EASA User Guides UG.CAO.00126-003 & UG.CAO.00121-004 specifically deal with the needs of the Certifying Staff.

We are considering the person/persons who sign the EASA Form 1 on behalf of the organisation (having satisfied themselves that all elements of the rectification have been accomplished correctly in accordance with approved data, using approved material facilities, tools & equipment)

Many organisations employ a QC department which manages the final acceptance & release of components. It is required for them to demonstrate receipt of regulatory training which is organisationally acceptable as compliant with Part 66 Module 9 & 10.

Considering the Role of Module 9 within the EASA Part 145 Organisation

Part 66 module 9 is only relevant to Part 66 Licensed aircraft engineers & is not relevant to EASA Part 145 or Third Country EASA 145 organisations. Consider that a licensed engineer who has completed Module 9 in accordance with Part 66 will still have to complete organisational Human Factor Training to comply with GM 1 145.A.30(e)

Part 66 Human Factors is focused on theory. Part 145 Human Factors is focused on the practical & organisational aspects of Human Factors.

Considering the Role of Module 10 within the EASA Part 145 Organisation

The focus of Part 66 Module 10 is specifically aimed at the needs of the Part 66 licensed engineer.

For example, Part 66 Module 10 requires:

A general understanding of Part-21 & EASA certification specifications CS-23, 25, 27, 29 & a detailed understanding of Part-66.

145 requires that the organisation manages the competence of employees in respect of the job function regarding regulations whose focus is on Knowledge of Part-M, Part-145 & any other relevant regulations.

Consider the organisation competence expectation, for example, that a Maintenance Planner would have a more detailed understanding of Part 21 & Supplemental Type Certificates STC’s than the required for Part 66 engineer & the need for detailed awareness of Part 66 may not be necessary.

Final Comments

The Management of Internal Training Standard is responsibility of the Quality Manager & organisational competence is of critical importance.

Consideration needs to be given to managing training in Human Factors, Organisational Procedures, EASA Regulations, Electrical Wiring Interconnect Systems & Fuel Tank Safety to an organisation standard which meets the needs & objectives of the organisation & of course demonstrates compliance with all applicable regulatory requirements.

Note: Part 66 Module 9 & 10 is not directly relevant to a 145 organisation's training needs.

Reality Check: It's necessary for regulatory auditors to be guardians of the standards & it's important that industry isn't misinformed in any way regarding obligations & responsibilities.

It's important that Industry focuses on compliance with the regulations as minimum compliance – means compliance with the regulations should always be a step on the journey and not the journey.

What’s on offer for 3rd Country EASA Part 145 Approval Holders?

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