CAP 1528 Guidance For Instructors v7

SARG AW
Guidance for Part-147 Maintenance Training Organisations:

Qualifications, Skills, Competency and the Revalidation of Part 147
Instructors, Knowledge Examiners, Exam Invigilators and Practical
Assessors
CAP 1528
Published by the Civil Aviation Authority, 2020
Civil Aviation Authority

Aviation House
Gatwick Airport South
West Sussex
RH6 0YR
You can copy and use the text, but please ensure you always use the most up to date version and use it in
context so as not to be misleading. Credit must be made to the CAA.
First published March 2017
Enquiries regarding the content of this publication should be addressed to: [email protected]
The latest version of this document is available in electronic format at: www.caa.co.uk
Revision history and effective pages
Revision Number Summary of Revision Date
01 Initial Issue March 2017
02 Minor Update August 2017
03 Minor Update May 2018
04 Minor Update September 2018
05 Minor Update May 2019
06 Increased Guidance for September 2019

Exam Invigilators
07 Reviewed against EASA September 2020

UG.CAO.00154
CAP 1528 Sep 2020 V7 Page 2

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Contents
Revision history and effective pages 2
Contents 3
Introduction 6
Terminology 7
Engineering Instructor Requirements 8
General 8
Basic Training Instructor/Examiners (Modules 1,2,3,4) 9
Basic Training Instructor/Examiners (Modules 5,6,8) 10
Basic Training/Examiners (Module 7) 12
Basic Training/Examiners (Module 9) 13
Basic Training Instructor/Examiners (Modules 11,12,13,14,15,16,17) 15
Basic Training Instructor/Assessors 16
Type Training Theory Instructor/Knowledge Examiners 19
Type Training Practical Instructors 21
English Language Proficiency 22
Competency of Instructional Staff 22
Acceptance of other type-training courses and their Accreditation 23
Part 147 Requirements 24
Examination Invigilator Requirements 24
Nomination of an Invigilator 24
Invigilator Training 25
Examination Misconduct 26
The continuation of an Instructor, Knowledge Examiner and Practical Assessors
authorisation 26
General 26
Revalidation of Authorisation 27
General 27
Distance Learning – Delivery of Training 28
‘Grandfathering’ 28
General 28
Permanent Instructors V Contract Instructors 28
CAP DRAFT 2020 V7 Page 3

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Additional Guidance 29

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Abbreviations
AMC Acceptable Means of Compliance
GM Guidance Material
MTOE Maintenance Training Organisation Exposition
NPA Notice of Proposed Amendment
EASA European Aviation Safety Agency
CAA Civil Aviation Authority
TNA Training Needs Analysis

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Introduction
This document is intended to provide guidance to UK Part 147 training organisations, for
the initial assessment of qualifications, competencies and skills for the appointment of
engineering instructors, knowledge examiners and practical assessors in respect of
compliance with EC Regulation 1321/2014. This document re-affirms the guidance given
in EASA UG.CAO.00154-002. It also provides guidance for the continuance / revalidation
of existing Part 147 instructors, knowledge examiners and practical assessors.
The assessment process and the continuance / revalidation process should be developed
by the maintenance training organisation and referenced in the relevant maintenance
training organisation exposition (MTOE).
Training organisations should retain a record of the instructors, knowledge examiners,

practical assessors and invigilators training, qualifications and experience for an indefinite
period as well as ensuring that ALL instructional staff are issued with copies of their
personal authorisation certificates.
A record system should be established within the organisation to record the skills,
proficiencies and competencies for the continuance / revalidation of instructors, knowledge
examiners and practical assessors within the approved training organisation. Periodicity of
these checks should be recorded and retained in the individual’s personal training record
file.
The UK Civil Aviation Authority (CAA) or any representative assigned by EASA shall have
access to these records during compliance audits.
This document is subject to periodic revision.

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Terminology
AMC Acceptable means of compliance Part 66 EASA Engineer Training

Regulations
CAA Civil Aviation Authority Part 145 EASA Maintenance Regulations
CAP Civil Aviation Publication Part M EASA Continued Airworthiness

Regulations
CR EU Commission Regulation Part 21 EASA Design and Production

Regulations
CS EASA Certification Specification
EASA European Certification

Specification
MTO Maintenance Training Organisation
MTOE Maintenance Training Organisation

Exposition
TNA Training Needs Analysis

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Engineering Instructor Requirements

General
All aircraft basic skills and type training instructors whether permanently or temporally
employed, must have undergone an instructional techniques training course to a nationally
recognised standard e.g. ISO90001 or equivalent and be able to demonstrate a
comprehensive understanding of the EASA Part 66 and 147 regulatory requirements.
Additionally, they should have a practical working knowledge of the maintenance training
organisations exposition (MTOE) and associated training procedures and be familiar in
their application.
Instructors, knowledge examiners, practical assessors and invigilators within the Part 147
must be listed in Part 1.5 of the MTOE.
EASA Form 4’s are only required for Training Manager, Quality Manager and
Examinations Manager. (In smaller organisations, a combination of these positions may be
held by the same person).
Instructors may with the approval of the CAA also combine roles/ positions within the
training organisations, i.e. knowledge examiner, practical assessor; these other roles must
be clearly identified against the individual within the relevant MTOE and annotated on their
personal authorisation certificates.

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Basic Training Instructor/Examiners (Modules 1,2,3,4)
Basic Training - Theoretical Elements Instructors
Modules 1,2,3,4
Qualification/ Acceptable Means of Compliance Comments/ Limitations

Experience
-Option 1: Knowledge level attested by a school *i.e. college, university etc.… the
specialty diploma* that is recognised by the local diploma’s specialty must be consistent
Authorities, or an acceptable equivalent, with the modules to be taught (the
curriculum must include the appendix 1
or
sub-modules), and the level of the
-Option 2: EASA Part 66 Basic Licence endorsing studies must be adapted to the level (1, 2
Specialty the category (i.e. B1 for B1 instructors) or 3) of the modules to be taught.
knowledge
or
-Option 3: Part 147 Certificates of recognition

(training + exam) for the modules to be taught, at
**In order to avoid conflicts of interest,
the appropriate level (i.e. Module 1 level 2 for a
the Part 147 exam should not be
B1/B2 instructor in module 1 class)**. The scope of
attended in the Part 147 organisation
instruction will be limited to the passed modules.
where the instructor is to exercise its
privileges unless specific measures are
taken and accepted by the surveyor to
demonstrate that the integrity of the
examination is ensured.
-Option 1: Instructor Techniques Training delivered *When the detention of such a certificate
by a legal entity to a nationally recognised standard is imposed by the national authority of the
country where the instructor will exercise
or
his privileges, it should be demonstrated
-Option 2: completion of a “Train the trainer that the certificate is acceptable for this
Pedagogical
course” to a nationally recognized standard. authority, in particular when the certificate
Skills
was issued in another country.
and
Accepted by the Competent Authority following an

in-situ audit in real training conditions.
- A documented familiarisation with the specific

training procedures and requirements (i.e.
Other
organisation of courses, attendance etc...) as
Knowledge
described in the approved Training organisation’s

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exposition (MTOE).
*: however practical experience in A/C

maintenance, design or production
Specialty
activities is advantageous; the advantage
Experience
for the instructor is to understand the
practical applications of a scientific
knowledge and therefore to better
appreciate the knowledge that the
student must receive (i.e. for a
mathematics instructor, the practical
applications may be the reading of
inflation charts, the conversation of units
(metric system…) or determination of a
centre of gravity etc.…)
Basic Training Instructor/Examiners (Modules 5,6,8)
Modules 5,6,8

Experience
- Option 1: Knowledge level attested by a school specialty *: i.e. college, university etc.…
diploma* that is recognised by the local Authorities, or an curriculum must be consistent
acceptable equivalent, with the modules to be taught
(the curriculum must include the
and
appendix 1 sub-modules), and
A training received to gain knowledge about the design, the the level of the studies must be
Specialty function and the operation of relevant typical aircraft systems adapted to the level (1, 2 or 3) of
knowledge and components the modules to be taught
or
-Option 2: Part 66 Basic Licence endorsing the category (i.e. **In order to avoid conflicts of
B1 for B1 instructors) interest, the Part 147 exam
should not be attended in the
or
Part 147 organisation where the
-Option 3: Part 147 Certificates of Recognition (training + instructor is to exercise its
exam) for the modules to be taught, at the appropriate level **. privileges unless specific
measures are taken and

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The scope of instruction will be limited to the passed modules. accepted by the surveyor to
demonstrate that the integrity of
the examination is ensured.
-Option 1: Instructor Certificate delivered by a legal entity

recognised by its local authorities and acceptable to the
national authority where the instructor will exercise his
privileges
or
Pedagogical -Option 2: completion of a “Train the trainer course”

Skills
or
-Option 3: Assessment performed and documented by the

Training Organisation’s Training Manager if himself
appropriately qualified as instructor and in accordance with an
MTOE procedure.
and
Accepted by the Competent Authority following an in-situ audit

in real training conditions.
- A documented familiarisation with the specific training

Other
procedures and requirements (i.e. organisation of courses,
Knowledge
attendance etc...) as described in the approved Training
organisation’s exposition (MTOE).
nil* *: however practical experience
in A/C maintenance, design or
Specialty
production activities is
Experience
advantageous; the advantage for
the instructor is to understand
the practical applications of a
scientific knowledge and
therefore to better appreciate the
knowledge that the student must
receive.

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Basic Training/Examiners (Module 7)
Module 7

Experience
-Option 1: Knowledge level attested by a school* accredited by *: curriculum must be consistent

the local Authorities to issue Aircraft Maintenance & with the syllabus of module 7, level
engineering specialty diploma. The training syllabus should 3.
meet the Part 66 appendix 1 elements at the appropriate level
and for the adequate category/ subcategory (i.e. B1.4)
and
at least a completed A/C type training iaw Part 66 standard,

Specialty
which must be representative of the category/ sub category (i.e.
knowledge
B1.4)
** In order to avoid conflicts of
or interest, the Part 147 exam should
not be attended in the Part 147
-Option 2: Part 66 Basic Licence endorsing the relevant
organisation where the instructor is
category (i.e. B1.1 for B1.1 instructors)
to exercise its privileges unless
and specific measures are taken and
accepted by the surveyor to
at least an A/C type representative of the category/ sub
category (i.e. B1.1) endorsed on the licence
or
-Option 3: Part 147 Certificates of recognition level 3 for the

module 7 (training + exam)**
and
at least a passed A/C Type Training iaw Part 66 standard,

which must be representative of the category/ sub category (i.e. ***: the purpose is to facilitate the
B1.1) use of instructors –non-maintenance
specialised- providing a very
or
specialised training (i.e. on welding)
-Option 4: Specialised training received from acceptable as part of the module7 training and

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training organisations/ institutions for specialised services (i.e. under the oversight of the module 7
for welding, NDT etc..)*** maintenance instructor(s). The
instruction will be limited to the
concerned sub-modules.
-Option 1: Instructor Certificate delivered by a legal entity

recognised by its local authorities and acceptable to the
national authority where the instructor will exercise his
privileges
Pedagogical or
Skills
-Option 2: completion of a “Train the trainer course”
or

MTOE procedure.
and

- A training on EASA regulation: part 66 (basic), 147 (basic)

and 145 (detailed), and the Training Organisation procedures
Other
(MTOE etc..).
Knowledge
Specialty - 3 years of relevant experience in civil aviation environment

Experience (aeronautical maintenance) or acceptable equivalent; the
experience must be representative of the subject(s) to be
taught.
Basic Training/Examiners (Module 9)
Module 9

Experience

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-Option 1: A documented training on Human Factors in *In order to avoid conflicts of

Aviation, of a minimum of 2 days. The syllabus of the training interest, the Part 147 exam should
must comply with Part 66 appendix 1. not be attended in the Part 147
Specialty organisation where the instructor is
or
knowledge to exercise its privileges unless
-Option 2: a certificate of recognition for the module 9 at level 2 specific measures are taken and
(training + exam).* accepted by the surveyor to
-Option 1: Instructor Certificate delivered by a legal entity *When the detention of such a
recognised by its local authorities and acceptable to the certificate is imposed by the
national authority where the instructor will exercise his national authority of the country
privileges* where the instructor will exercise his
privileges, it should be
or
demonstrated that the certificate is
Pedagogical -Option 2: completion of a “Train the trainer course” acceptable for this authority, in
Skills particular when the certificate was

or
issued in another country.

MTOE procedure.
and

- training on EASA regulations: part 66 (basic) and 145

(detailed)
Other
Knowledge and

procedures and requirements (i.e. organisation of courses,
attendance etc...) as described in the approved Training
nil * *: however, experience in an

environment that is representative
Specialty
of human factors affecting aviation
Experience
maintenance (i.e. Line & Base
maintenance experience) is
advantageous;

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Basic Training Instructor/Examiners (Modules

11,12,13,14,15,16,17)
Modules 11,12,13,14,15,16,17

Experience
-Option 1: Knowledge level attested by an aviation *: Diploma’s specialty must be

engineering diploma* recognised by the local Authorities and consistent with the modules to be
covering the subject to be taught, or an acceptable taught (the curriculum must
Specialty equivalent, include the appendix 1 sub-
modules), and the level of the
knowledge or
studies must be adapted to the
-Option 2: Part 66 Basic Licence endorsing the category (i.e. level (1, 2 or 3) of the modules to
B1 for B1 instructors) be taught.
or **In order to avoid conflicts of

interest, the Part 147 exam should
-Option 3: Part 147 Certificates of recognition (training +
exam) for the modules to be taught, at the appropriate level
organisation where the instructor is
**. Scope of instruction will be limited to the passed
to exercise its privileges unless
module(s).
specific measures are taken and
or accepted by the surveyor to

demonstrate that the integrity of
-Option 4: specialised training received from acceptable
training organisations or institutions***
***: the purpose is to facilitate the
use of specialised instructors
providing a very specialised
training (i.e. on hydraulic power)
as part of a complete module and
under the oversight of the training
manager. The instruction will be
limited to the concerned sub-
modules. Acceptable specialised
training may for instance include
specialised training offered by A/C

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manufacturers etc.…
privileges* where the instructor will exercise
his privileges, it should be
or
-Option 2: completion of a “Train the trainer course” acceptable for this authority, in
particular when the certificate was
Pedagogical or
Skills
MTOE procedure.
and
Accepted by the Competent Authority following an in-situ

audit in real training conditions.

Other procedures and requirements (i.e. organisation of courses,
Knowledge attendance etc...) as described in the approved Training
-Option 1: 1 years of relevant experience in a civil aviation

Specialty environment. The experience must be adapted to cover the
Experience subject to be taught and gained in an aviation engineering
dept or in base maintenance AMO.
Basic Training Instructor/Assessors
Basic Training - Practical Elements Instructors

Experience
-Option 1: Part 66 Basic Licence endorsing the appropriate

category/ sub. category (i.e. B1.1 for B1.1 instructors)
and
A/C type endorsed on the appropriate category / sub.

**In order to avoid conflicts of

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category of licence, for each aircraft type used for the training. interest, the Part 147 exam should
or
organisation where the instructor
-Option 2: Part 147 Certificates of recognition** (Cat B1 or B2 is to exercise its privileges unless
as applicable), covering training & exam at level 3 for the specific measures are taken and
module 7, level 2 for modules 9 and 10, and at the level accepted by the surveyor to
defined by part 66 appendix 1 for module 11 to 17***. demonstrate that the integrity of
and
Approved type training (theory + practical) passed in the

appropriate category / sub. category for each aircraft type ***: the required level depends on
Specialty used for the purpose of the training. the instructor’ speciality (airframe
knowledge or avionics).
or
-Option 3: Specialised training received from acceptable

training organisations/ institutions to cover specialised
services (i.e. welding, NDT inspections etc..). ****
The instruction will be limited to the subjects/methods covered

by the specialised training(s). NDT instructors should be
holder of a valid licence iaw EN4179 (level 2 minimum) or
acceptable equivalent.
or
****: the purpose is to facilitate the
-Option 4: A documented release to service authorisation (or use of instructors –non-
an internal certification authorisation) granted by an approved maintenance specialised-
Part 145 organisation iaw the approved MOE and covering providing a very specialised
the subjects to be taught. For aircraft maintenance instructors training (i.e. on welding) as part of
the authorisation should include privileges for A/C certification the module7 training and under
that are comparable to B1 or B2 C/S as applicable and the oversight of the module 7
include each aircraft type used for the purpose of the training. maintenance instructor(s). The
For shop (i.e. structure, components) & specialised services instruction will be limited to the
the qualifications must meet the standard as exposed in the concerned sub-modules.
organisation’s MOE. The instruction will be limited to the
subjects covered by the AMO authorisation(s).
privileges* where the instructor will exercise
his privileges, it should be
or

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-Option 2: completion of a “Train the trainer course” to a acceptable for this authority, in
nationally recognised standard particular when the certificate was
or
-Option 3: a practical instructor privilege (documented)

Pedagogical
granted by the Maintenance organisation when this part is
Skills
contracted out (note: an administrative assessment of the
competency is still required to be completed and documented
by the Part 147 training organisation to determine how the
maintenance organisation qualifies internal instructors)
or

Training Organisation’s Training Manager (if himself
appropriately qualified as practical instructor and in
accordance with an MTOE procedure).
and
Accepted by the Competent Authority following an in-situ

audit in actual training conditions.

Experience
- 3 years of relevant experience. The experience must be * Care should be exercised that
representative of the subject(s) to be taught and gained as the experience gained in a non-
Specialty
following: aeronautical industry is relevant
Experience
and transferable to aviation
1) A/C Maintenance instructor: experience to be gained in a
maintenance practices.
regulated* civil aviation environment or acceptable equivalent,
including line and/ or hangar maintenance experience; If the proposed instructor is from
the military, this experience may
2) Shop Maintenance instructors (component/structural
be considered acceptable
elements etc.…): experience to be gained in approved civil
providing the organisation can
aviation workshops and adequate to the component
evidence suitable training on the
maintenance to be taught.
civil environment and regulations
3) For Specialised Services (Welding, NDT etc.…): relevant
experience to be gained in industry*

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Type Training Theory Instructor/Knowledge Examiners
Type Training - Theoretical Elements Instructors and Knowledge Examiners

Experience
-Option 1: A Part 147 Certificate of Recognition** (training + **In order to avoid conflicts of
exam) issued by a Part 147 training organisation for a type interest, the Part 147 exam
training (level 3) successfully received on the relevant A/C(s) should not be attended in the
and including theory & practical. The Certificate of recognition Part 147 organisation where
should address the category of licence corresponding to the the instructor is to exercise its
speciality of the instructor (i.e. B2 for an avionic instructor) privileges unless specific
measures are taken and
and
accepted by the surveyor to
A refresher/update course on the concerned A/C type if the demonstrate that the integrity
instructor has not instructed the concerned A/C type(s) in a of the examination is ensured.
Specialty
Part 147 environment during the two years preceding its
knowledge employment in the current 147 organisation.
or
-Option 2: a type training (theory + practical) received in a non-

Part 147 organisation. The curriculum/ level of the course must
be equivalent to Part 66 appendix 3. the equivalency of the
course shall be demonstrated to the satisfaction of the
competent authority.
and
A refresher/update course on the concerned A/C type if the

instructor has not instructed the concerned A/C type(s) in a
Part 147 environment during the two years preceding its
employment in the current 147 organisation.
or
-Option 3: a specialised training (i.e. hydraulics) on the

relevant A/C type(s). The curriculum/ level of the course must
comply with at least with Part 66 appendix 3. the scope of
instruction must be limited to the relevant specialty.
and
A refresher/update course on the concerned A/C type or A/C

type concerned systems if the instructor has not instructed the
concerned A/C type(s) in a Part 147 environment during the

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two years preceding its employment in the current 147

organisation.
national authority where the instructor will exercise his national authority of the
privileges* country where the instructor
will exercise his privileges, it
Pedagogical or
should be demonstrated that
Skills
-Option 2: completion of a “Train the trainer course” to a the certificate is acceptable for
nationally recognised standard this authority, in particular
when the certificate was issued
or
in another country.
Option 3: Assessment performed and documented by the
MTOE procedure.
and

Qualification/ Acceptable mean of compliance Comments/ Limitations

Experience
- A documented familiarisation with the specific training Accepted by the Competent

procedures and requirements (i.e. organisation of courses, Authority following an in-situ
Other
attendance etc...) as described in the approved Training audit in real training conditions.
Knowledge
organisation’s exposition (MTOE)
and
- A training on specific instructional methods or training devices

used by the training organisation (i.e. simulators, synthetic
trainers etc.…)
- 3 years of relevant experience, including 1 year of experience * does not apply for new type
on the relevant A/C type(s)*. The experience must be certified aircraft. Contact UK
Specialty
representative of the elements(s) to be taught and gained in CAA for these specific cases.
Experience
civil aviation environment or acceptable equivalent
** For Practical Instructors
(maintenance, engineering, design organisation etc.)
- 3 years of experience on similar aircraft types **

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And
Additional experience on the particular type gained through

type trainings etc.…
Type Training Practical Instructors
Type Training – Practical Assessors

Experience
Specialty Practical assessors should meet the same criteria as the

Knowledge Practical instructor of the concerned elements (i.e. assessor
for landing gear tasks meet the criteria of landing gear
elements practical instructor)
- Completion of a “Train the assessor “course
Pedagogical and
Skills
- an assessment performed and documented by the Training
Organisation’s Examination’s Manager (if himself
appropriately qualified as practical assessor and in
accordance with an MTOE procedure).
-Training to the Organisations procedures (MTOE) addressing

practical assessments
Other
Knowledge and
-Training on specific assessment methods or devices used by

the training organisation (i.e. simulators, synthetic task
trainers etc.…)
-Option 1: 3 years of relevant experience including 1 year of

experience on the relevant A/C type(s). The experience must
Specialty
be representative of the tasks to be assessed and gained in
Experience
approved civil aviation environment or acceptable equivalent,
including line and/ or hangar maintenance experience;

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English Language Proficiency
All instructional staff should be able to meet the Common European Framework of
Reference for Languages: Learning, Teaching, Assessment, abbreviated as CEFR.
The minimum level required for such staff is B1 however all schools should progressively
bring their staff proficiency to a B2 level or above.
Level Description
B1 Can understand the main points of clear standard input on familiar matters
regularly encountered in work, school, leisure, etc. Can deal with most situations
likely to arise whilst travelling in an area where the language is spoken. Can
produce simple connected text on topics which are familiar or of personal
interest. Can describe experiences and events, dreams, hopes & ambitions and
briefly give reasons and explanations for opinions and plans.
B2 Can understand the main ideas of complex text on both concrete and abstract
topics, including technical discussions in his/her field of specialisation. Can
interact with a degree of fluency and spontaneity that makes regular interaction
with native speakers quite possible without strain for either party. Can produce
clear, detailed text on a wide range of subjects and explain a viewpoint on a
topical issue giving the advantages and disadvantages of various options
Competency of Instructional Staff

The instructors (basic & type) should attend a number of lesson “sit-ins” of the type-
training course on the material he or she is to deliver prior to attaining their authorisation.
This number may vary with each organisation, depending upon the experience of the
instructor and their approved procedures.
The instructor should also as part of the initial assessment, prepare and deliver a training
session in a monitored environment, attended and assessed either by the training
manager and/or his delegated representative as part of the organisation’s assessment
process, prior to the instructor being approved to deliver a course, (commonly referred to
as a competency assessment. (CAP 1742 provides more detail for competency).
After the initial assessment the training organisation should conduct regular assessments
of their instructional staff to ensure the competency remains and the instructor is able to
openly discuss and converse with his students on technical matters.

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Acceptance of other type-training courses and their

Accreditation
Other type-training courses received in a non-Part 147 organisation (including theory and
practical elements) can only be considered for acceptance when the curriculum/level of the
course is equivalent to Part 66 Appendix III.
To get these courses accredited for the purpose of satisfying qualification requirements,
the equivalency of the course shall be demonstrated by the maintenance training
organization by following these principles:
When a Part 147 maintenance training organisation intends to nominate training staff not
having attended the relevant type training course in an approved Part 147 maintenance
training organisation (so the instructor does not hold a Part 147 type training certificate),
the internal Quality system of the Part 147 organisation must demonstrate the equivalency
of the other course by reviewing and assessing the following items:
1. Type training syllabus:
Syllabus levels for the type training should be assessed for equivalence to Part 66 Appendix
III for the relevant licence-category;
2. Type training course length:
Verify that the course length is equivalent to an EASA Part 147 course for the same or
similar aircraft type.
3. Type training course provider:
Record the course provider. Assess as far as it is possible that the training documentation/
material came from a reputable source.
4. Category of type training:
Ensure that course completed by the Type instructor is relevant to the scope of the licence
category intended for the course that is to be included in the individual’s approval (e.g.
avionic = avionic type training course and not Airframe/power plant).
5. Theoretical and practical training:
Verify that the course covered the theoretical and practical elements. If the training covered
only the theoretical aspect, then the practical training shall be justified separately. In this
case it should be noted that the practical training may have been carried out in the past as a
structured OJT when the applicant was under the control of an approved maintenance
organisation before CR(EU)1149/2011 became effective.
6. Examination:
Verify that individual training course certificates and the associated examination results are
available. Verification that the exam result is at least equivalent to Part-66 requirements;
Review, when available, the examination paper and assess the multi-choice questions
(number of multi-choice question per hour of training, pertinence of the questions, etc.).

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This process will be the responsibility of the Training Organisation and it is down to them to
develop a process to the satisfaction of the competent authority on how they qualify their staff.
Part 147 Requirements

All Part 147 basic and type instructors should be listed in Part 1.5 of the MTOE. (List of
training instructors, knowledge examiners and practical assessors). This list should identify
the scope of authorisation for each instructor e.g. B1, B2, B757, B777, Airbus 340 etc and
should include specific types/ engines and variants and should also clearly state theory,
practical or both. The Part 147 organisation should ensure that the scope of authorisation
for each instructor, including any sub-contracted instructor, is current and applicable to the
subject being taught.
The Part 147 organisations should ensure that all staff remain conversant with the
requirements of Part 66 / 147 and associated AMC’s, Guidance notes and Notices of
Proposed Amendments (NPA’s) via update training.
A record of instructor / examiner recency check should be retained, by the Part 147
training organisation, demonstrating at least 35 hours of update training carried out over a
24-month period, in both THEORY & PRACTICAL skills (as applicable). And be able to be
produced during audit by the competent authority. (see section 5 Continuation / Update
training)
Examination Invigilator Requirements

Nomination of an Invigilator
An examination invigilator is understood to be someone, who is appointed by the
maintenance training organisation for ensuring the proper conduct of a particular
examination in accordance with the examination procedures of the organisation. The
nomination of such a person can be either permanent, for those examinations taking place
within an approved training address, or ‘ad-hoc’ for those venues where an examination is
taking place away from the approved address (‘one-off’ remote site). The non-permanent
“ad-hoc” nomination is understood to be valid only when the Maintenance Training
Organisation includes an acceptable procedure in the MTOE to control the suitability of the
nominated person in terms of integrity and independence. Accordingly, permanently
appointed examination invigilators should be listed in Part 1.5 of the MTOE and a
paragraph detailing their duties and responsibilities should be included in Part 1 of the
MTOE. It should be noted that the individual can also hold other positions within the
training organisations, (i.e. knowledge examiner, practical assessor, instructor); these
other roles must be clearly defined against the individual within the relevant MTOE. The
procedure for conducting examinations at either approved addresses or locations not listed
in the MTOE should be included at 2.12 and 2.16 of the MTOE.

CAP 1528
Invigilator Training
In all cases, invigilators must be conversant with the Part 147 requirements related to the
integrity of examinations and the security of exam questions; and, with the specific
procedures approved for the maintenance training organisation for the conduct of
examinations.
All invigilators should be trained by either an approved examiner, examinations manager,

training manager or the quality manager on the duties and responsibilities of the invigilator
using the training organisation’s approved procedure.
After the training, an assessment should be recorded, by the quality manager or training
manager. The record should have the date and assessor’s name. The record is to be
retained on the individual’s personnel file. A recurrent training assessment is not required
providing the invigilator remains current i.e. invigilates at least once in each subsequent
12-month period.
The invigilator training should include, but is not limited to, addressing the following areas:
a) The preparation of the classroom / examination room in accordance with the
requirements of the approval under which the course is being delivered.
b) Particular attention is to be drawn towards the spacing between candidates.
Ensuring that desks are spaced so that each student cannot copy from another
student, there should be a minimum of 1 metre between students and each student
should be within direct line of sight (facing the front of the room) of the invigilator.
The invigilator should be able to see every student face-on.
c) Students should be prevented from entering the room until it is properly prepared.
d) Each student’s identity is to be confirmed prior to the examination. If necessary
copies of passports should be reviewed to confirm. In cases whereby outside
attendees are sitting the examination an example of the student’s signature should
also be checked.
e) Adequate security of the examination papers is to be maintained throughout. Only
the correct number of examination papers is to be taken into the examination room.
Under no circumstances is the examination marking sheet to be taken into the
examination room, and at no time should an examination be marked in the vicinity
of the students.
f) Students are to be clearly briefed before the exam. The brief should consist of a
prepared statement and should be addressed to ALL the students at the beginning
of ALL examinations. The brief is to outline the procedures and conditions of the
examination process. This is to include actions to be taken if the examination has to
be stopped for any reason.
g) It is to be made clear that the invigilator should not engage in any form of dialog
with the students during the examination, this should be outlined in the opening
brief.
h) The exam is to be conducted in a manner in keeping with the briefing. The
invigilator is not to conduct any other work whilst monitoring the examination.

CAP 1528
Invigilators selected for a temporary approval should be nominated by the customer’s

quality manager or deputy, who hold a form 4 or equivalent. They should be trained by a
representative of the training organisation who is on-site (instructor). In some cases, it may
be appropriate for the instructor to sit at the rear of the classroom to ensure that the
training organisations procedures are adhered to. However, they must not take part in the
examination procedure.
The training should be conducted using the procedure detailed in the MTOE, detailing the
duties and responsibilities of the invigilator, with particular emphasis on points a) – h)
above and the Part 147 requirements related to the integrity of examinations and the
security of exam questions. (See section 5 for continuation / update training for staff)
Examination Misconduct
The invigilator training should include the procedure detailing the physical actions to be taken in
the event of an Invigilator witnessing or suspecting that cheating is or has taken place during an
examination.
Note: A knowledge examiner shall not issue an examination paper or invigilate an examination
in a subject area where he/she has acted as an instructor.
The continuation of an Instructor, Knowledge Examiner and

Practical Assessors authorisation
General
Part 147.A.105 Personnel Requirements, state: “Instructors and knowledge examiners
shall undergo update training at least every 24 months relevant to current technology,
practical skills, human factors and the latest training techniques appropriate to the
knowledge being trained or examined”. This should also be supported with a valid
competency review for that period.
This training should consist of a minimum of 35 hours within the 24-month period; in
addition, training school personnel are to remain conversant with the latest revision of the
EASA Part 147 regulations, AMC’s, Guidance notes and NPA’s. They should also be
conversant with the respective organisations MTOE and associated training procedures.
Part 147 training organisations should ensure that personnel training records, including
records of qualifications, update training and experience and competency is retained for
each Instructor, Knowledge Examiner and Practical Assessor. It is also expected that a
Part 147 organisation and its instructional staff should be able to evidence recency as part
of the continuation of an approval. Organisations may wish to adopt the standard industry
default of 6 months experience in a 24-month period, alternatively they may wish to define
their own within their approved MTOE, subject to the approval of the competent authority.

CAP 1528
The organisation should deliver continuation training to all its staff in some form or another
depending upon their scope and authorisation. e.g. invigilators and examiners need to be
familiar with exam process, Instructors and assessors the training and assessment
process. See CAP 1742 for additional guidance as to what should be included in
continuation training and how it should be developed.
Revalidation of Authorisation
General
In order for an instructor, knowledge examiner or practical assessor’s authorisation to be
revalidated following renewal / expiry / withdrawal. The maintenance training organisation
should implement a reinstating procedure within their approved MTOE that will cover the
relevant training disciplines associated with the authorisation concerned and evidence of
recency, where applicable.
The criteria for reinstating should take into consideration the length of time the individual
has been away from that specific training environment or discipline.
Any instructor, knowledge examiner or practical assessor who has passed 24-month
period without exercising the privileges of his authorisation, as a minimum, must comply
with the table below:
Inactive Period Recovery Action
24 to 30 months 35 hours update training + continuation

training + training school
procedures/processes + 2 monitored
training sessions with another instructor
covering both theory and practical aspects.
30 to 60 months As above plus two sit-ins on the type course

for the authorisation being sought.
60 months and longer Re-training in the core subject with

successful examination to the current
National/European standard.
The competent authority has the authority to challenge and where necessary refuse any
applicant’s approval to be named as an instructor, assessor or examiner. This is
regardless of whether the applicant has held an instructional position previously (i.e. where
an organisation may be wishing to claim ‘grandfather’ privileges).

CAP 1528
Distance Learning – Delivery of Training

Training managers should ensure instructors are familiar and competent with all methods
of training delivery used by their organisation. Where courses are delivered via distance
learning, training should be given as to the most appropriate delivery method and how the
instructor may have to adapt the delivery style to not only utilise technologies, but to also
ensure the delegate is engaged and receives a good experience.
The TNA should be updated reflect the delivery methodologies/technologies to be used.
CAP 1933 provides further guidance on distance learning.
‘Grandfathering’
General
1. Instructors, examiners and assessors accepted by an organisation via their approved
MTOE prior to the entry into force of the revision of this document and Commission
Regulation EU1149/2011(repealed by EU1321/2014), and exercising their privileges,
or part thereof, at the entry into force of this standard, are considered as fulfilling the
knowledge and experience requirements.
2. However, an assessment of the gap between actual training qualifications and this
standard in order to identify deficiencies in the qualification should be performed by
the Part 147 maintenance training organisation, and a corrective-plan should be
provided to the competent Authority within a reasonable timeframe.
With respect to para: 3.2.1(c) and 3.5.1(b) & (c) of this document, “Grandfather” provisions
accepting full compliance with the above criteria at the time of the entry into force of the
revision of this document cannot be considered as transferrable between different Part 147
maintenance training approvals. Any Instructors, examiners and assessors qualifying in
respect of Section 9(1) above within an organisation after this must comply with the
requirements of Annex IV (Part 147) EU1321/2014
Permanent Instructors V Contract Instructors
Part 147.A.105(c) requires organisation to have a nucleus of permanently employed staff

sufficient to undertake the minimum required to maintain the organisations scope of
approval. Such staff should therefore be directly employed by the organisation and to
giving the necessary capacity and stability with regards to permanently employed
instructors, assessors & examiners to ensure the continued stability of the organisation.
Therefore, ensuring the organisations ability to meet the requirements of its approval and
any subsequent scope. The CAA recently released IN 2017/015 and whilst the document
focuses on Part 145, the principles apply also to Part 147. Any staff on zero hours

CAP 1528
contracts will be considered as contractors unless the organisation can satisfy to the CAA
that an individual:
i) Meets the requirements for an employee;
ii) Is required to report for work when requested;
iii) Does not perform any work for another aviation maintenance training organisation.
A failure to meet any of the requirements above is considered to be a failure of the

organisation to fulfil its obligations under Part 147. Findings of the appropriate level will be
raised in accordance with Part 147.A.160. Where this impacts on the capability of the
organisation to perform its approved scope of work the CAA may decide to suspend, limit
or revoke the affected parts of the approval.
The use of contract instructors is permitted providing the organisation can evidence that
without the use of the contractors they can still support the organisations scope of
approval.
Additional Guidance
For Additional guidance organisations may refer to EASA UG.CAO.00154-002

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SARG AW

Guidance for Part-147 Maintenance Training Organisations:

Civil Aviation Authority

First published March 2017

Revision history and effective pages

Revision Number Summary of Revision Date

01 Initial Issue March 2017

02 Minor Update August 2017

03 Minor Update May 2018

04 Minor Update September 2018

05 Minor Update May 2019

06 Increased Guidance for September 2019

07 Reviewed against EASA September 2020

CAP 1528 Sep 2020 V7 Page 2

CAP DRAFT 2020 V7 Page 3

CAP DRAFT 2020 V7 Page 4

MTOE Maintenance Training Organisation Exposition

NPA Notice of Proposed Amendment

EASA European Aviation Safety Agency

CAA Civil Aviation Authority

TNA Training Needs Analysis

CAP DRAFT 2020 V7 Page 5

Training organisations should retain a record of the instructors, knowledge examiners,

This document is subject to periodic revision.

CAP DRAFT 2020 V7 Page 6

AMC Acceptable means of compliance Part 66 EASA Engineer Training

CAA Civil Aviation Authority Part 145 EASA Maintenance Regulations

CAP Civil Aviation Publication Part M EASA Continued Airworthiness

CR EU Commission Regulation Part 21 EASA Design and Production

CS EASA Certification Specification

EASA European Certification

MTO Maintenance Training Organisation

MTOE Maintenance Training Organisation

TNA Training Needs Analysis

CAP DRAFT 2020 V7 Page 7

Engineering Instructor Requirements

CAP DRAFT 2020 V7 Page 8

Basic Training Instructor/Examiners (Modules 1,2,3,4)

Basic Training - Theoretical Elements Instructors

Qualification/ Acceptable Means of Compliance Comments/ Limitations

-Option 3: Part 147 Certificates of recognition

Accepted by the Competent Authority following an

- A documented familiarisation with the specific

CAP DRAFT 2020 V7 Page 9

*: however practical experience in A/C

Basic Training Instructor/Examiners (Modules 5,6,8)

Basic Training - Theoretical Elements Instructors

Qualification/ Acceptable Means of Compliance Comments/ Limitations

knowledge and components the modules to be taught

CAP DRAFT 2020 V7 Page 10

-Option 1: Instructor Certificate delivered by a legal entity

Pedagogical -Option 2: completion of a “Train the trainer course”

-Option 3: Assessment performed and documented by the

Accepted by the Competent Authority following an in-situ audit

- A documented familiarisation with the specific training

CAP DRAFT 2020 V7 Page 11

Basic Training/Examiners (Module 7)

Basic Training - Theoretical Elements Instructors

Qualification/ Acceptable Means of Compliance Comments/ Limitations