Competency assessment under AMC1 and AMC2 145.A.30(e): what auditors look for

What is a competency assessment under 145.A.30(e)?

A competency assessment is a documented judgement that a named person is competent for named tasks. AMC1 145.A.30(e) puts it before unsupervised work starts and keeps it under continuous control; AMC2 145.A.30(e) requires a written procedure that specifies nine things. Auditors check that the procedure exists, that it was followed, and that it produced a record.

Nothing in Part-145 says how to run one: the rule sets an outcome, the AMCs describe an acceptable method. Findings live in that gap.

Which rule creates the duty to assess competency?

It is how an organisation discharges a duty written as an outcome. The rule:

“The organisation shall establish and control the competency of the personnel involved in any maintenance, airworthiness reviews, safety management and compliance monitoring in accordance with a procedure and to a standard agreed with the competent authority.” — 145.A.30(e)

Two words do most of the work. Establish is a point-in-time judgement; control is a duty that never ends. AMC1 145.A.30(e) splits them the same way and names who is caught:

“The procedure referred to in 145.A.30(e) should require amongst others that planners, mechanics, specialised services staff, supervisors, certifying staff and support staff, whether employed or contracted, are assessed for competency before unsupervised work commences and competency is controlled on a continuous basis.” — AMC1 145.A.30(e)

Employed or contracted is the part most procedures fail to reflect. AMC2 145.A.30(e)(c) closes the loop:

“All prospective maintenance staff should be assessed for their competency related to their intended duties.” — AMC2 145.A.30(e)(c)

Certifying staff carry a second trigger, in the rule rather than the AMC: 145.A.35(f) requires them to be assessed for competency, qualifications and capability to carry out their intended certifying duties, under a procedure in the Maintenance Organisation Exposition (MOE), before a certification authorisation is issued or reissued. AMC1 145.A.35(f) routes that assessment straight back to AMC 1 to 5 to point 145.A.30(e). One method, two triggers.

Nor is the procedure yours to change quietly. GM1 145.A.85(b) lists among the changes needing prior approval:

“(e) changes to the procedures to establish and control the competency of personnel [145.A.30(e)];” — GM1 145.A.85(b)

What must the procedure contain?

AMC2 145.A.30(e) converts the principle into a checklist:

(a) The organisation should develop a procedure that describes the process for conducting competency assessments of personnel. The procedure should specify:

(1) the persons who are responsible for this process;

(2) when the assessments should take place;

(3) how to give credit from previous assessments;

(4) how to validate qualification records;

(5) the means and methods to be used for the initial assessment;

(6) the means and methods to be used for the continuous control of competency, including how to gather feedback on the performance of personnel;

(7) the aspects of competencies to be observed during the assessment in relation to each job function;

(8) the actions to be taken if the assessment is not satisfactory; and

(9) how to record the assessment results.

— AMC2 145.A.30(e)(a)

Nine items, nine places to fail. What each must name, and the evidence behind it:

#	What your procedure must name	Evidence an auditor asks for
1	Who owns the process and may sign an assessment	A named role, not “management”; a signature matching it
2	The triggers: unsupervised work, certification authorisation, scope change	A joiner’s start date against the assessment date
3	The rules for crediting an earlier assessment	A file where credit was given, and on what basis
4	How licences and certificates are checked back to the issuer	A confirmation check on record, not a photocopy
5	The initial method: observation, knowledge test, interview, or a mix	A completed form showing the method used
6	How competency is watched afterwards, and feedback collected	Error feedback reaching the assessment file
7	The competencies observed, job function by job function	Different criteria for a planner and a supervisor
8	What happens when someone is not yet competent	One case where the answer was not “pass”
9	The record format, where it is filed, who may read it	The record itself, retrievable in reasonable time

Item 7 separates a real procedure from a template: one form for every job title cannot show which competencies are observed per job function.

How is competency evaluated?

AMC1 145.A.30(e) names three strands and expects all three:

Competency should be assessed by the evaluation of:

− on-the-job performance and/or testing of knowledge by appropriately qualified personnel, and

− records for basic, organisational, or tasks training and/or product type and differences training, and

− experience records.

— AMC1 145.A.30(e)

Paperwork alone is not an assessment; nor is observation alone. AMC1 adds a validation step most files skip:

“Validation of the above could include a confirmation check with the organisation(s) that issued the document(s). For that purpose, experience/training may be recorded in a document such as a log book, or based on the suggested template in GM3 145.A.30(e).” — AMC1 145.A.30(e)

How long observation runs is deliberately elastic:

“Competency may be assessed by having the person work under the supervision of another qualified person for a sufficient time to arrive at a conclusion. Sufficient time could range from several days to several weeks depending on the complexity of the task(s) and the work exposure. The person need not be assessed against the complete spectrum of their intended duties. […] a written confirmation from the previous organisation could be taken into consideration to reduce the duration of the assessment.” — AMC2 145.A.30(e)(b)

That is permission to be proportionate, not brief by default. The elided condition is that the person was recruited from another approved maintenance organisation, and the shortcut is a confirmation on file, not an assumption.

The assessment must then decide something:

As a result of this assessment, an individual’s qualifications should determine:

− the scope of tasks this individual is authorised to perform and/or supervise and/or sign off (as applicable) or which level of ongoing supervision would be required;

− whether there is a need for additional training.

— AMC1 145.A.30(e)

AMC1 recommends job descriptions detailed enough to enable the assessment, and its fifth consideration sets out what the criteria establish:

“Criteria should allow the assessment to establish that, among other aspects (titles might be different in each organisation):” — AMC1 145.A.30(e), item 5

Ten bullets follow, one per job family, ending with one for everybody: all staff familiar with the safety policy and the tools for internal safety reporting. AMC1 then names GM2 145.A.30(e) as the basis — a non-exhaustive table of knowledge, understanding, ability and skill elements crossed against eight job-function columns, and a ready-made starting point for item 7.

How does training fit in?

Training is an input to the assessment and an output of it, never a substitute. The first three considerations in AMC1 145.A.30(e) say so:

1. In accordance with the job function, adequate initial and recurrent training has been received by the staff and recorded to ensure continued competency so that it is maintained throughout the duration of the employment/contract.

[…]

3. All staff should be able to demonstrate an understanding of the safety management principles, including human factors related to their job function, and be trained as per AMC4 145.A.30(e).

— AMC1 145.A.30(e)

Elided item 2 asks that staff demonstrate knowledge of and compliance with the organisation’s own procedures. Item 1 requires training to have been received and recorded; item 3 hard-wires AMC4 145.A.30(e) into the judgement. Our guide on how often human factors training is required covers that clock; the MOE training chapter guide covers where the procedures sit.

AMC3 145.A.30(e) adds the maintaining duty:

(a) Adequate initial and recurrent training should be provided in relation to the job function to ensure that staff remain competent. Completion of such training should be recorded.

— AMC3 145.A.30(e)(a)

Its point (b) ties continuation training to what your people report through the internal safety reporting scheme — the loop item 6 has to close — and point (c) requires those managing compliance monitoring to be trained on that task: requirements, manuals and procedures, audit techniques, reporting and recording.

Note the direction of travel in AMC4 145.A.30(e)(b) too. Initial safety training is due before the job function starts, unless the competency assessment justifies that there is no need for it. The assessment can waive the training; training cannot waive the assessment.

What records prove it?

One sentence in AMC1 fixes the obligation:

“A record should be kept of each individual’s qualifications and competency assessment (refer also to point 145.A.55(d)). This should include copies of all documents that attest to their qualifications, such as a licence and/or any authorisation held, as applicable.” — AMC1 145.A.30(e)

Retention sits in 145.A.55(d): records of the qualifications, training and experience of personnel involved in maintenance, compliance monitoring and safety management are kept while the person works for the organisation, and at least 3 years after they leave or an authorisation is withdrawn. AMC1 145.A.55(d) adds the minimum fields for certifying and support staff — basic training, task or type training, continuation training, experience, qualifications, and the scope and dates of the authorisation — in any format, controlled by the compliance monitoring function.

For experience arriving from elsewhere, GM3 145.A.30(e) does publish a template, headed “Aviation Maintenance personnel experience credential”. It records the maintenance organisation and approval number, the period and domain of employment, the work performed, licence categories and types, certification privileges, tick-boxes from specialised services to safety management, training received from the contracting organisation, and a certified-by block. Its advisory note reads:

“A copy of the present credentials will be kept for at least 3 years from their issuance by the maintenance organisation.” — GM3 145.A.30(e)

It is a credential to be considered during an assessment elsewhere, not an assessment form. EASA publishes no form for the assessment itself; item 9 of your procedure settles that.

Where do auditors find the gaps?

A procedure missing one of the nine items. Check items 3, 6 and 8 specifically: credit rules, continuous control, and what happens when the answer is no.

Contracted staff outside the process. AMC1 catches them expressly — employed or contracted — so check that agency files carry assessments too.

One criteria set for every job function. GM2 145.A.30(e) shows what per-function criteria look like.

Assessments with no adverse outcome, ever. A process that never restricts a scope or orders training reads as a signing exercise.

Certificates never checked back to their issuer. AMC1 says validation could include a confirmation check, so it is not mandatory — but where the issuer is unfamiliar, expect a question.

Related courses. EASA Part-145 Safety Training including Human Factors – Initial covers the safety management and human factors understanding that item 3 of AMC1 145.A.30(e) requires every assessment to establish. EASA Part-145 Regulatory Training – Initial covers the rule structure this guide relies on.