Part-145 training records: what to keep, for how long, and what a surveyor asks for

What training records must a Part-145 organisation keep?

Under EASA/UK Part-145, not FAA 14 CFR 145.163, point 145.A.55(d) requires records of the qualifications, training and experience of everyone involved in maintenance, compliance monitoring and safety management. They are kept for as long as the person works for the organisation and at least 3 years after they leave.

Everything else — the record’s fields, its format, who may read it — sits in the AMC, not the rule.

Which records does 145.A.55(d) require?

Two groups, named separately:

(d) Personnel records

(1) The organisation shall ensure that the following records are retained:

(i) records of the qualifications, training and experience of the personnel involved in maintenance, compliance monitoring and safety management;

(ii) records of the qualifications, training and experience of all airworthiness review staff.

— 145.A.55(d)(1)

The first limb reaches well past certifying staff. AMC1 145.A.30(e) reads the same population as planners, mechanics, specialised services staff, supervisors, certifying staff and support staff, whether employed or contracted — everyone needing a competency assessment needs a record too.

Point (d)(2) adds content for airworthiness review staff: qualifications held, a summary of relevant continuing airworthiness experience and training, and a copy of the airworthiness review authorisation. Point (d)(3) adds content for certifying and support staff:

(3) The records of all the certifying staff and support staff shall include the following:

(i) the details of any aircraft maintenance licence held under Annex III (Part-66) or equivalent;

(ii) the scope of the certification authorisations that were issued to that staff, where relevant;

(iii) the particulars of the staff that held limited or one-off certification authorisations referred to in point 145.A.30(j).

— 145.A.55(d)(3)

Item (iii) reaches beyond permanent staff: a one-off authorisation issued to a pilot or another organisation’s engineer creates a personnel record obligation of its own.

Safety training joins the same file by cross-reference. AMC4 145.A.30(e) closes:

“Safety training is subject to the record-keeping requirements in point 145.A.55(d).” — AMC4 145.A.30(e)(c)

How long must they be kept?

One sentence, two triggers:

(4) Personnel records shall be kept for as long as a person works for the organisation, and shall be retained for at least 3 years after the person has left the organisation, or after an authorisation issued to that person has been withdrawn.

— 145.A.55(d)(4)

Leaving is the obvious trigger. Withdrawal of an authorisation is the other, and it can fire while the person is still on the payroll — a scope narrowed, a type removed, an authorisation revoked. Check that the file of a still-employed engineer whose authorisation was withdrawn is still recoverable.

When the clock starts is answered in the AMC:

“The retention period starts when the record is created or was last amended.” — AMC1 145.A.55(b)

The other classes in 145.A.55 run to different periods, so one organisation-wide retention instruction under-retains. Point (a)(3) sets 3 years from the certificate of release to service for detailed maintenance records and associated data; point (c) requires records of management system key processes (145.A.200) and contracts (145.A.205) to be retained for a minimum period of 5 years. AMC1 145.A.55(d) adds a floor where the relevant provision specifies no period: in the absence of any such indications, a minimum of 3 years.

What does a certifying staff record contain?

The rule gives three items. AMC1 145.A.55(d) gives eleven:

1. The following minimum information, as applicable, should be kept on record in respect of certifying staff or support staff:

(a) Name;

(b) Date of birth;

(c) Basic training;

(d) Task training or product/type training;

(e) Recurrent training;

(f) Experience;

(g) Qualifications relevant to the authorisation;

(h) Scope of the authorisation (role, product, level of maintenance, etc.);

(i) Date of first issue of the authorisation;

(j) Expiry date of the authorisation (if appropriate); and

(k) Identification number of the authorisation.

— AMC1 145.A.55(d)

Items (c) to (f) are the training and experience spine; (g) to (k) describe the authorisation it supports. Item (e) — continuation training, in this site’s naming — is what 145.A.35(d) requires in each 2-year period, and AMC1 145.A.35(e) says where its evidence ends up:

“The programme for recurrent training should list all certifying staff and support staff and when the training will take place, the elements of such a training, and an indication that it was carried out on time as planned. Such information should subsequently be transferred to the certifying staff and to the support staff records as required by point 145.A.55(d)(3).” — AMC1 145.A.35(e)

A training plan that stays in the training department, never reaching the personnel record, is a gap the AMC names. Control is settled too: the record may be kept in any format but should be controlled by the compliance monitoring function — which, AMC1 adds, does not mean the compliance monitoring manager runs the system.

Two duties in 145.A.35 attach to the authorisation rather than the file:

(j) The organisation shall provide certifying staff with a copy of their certification authorisation in either a documented or electronic format.

(k) Certifying staff shall produce their certification authorisation to any authorised person within 24 hours.

— 145.A.35(j) and (k)

Point (j) is the organisation’s duty, (k) the individual’s. Where authorisations exist only as database rows, (j) is unmet and (k) is hard to meet.

What does a surveyor ask to see?

Not a prediction — an entitlement. Point 145.A.140 grants the access:

“[…] the organisation shall ensure that access to any facility, aircraft, document, records, data, procedures or to any other material relevant to its activity subject to certification, whether it is subcontracted or not, is granted to any person authorised by […]” — 145.A.140

The first elision is the purpose clause; the second names the competent authority defined in point 145.1 and the authority performing oversight tasks under point 145.B.300(d). Personal records are named in the AMC:

“The competent authority is authorised to access personal records when investigating the records system for initial certification and oversight, or when the competent authority has cause to doubt the competency of a particular person.” — AMC1 145.A.55(d)

The entitlement covers the system and the individual file. AMC1 145.A.55(a) sets what the system must deliver: all records accessible within a reasonable time whenever they are needed, organised so as to ensure traceability and retrievability throughout the retention period. Retrieval speed is a compliance question.

Three more checks follow from the text. Point 145.A.55(f) puts the format of the records in the organisation’s procedures, so the Maintenance Organisation Exposition (MOE) must describe it — AMC1 145.A.70(a) offers chapters 3.10, 3.14 and 3.22 (drafting guide). Point 145.A.55(e) requires a record-keeping system allowing adequate storage and reliable traceability of all activities; point 145.A.55(g) requires records protected from damage, alteration and theft.

How do external certificates fit the record?

A certificate from an outside provider is a document in the file, not the file. AMC1 145.A.30(e) fixes that:

“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)

The same AMC allows a validation step: validation could include a confirmation check with the organisation that issued the documents. AMC 145.A.35(a) point 5 restates the retention link — copies of the documents attesting to the holder’s competency and recent experience, held for the period in point 145.A.55(d)(4).

Three things sit behind a purchased course, and all three belong on file. First, the certificate, with the issuing organisation identifiable so a confirmation check is possible. Second, a mapping from course content to the syllabus the rule requires — for EWIS, the target-group programme in AMC 20-22, whose section 8(a) leaves assessment of the objectives to the training organisation’s discretion, by written test, oral test or demonstration of skills. Third, the competency assessment under 145.A.30(e), which cannot be bought in. Our guides on online training and the human factors interval cover the first two.

The records at a glance

Record	Clause	Retention	Evidence named in the cited text
Personnel in maintenance, compliance monitoring and safety management	145.A.55(d)(1)(i)	Employment + at least 3 years	Copies of documents attesting to qualifications; the competency assessment record (AMC1 145.A.30(e))
Airworthiness review staff	145.A.55(d)(1)(ii), (d)(2)	Employment + at least 3 years	Qualifications held; a summary of continuing airworthiness experience and training; a copy of the review authorisation
Certifying staff and support staff	145.A.55(d)(3), AMC1 145.A.55(d)	Employment + at least 3 years	Part-66 licence details; scope of the certification authorisation; particulars of limited or one-off authorisations; the eleven fields of AMC1 145.A.55(d)
Safety training, including human factors	AMC4 145.A.30(e)(c), routed to 145.A.55(d)	Employment + at least 3 years	Completion of the training recorded (AMC3 145.A.30(e)(a))
Continuation training for certifying and support staff	145.A.35(d), AMC1 145.A.35(e)	Employment + at least 3 years, inside the (d)(3) record	The programme listing staff, dates, elements, and an indication it ran on time as planned
Detailed maintenance records, including certificates of release to service	145.A.55(a)(3)	3 years from issue of the certificate	Records proving the requirements for issue were met, plus associated maintenance data
Management system key processes and contracts	145.A.55(c)	Minimum 5 years	Key process records (145.A.200); contracts (145.A.205)

Where record systems come apart

One retention rule for the whole organisation. Three periods live in 145.A.55: 3 years, 5 years, and employment plus 3 years.

The withdrawal trigger ignored. Point (d)(4) starts the clock on withdrawal as well as on departure.

Nothing transferred. AMC1 145.A.35(e) requires the programme’s evidence to reach the personnel record; 145.A.35(j) requires a copy of the authorisation to reach its holder.

Backups beside the working data. AMC1 145.A.55(d) asks for backup hardware in a different location.

Related courses. EASA Part-145 Regulatory Training – Initial covers Part-145 Section A, including the record-keeping and certifying staff requirements this guide relies on.