transcription

1 Engineer Stards CAP1528 Guidance Material Guidance f assessing the qualifications, skills, competency the revalidation of Part 147 Instructs, Knowledge Examiners, Exam Invigilats Practical Assesss (Replaces CAA Stards Document 46 v1)

2 Index Abbreviations Terms General Definitions Engineering Instruct requirements Knowledge Examiner requirements Exam Invigilat requirements Practical Assess requirements The continuation of an instruct, knowledge examiner practical assess s authisation Revalidation of Authisation 'Grfathering' Permanent Instructs v Contract Instructs Additional Guidance Civil Aviation Authity Aviation House Gatwick Airpt South West Sussex RH6 0YR ELDWEB@caa.co.uk September 2018 Page 2

3 Abbreviations Terms AMC EI GM KE MTOE NVQC NPA PA Acceptable means of Compliance Engineering instructs Guidance material Knowledge examiners Maintenance Training Organisation Exposition National Vocational Council Notice of Proposed Amendment Practical assesss 1. General This document is intended to provide guidance to UK Part 147 training ganisations, f the initial assessment of qualifications, competencies skills f the appointment of Engineering Instructs, Knowledge Examiners, Practical Assesss Invigilats in respect of compliance with EC Regulation 1321/2014. This document re-affirms the guidance given in EASA UG.CAO It also provides guidance f the Continuance / Revalidation of existing Part 147 Instructs, Knowledge Examiners, Practical Assesss Invigilats. The Assessment process the Continuance / Revalidation process should be developed by the Maintenance Training Organisation referenced in the relevant Maintenance Training Organisation Exposition (MTOE). Training ganisations should retain a recd of the Instructs, Knowledge Examiners, Practical Assesss Invigilats training, qualifications experience f an indefinite period as well as ensuring that ALL instructional staff are issued with copies of their Personal Authisation Certificates. A recd system should be established within the ganisation to recd the skills, proficiencies competencies f the continuance / revalidation of Instructs, Knowledge examiners, Practical assesss Invigilats within the approved training ganisation. Periodicity of these checks should be recded retained in the individual s personal training recd file. The UK Civil Aviation Authity (CAA) any representative assigned by EASA shall have access to these recds during compliance audits. September 2018 Page 3

4 2. Definitions The definitions are drawn from the rule defined in EASA FAQ s which refer to Joint practical guide of the European parliament which defines the following definitions: "Expect" "Should" are used to indicate strong obligation. "May" is used to indicate discretion. Qualification assessment: A check of the authenticity of the applicants Curriculum Vitae (CV), Training certificates experience. Revalidation Check: A periodic review carried out by the training ganisation to check instructs recency in accdance with the Part 147 regulation. Terms of Reference: A personal approval document (commonly referred to as a Personal Authisation Certificate PAC) indicates the scope of approval f each instruct / examiner / practical assess. The document should list subjects modules that the individual is approved to deliver / examine / assess. This document must be issued to the instruct/assess/examiner be produced to a member of the competent authity upon request. "Shall" "Must" are used to indicate a maty requirement. Skills Test: demonstration of knowledge skill. Update training: The scope of this training can include, but is not restricted to: changes in technologies, new instructional techniques knowledge of aircraft maintenance processes etc. 3. Engineering Instruct requirements General All Aircraft Basic skills type training Instructs whether permanently tempally employed, must have undergone an Instructional techniques training course be able to demonstrate a comprehensive understing of the EASA Part regulaty requirements. Additionally, they should have a practical wking knowledge of the Maintenance Training Organisations Exposition (MTOE) associated training procedures. All Engineering instructs, Knowledge examiners Practical assesss permanently employed within the Part 147 must be listed in Part 1.5 of the MTOE, (List of Maintenance Training Instructs, Knowledge Examiners Practical Assesss). EASA Fm 4 s are required f Training Manger, Quality Manager, Examination Manager Examiners (See Para 4 Knowledge Examiners). Engineering instructs may with the approval of the CAA also hold other positions within the training ganisations, i.e. Knowledge examiner, Practical assess; these other roles must be clearly identified against the individual within the relevant MTOE annotated on their Personal Authisation Certificates. September 2018 Page 4

5 All sub contracted Basic Type instructs are to be vetted assessed pri to the commencement delivery of any training. The assessment process is to consist of a face to face event with the training manager deputy. The process should also include a presentation demonstration to ascertain the applicant s levels of subject knowledge; delivery skills techniques. All such assessment is to be recded retained by the training ganisation. Type Training They Instruct The basic criteria f an aircraft Type training instruct must be, either: a) Hold an aircraft maintenance engineer s licence acceptable to the competent authity successfully completed an instructional techniques / train the trainer course to a nationally recognised stard to a stard agreed by the competent authity b) Hold an aeronautical / electrical mechanical engineering degree successfully completed an instructional techniques / train the trainer course to a nationally recognised stard to a stard agreed by the competent authity c) Have evidence of previous employment as an aeronautical type-training instruct. (See Section 9) - Grfather Rights will be given to any individual who can satisfactily demonstrate previous employment as an Instruct however befe being permitted to instruct they must demonstrate satisfacty update training. d) 3 years of relevant experience, including 1 year of experience on the relevant A/C type(s). The experience must be representative of the elements(s) to be taught gained in civil aviation environment acceptable equivalent (maintenance, engineering, design ganisation, etc...). This requirement does not necessarily apply f new type- certified aircraft. Contact the competent Authity f these specific cases. With respect to para: b) c) above the prospective Type training instruct should undergo a type course specific to the categy type to be taught. This must be evidenced by: i) A Part 147 Certificate of Recognition** (training + exam) issued by an approved Part 147 maintenance training ganisation f a type training (level 3) successfully received on the relevant A/C(s) including they & practical. The Certificate of recognition should address the categy of licence cresponding to the specialty of the instruct (i.e. B2 f an avionic instruct) ii) A refresher/update course on the concerned A/C type if the instruct has not instructed the concerned A/C type(s) in a Part 147 environment during the two years preceding its employment in the current 147 ganisation. September 2018 Page 5

6 To avoid conflicts of interest, the Part 147 exam should not be attended in the Part 147 ganisation where the instruct is to exercise its privileges, unless specific measures are taken accepted by the competent Authity to demonstrate that the integrity of the examination is ensured. The instruct should attend a number of lesson sit-ins of the type-training course on the material he she is to deliver. This number may vary with each ganisation, depending upon the experience of the instruct their approved procedures. The instruct should then prepare deliver a training session in a monited environment, attended assessed either by the training manager his delegated representative as part of the ganisations assessment process, pri to the instruct being approved to deliver a course, (commonly referred to as a competency assessment). Acceptance of other type-training courses their Accreditation Other type-training courses received in a non-part 147 ganisation (including they practical elements) can only be considered f acceptance when the curriculum/level of the course is equivalent to Part 66 Appendix 3. To get these courses accredited f the purpose of satisfying qualification requirements, the equivalency of the course shall be demonstrated by the maintenance training ganization by following these principles: When a Part 147 maintenance training ganisation intends to nominate training staff not having attended the relevant type training course in an approved Part 147 maintenance training ganisation (so the instruct does not hold a Part 147 type training certificate), the internal Quality system of the Part 147 ganisation has to demonstrate the equivalency of the other course by reviewing assessing the following items: 1. Type training syllabus: Syllabus levels f the type training should be assessed f equivalence to Part 66 Appendix III f the relevant licence-categy; 2. Type training course length: Verify that the course length is equivalent to an EASA Part 147 course f the same similar aircraft type. 3. Type training course provider: Recd the course provider. Assess as far as it is possible that the training documentation/ material came from a reputable source. 4. Categy of type training: Ensure that course completed by the Type instruct is relevant to the scope of the licence categy intended f the course that is to be included in the individual s approval (e.g. avionic = avionic type training course not Airframe/power plant). 5. Theetical practical training: Verify that the course covered the theetical practical elements. If the training covered only the theetical aspect, then the practical training shall be justified separately. In this case it should be noted that the practical training may have been carried out in the past as an structured OJT when the applicant was under the control of an approved maintenance ganisation befe CR(EU)1149/2011 became effective. 6. Examination: September 2018 Page 6

7 Verify that individual training course certificates the associated examination results are available. Verification that the exam result is at least equivalent to Part-66 requirements; Review, when available, the examination paper assess the multichoice questions (number of multi-choice question per hour of training, pertinence of the questions, etc.).update Training f Type Training They Instruct. Update Training f the Type Training Instruct Update training should consist of 35 hours. It may be sub-divided over 24 months into me than one element should include such activities as awareness of the latest training techniques, any specific technical upgrade to the aircraft type, attendance at relevant lectures symposiums etc. appropriate to the knowledge being trained. Recds should indicate when update training was scheduled when it took place f each instruct / examiner practical assess. The update training must also evidence compliance in both THEORY PRACTICAL skills. And a competency review should be held on file f the relevant period suppting the authisation Basic Training Instruct The basic criteria f an aircraft Basic skills instruct must be, to either: a) Comply with any of the requirements listed in (Section 3, General) Hold a Part 66 aircraft maintenance engineer licence applicable to the relevant categy/sub-categy b) Provide evidence of previous employment as a basic mechanical electrical engineering training instruct c) Hold an aeronautical / electrical mechanical engineering degree have successfully completed a fmal instructional techniques course to nationally recognised stard to a stard agreed by the competent authity d) Provide evidence of previous employment as a technical training instruct (See Section 9). e) 1 year of relevant experience in a civil aviation environment f those instructs nominated to teach Modules 11,12,13,14,15,16,17. The experience must be adapted to cover the subject to be taught gained in an aviation engineering dept. in a line/base maintenance AMO. This should be increased to 3 years of relevant experience in civil aviation environment (aeronautical maintenance), acceptable equivalent, f those instructs nominated to teach Module 7; the experience must be also representative of the subject(s) to be taught. September 2018 Page 7

8 NOTE: F individuals involved with the instruction of Modules 1 2 ONLY, an academic teaching qualification, relevant to the modules being taught is acceptable. No requirement of specialty experience has been defined f instructs nominated to teach the remaining Modules of Part 66 Basic syllabus; however practical experience in A/C maintenance, design production activities is considered advantageous; the advantage f the instruct is to underst the practical applications of a scientific knowledge, therefe to better appreciate the knowledge that the student must receive. On meeting the criteria as stated above; the prospective Basic training instruct should attend training on the specific Part 66 module to be taught. Ideally the Basic Skills Instruct should attend a number of lesson sit-ins of the specific Basic Part 66 module course he is to deliver, in a monited environment, attended assessed by either, the training manager, his delegated representative, as part of the ganisations assessment process, pri to the instruct being approved to deliver a course Update Training f the Basic Training Instruct Update training should consist of minimum of 35 hours. It may be sub-divided over 24 months into me than one element should include such activities as awareness of the latest training techniques, any specific technical upgrade to the aircraft type, attendance at relevant lectures symposiums etc. appropriate to the knowledge being trained. Recds should indicate when update training was scheduled when it took place f each instruct / examiner practical assess. Part 147 Requirements All Part 147 Basic Type Instructs should be listed in Part 1.5 of the MTOE. (List of training instructs, knowledge examiners practical assesss). This list should identify the scope of authisation f each instruct i.e. B1, B2, B757, B777, Airbus 340 etc. The Part 147 ganisation should ensure that the scope of authisation f each instruct, including any sub-contracted instruct, is current applicable to the subject being taught. The Part 147 ganisations should ensure that all staff remain conversant with the requirements of Part 66 / 147 associated AMC s, Guidance notes Notices of Proposed Amendments (NPA s) via update training. Part 147 training ganisations that employ sub-contracted instructs should maintain a recd of the courses instructed identify the amount of experience gained in each discipline. A recd of instruct / examiner recency check should be retained, by the Part 147 training ganisation, demonstrating at least 35 hours of update training carried out over a 24 month period, in both THEORY & PRACTICAL skills (as applicable). And be able to be produced during audit by the competent authity. September 2018 Page 8

9 Type Training / Practical Instruct: Basic criteria f an aircraft Type Training / Practical instruct must be: Speciality Knowledge: A Part 147 Certificate of Recognition (training + examination + practical assessment) issued by a Part 147 training ganisation f a type training (level 3) successfully received on the relevant A/C(s) including they & practical**. The Certificate of recognition should address the categy of licence cresponding to the speciality of the instruct (ie B2 f an avionic instruct) a) A refresher/update course on the concerned A/C type if the instruct has not instructed the concerned A/C type(s) in a Part 147 environment during the two years preceding its employment in the current 147 ganisation. b) a type training (they + practical) received in a non Part 147 ganisation***. The curriculum/ level of the course must comply with Part 66 appendix 3. c) A refresher/update course on the concerned A/C type if the instruct has not instructed the concerned A/C type(s) in a Part 147 environment during the two years preceding its employment in the current 147 ganisation. d) A specialised training (ie hydraulics) on the relevant A/C type(s). The curriculum/ level of the course must comply with at least with Part 66 appendix 3. The scope of instruction must be limited to the relevant speciality. NOTES: A refresher/update course on the concerned A/C type A/C type concerned systems if the instruct has not instructed the concerned A/C type(s) in a Part 147 environment during the two years preceding its employment in the current 147 ganisation. 1) **In der to avoid conflicts of interest, the Part 147 examination & practical assessment should not be attended in the Part 147 ganisation where the instruct is to exercise its privileges unless specific measures are taken accepted by the CAA to demonstrate that the integrity of the examination is ensured. 2) ***In der to avoid conflicts of interest, the exam & practical assessment must not be attended in the ganisation where the instruct is to exercise its privileges. And Pedagogical Skills i.e: a) Instruct Certificate (delivered by a legal entity, recognised by its local authities acceptable to the CAA to a national recognised stard, where the instruct will exercise his privileges* September 2018 Page 9

10 b) Evidence completion of a Train the trainer course to a nationally recognised stard c) A practical instruct privilege (documented) granted by the Maintenance ganisation when this part is contracted out (note: an administrative assessment of the competency is still required to be completed documented by the Part 147 training ganisation to determine how the maintenance ganisation qualifies internal instructs) d) Assessment perfmed documented by the Training Organisation s Training Manager (if himself appropriately qualified as practical instruct in accdance with an MTOE procedure). Be acceptable to the Competent Authity, following an in-situ audit in actual training conditions. Speciality Experience: - a) 3 years of relevant experience, including 1 year of experience on the relevant A/C type(s)*. (The experience must be representative of the tasks to be instructed gained in approved civil aviation environment i.e aviation maintenance/production), acceptable equivalent, including line / hangar maintenance experience b) 3 years of experience in similar aircraft types, additional experience on the particular aircraft type gained through type training, etc Update Training f the Practical Instruct Update training should consist of minimum of 35 hours. It may be sub-divided over 24 months into me than one element should include such activities as awareness of the latest training techniques, any specific technical upgrade to the aircraft type, attendance at relevant lectures symposiums etc. Recds should indicate when update training was scheduled when it took place f each instruct / examiner practical assess. The update training must also evidence compliance in PRACTICAL skills evidencing where possible application of use of practical involvement (i.e.: Being involved in maintenance activities such as: Engines Changes, component removals/refits, BITE tests, detailed system tests, structural repairs etc). September 2018 Page 10

11 4. Knowledge Examiner requirements General All Knowledge examiners must be able demonstrate an understing of the EASA Part regulaty requirements a comprehensive wking knowledge of the MTOE document associated training procedures. All Part 147 Knowledge examiners should be listed in Part 1.5 of the MTOE, (List of Training Instructs, Knowledge Examiners Practical Assesss). A Knowledge Examiner may at the discretion of the CAA also hold other positions within the training ganisation, i.e. Engineering Instruct Practical assess; these other roles must be clearly identified against the individual within the relevant MTOE on their personal Authisation Certificate. Note: A Knowledge Examiner shall not issue an examination paper invigilate an examination in a subject area where he/she has acted as an instruct. An ganisation may appoint a Chief Knowledge Examiner (Examination Manager). This person should submit an EASA Fm 4 to the CAA f approval pri to inclusion into the MTOE Para 1.2. Note: Knowledge Examiners listed in the MTOE Para 1.5, appointed by a Chief Knowledge Examiner, are not required to submit an EASA Fm 4. Qualifying the Knowledge Examiner The knowledge examiner must be: a) Meet the same criteria as the theetical instruct of either the concerned Basic Modules (i.e. examiner f Module 11 should meet the criteria of instruct f Module 11) Type Training elements (i.e. examiner f navigation topic meet the criteria of navigation elements instruct f type-training) b) Evidence completion of a train the examiner course to a nationally recognised stard. c) Conversant with the Part 66 syllabus that details the level of number level of questions per module d) Able to compile both written multi choice question papers, in the case of the written papers supply a model answer sheet detailing the marking guide e) Able to mark analyse the students responses provide feedback to the instruct / training manager, detailing any inconsistencies with the examination results process. September 2018 Page 11

12 5. Exam Invigilat requirements Nomination of an Invigilat An exam invigilat is understood to be someone, who is appointed by the maintenance training ganisation f ensuring the proper conduct of a particular examination in accdance with the examination procedures of the ganisation. The nomination of such a person can be either permanent, f those examinations taking place within an approved training address, ad-hoc f those venues where an examination is taking place away from the approved address ( one-off remote site). The non-permanent ad-hoc nomination is understood to be valid only when the maintenance training ganisation includes an acceptable procedure in the MTOE to control the suitability of the nominated person in terms of integrity independence. Accdingly, permanently appointed examination invigilats should be listed in Part 1.5 of the MTOE a paragraph detailing their duties responsibilities should be included in Part 1 of the MTOE. It should be noted that the individual can also hold other positions within the training ganisations, (i.e. knowledge examiner, practical assess, instruct); these other roles must be clearly defined against the individual within the relevant MTOE. The procedure f conducting examinations at either approved addresses locations not listed in the MTOE should be included at of the MTOE. Invigilat training In all cases, invigilats must be conversant with the Part 147 requirements related to the integrity of examinations the security of exam questions;, with the specific procedures approved f the maintenance training ganisation f the conduct of examinations. All invigilats should be trained by either an approved Examiner, Examinations Manager, Training Manager the Quality Manager on the duties responsibilities of the invigilat using the training ganisation s approved procedure. After the training, an assessment should be recded, by the Quality Manager Training Manager. The recd should have the date assess s name. The recd is to be retained on the individual s personnel file. A recurrent training assessment is not required providing the invigilat remains current i.e. invigilates at least once in each subsequent 12- month period. The Invigilat training should include, but is not limited to, addressing the following areas: a) The preparation of the classroom / examination room in accdance with the requirements of the approval under which the course is being delivered. b) Particular attention is to be drawn towards the spacing between cidates. Ensuring that desks are spaced so that each student cannot copy from another student, there should be a minimum of 1 metre between students each student should be within direct line of sight (facing the front of the room) of the invigilat. The invigilat should be able to see every student face-on. c) Students should be prevented from entering the room until it is properly prepared. d) Each student s identity is to be confirmed pri to the examination. If necessary copies of passpts should be reviewed to confirm. In cases whereby outside September 2018 Page 12

13 attendees are sitting the examination an example of the student s signature should also be checked. e) Adequate security of the examination papers is to be maintained throughout. Only the crect number of examination papers is to be taken into the examination room. Under no circumstances is the examination marking sheet to be taken into the examination room, at no time should an examination be marked in the vicinity of the students. f) Students are to be clearly briefed befe the exam. The brief should consist of a prepared statement should be addressed to ALL the students at the beginning of ALL examinations. The brief is to outline the procedures conditions of the examination process. This is to include actions to be taken if the examination has to be stopped f any reason. g) It is to be made clear that the invigilat should not engage in any fm of dialog with the students during the examination, this should be outlined in the opening brief. h) The exam is to be conducted in a manner in keeping with the briefing. The invigilat is not to conduct any other wk whilst moniting the examination. Invigilats selected f a tempary approval should be nominated by the customer s Quality Manager deputy, who hold a fm 4 equivalent. They should be trained by a representative of the training ganisation who is on-site (instruct). In some cases, it may be appropriate f the instruct to sit at the rear of the classroom to ensure that the training ganisations procedures are adhered to. However, they must not take part in the examination procedure. The training should be conducted using the procedure detailed in the MTOE, detailing the duties responsibilities of the invigilat, with particular emphasis on points a) h) above the Part 147 requirements related to the integrity of examinations the security of exam questions. Examination misconduct. The invigilat training should include the procedure detailing the physical actions to be taken in the event of an invigilat witnessing suspecting that cheating is; has taken place during an examination. Note: A Knowledge Examiner shall not issue an examination paper invigilate an examination in a subject area where he/she has acted as an instruct. 6. Practical Assess requirements General All Part 147 nominated Practical Assesss, whether permanently tempally employed, must demonstrate a comprehensive understing of the EASA Part regulaty requirements; additionally, they should demonstrate a comprehensive practical wking knowledge of the MTOE document associated training procedures. Practical Assesss should be listed in Part 1.5 of the MTOE, (List of Training Instructs, Knowledge Examiners Practical Assesss). This list should identify the scope of September 2018 Page 13

14 authisation f each Practical Assess i.e. B1, B2, B757, B777, Airbus 340 etc be clearly shown on their Personal Authisation Certificate (commonly referred to as scope of approval). Practical Assesss may also hold other positions within the training ganisations, i.e. Engineering Instruct Knowledge examination; these other roles must be clearly identified against the individual MTOE. The Practical Assess should assist instructional personnel in developing the practical training tasks assessment criteria. An ganisation may appoint a Chief Assess; this person should submit an EASA Fm 4 to the CAA f approval pri to inclusion into the MTOE Para 1.2. Note: Practical Assesss listed in the MTOE Para 1.2, appointed by the Chief Assess, are not required to submit an EASA Fm 4. Qualifying the Practical assess The Practical Assess must either: a. Meet the same criteria as the Practical instruct of either the concerned Basic training Modules (ie Practical assess f module 11 meet the criteria of Instruct f Module 11) the concerned Type-training elements (ie Practical assess f ling gear tasks meet the criteria of practical Instruct f ling gear elements), having also successfully completed a fmal instructional / facilitats techniques course, an assess training course. b) When training is delivered assessed under the control of an approved AMO (Basic Practical training elements contracted to another AMO, maintenance Practical training directly-approved by the competent Authity, etc.) hold a current aircraft-type technical authisation, issued by a Part 145 ganisation, on the subject/aircraft-type being taught, having also successfully completed a fmal instructional / facilitats techniques course, an assess training course. September 2018 Page 14

15 All Part 147 / 145 nominated Practical Assesss should be listed in Part 1.5 of the MTOE. (List of Training Instructs, Knowledge Examiners Practical Assesss). This list should identify the scope of authisation f each Practical Assess i.e B1, B2, B757, B777, Airbus 340 etc. When Practical assesss hold other positions within the training ganisations, although the roles of the assess the instruct f the Practical elements of a Type Training course may be combined, the objectives associated with each function should be clearly understood, the competence qualification criteria accding to ganisation s procedures should be met f both functions. Whenever possible (depending on the size of the ganisation), it is recommended to split the roles, in der to avoid any conflicts of interest. 7. The continuation of an instruct, knowledge examiner practical assess s authisation. General Part 147.A.105 Personnel Requirements, state: Instructs Knowledge examiners shall undergo update training at least every 24 months relevant to current technology, practical skills, human facts the latest training techniques appropriate to the knowledge being trained examined. This should also be suppted with a valid competency review f that period. This training should consist of a minimum of 35 hours within the 24-month period; in addition, training school personnel are to remain conversant with the latest revision of the EASA Part 147 regulations, AMC s, Guidance notes NPA s. They should also be conversant with the respective ganisations MTOE associated training procedures. Part 147 training ganisations should ensure that personnel training recds, including recds of qualifications, update training experience competency is retained f each Instruct, Knowledge Examiner Practical Assess. It is also expected that a Part 147 ganisation its instructional staff should be able to evidence recency as part of the continuation of an approval. Organisations may wish to adopt the stard industry default of 6 months experience in a 24 month period, alternatively they may wish to define their own within their approved MTOE, subject to the approval of the competent authity. 8. Revalidation of Authisation General In der f an Instruct, Knowledge examiner Practical Assess s authisation to be revalidated following renewal / expiry / withdrawal. The maintenance training ganisation should implement a reinstating procedure within their approved MTOE that will cover the relevant training disciplines associated with the authisation concerned evidence of recency, where applicable. September 2018 Page 15

16 The criteria f reinstating should take into consideration the length of time the individual has been away from that specific training environment discipline. Any Instruct, Knowledge examiner Practical assess who has passed 24-month period without exercising the privileges of his authisation, as a minimum, must comply with the table below: Inactive Period Recovery action 24 to 30 months 35 hours update training + Continuation training + Training School procedures processes + 2 monited training sessions with another instruct covering both They Practical aspects. 30 months 60 months As above plus two sit-ins on the type course f the authisation being sought. 60 months longer Re-training in the ce subject with successful examination to the current National/European stard. The competent authity has the authity to challenge where necessary refuse any applicants approval to be named as an instruct, assess examiner. This is regardless of whether the applicant has held an instructional position previously (i.e where an ganisation may be wishing to claim grfather privileges). 9. 'Grfathering' General 1. Instructs, examiners assesss accepted by an ganisation via their approved MTOE pri to the entry into fce of the revision of this document Commission Regulation EU1149/2011(repealed by EU1321/2014), exercising their privileges, part thereof, at the entry into fce of this stard, are considered as fulfilling the knowledge experience requirements. 2. However an assessment of the gap between actual training qualifications this stard in der to identify deficiencies in the qualification should be perfmed by the Part 147 maintenance training ganisation, a crective-plan should be provided to the competent Authity within a reasonable timeframe. With respect to para: 3.2.1(c) 3.5.1(b) & (c) of this document, Grfather provisions accepting full compliance with the above criteria at the time of the entry into fce of the revision of this document cannot be considered as transferrable between different Part 147 maintenance training approvals. Any Instructs, examiners assesss qualifying in respect of Section 9(1) above within an ganisation after this must comply with the requirements of Annex IV (Part 147) EU1321/2014 September 2018 Page 16

17 10. Permanent Instructs v Contract Instructs Part 147.A.105(c) requires ganisation to have a nucleus of permanently employed staff sufficient to undertake the minimum required to maintain the ganisations scope of approval. Such staff should therefe be directly employed by the ganisation to giving the necessary capacity stability with regards to permanently employed Instructs, Assesss & Examiners ensure the continued stability of the ganisation therefe ensuring the ganisations its ability to meet the requirements of its approval any subsequent scope. Any staff on zero hours contracts will be considered as contracts unless the ganisation can satisfy to the CAA that an individual: i) Meets the requirements f an employee; ii) iii) Is required to rept f wk when requested; Does not perfm any wk f another aviation maintenance training ganisation. A failure to meet any of the requirements above is considered to be a failure of the ganisation to fulfil its obligations under Part 147. Findings of the appropriate level will be raised in accdance with Part 147.A.160. Where this impacts on the capability of the ganisation to perfm its approved scope of wk the CAA may decide to suspend, limit revoke the affected parts of the approval. The use of contract instructs is permitted providing the ganisation can evidence that without the use of the contracts they can still suppt the ganisations scope of approval. 11. Additional Guidance F Additional guidance ganisations may refer to EASA UG.CAO September 2018 Page 17