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8900.1 CHG 460

VOLUME 6  SURVEILLANCE

CHAPTER 10  PART 147 INSPECTIONS

Section 1  General

6-2140    PROGRAM TRACKING AND REPORTING SUBSYSTEM (PTRS) ACTIVITY CODES.

A.    Maintenance: 3650, 3659, 3661.

B.    Avionics: 5650, 5659, 5661.

6-2141    OBJECTIVE. This chapter provides guidance for conducting surveillance of certificated Aviation Maintenance Technician Schools (AMTS).

6-2142    GENERAL.

Indicates new/changed information.

A.    Inspections. A certificated AMTS must be monitored for adherence to its curricula and continued compliance with the certification requirements and operating rules. The aviation safety inspector (ASI) performing the inspections must have completed Federal Aviation Administration (FAA) Course 21000113, Aviation Maintenance Technician Schools and its electronic Learning Management System (eLMS) prerequisite course 27100162. The ASI must also have knowledge of the regulatory requirements of Title 14 of the Code of Federal Regulations (14 CFR) parts 43, 65, and 147.

B.    Inspection Scheduling. Part 147, 147.43 allows inspection of a school at any time to determine its compliance with part 147.

1)    Formal Inspections. The purpose of a formal inspection is to determine whether the school continues to meet the requirements under which it was certificated.
a)    In accordance with 147.43, normally such an inspection is made once every 6 months to determine if the AMTS continues to meet certification requirements. For the formal inspection, FAA Form 8310-6, Aviation Maintenance Technician School Certificate and Ratings Application, is utilized. The information collected on this form is necessary to ensure that AMTS meets the minimum requirements for the procedures and curriculum set forth by the FAA in part 147. The information will be used to validate the certificated AMTS’s continued eligibility and regulatory compliance.
Indicates new/changed information.
b)    At the inspection exit briefing, the inspector must provide the school with notification of discrepancies found during the formal inspection. Within 5 business days of the exit briefing, the inspector will provide a written followup list of areas of noncompliance to the school. The school must initiate immediate corrective action to demonstrate regulatory compliance and must provide the district office with written notification of the action taken.
c)    Before beginning subsequent inspections and surveillance of the AMTS, the ASI will review the AMTS office file at the certificate-holding district office (CHDO), the operations specifications (OpSpecs), approved curriculum, and existing AMTS-related PTRS entries to identify any previous deficiencies noted during previous inspections. The inspector will inspect the AMTS to validate the level of regulatory compliance in these areas.
2)    Informal Inspections. An informal inspection will be less comprehensive than a formal inspection. This inspection may be unannounced, at the inspector’s discretion. The purpose of the informal inspection is to evaluate a specific area of the operating rule for regulatory compliance by the AMTS, or to ensure the program is effective.
a)    The frequency of informal inspections will vary according to the needs of the individual school and the FAA workload. At a minimum, however, there must be no fewer than two informal inspections per school year.
b)    The inspector must notify the school in writing of deficiencies found during the informal inspection. The discrepancies must be recorded and the record placed in the office file for reference and followup purposes.

NOTE:  In the written notification, the inspector must explain to the school the timeframe within which the discrepancies must be corrected.

C.    Review the Applicant’s File. Before inspecting the facility, review the applicant’s application and Flight Standards District Office (FSDO) file. Check for any previous violation history. Check the curriculum or proposed curriculum for currency. Take a copy of the curriculum, OpSpecs, and facility layout to the school site. During review of a current curriculum, ensure FAA approval is evident by means of an FAA signature or stamp on a control or cover page.

D.    Review OpSpecs. Determine that the following is complete:

    Mandatory OpSpecs are issued.

    Optional applicable OpSpecs are issued.

    AMTS maintains a current set of OpSpecs.

    AMTS is operating in accordance with the OpSpecs.

E.    AMTS Approval and Implementation of Distance Learning Programs.

1)    A certificated AMTS proposing the implementation of distance learning should submit a request to local FSDO requesting information and or approval for distance learning.
2)    The responsible principal inspector (PI) should either provide source references of distance learning program guidance to the AMTS as requested, or, if the AMTS has submitted a program, the PI must review the entire program for written policies, procedures, and equipment sufficient to conduct distance learning prior to approval authorization of the program.

NOTE:  Approval for the AMTS to utilize distance learning as a teaching delivery method does not alleviate the AMTS from meeting all requirements of part 147. If the AMTS does not meet the minimum requirements to support implementation of distance learning, the PI must not approve distance learning for the AMTS. The PI must also ensure OpSpec A026, Authorizations/Limitations, is not issued until all of the minimum requirements are met.

F.    Distance Learning Program Surveillance. As an alternative to classroom training, the distance learning curriculum delivery method continues to develop utilizing distance learning technology. The initial implementation and subsequent surveillance of a distance learning program requires written policy and procedures and, at a minimum, the following:

1)    An eLMS of sufficient hardware and software technology to accomplish comprehensive storage, handling, and tracking of all aspects of the distance learning program, including:
a)    Student online distance learning attendance tracking/recording.
b)    Student online distance learning participation tracking/recording.
c)    Student online distance learning performance measurement tracking/recording.
2)    AMTS to have issuance of OpSpec A026, Authorizations/Limitations, prior to conducting distance learning.
3)    Distance learning course list availability.
4)    FAA learning management system read-only access (surveillance).
5)    Report availability for analysis of distance learning test scores in comparison to traditional classroom test scores.
6)    Report availability for analysis of distance learning course completion times in comparison to traditional course completion times.
7)    Verification by AMTS: Distance learning courses combined with traditional classroom AMTS courses meet, at a minimum, curriculum requirements defined by part 147.
8)    Identification of students who are not seeking any certificates but are enrolled in AMTS distance learning courses. Regulatory requirements would not apply to these students.

NOTE:  Deficiencies found within the distance learning program during surveillance must be identified and brought to the attention of the AMTS for necessary correction. An AMTS with approval to conduct distance learning must continually operate to meet the requirements of the approved distance learning program to enable continued approval authorization to conduct distance learning.

6-2143    SURVEILLANCE OBJECTIVES.

A.    Instruction Time. Based on a variety of indicators, it is apparent that some schools do not provide the number of hours of instruction specified in their approved curricula. One of the objectives of surveillance is to ensure that typical “time loss” items do not affect curriculum hours.

1)    The inspector must be aware of the following:

    Instructors ill or on leave (in small schools, this could result in classes being dismissed or students being sent to a room to study);

    Teachers’ strikes;

    Weeks during which students are scheduled for private study and/or testing outside of the approved curriculum;

    Class outings that take time away from instructional hours;

    Student achievement days, sports days, and special-event days;

    Teachers’ meetings and grading days;

    Absences beyond those permitted in the FAA-approved curriculum;

    Classroom time spent on noninstructional activities, such as school administrative work and pep rallies; and

    Any other activity that intrudes on instructional time.

2)    Published school calendars, individual student enrollment schedules, student makeup schedules, and class schedules are good sources of surveillance information.

B.    Credit for Prior Instruction or Experience.

1)    School records must show the basis for crediting previous instruction or experience, including records of tests and copies of documents. School records must also indicate the exact curriculum subjects to which previous instruction is credited.
2)    Section 147.31(c)(1) and (2) allows credit for instruction satisfactorily completed at the following:

    An accredited university, college, or junior college;

    An accredited technical school, trade school, vocational school, or high school;

    A military technical school; or

    A certificated AMTS.

NOTE:  Accreditation, as referenced in part 147, refers to schools accredited within the United States. Foreign AMTSs are not eligible for FAA certification. Therefore, no credit may be granted for prior instruction in foreign schools.

NOTE:  Section 147.31(c)(1)(iv) must not be interpreted as requiring a student to retake the general portion of the curriculum after successfully completing one rating and enrolling in a course of study for the other rating. The general portion is not required to be taken twice, provided that it is clearly separate from both the Airframe and Powerplant (A&P) portions and conforms to the requirements of part 147 appendices A and B.

3)    The recordkeeping requirements of 147.33 for previous experience or instruction are applicable. See Volume 2, Chapter 12, Section 2, for details.

C.    Progress Records or Charts. Progress records or charts need not show grades for practical laboratory work if these grades are available in another record.

D.    Transcripts. Grade transcripts must be available to the student regardless of whether the student graduates. Upon request, each certificated AMTS must provide a transcript of the student’s grades to each student who has graduated from that school or who leaves before graduating. An official of the school must authenticate the transcript. The transcript must state the curriculum in which the student was enrolled, whether the student satisfactorily completed that curriculum, and the final grades the student received.

1)    The transcript must be clearly distinguishable from a graduation certificate and must be limited to only those subjects required under part 147.
2)    A student will be issued a graduation certificate or certificate of completion only if all curriculum requirements have been completed, either by taking and passing the specified courses or by being correctly credited.

E.    Quality of Instruction. A school must provide instruction of such quality that during any 24‑calendar-month period, a prescribed percentage of its graduates will be able to pass the appropriate FAA written test on the first attempt. This information is available by review of the following reports:

    School Norms vs. National Passing Norms (Report 8080-08).

    Aviation maintenance test applicant listing.

1)    Corrective action may need to be initiated if the percentages fall below those specified in  147.38(a).
2)    While poor test performance alone may not indicate poor instruction, it may be an indication that some aspects of the school operation are inadequate or ineffective.
3)    Use of the AMTS norm.

F.    School Norms. When an individual school norm is significantly lower than the national norm (i.e., in excess of the requirements of 147.38(a)), an asterisk will appear next to the 2-year school norm score on the 8080-08 Report. The responsible region/district office may obtain more detailed performance information to assist in determining problem areas by requesting an aviation maintenance test applicant listing from the Airman Testing Standards Branch (AFS-630). The 8080-08 Report and the aviation maintenance test applicant listing data may be shared freely with the school to which it refers.

G.    AMTS Norm Versus National Passing Norms, Form 8080-08, and Associated Reports in the Series. This series of reports provides information to the school and the responsible FAA region and district offices about the test performance of school graduates. The reports are used to monitor school performance and to determine whether schools meet the quality of instruction provisions of 147.38(a). The reports are posted quarterly (6 weeks after the end of each calendar-year quarter) to the publicly accessible FAA Norms Web site at http://www.faa.gov/data_research/aviation_data_statistics/test_statistics/. Two years of norms reports are maintained and available on the Web site. The report data is available to the public and may be shared freely with the school to which it refers, as well as any other party.

1)    Report 8080-08 is the basic report of the series. It contains a record of test activity and performance of graduates of the subject schools who apply for a mechanic written test for the first time within 60 days after graduation.
2)    The aviation maintenance test applicant listing contains a record by applicant name of the test performance for graduates from a subject school for a time period specified by the requestor and is produced on request by AFS-630.
3)    “Non-school” reports are quarterly reports arranged by the region in which the testing occurred. These reports are made for the following:

    Applicants who graduate from a certificated school and who take the mechanic tests for the first time within 60 days of graduation (Report 8080-09).

    Applicants who graduate from a certificated school, but who take the mechanic tests for the first time more than 60 days after graduation (Report 8080-07).

    Applicants who qualify for testing through actual experience and are not graduates of a certified school (Report 8080-04).

H.    Review OpSpecs. Determine that the following is complete:

    Mandatory OpSpecs are issued.

    Optional applicable OpSpecs are issued.

    AMTS maintains a current set of OpSpecs.

    AMTS is operating in accordance with the OpSpecs.

I.    Distance Learning Program Surveillance. See subparagraph 6-2142F.

6-2144    PREREQUISITES AND COORDINATION REQUIREMENTS.

A.    Prerequisites:

    Knowledge of parts 43, 65, and 147; and

Indicates new/changed information.

    Successful completion of FAA Course 21000113, Aviation Maintenance Technician Schools.

B.    Coordination. This task may require coordination with Avionics inspectors.

6-2145    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Title 14 CFR Parts 43, 65, and 147.

    Volume 2, Chapter 12, Certification of a Part 147 Aviation Maintenance Technician School.

    Figure 6-96, Read Values for AC Form 8080-08.

B.    Forms:

    Norms Report 8080-04, Non-School NORMs vs National Passing NORMs.

    Norms Report 8080-07, Region NORMs vs National Passing NORMs (Exceeding 60 Days).

    Norms Report 8080-08, School NORMs vs National Passing NORMs.

    Norms Report 8080-09, Region NORMs vs National Passing NORMs (Within 60 Days).

C.    Job Aids. General Aviation Job Task Analysis (GA JTA): 2.4.14.

6-2146    PROCEDURES.

A.    Review FAA Office Files Relating to the School.

1)    Review the school’s approved curriculum, OpSpecs, and enhanced Vital Information Database (eVID). Take a copy of the curriculum, OpSpecs, and facility layout to the school site for reference and validation.
2)    Check the inspection history, if applicable.

B.    Review Enrollment Records. Determine that the number of students enrolled is not more than the number approved in the school’s application. Determine if the school can effectively instruct the number of students actually enrolled.

C.    Review Student Records. Determine whether records are available for all students. Select the records of one or two recently graduated students and one or two current students, and perform a total verification ensuring:

1)    The attendance system shows the hours of absences allowed and makeup provisions for subject material missed. See Volume 2, Chapter 12, Section 2, paragraph 2-1449.
2)    The attendance system does not permit the time required to make up missed material to be deducted from regular instruction time. See Volume 2, Chapter 12, Section 2, paragraph 2-1449.
3)    The approved attendance system is being followed.
4)    Recordkeeping meets the requirements of 147.33.

D.    Examine the System for Determining Final Course Grades. Ensure the system reliably distinguishes between successful students and unsuccessful students. See the curriculum in Volume 2, Chapter 12, Section 2.

1)    Ensure all grade reports and records identified, as part of the approved grading system, meet the recordkeeping requirements of 147.33.
2)    Ensure that the approved grading system is being followed.

E.    Ensure Maintenance of Instructor Requirements. Determine whether instructor resources are adequate and effective, meeting the requirements of 147.36.

1)    Check the instructor/student ratio against the maximum allowable ratio of 1:25 in a shop or lab. If necessary, require a lower ratio in any shop or lab to provide adequate instruction and supervision of students.
2)    Determine if instruction given by specialized instructors is well coordinated with aviation technical subjects (e.g., math instructors might teach Weight and Balance (W&B) principles). Evaluate the suitability of noncertificated instructors to teach certain general courses on an individualized basis.
3)    Determine whether the school has positive control over what is taught and when it is taught, in accordance with its approved curriculum.
4)    Observe classes and conduct interviews to determine individual instructor effectiveness. While it is permissible to talk to instructors and/or students in an ongoing lab or shop session, try to avoid disrupting any theory class while it is in session.
5)    As discussed in Volume 2, Chapter 12, Section 2, encourage the school to assess instructor performance regularly and provide for instructor improvement.

F.    Ensure School Space Usage Allows for Appropriate Separation of Classes in Session ( 147.15(a)). See Volume 2, Chapter 12, Section 3.

G.    Examine the AMTS Norm Versus National Passing Norms (Aeronautical Center (AC) Form 8080-08) to Identify Any Deficiencies. Determine the cause(s) of poor test performance and discuss with the school ways of improving the overall school program. See Volume 2, Chapter 12, Section 1, for guidance in the use of the National Passing Norms. Obtain from the school records the names and graduation dates of all graduates for the 24-month period desired. Ensure the ending date of the 24-month period is at least 60 days before the current date.

1)    For a record search to obtain subject grades for each individual, forward the list of names and graduation dates to:
Indicates new/changed information.
Federal Aviation Administration
Airman Testing Standards Branch, AFS-630
P.O. Box 25082
Oklahoma City, OK 73125
Or email to: 9-AMC-AFS630-NORMS@faa.gov.
Indicates new/changed information.
2)    If the record search indicates significant deviation from the norm, but does not involve intentional, reckless, or criminal behavior, and the organization is qualified and willing to cooperate, the Flight Standards Service (AFS) will resolve the issue through the use of compliance tools, techniques, concepts, and programs.

6-2147    TASK OUTCOMES.

A.    Complete the PTRS Record.

B.    Complete the Task. Notify the school in writing of any deficiencies found during the inspection.

6-2148    FUTURE ACTIVITIES.

    Ensure that any deficiencies have been corrected.

    If necessary, increase surveillance.

Figure 6-96.  Read Values for AC Form 8080-08

A. SCHOOL NORMS VERSUS NATIONAL PASSING NORMS 8080-08.

Please email all questions regarding this report or any other NORMs related information to: 9-AMC-AFS630-NORMS@faa.gov.

All the data in the report is for the first test attempts within 60 days of the graduation date.

Partial completions or retakes are not included in this data.

AMA – Airman Maintenance Technician Airframe.

AMG – Airman Maintenance Technician General.

AMP – Airman Maintenance Technician Powerplant.

Quarter Data.

Number of Applicants – Total number of applicants taking the test for the first time within 60 days of graduation from the school during the quarter.

Number of Applicants Passed – Total number of applicants passing the test on the first attempt within 60 days of graduation during the quarter.

Percentage of Applicants Passed – The percentage of applicants passing the test on the first attempt within 60 days of graduation during the quarter.

Average Grade – The average grade of first test attempts within 60 days of graduation during the quarter.

Two-Year Accumulative Data.

School Applicants – The total number of applicants taking the test for the first time within 60 days of graduation from the school during the 2‑year period.

School NORM – The percentage of applicants passing the test on the first attempt within 60 days of graduation during the 2-year period.

National Applicants – The total number of applicants from all part 147 schools taking the test for the first time within 60 days of graduation during the 2-year period.

National NORM – The percentage.

B. NON-SCHOOL NORMS VERSUS NATIONAL PASSING NORMS 8080-04.

Please email all questions regarding this report or any other NORMs related information to: 9-AMC-AFS630-NORMS@faa.gov.

All the data in the report is for the first test attempts who did not report graduating from a school.

Partial completions or retakes are not included in this data.

AMA – Airman Maintenance Technician Airframe.

AMG – Airman Maintenance Technician General.

AMP – Airman Maintenance Technician Powerplant.

Quarter Data.

Number of Applicants – Total number of applicants taking the test for the first from the region during the quarter.

Number of Applicants Passed – Total number of applicants passing the test on the first during the quarter.

Percentage of Applicants Passed – The percentage of applicants passing the test on the first attempt during the quarter.

Average Grade – The average grade of first test attempts during the quarter.

Two-Year Accumulative Data.

Region Applicants – The total number of applicants taking the test for the first time from the region during the 2-year period.

Region NORM – The percentage of applicants passing the test on the first attempt during the 2-year period.

C. REGION NORMS VERSUS NATIONAL PASSING NORMS (EXCEEDING 60 DAYS) 8080-07.

Please email all questions regarding this report or any other NORMs related information to: 9-AMC-AFS630-NORMS@faa.gov.

All the data in the report is for the first test attempts exceeding 60 days of the graduation date.

Partial completions or retakes are not included in this data.

AMA – Airman Maintenance Technician Airframe.

AMG – Airman Maintenance Technician General.

AMP – Airman Maintenance Technician Powerplant.

Quarter Data.

Number of Applicants – Total number of applicants taking the test for the first time exceeding 60 days of graduation from the region during the quarter.

Number of Applicants Passed – Total number of applicants passing the test on the first attempt exceeding 60 days of graduation during the quarter.

Percentage of Applicants Passed – The percentage of applicants passing the test on the first attempt exceeding 60 days of graduation during the quarter.

Average Grade – The average grade of first test attempts exceeding 60 days of graduation during the quarter.

Two-Year Accumulative Data.

Region Applicants – The total number of applicants taking the test for the first time exceeding 60 days of graduation from the region during the 2-year period.

Region NORM – The percentage of applicants passing the test on the first attempt exceeding 60 days of graduation during the 2-year period.

National Applicants – The total number of applicants from all part 147 schools taking the test for the first time exceeding 60 days of graduation during the 2-year period.

National NORM – The percentage of all applicants from all part 147 school passing the test on the first attempt exceeding 60 days of graduation during the 2-year period.

D. REGION NORMS VERSUS NATIONAL PASSING NORMS (WITHIN 60 DAYS) 8080-09.

Please email all questions regarding this report or any other NORMs related information to: 9-AMC-AFS630-NORMS@faa.gov.

All the data in the report is for the first test attempts within 60 days of the graduation date.

Partial completions or retakes are not included in this data.

AMA – Airman Maintenance Technician Airframe.

AMG – Airman Maintenance Technician General.

AMP – Airman Maintenance Technician Powerplant.

Quarter Data.

Number of Applicants – Total number of applicants taking the test for the first time within 60 days of graduation from the region during the quarter.

Number of Applicants Passed – Total number of applicants passing the test on the first attempt within 60 days of graduation during the quarter.

Percentage of Applicants Passed – The percentage of applicants passing the test on the first attempt within 60 days of graduation during the quarter.

Average Grade – The average grade of first test attempts within 60 days of graduation during the quarter.

Two-Year Accumulative Data.

Region Applicants – The total number of applicants taking the test for the first time within 60 days of graduation from the region during the 2-year period.

Region NORM – The percentage of applicants passing the test on the first attempt within 60 days of graduation during the 2-year period.

National Applicants – The total number of applicants from all part 147 schools taking the test for the first time within 60 days of graduation during the 2-year period.

National NORM – The percentage of all applicants from all part 147 school passing the test on the first attempt within 60 days of graduation during the 2-year period.

RESERVED. Paragraphs 6-2149 through 6-2150.