How often is human factors training required in an EASA Part-145 organisation?

How often is human factors training required under EASA Part-145?

Initial safety training including human factors before a person starts the job function, then further training in each 2-year period. That is the rule for everyone AMC4 145.A.30(e) lists, from nominated persons to stores staff. For certifying staff and support staff the 2-year cycle is a hard requirement in point 145.A.35(d), which asks for sufficient training in each 2-year period to keep knowledge of technologies, procedures and safety management, including human factors, up to date.

The rest of this guide gives you the exact wording, the full list of who is in scope, what the second and later sessions must contain, why a Part-66 module does not substitute for any of it, and how to keep the due dates from slipping.

What exactly does the regulation say about frequency?

Two clauses carry the requirement and they are worth quoting rather than paraphrasing.

Point 145.A.30(e) sets the competency duty. The organisation shall establish and control the competency of personnel involved in maintenance, airworthiness reviews, safety management and compliance monitoring, in accordance with a procedure and to a standard agreed with the competent authority, and that competency must include an understanding of the application of safety management principles, including human factors and human performance issues, appropriate to the person’s function.

Point 145.A.35(d) turns the cycle into a rule for a specific population:

“The organisation shall ensure that all certifying staff and support staff receive sufficient recurrent training in each 2-year period to ensure that they have up-to-date knowledge of relevant technologies, organisation procedures and safety management, including human factor issues.” — 145.A.35(d)

The acceptable means of compliance for the wider staff population is AMC4 145.A.30(e), “Safety training (including human factors)”. Its point (c) says the follow-on training:

“should be of an appropriate duration in each 2-year period in relation to the relevant compliance monitoring audit findings and other internal/external sources of information available to the organisation on safety and human factors maintenance issues.” — AMC4 145.A.30(e)(c)

Note the phrasing. The rule is “in each 2-year period”, a rolling window, rather than “within 24 months of the last certificate”. The only safe way to run a rolling window is to anchor it: take the date of the last training, and complete the next session before that date plus 24 months. That is the convention this site’s due-date tool uses, and it is the convention your Maintenance Organisation Exposition (MOE) should state.

Who is in scope?

Point (a) of AMC4 145.A.30(e) says all maintenance organisation personnel should be assessed for the need to receive initial safety training, and that personnel involved in delivering the basic maintenance service should receive both initial and further training appropriate to their responsibilities. It then lists, as a minimum:

• nominated persons, line managers and supervisors;
• certifying staff, support staff and mechanics;
• technical support personnel such as planners, engineers and technical records staff;
• persons involved in compliance monitoring and safety management processes, including human factors principles, internal investigations and safety training;
• specialised services staff;
• stores department staff and purchasing department staff;
• ground equipment operators.

“Line managers” is defined in the same point as departmental heads or persons responsible for operational departments or functional units directly involved in delivering the basic maintenance service. In practice the only people outside the list are those with no influence on the maintenance product, and even they should appear in the assessment record as “assessed, no training required”.

What is special about certifying staff and support staff?

They are covered twice. AMC4 145.A.30(e) places them in the safety training population like everyone else. Point 145.A.35(d) then adds a regulatory, not merely acceptable-means, requirement for training in each 2-year period, and its AMC1 describes what that training is for: a two-way process that keeps staff current on technical knowledge, procedures and safety management, and gives the organisation feedback on the adequacy of its procedures and maintenance instructions.

AMC1 145.A.35(d) is also the only place the guidance gets specific about duration. For an organisation maintaining aircraft with few relevant audit findings, the training could be limited to days rather than weeks. With many findings it may take several weeks. For component organisations it scales down, so certifying staff who release hydraulic pumps may only require a few hours, whereas those who release turbine engines may need a few days. The content should be related to relevant audit findings, hazards and identified safety risks, and the training programme should be reviewed at least once in every 24-month period.

What must continuation training contain?

Three things, and a generic slide deck covers only the first.

1. The syllabus, revisited. AMC4(c) says the primary purpose is to ensure staff remain current in terms of SMS principles and human factors. The GM1 145.A.30(e) syllabus, eleven topics from the introduction to safety management through human error, human performance, environment, procedures, communication, teamwork and professionalism to the organisation’s safety programme, is the reference for that currency.
2. Feedback from your own organisation. AMC4(c) says the second purpose is to collect feedback on safety and human factors issues, that compliance monitoring and key safety management staff should be involved, and that there should be a procedure for trainers to report feedback formally through the internal safety reporting scheme under 145.A.202.
3. What changed. AMC1 145.A.35(d) point 2 lists changes to the modification standard of the products maintained, changes to the requirements such as Part-145 itself, changes to the organisation’s procedures, safety policy and objectives, human factors and safety issues from internal or external analysis, and instances in which staff failed to follow procedures and why.

An external course can carry the first element for you. The second and third are yours: even the best online course does not know your audit findings. The efficient split is a course for the regulatory syllabus and a short in-house session, led by the safety manager, for the organisation-specific content. Both go in the record.

Does Part-66 Module 9 count?

No, and the reason is worth understanding because the two are often confused.

	Part-66 Module 9	Safety training under 145.A.30(e)
Legal basis	66.A.25 basic knowledge requirements, Appendix I to Part-66	145.A.30(e), AMC4 145.A.30(e), 145.A.35(d)
Purpose	Knowledge for the aircraft maintenance licence	Competency of the organisation’s staff
Who	Licence applicants	Everyone on the AMC4 list, licensed or not
Assessment	Multiple-choice examination under Appendix II (28 questions since Regulation (EU) 2023/989)	Whatever the MOE specifies; no examination prescribed
Frequency	Once, for the licence	Initial, then in each 2-year period
Syllabus	Appendix I Module 9 sub-modules	GM1 145.A.30(e) topics, adjustable to the organisation

A Module 9 pass tells you the licence holder studied human factors once. It does not tell you they understand your organisation’s safety programme, and it does not recur. AMC4(b) does allow the competency assessment to conclude that a new joiner needs no initial training, and Module 9 knowledge can be part of that judgement, but the 2-year cycle still applies from then on.

How do you track the due dates?

Four habits keep organisations out of findings:

1. One record per person, one date per subject. Safety training including human factors, fuel tank safety Phase 2 and EWIS each run on their own 2-year cycle. Do not merge them into a single “HF” date.
2. Anchor on the training date, not the certificate print date. They can differ by weeks.
3. Plan the session at 18 to 21 months. That leaves a quarter for shift patterns, leave and the occasional missed class before the 24-month line.
4. Put the convention in the MOE. Say which date starts the period and how you treat staff who were trained at a previous employer.

The continuation due-date tool on this site does the arithmetic and exports a calendar entry, and each course page states which cycle it serves.

Related courses. Part-145 Safety Training including Human Factors — Initial for staff without a prior certificate; the Continuation course for the 2-year cycle; Part-66 Module 9 and Safety Training — Initial for licence candidates who also want the organisational syllabus.