Letter from Chief Surveyor
Index
Glossary
SectionSubjectPage
11.1 Introductionp 1
1.2 Background______p 1
1.3 Definition of “Best Practice”______p 2
1.4 The Regulator’s View______p 2
1.5 FASS______p 2
1.6 Central Register of Contractors______p 3
2Who are the Contractors?p 3
3Why Employ Contractors?______p 4
4Risk Factorsp 5
5Regulatory Frameworkp 5
6Best Practice Recommendationsp 6
7Contractor Supplier Auditp 6
8Contractor Suppliers (Agencies)p 6
9Ratios of Permanent:Temporary Staffp 6
10Contractor Supply Order Specificationsp 7
11Verificationp 8
12Working Relationships______p 9
13Pre-joining Proceduresp 10
14Maintenance Human Factors Training
14.1 Requirement______p 10
14.2 Syllabus______p 10
14.3 MHF Training Delivery (General)______p 11
14.4 MHF Training Delivery (Contractors)______p 11
14.5 FASS Contractor MHF Course (Modules 1 – 9)___p 11
14.6 Module 10 and Induction Training______p 11
15Permanent Staff Briefing p 12
16Supervision p 13
17Log Books______p 13
19Risk Assessmentp 14
Annexes1FASS Quality Code______p 15
2Extracts from CAP 716 (Issue 2)
Chapter 11; 11.2 - Module 10 of the Syllabus______p 17
Chapter 11; 14 - HF Training for Contract Staff______p 17
Appx A; Att 6; - Syllabus for Initial MHF Training______p 18
GLOSSARY
Terms are used in this document as described-
AgencyA Contractor supplier; an employment business or agency that specializes in recruiting temporary staff with aerospace-related skills and qualifications (as well as many other categories, probably) and offering them to fulfil an MO’s requirements for short-term staff.
AMCAcceptable Means of Compliance
MOAircraft Maintenance Organisation, and Maintenance and Repair Organisation. In this document the term is used to encompass all maintenance and manufacturing organisations, so far as their recruitment and management of contractors are concerned.
AuditProcess of investigation to establish compliance with procedures set out in an operating manual.
Best PracticeDefinition of procedures that an auditor seeks to find as evidence that the organization is operating to the accepted standard.
CAACivil Aviation Authority.
ContractorAn aircraft maintenance worker who is employed on temporary contracts, directly or via an Agency to work for MOs, and is not on the payroll of the MO where he/she is working as a permanent employee. (The term “contractor” is rather inaccurate, but is commonly used instead of the more accurate “temporary worker”)
CAPCivil Aviation Publication.
EASA Part 145EASA is the European Aviation Safety Agency, and adopted much of the previous JAA documentation. The EASA Commission Regulation is an implementing regulation, and its Annexes are referred to as Parts (so far: M, 145, 147 66 and 21). JAR 145 approved MO’s must transit to Part 145.
FASSFederation of Aerospace Support Services. (see 1.4, p2).
GMGuidance Material
ISO 9001:2000International Quality Standard for organisations such as Agencies.
JAAJoint Aviation Authorities.
EASAEuropean Aviation Safety Agency.
MORMandatory Occurrence Report.
QMQuality Manager; the person responsible in an MO for the Quality Assurance Management function and named as such in its exposition. Must have a direct reporting line to the Accountable Manager.
SRGSafety Regulation Group of the CAA
UKFSC UK Flight Safety Committee
“Managing Contractors Safely” 2nd Edition
1.INTRODUCTION
1.1Background
Aircraft maintenance providers and manufacturers must often react quickly and safely to a sudden increase in workload, either to support a new operator, or to execute a maintenance check or modification, or to meet a buyer’s order for completion, conversion or refurbishment. From time to time, extra manpower is needed for work planned well in advance but outside the permanent workforce’s capacity.
Demand for additional, short-term skilled manpower is met by the pool of contractors, a resource without whom the air transport industry could not function. Use of them is expected to grow by 5% – 10% over the next decade.
Although the CAA recommends that maintenance organisations retain their staff on a permanent basis, it does acknowledge that contractors will continue to be an essential resource, integral to the industry.
The majority of contractors currently available world-wide have until recently come from the UK. However, recent experience indicates that contract staff are beginning to appear in the UK from all over the world, with unfamiliar qualifications and backgrounds that are more difficult to verify quickly.
The United Kingdom Flight Safety Committee’s (UKFSC) “Review of Temporary Staff in Aircraft Maintenance in the UK” published in February 2001, confirmed that there is no evidence that any aircraft incident has occurred as a direct result of the use of contractors. Nonetheless, it highlighted increasing concerns that the risks inherent in their use should be identified and dealt with as a preventative measure, including security risks.
The UKFSC Review concluded with the following recommendations aamong others…..
- “Some form of accreditation of Agencies should be considered……..through a scheme operated through the Agencies’ representative body, i.e. Federation of Aerospace Support Services (FASS).”
- “…a universal system for verification for employment purposes be established for staff employed in the aircraft maintenance industry.”
- As a minimum all MOs should include in either the induction process or separately a training package on Company documentation and Quality procedures for contract staff…..”.
The UKFSC Maintenance Steering Group’s first recommendation above was intended to create a situation in which MOs use accredited agencies exclusively, once the system for accreditation and the standards required were in place through FASS. The system for accreditation, and the standards, are now in place and FASS Members adhere to the standards set in the FASS Code of Practice (Annexe 1).
FASS is now inviting aircraft maintenance Contractors to join the Federation as Contractor Members. Enrolment requires that applicants supply a CV, which is then verified to the standard set by the FASS Code of Practice. Full details of training, qualifications and work record are held on a Central Register, and can be supplied on demand to a FASS Member Agency for use by an MO as unimpeachable documentary evidence of a FASS Contractor Member’s training, qualifications and work record.
All MO’s are urged to use FASS members exclusively, firstly to obtain the assurance of Quality that FASS offers, and secondly to help the industry achieve the UK Flight Safety Committee’s objective of eliminating unsafe operating standards and practices through the operation of an accreditation scheme.
1.2Definition of Best Practice
FASS and CAA acknowledge that this document provides helpful guidance in the form of “Best Practice” to organisations recruiting, inducting and managing contractors, where previously there was no such guidance.
As such, it can be used as guidance by EASA Part 145 approved organisations when conducting audits that include the areas of “sufficient” and “competent” staffing with particular reference to Part 145.A.30 (d), (e), (g) and (j), and Part 145.A.35.[1] The need to establish and verify qualifications, training, work experience and competence of contractors is absolute.
1.3Maintenance Human Factors (MHF)
EASA Part 145 requires that all maintenance-related staff (not just licensed engineers) must receive both initial and recurrent human factors training. This is training in the practical application of human factors and error management, in a work-related context. This requirement applies equally to contractors as it does to permanent staff.
This subject is dealt with in more detail in Section 14 of this document, which distinguishes between what training will be expected prior to joining an MO, and which elements are company specific and therefore need to be included within induction training.
The 1st Edition of this document provided guidance on induction training. This guidance still applies, although it may be expanded to incorporate Module 10 of the MHF training syllabus, which includes the MO's MHF programme and processes. (See 14.5 below).
Further guidance to the recently introduced MHF requirements may be found in CAP 716 (Issue 2).
1.4The Regulator’s View
The CAA welcomes this FASS initiative and acknowledges that when applied as intended, it could enable an EASA 145 organisation to discharge its obligations in respect of an contract staff member’s identity, qualifications, training, experience and work history, by reviewing the documentation supplied by a FASS member. (See 1.6 for information about the FASS Central Register of Contractors).
Therefore, it is recommended by FASS that organisations using contract staff study this document and carry out the risk assessment recommended in CAP 712, thereby enabling them to establish robust procedures to manage the recruitment, induction, training and management of such staff.
1.5FASS
The Federation of Aerospace Support Services was incorporated in 2001 by a group of reputable agencies wishing to work together to improve the standards of the industry, and thereby positively to address the safety and quality issues raised in the UKFSC’s Maintenance Working Ggroup 2001 Review.
FASS Agency Members, with encouragement from the CAA, now set an industry benchmark for others to emulate, with clearly stated standards of operations and quality management.
Applications to join the Federation are accepted from any Agency who subscribes to and meets FASS’ Codes of Conduct, and who is, or expects to be shortly, accredited under ISO 9001:2000.
Equally, applications to join are now welcomed from aircraft maintenance contractors. Upon completion of the enrolment verification process, each Contractor Member will be issued with a FASS Contractor Member card. Enrolment and membership are free of charge to contractors.
An independent Executive Director manages FASS and represents Members’ interests in any industrial or regulatory forum. He is available to discuss with a FASS Member’s client any matter between a FASS member and a client.
The FASS Code of Quality Conduct governs recruitment, verification and records and is set out in full in Annex 1 of this document. Further development of this Code is an on-going process.
Any comments or suggestions about this document will be welcomed, and should be addressed to the Executive Director. (See inside front cover for details).
Up-to-date information about FASS and its Membership can be found on or obtained by contacting the Executive Director.
1.6Central Register of Contractors
From December 2003, details of the training, qualifications, experience and work record of each Contractor Member are being acquired and held on the FASS Central Register of Contractors. These details are verified in accordance with the FASS Code of Practice, (see Annexe 1). The register holds the documentary evidence of verification in the form of employer confirmations of employment, and verified true copies of original licences, approvals, certificates and the like. All information and procedures are auditable, and audits from MOs are welcomed.
The Register is undertaking the process of accreditation under ISO 9001:2000.
Information about any Contractor Member is available in a standard summary format known as a “Personal Data Summary” (PDS), which, together with the card held by a Contractor Member, provides a Quality Manager of an MO with confirmation of identity and the information needed to fulfil the requirements of EASA Part 145 for establishing the competence of personnel, backed up by the documentary records held in the Register.
It must be emphasised that the Contractors card itself proves only that the holder is a Registered Contractor and that the information required is available in the Register. Bona-fide Contractors at all levels (see below) from semi-skilled to those with the highest qualifications may join FASS and thus become registered. The competence of any individual can only be established from the information given in a valid PDS, using the Card to establish that the identity of the holder is the same as the subject of the PDS.
2WHO ARE THE CONTRACTORS?
Contractors (for the purpose of this Guidance) include any form of design, manufacturing or maintenance worker who, instead of working under a full-time contract for a single employer, works as a temporary worker on short-term contracts. Their disciplines/skills include
- licensed aircraft maintenance engineers
- airframe/engine mechanics
- skilled sheet metal workers
- avionics technicians
- electricians
- composites specialists
- specialised workshop personnel
- design staff in all disciplines (e.g. stress, aerodynamics etc)
- Staff engaged in maintenance-related administration, e.g. technical publications, and storemen
- Production workers
There are believed to be around 10,000 aerospace workers from the UK working as contractors, of whom 15% or so are licensed. The qualifications of licensed engineers are evidenced by their licenses and not difficult to verify, and are well documented by Part 145 approved MOs’ systems, however those of non-licensed staff are less formalised, and thus less easy to verify.
Contractors normally apply to many agencies as a means of obtaining employment.
This Guidance applies equally to the management of all skilled and semi-skilled contractors, regardless of whether they are recruited directly or are supplied by an agency.
It does not apply, in a formal sense, to staff recruited via an agency or otherwise for relatively unskilled tasks such as cleaning although the nearer the worker will be to aircraft, the more some parts of this Guidance will be relevant. MO’s should identify such parts and incorporate them into their procedures for recruiting and managing these staff.
It is the employing MO’s Quality Manager’s responsibility to ensure that a Contractor’s claimed qualifications, training, experience and record have been fully verified before the Contractor starts work, and that his/her competence has been assessed only on the basis of this robust information. In addition the information required for security purposes and issue of an airside pass may well be needed very quickly, including a full background history check covering the previous 5 years. (see Section 11, p8).
3WHY EMPLOY CONTRACTORS?
Contractors are employed by Aircraft Maintenance Organisations (MOs) and manufacturers alike for a number of valid and acceptable reasons including;
- Enable operations with the minimum permanent establishment
- Cover for permanent staff who are temporarily unavailable
- Fill gaps in skills coverage
- Cope at short notice with an unforeseen high workload
- Facilitate expansion
The total cost of hiring contractors per productive hour is often less than the total cost of a permanent employee per productive hour, once all factors are taken into account including the permanent worker’s unproductive but paid time and the overhead costs of employment.
Many employment costs are included in the hourly charge for a contractor. These include, as well as the obvious pension and Social Security costs, costs of the company sick pay scheme, staff administration costs, holiday pay, legal costs, and recruitment and termination expenses.
Overtime can be more expensive than a contractor’s hourly charge, especially if the on-cost of overtime pay is taken into account.
The mis-perception that contractors are high-earners and very expensive, compared with permanent staff, is a common cause of resentment among permanent staff in MO’s.
4RISK FACTORS
The UKFSC Review stated that:
“there has been no suggestion…that the use of contractors is in any way contributory to maintenance related incidents”.
Nonetheless, use of contractors raises the possibility of some risk.
Positive action is required to eliminate any such risk, before it becomes a safety issue.
The following possible risk factors have been identified:
Arising Before Commencement of Work
- False documentation
- Inappropriate qualifications
- Inappropriate experience
Arising in the Workplace
- Inadequate induction training
- Inadequate task briefing and supervision
- Unfavourable working conditions
- Poor working relationships
Of these, the first three concern recruitment, verification of CV’s, and systematic, careful selection of personnel for a specific job. The FASS Code of Quality Conduct covers these items on behalf of clients, although the responsibility rests with the MO (See Section 11 and Annexe 1). Selecting the right person does depend, of course, on having a good specification in the first place, and that is in the client’s control, although the agency has a responsibility to make sure it understands what is needed.
The last four are within the control of the client MO’s management.
The purpose of this Guidance is to recommend ways of addressing the risk factors, in the form of “Best Practice” guidance.
5REGULATORY FRAMEWORK
The requirements for ascertaining qualifications, training and experience, and thereby assessing competence, apply to contractors exactly as they do to permanent staff members. Section 6 deals with the requirements in more detail.
Contractors may well not be known to the MO prior to arrival for work. Therefore, assessment of their competence is necessarily based on the documentation evidencing training, qualifications and experience. Proper and systematic verification of the documentation offered is, for this reason, an essential part of the process of assessing competence, and must be done before the contractor starts work, not after.
The responsibility for ensuring compliance with EASA Airworthiness Requirements, with special reference to Part 145.A.30 and A.35, remains with the MO.
6BEST PRACTICE RECOMMENDATIONS
Part 145.A.30 (e) Personnel Requirements states:
“The organisation shall establish and control the competence of personnel involved in any maintenance, management and/or quality audit in accordance with a procedure and to a standard agreed by the competent authority .”
For the avoidance of any doubt, this means that the MO must establish and control the competence of anyone, permanently or temporarily employed, who is working on an aircraft or component, including support staff such as storemen, technical records staff, engineering planners and so on, regardless of the nature of that person’s engagement to do the work.
The standard of verification of documents set by FASS, followed by its Agency members and by its central register, has been discussed and agreed with the CAA, and can be regarded as defining “Best Practice” for the industry in relation to complying with this requirement.
Any person employed in an approved facility must be both suitably trained and competent for the intended task. Comprehensive recruitment and vetting procedures must be in place, including induction procedures and training.
Agencies recruit, administer, vet, verify and offer personnel to their clients for a specified task, in accordance with the specification advised by the client.. The client MO’s Quality Manager remains fully responsible for establishing a contractor’s identity, and for ensuring that the contractor’s training, qualifications and experience are adequate and appropriate for the task and properly verified prior to the contractor starting work, and for assessing each person’s competence.
An MO, having identified a contractor supplier whom it wishes to use, should place the supplier on its approved supplier list only after auditing it, with particular reference to recruitment and verification procedures. The MO has a choice of auditing a particular agency, or of auditing the central FASS Contractor Register and then adding all FASS Members to its list of approved suppliers. The MO should carry out the same supplier selection process using the same criteria (including regular audit) that it uses for suppliers of all equipment, components, consumables and services for use on aircraft, with the appropriate level of audit.