A Perspective from the Aviation Regulatory Training Standards Association (ARTSA)

This discussion clarifies the regulatory boundaries of EASA Part-147 organizations and defines the role of the EASA Inspector regarding specialized third-party training providers, in accordance with EASA FAQ n.19073.

The existence of specialized providers offering extensive portfolios of regulatory and vocational training illustrates why the EASA Inspector’s role must be clearly distinguished between the Provider (Part-147/Third-Party) and the User (Part-145/CAMO).

The Regulatory Reality: The Limits of Part-147

A common industry misconception is that all regulatory training, such as Safety Management Systems (SMS), Human Factors, or Part-145 Essentials, requires a Part-147 “stamp” of approval to be valid.

This is a misunderstanding of the regulation.

• Part-147 Limits – This approval is strictly reserved for Part-66 Basic and Type training.
• The “Other” 90% – Specialized providers often operate in the “Regulatory Training” space (vocational and regulatory compliance), which sits, by definition, outside the narrow privileges and audit scope of a Part-147 approval.

Important Note – Exclusion from the Approval Schedule As clarified in EASA FAQ n.19073, courses that do not lead to Part-66 qualifications cannot be part of an organization’s Part-147 Approval Schedule.

• Because they are not within the official scope of the training organization’s approval, the Agency or Member State does not “approve” the pedagogy, content, or delivery platform (e.g., e-learning vs. classroom) for these courses under the Part-147 banner.

The Inspector’s Focus: Acceptance vs. Approval

When an EASA Inspector audits a maintenance organization (Part-145), their role regarding a certificate from a third-party provider is not to “approve” the school, but to assess the “Acceptance” process of the Part-145 organization.

Validating Competence Oversight Instead of debating the “delivery method”, such as whether an online diploma is as effective as a classroom setting, the Inspector focuses on regulatory requirements like 145.A.35.

• The Question – Is the staff member actually competent to perform their assigned tasks?
• The Answer – The certificate from a third-party provider is a “Record of Training.” The validation of competence remains the legal responsibility of the Part-145 or CAMO organization, not the training provider or the Part-147 approval.

How the Inspector Validates External Training

Since an Inspector cannot possibly audit every delivery method or slide in an external provider’s extensive catalog, they assess the Maintenance Organisation Exposition (MOE) or CAME.

They challenge the Quality Manager with questions such as:

• “How did your Quality System verify that this external course meets our internal standards?”
• “Did you audit the syllabus or content before enrolling your staff?”

Managing Competence in the “Non-Regulated” Space With providers offering specialized Diplomas (e.g., CAMO Diplomas or Quality & Safety Packages), the EASA Inspector’s role shifts toward Competence Management Oversight. The Inspector verifies that the Quality Manager has vetted the third-party training to ensure it meets the organization’s specific needs.

The Inspector’s Role: Non-Interference at the Provider Level

It is crucial to understand where the Inspector’s jurisdiction begins and ends during a Part-147 audit:

• Primary Role. To ensure compliance with the requirements for Basic and Type training.
• Non-Interference. The Inspector should not include the choice of delivery method, content, or scope of “extra” commercial courses in their assessment.
• Organizational Freedom. Training organizations (including non-147 organizations) are free to provide these courses as commercial entities, but they do so without the specific “EASA Part-147” stamp of approval for that specific content.

Summary: Oversight at the User Level

If the EASA Inspector does not audit these courses at the training provider level, the responsibility shifts entirely to the User.

• At the Part-147 Organization – The Inspector ensures they are not certifying non-Part-66 courses under their 147 stamp.
• At the Part-145/CAO Organization – The Inspector assesses the “appropriateness” of the training received by the staff rather than the training provider itself.