Guidance for Part 147 approval holders

This guidance material is intended to assist existing approved organisations under Part 147 who wish to incorporate new technologies and training methods for delivery of their approved courses. It defines the Civil Aviations Authority's (CAA) expectations on how to meet the existing requirements of their training approval using revised training methodologies.

Purpose

The purpose of this guidance material is to specify the extent of training permitted under these methodologies, the scope of that training delivery, the responsibilities of the approved organisations and the CAA, the additional requirements of the training provider prior to and during training, procedural changes introduced by this methodology, performance measures and record keeping.

Please note this information only applies to UK CAA approved Part 147 Maintenance Training Organisations who have already exercised the full scope of their approval.

It is not the intention to issue an Online training approval to organisations who have not yet exercised the privileges of their approval. This also applies to new organisations awaiting approval by the UK CAA.

Responsibilities

Approved Part-147 training providers, who have already exercised their approval, that is delivered training courses within a classroom environment, will be required to submit details of proposed changes to existing training methods and technologies to the CAA in the form of a revised Maintenance Training Organisation Exposition (MTOE) and supporting procedures. This should be supported by appropriate documentation, training material, MTOE revision and so on and a satisfactory compliance report endorsed by the organisation's Quality Department.

The CAA will review the submitted application and supporting data to establish that the proposed training complies with Appendix III to UK Part-66. This will include an on-site visit and / or a demonstration of the revised training methods and technologies.

When satisfied with the proposed changes to the training organisation's processes, procedures and training methodologies, the CAA will approve the change by approval of the revised MTOE and supporting data as appropriate. If the proposed change includes new aircraft type or basic training, then this will require a change to an existing Part 147 organisations approval document in accordance with 147.A.50 and current approved procedures.

Scope

The UK CAA implements the following restrictions as applicable to web based remote training processes as follows:

• Use of web-based training is limited to Theory courses only.
• Basic training, (including modules only) and Type training examinations shall not to be carried out using these methods.
• No change to an organisations current approved methodology regarding Practical Training or Aircraft Visits is permitted under this Guidance Material.
• Training must not be asynchronous and must be interactive.
• These training methods are initially envisaged for organisations to make training delivery changes to existing approved courses or modules; however, the regulation does not restrict organisations applying for a change to their training methods.

Procedure

When submitting a proposed change to an organisations approval to incorporate revised training technologies and methods as detailed in:

Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Annex IV (Part-147) to UK Regulation (EU) No 1321/2014.

The following should be considered and addressed by the organisation making the application:

• Verification that access to each training course for the CAA has been established before its delivery.
• Satisfactory demonstration of training staff competence to use web-based applications, in other words, Skype, WebEx, ZOOM, MS Teams or specific VR Software and so on.
• The receiving student should have the means of a robust computer / network systems to receive information and communicate with the instructor.
• The student is to be in an area that is conducive to receiving such online training where he or she will not be disturbed or interrupted during the process. Please note it is the responsibility of the Training organisation to be satisfied that this condition remains in place during the training session.
• Satisfactory training material delivery to students.
• Students having access to appropriate technology to ensure interaction with instructor.
• Validation of student attendance; ability to understand, read and write in English; identity verification.
• Maximum student capacity (20). Note: it is expected that the maintenance training organisation to determine the best number of students per session.
• Maximum number of training hours per day (6) with defined and regular break periods. Note: Feedback received thus far indicates that a reduced training day of 4 to 5 hours is more practical for instructors and delegates.
• Student / Instructor interaction including verification of student understanding and engagement including component demonstrations where required and appropriate.
• Organisation's Quality System's oversight including compliance verification.
• Potential time zone differences between students and instructors including Human Factors issues considerations.
• Instructional environment, in other words, training delivery will normally only be from approved facilities. However, if instructors are delivering training from their homes, this will require the organisation to conduct its own audit of the instructors and submit a remote site application.
• Approval will normally be granted after satisfactory demonstration to the CAA.
• If training is proposed subsequently (after initial approval of web-based training) from a remote site, the normal remote site approval will be required.
• Organisation's quality and compliance system is required to demonstrate initial and continuing oversight of these systems.

Performance

Performance measures will be monitored by the CAA standard oversight procedures including reviews of the organisation's compliance systems.

The training organisation is to enhance and record the quality audit programme during the initial phases of the Online training activity.

Records

Records of the organisation's approvals, MTOE, TNA(s) SF and so on, will be maintained by the CAA in accordance with current procedures.

Organisations will be required to maintain sufficient & adequate records of training delivery, student attendance, engagement; hours of tuition per day etc in accordance with current approved procedures.



• Regulation (EU) No 1321/2014 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018
• UK Regulations
• The Air Navigation Order 2016 (ANO) and Regulations
• Mandatory Requirements for Airworthiness (CAP 747)

• Civil Aircraft Airworthiness Information and Procedures (CAAIP) (CAP 562).
• On the job training (OJT) for first type rating recommendation within a Part 145 (CAP 1530).
• Aircraft ratings are defined as per UK Part-66 Type Rating list (SRG1782).
• Aircraft Maintenance Incident Analysis provides information on the common causes where maintenance error has been a contributory factor in incidents and occurrences reported to the Civil Aviation Authority (CAA).
• The Confidential Human Factors Incident Reporting Programme (CHIRP).
• Rotorcraft - Critical Parts Awareness and Training.

• Regulation (EU) No 1321/2014 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018
• UK Regulations
• The Air Navigation Order 2016 (ANO) and regulations
• Aircraft maintenance incidence analysis 
• CAA policy on fitness of character
• UK CAA Interpretation of Principal Place of Business
• List of Approved Organisations
• The Confidential Human Factors Incident Reporting Programme (CHIRP)