ED Decision 2015/029/R
1. The pre audit procedure should focus on establishing compliance with the training and examination standards set out in Part-147 and Part-66.
2. The fundamental reason for allowing a maintenance training organisation approved under Part-147 to sub-contract certain basic theoretical training courses is to permit the approval of maintenance training organisations, which may not have the capacity to conduct training courses on all Part-66 modules.
3. The reason for allowing the subcontracting of training modules 1 to 6 and 8 to 10 only is, most of the related subjects can generally also be taught by training organisations not specialised in aircraft maintenance and the practical training element as specified in 147.A.200 does not apply to them. On the contrary, training modules 7 and 11 to 17 are specific to aircraft maintenance and include the practical training element as specified in 147.A.200. The intent of the ‘limited subcontracting’ option as specified in 147.A.145 is to grant Part-147 approvals only to those organisations having themselves at least the capacity to teach on aircraft maintenance specific matters.
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