In response to an ARSA inquiry, the European Aviation Safety Agency (EASA) confirmed that U.S. repair stations with EASA part 145 approval should achieve compliance with EASA human factors requirements by following Federal Aviation Administration (FAA) guidance. There had been confusion on this issue since some repair stations were told to comply with guidance prepared by EASA for repair stations directly certificated by that agency. The EASA part 145 guidance material for human factors training programs, specified in GM 145.A.30(e), differs from current FAA guidance, notably in its recommendations for topics requiring coverage in a training program.
While 14 CFR does not specifically require human factors training, the FAA has released guidance on the subject in response to the Maintenance Implementation Procedures. The guidance, issued to FAA Aviation Safety Inspectors, outlines the acceptable components of a human factors training course needed to secure EASA part 145 approval. This guidance was subsequently incorporated into FAA Order 8300.10, Volume 2, Chapter 168, which includes the listing of topics to be covered in a training program.
The communication between ARSA and EASA confirmed that compliance with the FAA guidance would be treated as the equivalent of compliance with GM 145.A.30(e), dispelling earlier confusion. Additional clarification will be included in the proposed new FAA-European Union bilateral agreement.
ARSA’s correspondence and the EASA response can be viewed here.
