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8900.1 CHG 494

VOLUME 3  General technical administration

CHAPTER 24  Evaluate 14 cfr parts 91 subpart k/121/135.411(a)(2) maintenance training program record

Section 2  Safety Assurance System: Evaluate and Accept a Maintenance Human Factors Training Program

3-1903    REPORTING SYSTEM(S).

A.    Program Tracking and Reporting Subsystem (PTRS). For Title 14 of the Code of Federal Regulations (14 CFR) part 91 subpart K (91K), use activity codes 4306, 4307, 6306, and 6307.

B.    Safety Assurance System (SAS). For 14 CFR parts 121/135, use SAS automation. This section is related to SAS Element 4.1.3 (AW), Maintenance/Required Inspection Item (RII) Training Program.

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3-1904    OBJECTIVE. This section provides guidance for evaluation and acceptance of human factors training programs. Inspectors may also use this guidance for acceptance of human factors training programs for both the Aviation Maintenance Technician (AMT) awards and Inspection Authorization (IA) renewals.

3-1905    GENERAL.

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A.    Human Factors. Human factors is anything that affects human performance. More formally, human factors entails a multidisciplinary effort to generate and compile information about human capabilities and limitations, and apply that information to equipment, systems, facilities, procedures, jobs, environments, training, staffing, and personnel management for safe, comfortable, and effective human performance.

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B.    Effective Training. Effective training is the basis for a successful maintenance and inspection program. Although many procedures for maintaining and inspecting aircraft may be similar, the equipment, procedures, and task documentation vary widely depending on the operator/applicant’s specific program. Human factors training plays an essential part in identifying the differing areas between specific programs and is the most efficient manner of educating maintenance technicians and others of the importance of good human factors principles, practices, and techniques.

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C.    Human Factors Training Programs. Numerous airlines, repair stations, and training organizations now provide human factors training and seek Federal Aviation Administration (FAA) recognition of their training programs. This section provides guidance for acceptance of these vital human factors training programs.

D.    AMT Awards Program. In October 1991, the Aircraft Maintenance Division (AFS-300) determined a need for an incentive program to encourage training recognition for AMT employees and employers. Human factors training is now an acceptable portion of the training for the AMT Awards Program.

3-1906    DISCUSSION.

A.    Human Factors Issues. Human factors issues contribute to approximately 80 percent of all aviation accidents and incidents. Factors that influence the human must be recognized, identified, and communicated. Maintenance procedures and controls can then be used to reduce or prevent outside influences that cause performance mistakes. Research and experience have shown that human factors training can address many of the issues that contribute to these maintenance events. Attention to maintenance human factors can raise efficiency, effectiveness, and safety in aviation environments. This translates to better expense control and long-term safety benefits.

B.    Maintenance Human Factors Training. Maintenance human factors training is part of a total system in managing human error. It is an essential part of a system aimed at individuals engaged in hands‑on maintenance, and those who supervise and plan maintenance activity. Human factors training should cover the basic safety principles and practices integrated within a maintenance organization’s program.

C.    Objective. The objective of human factors training is to provide principles and techniques that will help operators do a better job by:

    Improving safety,

    Decreasing organizational exposure to risk,

    Reducing and capturing errors,

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    Ensuring worker health and safety,

    Improving operational efficiency, and

    Encouraging employees to report safety issues and concerns without fear of retribution.

NOTE:  These objectives contribute to the FAA’s safety goal of achieving the lowest possible accident rate and continuously improving safety.

D.    Designing Human Factors Training. Designing human factors training for specific organizations is often most effective when considering such factors as:

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    Physical, psychological, and other characteristics of the people in the work force;

    Physical and social conditions of the work environment;

    Type of work being performed, like heavy maintenance, light maintenance, aircraft line maintenance, and aircraft size and type; and

    Resources necessary to complete the work safely and efficiently.

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E.    Initial/General Human Factors Training. For initial or general human factors training, it may not be necessary for an operator to conduct an extensive job and task analysis, but to merely understand the most important safety concerns within its organization. There are many fundamental principles of human factors that apply to all maintenance work. Detailed task analysis and understanding of maintenance human factors is widely available at the FAA Human Factors in Aviation Maintenance website and elsewhere.

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F.    Proposed Training Plans. The aviation safety inspector (ASI) should review proposed human factors training to ensure its focus on “real-world” human factors challenges. Proposed training plans that lack sound fundamentals or examples of real-world aviation maintenance challenges are likely not as acceptable or desirable for aviation maintenance human factors training.

G.    Design of Human Factors Training. The design and delivery of repeated, recurrent, or continued human factors training within a specific organization should have as its basis company-specific examples derived from its event investigation system data. AMTs learn best from specific examples within their own organization.

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H.    Commercial Multimedia Human Factors Training Products. A number of commercial multimedia human factors training products should receive consideration for an accepted or approved training program. However, these products are best when reinforced by a competent human factors instructor. The ASI should review all media and movies included in the application package.

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I.    Aviation Maintenance/Human Factors Discipline. The instructor should have capabilities and experience related to aviation maintenance and/or the human factors discipline that a reasonable person would accept as credible. The instructor should have effective communication skills and the ability to convey his or her credibility to the majority of the students or course participants. An acceptable course leader’s most highly preferred attribute is knowledge and experience in aviation maintenance.

3-1907    CONSIDERATIONS FOR ACCEPTABLE CONTENT.

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A.    Acceptable Topics. An unlimited number of human performance topics are acceptable for all types of human factors training. Review and acceptability of the content should be guided by this document and references herein. The ASI should consider the size of an organization and the work it performs when reviewing an organization’s human factors training program.

B.    Key Topics in a Good Human Factors Training Program. The FAA’s maintenance human factors experts along with other regulatory agencies, including the European Aviation Safety Agency (EASA) and Transport Canada (TC), have identified the following key topics that a good human factors training program is likely to include:

1)    A general introduction to human factors.
2)    Safety culture/organizational factors.
3)    Human error (i.e., error principles, event investigation, and case studies).
4)    Human performance and limitations.
5)    Environments, both physical and social.
6)    Organizational procedures, information, tools, and proper task documentation and sign‑off practices.
7)    Planning of tasks, equipment, and spares.
8)    Communication and the lack thereof.
9)    Teamwork and leadership.
10)    Professionalism and integrity.
11)    Shift and task turnover.
12)    Undocumented maintenance.
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13)    The “Dirty Dozen”, to include:
a)    Complacency.
b)    Lack of knowledge.
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c)    Lack of communication.
d)    Lack of teamwork.
e)    Distraction.
f)    Lack of resources.
g)    Pressures.
h)    Lack of assertiveness.
i)    Norms.
j)    Stress.
k)    Lack of awareness.
l)    Fatigue management/fitness for duty.
14)    Procedural noncompliance.
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15)    Voluntary reporting and just culture.
16)    Risk-based decisionmaking and risk assessment.
17)    FAA Compliance Philosophy.

C.    Supportive Content. The ASI should consider content not included in subparagraph 3-1907B if it directly relates to a case study or other scenarios that support human factors initiatives.

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3-1908    HOURS OF HUMAN FACTORS TRAINING CREDIT. A formal block of human factors training lasting at least 50 minutes constitutes 1 hour of training. For the AMT awards program, refer to the current edition of Advisory Circular (AC) 65-25, William (Bill) O’Brien Aviation Maintenance Technician Awards Program, for details on the acceptable amount of hours in human factors training for credit. The FAA will also accept up to 6 hours of human factors training towards IA renewal.

3-1909    APPLICATION PROCESS.

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A.    Course Review. For review of a human factors training program, an applicant should either contact the FAA office in person, make arrangements to have a meeting, or submit a letter of request for course review to the local FAA office. The applicant should provide all material used for the training to the FAA to ensure proper course review.

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B.    Non-U.S. Organizations’ Courses. Non-U.S. organizations also provide training in areas required by their aviation authority that may crossover to required training such as human factors. These courses may be found acceptable using this guidance, but exercise caution during the review process to ensure they do not embed foreign aviation authority regulations, which could confuse technicians on FAA regulatory and nonregulatory requirements. The foreign applicant should contact its closest regional FAA office for further assistance.

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3-1910    RECONSIDERATIONS.

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A.    Notification of Unacceptability. If the FAA determines that a course is unacceptable, it will notify the training provider in writing and explain why. It is highly recommended that the training provider work closely with the FAA office to understand why the training program was unsatisfactory and to remedy the training deficiencies as soon as possible.

B.    Reconsideration Request. If the training provider does not agree with the reviewing office regarding the nonacceptance, the training provider may request reconsideration of the decision by writing to:

FAA Headquarters,

Aircraft Maintenance Division, AFS-300,

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950 L’Enfant Plaza North SW, 5th Floor,

Washington, DC 20024

Phone: 202-267-1675

Fax: 202-267-1812

Email: 9-AWA-AFS-300-maintenance@faa.gov

C.    Final Decision. AFS-300 will make the final decision on the request for reconsideration. AFS‑300 will directly forward the decision to the training provider with a copy to the associated FAA office. The AFS‑300 decision may affirm, modify, or reverse the initial decision.

3-1911    RELATED REGULATORY AND CONTENT GUIDANCE. For more information, consult the following documents (current editions):

A.    Title 14 CFR Part 1. Part 1, Definitions and Abbreviations.

B.    Title 14 CFR Part 43. Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration.

C.    AC 120-16. AC 120-16, Air Carrier Maintenance Programs, which describes air carrier aircraft maintenance programs. It explains the background as well as the FAA regulatory requirements for these programs.

D.    AC 120-66. AC 120-66, Aviation Safety Action Program (ASAP), which provides information encouraging air carrier and repair station employees to voluntarily report critical safety information.

E.    AC 120-72. AC 120-72, Maintenance Resource Management Training, which presents guidelines for developing, implementing, reinforcing, and assessing maintenance resource management training programs for improving communication, effectiveness, and safety in maintenance operations. This AC also provides a training template.

F.    AC 120-78. AC 120-78, Acceptance and Use of Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals, which provides information on electronic recordkeeping.

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G.    AC 120-79. AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System, which provides information on how to implement a Continuing Analysis and Surveillance System (CASS) that part 121 requires for air carriers, and that part 135 requires for air carriers with “10 or More.”

H.    AC 120-92. AC 120-92, Safety Management Systems for Aviation Service Providers, which provides information on how to develop a Safety Management System (SMS).

I.    Volume 3, Chapter 24, Section 1. Volume 3, Chapter 24, Section 1, Safety Assurance System: Training Program Evaluation, which provides guidance for evaluating and accepting an operator/applicant’s maintenance/inspection training program.

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J.    FAA Operator’s Manual for Human Factors in Aviation Maintenance. The FAA Operator’s Manual for Human Factors in Aviation Maintenance, which provides information on how to implement a human factors program in maintenance. The manual is available at www.humanfactorsinfo.com.

K.    Further Information. You can obtain further information regarding the 12 common causes of maintenance human factor errors (included in paragraph 3-1907) from the TC link below: http://www.tc.gc.ca/eng/civilaviation/standards/systemsafety-posters-menu-723.htm. Additionally, many aviation training and consulting organizations provide excellent information regarding the “dirty dozen,” which you can easily reference using the Web.

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L.    Human Factors in Aviation Maintenance Website. The FAA Human Factors in Aviation Maintenance is available at www.humanfactorsinfo.com.

3-1912    PREREQUISITES AND COORDINATION REQUIREMENTS.

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A.    Prerequisites. Knowledge of the regulatory requirements of 14 CFR parts 43, 65, 121, and 135, or part 91K.

B.    Coordination. This task may require coordination with other Flight Standards District Offices (FSDO), certificate management offices (CMO), and International Field Offices (IFO).

3-1913    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    AC 65-25, William (Bill) O’Brien Aviation Maintenance Technician Awards Program.

    AC 120-72, Maintenance Resource Management Training.

    FAA Operator’s Manual for Human Factors in Aviation Maintenance.

    Volume 3, Chapter 24, Section 1, Safety Assurance System: Training Program Evaluation.

    Volume 5, Chapter 5, Section 7, Evaluate a Part 65 Inspection Authorization.

B.    Forms:

    FAA Form 8310-5, Inspection Authorization.

    FAA Form 8610-1, Mechanic’s Application for Inspection Authorization.

    Aviation Maintenance Technician Awards Certificates.

    Aviation Maintenance Technician Awards Brochure.

C.    Job Aids. None.

3-1914    PROCEDURES.

A.    Ensure Applicant Meets Eligibility Requirements.

B.    Evaluate Training Program Content.

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1)    The procedure for obtaining training program acceptance normally begins with a meeting between the training provider’s key personnel and the principal inspector (PI) or responsible ASI to discuss the scope of the training, the timing of the program document submittal, and other issues. This meeting will be an opportunity for the training provider to ask questions about the FAA process. Although highly recommended, this is not a required meeting.
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2)    The training provider may submit its training program contents as electronic media if it ensures the reviewing FAA office is able to look at and store the submitted material in the selected media format. A transmittal document must accompany material submitted electronically. These transmittal documents may be in the form of an email, fax, or letter and may include the use of electronic signatures. The training provider’s accountable manager or someone acting on the manager’s behalf should sign the submittal. If a program is too large to send electronically, it will be the responsibility of the training provider to make alternate arrangements to deliver the program to the FAA office for review.
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3)    The reviewing FAA office may use the criteria and standards described in AC 120-72 (or the equivalent advisory material), and the items listed in paragraph 3-1907 to review the content of the initial training program. Not every item listed in the guidance needs to appear in the training, but the reviewing office should use the list to suggest items that better meet the needs of the maintenance organization.
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4)    The FAA will review the proposed training program or revision and either accept it or prepare an explanation of why the program or revision is not acceptable as submitted. The reviewing office will send a letter or electronic transmittal of its approval or nonacceptance to the individual who signed the submittal for the training.
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5)    If the FAA does not accept a submittal, the training provider should propose revisions that address the FAA’s concerns. When the training provider has adequately addressed all the concerns expressed in the FAA nonacceptance, the FAA will accept the human factors training program content.
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6)    The training provider, or input from the PI or responsible ASI, can initiate a change to the accepted human factors training program. The training provider should provide any revisions to the program content to the inspector for acceptance. The training program may change to accommodate modifications to the training provider’s work, and/or its customers, and in response to the ongoing assessment processes of the customer and of the FAA. Correction of typographical errors and changes to phone numbers are examples of changes not requiring FAA acceptance or approval. However, the training provider should send a corrected copy to the FAA.
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7)    The instructor should have capabilities and experience related to aviation maintenance and/or the human factors discipline that a reasonable person would accept as credible. The instructor should have effective communication skills and the ability to convey credibility to the majority of the students or course participants. Experience in, and understanding of, aviation maintenance is an acceptable course leader’s most highly preferred attributes.
8)    The FAA does not determine instructor qualifications. However, if the FAA—through its surveillance process—finds that the qualifications or skills of an instructor are deficient, the training provider must correct any deficiency associated with that instructor and with its instructor selection.
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9)    The training program should have a process measurement element that verifies the effectiveness of the training. This provides a continuous improvement characteristic to the training program. Therefore, one of the key areas the FAA will monitor is the feedback process, which takes evaluation results and adjusts training needs. The FAA may independently assess training to evaluate effectiveness, particularly where safety risk is relatively high.
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10)    If the program or program revision submittal is in an electronic format, the FAA inspector will indicate acceptance, or nonacceptance, with an email message or letter. If the FAA denies the submittal, the email message or letter will include an explanation of the denial.
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11)    The training provider or operator should initiate its revision process by informing the FAA that it is planning to submit a human factors training program for acceptance. This should be done with an in‑person initial meeting, or a letter of request sent to the local FAA office.
12)    The FAA will communicate acceptance status by one of the following means:
a)    The FAA issues a letter of acceptance when the review of the training program or revision shows compliance with the form and manner prescribed in this chapter. See Figure 3-217, Example Letter of Acceptance and Figure 3-218, Example Letter of Acceptance (AMT Awards Program).
b)    The FAA issues a letter of nonacceptance, with an explanation of the discrepancies, when rejecting a human factors training program or revision. See Figure 3-219, Example Letter of Nonacceptance.

3-1915    TASK OUTCOMES. Complete the PTRS record for part 91K.

3-1916    FUTURE ACTIVITIES. For part 91K, maintain routine surveillance. For parts 121/135, follow SAS guidance.

Figure 3-217.  Example Letter of Acceptance

XYZ Training

Accountable Manager

123 Anywhere Blvd

Somewhere, PA 13579

Dear Mr. Trainer,

The FAA is pleased to notify you we have reviewed and accepted the XYZ human factors training course for the purpose you submitted with the revision date of [XX/XX/XX].

As a training provider of an FAA-accepted course you must:

    Keep the course material current and complete according to the original submission.

    Facilitate it in the intended manner and length.

    Allow Flight Standards to monitor sessions presented under this letter of acceptance. In addition, provide all training materials the attendees would receive, upon the request of the FAA individual monitoring the training.

    Upon completion of training, provide the attendees with a certificate verifying their completion of the FAA-accepted training, and the total length of time for the course.

    Maintain a list of attendees or training records to document that personnel have received adequate training in human factors, to be available to any FAA office upon request.

You may revise the course at any time using one of the following two methods:

1.  Change: These are minor updates, alterations, and deletions that constitute minimal course revisions to the original material. The training provider does not have to notify the FAA of these types of changes.

2.  Revisions: These are major rewrites to the original course material submitted for acceptance. Revisions may include changing course subjects, subtracting or adding course material not found in the original course. The training provider must submit the revision to this office for review and acceptance at least 30 days prior to facilitating the revised course. After reviewing and accepting the modifications, the FAA will issue a new letter of acceptance in accordance with the current edition of AC 65-25, William (Bill) O’Brien Aviation Maintenance Technician Awards Program.

Again, congratulations and thank you for your interest in maintenance human factors, and your commitment to maintenance training, and aviation safety. Should you have any further questions, contact this office at [(XXX) XXX-XXXX].

Sincerely,

John J. Inspector

Aviation Safety Inspector

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Anywhere Ave.

Anywhere, USA 11111

Figure 3-218.  Example Letter of Acceptance (AMT Awards Program)

ABC Training

Accountable Manager

456 Anywhere Blvd

Anywhere, PA 24680

Dear Mr. Trainer,

The FAA is pleased to notify you we have reviewed and accepted the ABC human factors training course for the purpose you submitted. As of this date, the training course provided with the revision date of [XX/XX/XX] meets the requirements specified in the current edition of AC 65-25, William (Bill) O’Brien Aviation Maintenance Technician Awards Program, and is granted [X] hours of credit towards the Aviation Maintenance Technician (AMT) Awards Program.

As a training provider of an FAA-accepted course you must:

    Keep the course material current and complete according to the original submission.

    Facilitate it in the intended manner and length.

    Allow Flight Standards to monitor sessions presented under this letter of acceptance. In addition, provide all training materials the attendees would receive, upon the request of the FAA individual monitoring the training.

    Upon completion of training, provide the attendees with a certificate verifying their completion of the FAA-accepted training, and the total length of time for the course.

    Maintain a list of attendees or training records to document that personnel have received adequate training in human factors, to be available to any FAA office upon request.

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Please advise those individuals successfully completing this training that the FAA will accept the total hours of your training program towards the AMT Awards Program. The AMT Awards Program is a self-service, fully automated process, and is located at www.FAASafety.gov.

NOTE:  The FAASTeam Program Manager (FPM) will address public inquiries about the program if requested. The FPM will promote and respond to individual AMT and employer inquiries regarding the AMT Awards Program for their assigned Flight Standards District Office (FSDO) district. The Regional FAASTeam Point of Contact (RFPOC) will address the AMT Awards Program inquiries for those FSDOs that do not have an Airworthiness FPM assigned. If requested by an Employer Award recipient, the RFPOC or FPM is encouraged to attend the employer event to recognize and acknowledge their receipt of the award. Eligible FPMs are encouraged to register and participate to improve their knowledge of the program as well as demonstrate program value.

You may revise the course at any time using one of the following two methods:

1.  Change: These are minor updates, alterations, and deletions that constitute minimal course revisions to the original material. The training provider does not have to notify the FAA of these types of changes.

2.  Revisions: These are major rewrites to the original course material submitted for acceptance. Revisions may include changing course subjects, subtracting or adding course material not found in the original course. The training provider must submit the revision to this office for review and acceptance at least 30 days prior to facilitating the revised course. After reviewing and accepting the modifications, the FAA will issue a new letter of acceptance in accordance with AC 65-25.

Again, congratulations and thank you for your interest in maintenance human factors, and your commitment to maintenance training and aviation safety. Should you have any further questions, contact this office at [(XXX) XXX-XXXX].

Sincerely,

John J. Inspector

Aviation Safety Inspector

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Anywhere Ave.

Anywhere, USA 11111

Figure 3-219.  Example Letter of Nonacceptance

XYZ Training

Accountable Manager

123 Anywhere Blvd

Somewhere, PA 13579

Dear Mr. Trainer,

This letter is in response to your request for acceptance of Revision 2 to XYZ training program/revision, dated [XX/XX/XX]. We have rejected your request for approval of Revision 2 for the following reason(s). Revision 2 deletes training previously given on communications and fatigue and does not provide any additional type of identifiable instruction to your mechanics, repairmen, or technicians.

Presently, no other course of training for XYZ training contains adequate information on these important human factors issues. For further information, you may contact this office at [(XXX) XXX-XXXX].

Sincerely,

John J. Inspector

Aviation Safety Inspector

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Anywhere Ave.

Anywhere, USA 11111

RESERVED. Paragraphs 3-1917 through 3-1920.