LAMPIRAN PERATURAN DIREKTUR JENDERAL PERHUBUNGAN UDARA NOMOR : KP 254 Tahun 2017 TANGGAL : 25 September Staff Instruction

Transcription

1 LAMPIRAN PERATURAN DIREKTUR JENDERAL PERHUBUNGAN UDARA NOMOR : KP 254 Tahun 2017 TANGGAL : 25 Staff Instruction SI Certification or Renewal or Amendment and Surveillance of a CASR Part 147 Aircraft Maintenance Training Organization (AMTO) Edition : 1 Amendment : 0 Date : REPUBLIC OF INDONESIA MINISTRY OF TRANSPORTATION DIRECTORATE GENERAL OF CIVIL AVIATION JAKARTA INDONESIA

2 SUMMARY OF AMENDMENTS AMENDMENT No. DG DECREE No. ISSUE DATE REMARK Original March 2001 To include ICAO of Annex 1 Edition 1 KP 254 Tahun Sept To include new requirement of CASR 147, harmonized with ICAO Annex 1 and Doc i

3 FOREWORD 1. PURPOSE : This Staff Instruction prescribes responsibilities, policies, and procedures to be used by the Directorate General of Civil Aviation (DAAO) for evaluating an applicant for certification or renewal or amendment of CASR Part 147 Aircraft Maintenance Training Organization (AMTO). 2. REFERENCES : This Staff Instruction should be used in accordance with the applicable regulations. 3. CANCELATION : SI , Revision Original, dated 6 March 2001 is canceled. SI , Revision Original, dated 21 April 2008 is canceled. 4. AMENDMENT : The amendment of this Staff Instruction shall be approved by the Director General of Civil Aviation. DIRECTOR GENERAL OF CIVIL AVIATION ttd Dr. Ir. AGUS SANTOSO, M.Sc. ii

4 TABLE OF CONTENTS SUMMARY OF AMENDMENTS... i FOREWORD... ii CHAPTER I. INTRODUCTION Objective Definitions... 1 CHAPTER II. CERTIFICATION OF PART 147 AIRCRAFT MAINTENANCE TRAINING ORGANIZATIONS General Pre-application Phase Formal Application Phase Document Compliance Phase Demonstration and Inspection Phase Certification Phase Applicable Forms CHAPTER III. EVALUATE CURRICULLUM/REVISION AND INSTRUCTOR QUALIFICATIONS General Procedures Applicable Forms CHAPTER IV. EVALUATE FACILITIES, FACILITIES, EQUIPMENT, MATERIALS, AND TOOLS General Procedures Applicable Forms CHAPTER V. EVALUATE QUALITY ASSURANCE SYSTEM & TRAINING PROCEDURES MANUAL General Procedures Applicable Forms CHAPTER VI. SURVEILLANCE OF PART 147 AIRCRAFT MAINTENANCE TRAINING ORGANIZATIONS General Procedure Applicable Forms CHAPTER VII. ISSUANCE OF EXAMINING AUTORITY General Procedure Applicable Forms CHAPTER VIII. RENEWAL and amendment OF PART 147 AIRCRAFT MAINTENANCE TRAINING ORGANIZATIONS General iii

5 2. Formal Application Phase Document Compliance Phase Demonstration and Inspection Phase Certification Phase Applicable Form iv

6 CHAPTER I. INTRODUCTION 1. Objective This staff instruction provides guidance for certificating an Aircraft Maintenance Training Organization (AMTO) under CASR Part 147, Aircraft Maintenance Training Organizations and guidance for evaluating the curriculum or curriculum revision of an Aircraft Maintenance Organization (AMTO) under CASR Part 147, Aircraft Maintenance Training Organizations. 2. Definitions Approved Non-Certificated Instructors (Specialized Instructors). Individuals who are not certificated but who have been found qualified by the AMTO to teach mathematics, physics, basic electricity, basic hydraulics, drawing, and similar subjects. Additional/Amendment approval means extension to the existing scope of approval. Audit means an in-depth review and evaluation of the activities of an organization to verify conformance to DGCA regulations and standards. Audit activities mean those activities and procedures through which information is obtained to verify the auditee s conformance to applicable regulations and standards. Such activities may include, but are not limited to: interviews, observations, inspections and the review of files and documents. Auditee means the organization to be audited. This term may be interchanged with organization, company, operator, air operator, private operator or flight training unit operator. Audit Finding means the determination of non-conformance of a product, process, practice, or procedure or a characteristic thereof to a specified regulation or standard. This will be documented on the Audit Finding Form. Audit Manager means the individual, designated by the DGCA, responsible for the planning and conduct of an audit, including the production of the audit report. Audit Member means the individual appointed by the respective directorate to participate in either the Airworthiness or the Operations or the safety portion of the audit. Audit Report means a report that outlines the audit process and provides a summary of the audit findings. Audit Program (AP) means the Annual program that promotes conformance with the aviation regulations and standards that collectively prescribe an acceptable level 1

7 of aviation safety. The AP ensures that DGCA audit policies and procedures are applied uniformly Audit Plan means the annual plan of scheduled audits intended to measure the level of an organization s conformance. These organizations include designated airworthiness organizations and air operator. Audit/Surveillance/Inspection Finding Form 1. Audit/ Surveillance/Inspection finding forms must be completed accurately as they form the basis of the audit report and a successful audit. Audit/ Surveillance finding form use DGCA Form Since a number of team members will be completing audit/ surveillance / Inspection finding forms, it is important that a standardized approach to inputting data on the form be taken to reduce the number of data entry errors. All supporting documentation will be included with the completed audit/ surveillance/ Inspection finding form for review by the Audit Manager/ PAI/ POI. Although supporting documentation will not be included in the audit/ surveillance report, it will be retained in the audit file. Certificated Instructors. Those instructors who hold DGCA Basic Certificate and the category appropriate for the AMTO subjects to be taught. Common Hand Tools. Small, ordinary tools such as ratchets, sockets, and screwdrivers. This should not be considered an all-inclusive list, but simply an example for the DGCA Airworthiness Inspector to consider. Certification means the process of determining competence, qualification, or quality on which the issuance of an AOC and/or Operation Specifications is based. This includes the original issuance, denial, renewal or Amendments/revision of that document. Characteristic means any distinct property or attribute of a product, process, service or practice of which the conformance to a regulation or standard can be measured. Combined Audit means an audit that targets both Airworthiness and Operations functional areas. Compliance means the state of meeting regulatory requirements. Confirmation means the assurance that audit findings are in accordance with data obtained from different sources. Confirmation Request Form (CRF) means a form issued during the inspection portion of an audit to the auditee by DGCA inspector requesting information that is not readily available. The auditee will be requested to respond within a specified time period. 1) The CRF is an effective audit tool in the following cases: 2

8 a) Where evidence indicates an audit finding, the company will be given the opportunity to show otherwise; b) The auditor will determine the course of action to be adopted based on the auditee s response; c) The auditor will observe the state of the company records management system from the auditee s perspective; d) Arbitrary audit findings based on subjective examples will be eliminated; e) The auditee will not be surprised at the end of the audit, as all contentious issues will have been discussed openly during the physical audit; f) The auditor can concentrate on auditing rather than on researching company files and records, and g) The auditor will receive a signed document from the auditee for inclusion in the supporting documentation package. 2) The CRF form (DGCA Form ) will be sent to the Audit Manager at the outset to avoid untimely surprises. All CRFs form will be issued sequentially to ensure that, upon completion of the physical audit, the CRFs have responses and appropriate action has been taken. 3) At the end of each day, the CRF form should be compared with the returned CRF to ensure that it is current. For a large audit, this can be done at the daily briefing with the company. In this manner, both the company and the audit team will be updated as to the status of these documents. Regardless of the way in which the CRF form is maintained, all CRFs should be cleared prior to the completion of the physical audit at that site or base. When the CRF has been returned and appropriate action taken, this material should be filed according to the appropriate audit area, allowing documentation relating to high-profile items to be maintained for later reference. This file will also provide background and evidence for any enforcement action to be taken at a later date. Conformance means the state of meeting the requirements of a regulation or standard. Convening Authority (CA) means the individual responsible for authorizing and overseeing the regulatory audit. The CA is also responsible for ensuring that the follow-up is completed. Corrective Action Plan (CAP) means a plan submitted to the CA or to his or her delegate byte auditee, following receipt of the audit report. This plan outlines the manner in which the company proposes to correct the cause(s) of deficiencies identified by the audit findings based on the root cause analysis. Carrying out the plan should bring the auditee into full conformance with regulatory requirements. Depth means the period of time over which a company will be audited, normally from the last audit up to the present day. 3

9 Documented means that which has been recorded in writing, photocopied or photographed and then signed, dated and retained so as to ensure the continuity of the evidence secured. Documented (evidence) recorded in writing, by photocopy or by photography and signed, dated and retained in a manner to ensure continuity of the evidence secured. Follow-Up means the activity following an audit that is dedicated to program modification based on an approved Corrective Action Plan. Follow-up ensures that the document holder meets regulatory requirements. Immediate Action means any necessary action taken by DGCA upon finding of non-compliance against Civil Aviation Safety Regulations or Aviation Act by air operator resulting from an audit Inspection means the basic activity of an audit, involving examination of a specific characteristic of a company. In-Depth means extensively, completeness or thoroughly. Instruction Hour. The educational unit hour, as used by an AMTO, that consists of a time period of not less than 50 minutes. This instructional time period conforms to the existing practices at many education institutions. Instructional Aid. Equipment used to provide instruction. Examples include diagrams, visual aids, computers, interactive software, aircraft, and mockups of aircraft, engines, and components, as well as actual components, such as magnetos and fuel controls. An instructional aid is not required to meet return to service standards. Non-Compliance (immediate corrective action/level 1) means a deficiency in characteristic, documentation, or procedure with respect to provisions of the Aviation Act No. 01 of 2009 or a CASR. This is action must be taken immediately but not exceed than 15 days upon identification of the audit and surveillance finding. Audit findings that have direct impact on aviation safety may be taken to stop the operation of aircraft, maintenance, suspend of personnel licensing or termination of AOC activities. Non-Conformance (Short-Term Corrective Action/Level 2) means a deficiency in a characteristics, documentation, or procedures. which renders the quality of a product or service unacceptable or indeterminate, or not according to specified requirements, e.g. physical defects, test failures. Inadequate documentation. This is short-term action to correct a non-conformance that does not pose an immediate threat to aviation safety, which ensures that conformance is established quickly until long-term action is completed to prevent recurrence of the problem. Short-term corrective action will maximum take place within 30 days. Non-adherence (Long-Term Corrective Action/Level 3) means a deficiency in characteristic, documentation, or procedure with respect to a recommended practice, procedure, guideline or good aviation safety. This is longer-term action and has two components. The first will involve identifying the cause of the problem 4

10 and indicating the measures the company will take to prevent a recurrence. These measures should focus on a system change. The second component will include a timetable for company implementation of the long-term corrective action. Long-term corrective action will maximum take place within 60 days. Non adherence finding including safety observation is linked to safety and evaluation of the risks linked to operational hazards and raised when the risk pertaining to a specific hazard is evaluated by DGCA as non acceptable for safety. Observers means a person(s) other than certified and approved auditors, assigned to participate in the audit for training purposes in an audit program. Observer is not an audit team member. Principle Airworthiness Inspector (PAI) means The individual Airworthiness Inspector the DGCA has assigned certificate management and surveillance responsibility of a particular company or Air Operator Certificate holder. Principle Operation Inspector (POI) means The individual Flight Operation Inspector the DGCA has assigned certificate management and surveillance responsibility of a particular company or Air Operator Certificate holder Practice means the method by which a procedure is carried out. Product means the end result of a procedure or process. Procedure or Process means a series of steps followed methodically to complete an activity. This includes: the activity to be done and individual(s) involved; the time, place and manner of completion; the materials, equipment, and documentation to be used; and the manner in which the activity is to be controlled. Root Cause means the initiating cause in a causal chain that leads to an undesirable situation or condition; the point in the causal chain where corrective action could reasonably be implemented and expected to correct and prevent recurrence of the undesirable situation or condition. Root cause analysis on DGCA Form No Auditee must correctly identify and thoroughly conduct root cause analysis of any finding (non-conformities) and written in DGCA Form No Root cause analysis will be evaluated by the Audit Manager and Audit member, as a mandatory requirement for closing finding. Sampling means the inspection of a representative portion of a particular characteristic to produce a statistically meaningful assessment of the whole. Scope means the number of functional areas within a company that will be audited. Specialist Audit means an audit that targets either Airworthiness or Operations functional areas. Special-Purpose Audit means an audit intended to respond to special circumstances beyond initial certification, requests for additional authority or routine conformance monitoring. 5

11 Standard means an established criterion used as a basis for measuring an auditor s level of conformance. Surveillance means routine continuing audit to ensure compliance with the CASR s, standards and approved manuals. The surveillance area is the same as the audit area. Surveillance carry out as a routine continuing inspection to ensure compliance with the CASR s, standards and approved manuals. Surveillance Program (SP) means the annual program for routine continuing inspections that promotes conformance with the aviation regulations and standards that collectively prescribe an acceptable level of aviation safety. The AP ensures that DGCA audit policies and procedures are applied uniformly Surveillance Plan means the annual plan of scheduled surveillance intended by routine basis to measure the level of an organization s conformance. These organizations include designated airworthiness organizations and air operator. Surveillance performed by Principle Airworthiness Inspector (PAI) and Principle Operations Inspector. Shop. Facilities for providing instruction on projects taught at teaching Level 2 or 3. The shop environment should resemble a typical aviation repair facility. Shop Equipment. Machinery and supportive equipment, such as air compressors, work stands, racks, benches, fabricating devices, sheet metal equipment, and battery chargers. Simulated Approval for Return to Service. A measured standard of instructing students academic and skills in which to prepare them with the needed skills to maintain and properly return aircraft, parts, or components to service. Special Tools. Highly specialized tools, such as tension meters, micrometers, and torque wrenches. Teaching Levels. Three levels of instruction with varying degrees of difficulty. a. Level 1 requires: Knowledge of general principles, but no practical application. No development of skill. Instruction by lecture, demonstration, and discussion. b. Level 2 requires: Knowledge of general principles, and limited practical application. Development of sufficient skill to perform basic operations. Instruction by lecture, demonstration, discussion, and limited practical application. c. Level 3 requires: Knowledge of general principles, and performance of a high degree of practical application. Development of sufficient skills to simulate return to service. 6

12 Instruction by lecture, demonstration, discussion, and a high degree of practical application. Troubleshoot. To systematically analyze and identify malfunctions, and to identify the source of trouble in an airframe, powerplant, or aircraft component. For the purposes of AMTO, the item of equipment or simulator training aids must be in operating condition. For example, a turbine powerplant must be operational for the student to troubleshoot. Curriculum Components. The DGCA must approve the curriculum or revision. The part 147 approved curriculum will consist of the following for each subject: Training Subjects taught; Training objective; Teaching level requirements; The total number of hours required for successful completion; Required practical projects with corresponding lab or shop hours. Verification means an independent review, inspection, examination, measurement, testing, checking, observation and monitoring to establish and document that products, processes, practices, services and documents conform to regulatory requirements. This includes confirmation that an activity, condition or control conforms to the requirements specified in contracts, codes, regulations, standards, drawings, specifications, program element descriptions, and technical procedures. Working Papers means all documents required by the auditor or audit team to plan and implement the audit. These may include audit schedules, auditor assignments, checklists and various report forms 7

13 CHAPTER II. CERTIFICATION OF PART 147 AIRCRAFT MAINTENANCE TRAINING ORGANIZATIONS 1. GENERAL This section prescribes procedures for evaluating applications for AMTO certification. The certification of an AMTO is not limited to organizations physically located within the Republic of Indonesia. The certification process provides for interaction between the applicant and the DGCA from initial inquiry to issuance or denial of an AMTO Certificate. It ensures the thorough review, evaluation and testing of programs, systems, and methods of compliance. The certification process consists of the following five phases: Pre-application phase, Formal application phase, Document compliance phase, Demonstration and inspection phase, and Certification phase. 2. PRE-APPLICATION PHASE Preliminary Assessment. Upon initial contact from an applicant requesting part 147 certification, the DGCA will conduct the preliminary assessment. During preliminary assessment meeting only basic information and general requirement might be assessed and discussed, these includes: Legal aspect of applicant Desired date of operations Curriculum and training procedures manual preparations Qualification of management personnel Training facilities, instructional equipment, tool, material and shop equipment. The proposed applicant will provide complete information and data concerning the ratings sought. After preliminary assessment the DAAO should make a determination if the proposed applicant is qualified or not to apply for certification. The applicant may request the other preliminary assessment at least 60 days after the date of the applicant failed the preliminary assessment. Establish Certification Team. When it is determined to proceed with the certification process, the DGCA establishes the team members to conduct the certification. The team will consist of at least two Maintenance Inspector from the DAAO, and, if required, one maintenance inspector from DGCA regional representative. One team member will be designated as the Certification Project Manager (CPM). The Sub Directorate of Standard will obtain a precertification number. 8

14 Responsibilities of the CPM. The team member designated as the CPM must have completed appropriate training (DGCA Formal Course No and 4503). The CPM should preferably have previous experience in the certification of an AMTO under part ) The CPM must serve as the primary spokesperson for the DGCA throughout the certification process. Consequently, the CPM must thoroughly coordinate all certification matters with all other specialists assigned to the certification project. 2) The CPM must be responsible for ensuring that all certification tasks are complete, and must coordinate all correspondence to and from the applicant. 3) The CPM must notify the Director of Airworthiness & Aircraft Operations of any information that may significantly affect or delay the certification project. 4) The CPM must ensure that individuals involved with the certification project is kept fully informed of the current status of the certification. 5) The CPM must ensure that an application for a certificate and rating, or for an additional rating, under part 147 is made on a form and in a manner prescribed by the Administrator, and submitted with: a. A description of the proposed curriculum; b. A list of the facilities and materials to be used; c. A list of its instructors, including the kind of certificate and ratings held and the certificate numbers; and d. A statement of the maximum number of students it expects to teach at any one time. Responsibilities of the Certification Team Members. It is the responsibility of each team member to respond to a CPM request for assistance and keep the CPM informed of the status of the certification. Immediately bring any discrepancy that may delay the certification effort to the attention of the CPM. Pre-application Meeting and Discussion Topics. In preparation for the preapplication meeting, the CPM should remind the applicant that the key management personnel should attend the meeting and should be prepared to discuss, in general terms, various aspects of the applicant s proposed operation. 1) The pre-application meeting should be held in the DAAO Office. This will allow the applicant to become familiar with the DGCA personnel. 2) During the pre-application meeting, the applicant should provide the DGCA with an AMTO point of contact (POC). Encourage the applicant to ask questions during the discussion. Applicants should be thoroughly familiar with the certification phase requirements before continuing with the certification process. It is important, therefore, that the CPM be thoroughly prepared to conduct the meeting. 3) Open discussion of the applicant s intent for AMTO certification should take place while the DGCA offers answers to any questions the applicant has 9

15 regarding the application process. At a minimum, the following should take place during the pre-application meeting: a. Discuss DGCA expectations of the AMTO to include ethical considerations, meeting minimum regulatory compliance with part 147 to qualify for certification, and maintaining consistent regulatory compliance at all times after certification. b. Discuss the five phases of certification and the requirements of each phase. c. Discuss what the applicant may expect from the DGCA during and after certification. d. Verify the applicant is aware of the regulatory requirements and DGCA policies regarding certification and operation of an AMTO. e. Inform the applicant of the three types of DGCA ratings that may be issued (i.e., Basic Aircraft Maintenance Training, Aircraft Type Training, and Component Type Training.). f. Provide instruction on the completion of DAAO Form No , Aircraft Maintenance Training Organization Application. g. Verify the applicant understands the purpose and content of the formal application documents. h. Discuss the AMTO requirement to provide written procedures on specific processes including tool control, use of cleaners, lubricants, and flammable liquids. i. Discuss AMTO procedures for administrative procedures and recordkeeping processes. j. Discuss and verify that the applicant understands section regarding crediting students for previous training. k. Inform the applicant that the organization may not teach students before certification as an AMTO and then give credit for that training after certification. l. Discuss the requirement for written approved procedures for recording and controlling attendance, and provisions for course makeup when curriculum subjects are missed. m. Discuss the procedures for taking DGCA written knowledge tests, oral (knowledge) and practical (skill) tests. n. Discuss the requirement for procedures to maintain, keep, and distribute student records and transcripts. o. Discuss the significance and issuance of part 147 AMTO operations specifications (OpSpecs). p. Discuss the content of a compliance statement listing each applicable part 147 section and the necessity for providing either a brief narrative or a specific reference to a document that describes the manner of compliance with the part 147 regulation. q. Discuss with the AMTO applicant the need to develop AMTO operating policies and procedures addressing allowances to deviate from the approved curriculum order of instruction on a case-by-case basis due to unexpected interruptions such as inoperative mockups, inclement weather, hospitalized instructor, etc. r. Discuss with the AMTO applicant the need for the AMTO to incorporate policies and procedures addressing the reporting of interruptions that 10

16 cause deviations in the order of instruction in the approved curriculum to the principal training inspector (PTI). s. Discuss with the AMTO applicant the issuance of OpSpecs as dictated by the AMTO-specific operations. Pre-application Meeting Discussion of Documents. 1) Inform the applicant of the following certification documents required to be submitted for review during the formal application meeting. It is important that the CPM be thoroughly prepared to conduct the meeting. 2) Inform the applicant to develop the following: a. An event-scheduling calendar developed by the applicant that identifies, documents and forecasts the step-by-step The event-scheduling calendar should be developed in a way that ensures the certification process covers all phases of certification. b. The applicant should develop a Schedule of Events (SOE) that ensures the certification process is sound, and is agreeable to the CPM. The applicant and the CPM should review the schedule periodically to ensure steps are not missed. A copy of the completed SOE should be retained by the CPM in the certification file completion of the certification process as outlined in the five phases of certification. c. Two completed copies of DAAO Form No d. A compliance statement listing each applicable part 147 section and providing either a brief narrative or a specific reference to a document that describes the manner of compliance with the regulations. e. A description of the proposed curriculum. Emphasize that the actual curriculum must receive approval before certification. f. A student enrollment statement indicating the maximum number of students to be taught for each rating during each enrollment period. The DAAO Form No application will also show this information. g. A Training Procedure Manual. Emphasize the written description of standards for graduation, written description of attendance and missed course content makeup procedures, description of grading procedures, description of the facilities to be used for instruction. Ask the applicant to provide detailed drawings with dimensions of classrooms and laboratory/shop facilities. The drawings should show the relative location of each organization facility h. An inventory of the materials, equipment, and tools to be used. Advise the applicant to detail which tools the organization will provide and which the students must furnish. i. A list of instructors showing any required certificate, license, ratings, and subjects to be taught by each. j. Each subject in the proposed curriculum must be accounted for on the instructor listing. Ensure that the applicant understands that technical maintenance courses other than certain general subjects must be taught by appropriately certificated, licensed, or rating. Inform the applicant that at least one certificated instructor is required for every 25 students in each shop or laboratory class (refer to section ). k. A written description of the method that ensures access to appropriate and current technical data necessary for the rating(s) sought. The procedures 11

17 should demonstrate the ability to access or possess the current information. The data should include the following: Civil Aviation Safety Regulations (CASR), Type Certificate Data Sheets (TCDS), Airworthiness Directives (AD), Supplemental Type Certificates (STC), Maintenance Manuals, and ACs. Conduct Precertification Inspections. If possible, visit the proposed organization before a formal application is filed. Inspect and make necessary recommendations regarding the following: Classrooms, Work areas, Materials, Laboratories, Technical data, Instructional aids, Other areas as needed. 3. FORMAL APPLICATION PHASE The formal application phase requires a formal application meeting to present the required certification documents and discuss those issues relevant to the particular application. a. Schedule and Conduct Formal Application Meeting. The CPM meets with the official(s) representing the organization. Review the submitted formal application and documents, including the SOE. Determine whether the applicant has submitted all documents, and if they are complete. b. Review the Document. If all documents are complete, review DAAO Form No , the compliance statement, the curriculum, standards for graduation, attendance and makeup procedures, grading procedures, facility layout, and the instructor qualifications for conformity to the regulations. NOTE: If discrepancies exist in the documents, return the documents to the applicant with a letter identifying the discrepancies. It should be clearly explained to the applicant the need to correct the document deficiencies in a timely manner to facilitate continuance of the certification process. NOTE: 1) Statement of Compliance (SOC). To benefit the applicant, development of a compliance statement assists in the certification process by showing in writing how the applicant intends to meet the requirements of each section of the part 147 rule. The compliance statement must list each applicable part 147 section and provide a brief narrative or a specific reference to a 12

18 manual or other document describing the planned method of compliance with the regulation. 2) Curriculum. For guidance on curriculum requirements see Chapter III. a) Practical projects referring to section (d) include all functions specified in the curriculum that involve hands-on tasks. Therefore, practical projects should include any task taught to Level 2 or 3, as specified in Advisory Circular and aircraft type rating practical projects as specified in Advisory Circular b) Section addresses the maintenance of curriculum requirements. CASR 147 prescribes minimum standards for certification and operation. These standards may be exceeded beyond what the rule requires, but only as part of an approved curriculum. 3) List of Instructors and Qualifications. The certificate number, license number, ratings, and subjects must be listed for each instructor. There must be at least 1 certificated or licensed instructor for every 25 students in each shop or laboratory class. Evaluate the suitability of non-certificated or licensed instructors to teach certain general courses on an individual basis. 4) Student Enrollment Statement. This statement indicates the maximum number of students to be taught for each rating during each enrollment period. Do not count students enrolled in other non-dgca-approved courses toward the maximum allowable part 147 enrollment. NOTE: Non-DGCA-approved courses may not detract from the part 147 organizations ability to provide for a quality education (due to facility overcrowding, equipment over use, etc.). PTIs must be cognizant of the effect non-dgca-approved courses may pose. 5) Diagram and Description of Facilities. This description must include a facility layout plan indicating the relative location of classrooms to shops/laboratories, including dimensions, and the relative location of each facility to each other facility when there is more than one site or location for the organization. 6) Inventory of Equipment, Materials, and Tools. The inventory must detail which tools the organization will provide and which tools the students must furnish. 7) Accept or Deny Formal Application. Acceptance or denial of the formal application is based on inclusion of all required materials as detailed in the pre-application meeting. The proposed methods of compliance are not being evaluated at this stage. Based on the initial review of the formal application and any meetings with the applicant, accept or deny the application. Advise the applicant in writing of the results. If the application is denied, return the application and attachments with a letter stating the reasons for denial. 13

19 4. DOCUMENT COMPLIANCE PHASE Review Documents. Thoroughly review the applicant s curriculum and other documents to ensure that each complies with the applicable regulations. Approve, accept, or deny each document as appropriate. Documents reviewed during this phase must include: 1) DAAO Form No ) Statement of Compliance (SOC). 3) Curriculum (refer to section and Chapter III of this Staff Instruction). 4) Instructor requirements and qualifications (refer to section ). 5) Contract agreement for facilities or instructional equipment (if any) 6) Training procedures manual (refer to section and Chapter V of this Staff Instructions) Document Deficiencies. If you find deficiencies in any document submitted by the applicant, return the document with a letter identifying the deficiency. NOTE: The certification team must be ready to offer suggestions, but not mandate how to improve the product but should avoid writing the applicant s documents. If Necessary, Terminate the Certification Process. If the documents submitted are consistently found to be of insufficient quality, schedule a meeting with the applicant to discuss each deficiency in detail. Advise the applicant that continuing the certification process is impractical and the option for the applicant to reapply for certification. 5. DEMONSTRATION AND INSPECTION PHASE In this phase, the certification team makes an onsite inspection to determine whether the applicant s proposed procedures and programs are effective. At this time, the applicant demonstrates that the facilities and equipment are safe and satisfactory. Emphasis is on compliance with the regulations. Throughout the demonstration and inspection phase, the CPM must ensure that each aspect of the applicant s required demonstration is first documented, then observed, and then either approved or disapproved. Evaluate Suitability of Facilities, Equipment, Tools, and Materials. 1) Facilities. The instructional aids, laboratory and shop equipment, and physical layout of the facilities must meet the requirements outlined in sections , , and The applicant should keep in mind that the facilities must constitute an environment suitable for learning. Excessive noise, dust, fumes, heat, cold, and clutter could distract the applicant during development of the AMTO facility. The ratings that the organization proposes to obtain will influence the layout of the AMTO facility. 2) Equipment. An AMTO is required to have sufficient shop equipment in place and in satisfactory operating condition to adequately serve the 14

20 student enrollment and meet shop/project subject requirements. The equipment must be situated so students can operate it in a safe and efficient manner. 3) Tools. The AMTO must provide an inventory of special tools required to provide instruction. All special tools must be in satisfactory working condition for the purpose for which they are to be used. Section requires the AMTO to furnish an adequate supply of special tools appropriate to the ratings and curriculum of the AMTO. 4) Materials. The AMTO must provide a list of materials required for instruction. The organization must have sufficient materials in stock and properly stored to provide for the approved student enrollment. 5) Quantities of Necessary Items. The amount of materials and the kinds of equipment and tools students will use also depends on the curriculum and number of students. For example, the applicant must demonstrate that the organization has the appropriate tools and equipment to accomplish each project. Observe Demonstrations and Conduct Inspections. Verify that the applicant s proposed procedures and programs are effective, and that facilities and equipment are safe and satisfactory. Follow the procedures in Chapter IV. Verify compliance with the regulations as follows: Facilities meet the requirements of section ; Instructional aids meet the requirements of section ; and Materials, special tools, and shop equipment meet the requirements of section Document Deficiencies. If deficiencies exist, provide a list of discrepancies to the applicant. Schedule a meeting to discuss in detail the appropriate corrective action to be taken. Place documentation in the certification file. If the applicant does not demonstrate compliance or if discrepancies cannot be resolved, send a letter of denial and a list of discrepancies. Inform the applicant that the CPM must be notified in writing of all corrective action taken. 6. CERTIFICATION PHASE An applicant is entitled to the issuance of an Aircraft Maintenance Training Organization Certificate with appropriate rating(s) and OpSpecs after accomplishing the following: 1) The certification process is completed; 2) Each unsatisfactory item has been corrected; 3) The DGCA has determined that the applicant has met all regulatory requirements and understands the related responsibilities; 4) The DGCA has determined that the applicant is capable of complying with CASR 147 on a continuing basis; and 5) The applicant has demonstrated capability of conducting operations in a safe manner. Issue Certificate. When the applicant has met all regulatory requirements, the CPM will accomplish the following: 15

21 1) Ensure all deficiencies have been documented and addressed. 2) Ensure all items in the CPM file are closed and satisfactory. 3) Review SOE for completeness. 4) Approve the curriculum and accept Training Procedures Manual (TPM) by signing and dating the List of Effective Pages (LEP) and prepare letter of approval and control page for curriculum and TPM indicating the date and revision status. 5) Obtain a final certificate number from Sub Directorate of Standard and prepare DAAO Form No , Certificate of Approval of AMTO Part 147. Ensure that the certificate is signed and give the original certificate to the new certificate holder. Make a copy for the certification file. 6) Prepare (as applicable) part 147 AMTO OpSpecs (DAAO Form No ): A001, Issuance and Applicability (mandatory). A002, Ratings (mandatory). A003, Management Personnel (mandatory). A004, Examining Authority (optional). CPM Drafts and Director Signs Certificate Approval and OpSpecs. The Certificate of Approval and Operation Specification (OpSpec) will be drafted by CPM and signed by Director of Airworthiness and Aircraft Operations showing the limitations issued. Issue all mandatory and any applicable optional DGCA OpSpecs with appropriate ratings. NOTE: The Certificate of Approval and OpSpecs are legal documents. Language should clearly specify the authorizations, ratings, and/or limitations being approved. When filling out these forms, erasures, strikeovers, or typographical errors must not exist on the completed document. Prepare Certification File. Once the applicant receives AMTO certification, prepare a part 147 Certification file to be kept at the DAAO for documented future review of the complete certification process. The file must include the name and title of each Maintenance Inspector who assisted in the certification. The CPM signs the file. The file must contain at least the following: DAAO Form No ; Statement of Compliance (SOC); Applicant s SOE; The Certification Job Aid; Complete inspection check list; Copy of the signed Certificate of Approval, DAAO Form No ; Copy of the OpSpecs issued to the AMTO (DAAO Form No ); List of the instructors, their qualifications, and the courses they will be teaching; Facility layout; Copy letter of approval curriculum and TPM; Copy of the approved curriculum (soft copy); Copy of training procedures manual (soft copy); and Summary of all discrepancies encountered during certification. 16

22 7. APPLICABLE FORMS No Form Number Form Title 1. DAAO Form No Application For Aircraft Maintenance Training Organization 2. DAAO Form No Certificate of Approval - Aircraft Maintenance Training Organization 3. DAAO Form No Operation Specifications (Opspec) - Aircraft Maintenance Training Organization 4. DAAO Form No A Certification Job Aids Pre Application Phase 5. DAAO Form No B Certification Job Aids Formal Application Phase 6. DAAO Form No C Certification Job Aids Document Compliance Phase 7. DAAO Form No D Certification Job Aids Demonstration and Inspection Phase 8. DAAO Form No E Certification Job Aids Certification Phase 9. DAAO Form No Evaluation of Training Procedure Manual and Quality System 10. DAAO Form No Curriculum and Syllabus Evaluation 11. DAAO Form No Training Facility Inspection 12. DAAO Form No Instructor Qualification Evaluation 13. DAAO Form No Reference Material Inspection 14. DAAO Form No Part 147 AMTO Certification Checklist: Preliminary Assessment 17

23 CHAPTER III. EVALUATE CURRICULLUM/REVISION AND INSTRUCTOR QUALIFICATIONS 1. GENERAL A. Hours of Instruction 1) Minimum Hours Instruction Specified by section The number of hours of instruction offered by a curriculum must be at least the minimum specified by section The training organization may offer more hours of instruction; however, regardless of the number of hours offered, the DGCA must approve the entire AMTO curriculum at the time of initial certification or any subsequent revisions to the curriculum as requested by the AMTO. 2) Deviations to the Curriculum. The following blocks of time are not to be included in calculating the minimum number of instructional hours specified in section : Time spent in taking the DGCA knowledge test; and Specific DGCA test-prep courses. B. Order of Instruction. The curriculum must describe the order of course progression for each rating offered. For example, basic electricity would be a prerequisite for Aircraft Electrical Systems. The order of instruction or prerequisites must be identified and evaluated by the DGCA during the curriculum approval process during initial certification and during review of subsequent curriculum revisions. 1) Interruption in the Order of Instruction (Curriculum). Interruptions causing deviations from the approved course curriculum (however frequent) must be reported by the AMTO to the principal training inspector (PTI). Reporting of an interruption in the order of instruction allows for discretionary surveillance by the PTI. Allowances to deviate from the approved curriculum order of instruction may be permitted on a case-by-case basis (inoperative mockups, hospitalized instructor, etc.) in accordance with procedures described in the curriculum and/or the training organization s operating procedures. 2) Revisions to the Curriculum. Deviations that are deemed to be continuous, on-going will necessitate a revision to the curriculum and subsequent DGCA approval. The assigned PTI will monitor all interruptions in the order of instruction to ensure that these interruptions do not detract from the quality of instruction. Prolonged or extended continuous interruptions in the order of instruction may require DGCA approval by the appropriate DGCA. NOTE: The DGCA does not consider student-induced interruptions in training due to absence (illness, financial problems, vacation, etc.) as a change in the order of instruction. These types of interruptions may require makeup provisions covering the missed subject matter. 18

24 C. Subjects Prescribed by Part 147 & 65. The curriculum must cover the subjects and items prescribed in section , and part 65 appendices A or B, as applicable. 1) Subjects that are submitted for approval as part of the curriculum will not be made part of the curriculum until approved by the DGCA. 2) Additional subjects/courses that are required by the training organization for their purposes (i.e., degree programs) must not be submitted as part of the DGCA-approved curriculum. 3) A distinction must be made between additional courses/subjects that are part of the approved curriculum under part 147, and those that are not. 4) The teaching of additional subject material beyond the requirements of part 147 & 65 will require additional instruction hours beyond those required by section ) The teaching of subject items beyond the requirements of part 147 & 65 will not require additional instructional hours beyond those required by section D. Practical Application Projects 1) The curriculum must list the practical projects that must be completed for each subject item. There must be sufficient practical projects to address the requirements of part 147 and part 65 appendices A or B, as applicable. The curriculum must include enough detail to evaluate the practical projects for correct teaching level, for equipment and tools needed, and for performance standards and objective grading criteria. 2) The curriculum must show an appropriate amount of time for each subject area, Maintenance Inspector who have oversight for the operation of, an AMTO will review and monitor curriculums to ensure they do not provide insufficient or excessive time allotments based on criteria associated with the rule. 3) The curriculum must provide that each task in each subject item is accomplished. For example, if a project requires that the student inspect and repair to accomplish a practical project, a requirement for both inspection and repair must be included in the project plan. 4) The Maintenance Inspector should ensure that instructional hours for each subject are distributed in a manner which allows both adequate theory instruction (Levels 1, 2, and 3) and sufficient lab/shop, instruction equipment (Levels 2 and 3) to obtain the required practical application (teaching level) for the item being taught. E. Scheduling of Tests. Upon completion of each curriculum subject, a test must be scheduled. Additional tests and quizzes may be administered during the subject being taught. F. Grading Criteria. An accepted academic standard for passing (including the DGCA written exams) is a minimum of 70 percent. However, the training organization may require a higher minimum passing grade. All theoretical and practical portions of each subject listed in the curriculum must be passed to the approved grading standard. Each practical project must be passed to the approved standard. 19

25 G. Revisions to the Curriculum. Changes to the approved curriculum must be approved before implementation. Changes in the curriculum may include changes in any of the following: Hours of instruction; Testing; Training subject; Required practical projects with corresponding lab or shop hours Teaching level H. Instructure Requirements. 1) An instructor must hold an DGCA Certificate/License with category/ratings appropriate to the subjects that the instructor teaches, and comply with section ) Individuals listed as instructors, lab assistants, or teaching assistants should also hold appropriate Certificate/License with category/ratings appropriate. However, the AMTO may provide specialized instructors who are not Certificate/License to teach mathematics, physics, basic electricity, basic hydraulics, drawing, and similar subjects. I. Student/Teacher Ratios. Section requires at least 1 instructor for each 25 students in each shop or laboratory class. NOTE: The PTI should monitor the student/teacher ratios and alert the training organization when the ratios have/will exceed the limitations set forth by section The training organization has the option to add another instructor(s) on a temporary or permanent basis depending on the staffing needs at the time. This will assure the student/teacher ratio of no more than 25 will be maintained continuously. Under certain circumstances, the AMTO has the option to apply for an exemption to the rule. J. Performance. The PTI should encourage the training organization to provide for regular assessment of instructor performance. K. Reference Material. The training organization may provide the training manual or handout to student containing all subject to be taught, and technical publication to support the training enrollment. 2. PROCEDURES A. Review the Curriculum. For an initial certification, thoroughly analyze the curriculum before the date of the team inspection. Ensure the following: The number of hours meets the requirements of section ; The curriculum fulfills the requirements of part 147 and part 65 appendices A or B; Instructor qualifications match the subjects being taught; All subjects taught to Level 2 or 3 involve some practical hands-on projects or skill demonstration; 20