Considering the Different FAA & EASA Approach to 3rd Country Certification

Considerations from SofemaOnline (www.sofemaonline.com) (Reference also AC 145-10 - Repair Station Training Program)

Introduction

Whilst EASA facilitates the development of 147 Organisation Approval in Non-EU Countries, the FAA does not certificate part 147 AMTSs outside of the U.S.

Aircraft Maintenance Technician Schools (AMTS)

An AMTS is an educational facility certificated by the FAA to train prospective aircraft mechanics for careers in the airline industry, in aviation maintenance facilities, and in commercial and General Aviation (GA). 14 CFR part 147 specifies requirements for the certification and operation of an AMTS. The regulation includes both the curriculum requirements and the operating rules for all certificated AMTSs. The knowledge, skills, and abilities required of mechanics are considerable and demand high-quality training. Therefore, the FAA requires high standards from the AMTS.

An AMTS may be FAA-certificated for the following ratings:

Airframe
Powerplant
Airframe and Powerplant (A&P)

A certificated AMTS is issued an Air Agency certificate as well as Operations Specifications (OpSpecs) which are legal documents by which the FAA authorizes the AMTS to operate and describes the schools’ operational requirements, conditions, and limitations.

Each authorizing document forms a legal contract between the FAA and the certificate holder.

There are 5 phases in the certification process, beginning with pre-application and ending with certificate issuance. Advisory Circular (AC) 147-3B and the Flight Standards Information Management System (FSIMS) (applicable chapter reference below) contain detailed descriptions of the applicant requirements in each phase. 

Phase 1 - Pre-application

In this phase, applicants conduct an initial inquiry by first educating themselves on part 147 requirements, and then contacting their local FAA office and advising of their intent to pursue part 147 AMTS certification. The AMTS applicant must submit a completed FAA form 8400-6, Pre-Application Statement of Intent to start the certification process. The FAA will arrange for a pre-application meeting with the applicant once it has the necessary resources to proceed with the certification. 

Phase 2 - Formal Application

In this phase, the applicant meets with the FAA for a formal application meeting and submits all required documents for the application.

Phase 3 - Document Compliance

In this phase, the FAA reviews the submitted certification documents to ensure compliance with part 147 requirements. If deficiencies are found in the curriculum or in any other pre-application documents, the FAA will return these documents to the applicant with a letter outlining the deficient areas.

Phase 4 - Demonstration and Inspection

In this phase, the FAA will arrange with the applicant to inspect the facility.

At this point, the FAA expects the AMTS facility to be complete with all the shop equipment, instructional aids, instructional aircraft, special tools, and other required laboratory or shop installations in place. 

During the inspection, the FAA inspectors will carefully examine the facilities and equipment to ensure that procedures, programs, facilities, and equipment meet FAA requirements and are safe and sufficient for the training program in the shop to be effective. 

Phase 5 - Certification

When all the regulatory requirements have been met, the school will be issued an AMTS Air Agency certificate and appropriate Operations Specifications. 

EASA Part 147 Maintenance Training Organisation Approval (MTOA)

EASA permits foreign (Non-European Countries) to hold EASA Part 147 Approval. EASA Part 147 deals with the standards which shall be followed by the various training organisations which hold or seek to hold approval. EASA Part 147 describes all the requirements that an organisation must meet to become one of the approved training organisations. 

The Regulatory Control document is the Maintenance Training Organisation Exposition (MTOE) which defines the organisation and procedures upon which the EASA Part 147 Organisation approval is based.

The MTOE must be constructed in such a way that through the document the organisation is able to demonstrate full compliance with all regulatory requirements.
 
Consider that the purpose of the MTOE is actually two-fold:

a) To demonstrate full compliance with the regulatory environment
b) To describe the most efficient process to enable the organisation to operate in an effective way

Also to consider that the Accountable Manager is responsible for the overall operation of the Maintenance Training Organisation and considering he has the necessary power to maintain adequate facilities, equipment, materials, technical data, and qualified personnel as necessary, pertinent to the operation of the Maintenance Training Organisation. It is important that the contents of the MTOE are fully understood and accepted by the AM 

Further Information

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