NATA is asking the FAA to set aside a revised draft Advisory Circular (AC) on maintenance human factors training, saying the proposed changes are inconsistent and could be contradictory with existing policies. Draft AC 120-72A, "Maintenance Human Factors Training," is designed to provide guidance for certificate holders to develop and implement aircraft maintenance human factors training programs.

The draft, NATA noted, is based on AC 120-72, which was issued in 2002 and provides guidance for maintenance resource management training programs. The AC sought to establish a maintenance resource management process that corresponded to the cockpit resource management philosophy at the time, NATA said, adding this was intended to help organizations provide training for improved communication, effectiveness and safety in maintenance organizations.

However, NATA stressed that applying a maintenance resource management model to fit human factors “results in a document that does not fit the proper audience.” NATA also pointed out that the AC references a regulatory requirement for human factors training, but said that such training is not required by FAA regulations. “It is a requirement of the European Aviation Safety Agency (EASA),” the association said. “The FAA has taken advantage of the EASA requirement under the bilateral [agreement] to ensure that at least the repair stations with EASA certification have human factors training.” The FAA needs to remove the reference to required human factors training to further analyze the application of such training for regulatory consistency, NATA added.