How do we comply with the new part 147 when there are challenges procuring equipment to teach new ACS elements?
Q: The ACS includes some new knowledge, risk mitigation, and skill elements that are not incorporated into our current part 147 program. The program is unable to procure the equipment necessary to adequately teach these elements in time to meet the Sept. 21 requirement. How are we expected to comply with the new rule if we can’t obtain the equipment in time to align our curriculum to the new mechanic airman certification standard?
A: First, since the vast majority of ACS elements are not new, we suggest you triple check that the element is in fact new and it’s not already addressed in the current part 147 curriculum requirements or in the practical test standard. If the element is incorporated in one of those documents, ask yourself how the program is addressing the element now? What equipment is the local DME using to test that element? So long as your curriculum addresses the element, the program is in compliance with the new rule.
For truly new elements (we estimate that around 9% of ACS elements are in fact new), part 147 will require that the school “align” curriculum with the standard, but the rule does not dictate how a program imparts the knowledge. The “how” is totally up to the school, including what equipment it decides to use. And just because the element is listed as a required skill in the certification standard, doesn’t mean you HAVE to tie it to a hands-on project. While that might certainly be the best way to impart the skill; for purposes of regulatory compliance, all the program needs to do is ensure the curriculum addresses it. Can it be addressed with a paper project?
For instance, the ACS requires schools to “troubleshoot an air-cycle air conditioning system.” While it would be great to have an air cycle machine or training aid to facilitate teaching of that skill, lead times are long and the school may not have the immediate funding to procure the equipment. The rule requires that the element be taught, but does not dictate how it is taught, that is up to the school. In the absence of the ideal equipment, schools must get creative.
Perhaps the program illustrates troubleshooting with an unserviceable component donated by an industry partner. It could use an online solution that allows the student to effectively troubleshoot in a virtual environment. It could provide the student with a maintenance manual and discrepancy scenarios for the student to research, troubleshoot, and describe possible repair solutions.
These potential approaches are not meant to suggest schools should not procure new equipment, but are a means of compliance in the short term, allowing the program to process and prioritize equipment purchases in the long term, as revised FAA guidance is published (i.e., 8083 handbook revisions) and student outcomes are assessed.
It's also important to consider that the FAA written, oral, and practical exams will not test any new ACS elements until next summer. Officials have told said DME minimum equipment lists will not change (at least in the short term). So, as long as the school ensures all ACS elements are addressed on Sept. 21, it has time to “perfect” training to ensure student outcomes meet expectations. In other words, the new rule requires that you teach it, but it won’t be tested by the FAA for another year.
In short, new equipment purchases are not mandated by the new part 147. Since the DME minimum equipment list isn’t expected to change, and the mechanic test won’t be revised until next summer, part 147 programs must get creative to ensure each element of the ACS is addressed with on hand or easily accessible resources. So long as the element is addressed, the school will comply with the new rule.
This issue was the topic of an ATEC Aug. 25, 2022 webinar. Check out the recorded version on the ATEC webinar channel.
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