Part-66 Module 9 versus Part-145 human factors training: same words, different rules

Does Part-66 Module 9 count as Part-145 human factors training?

They are two obligations in two Annexes. Part-66 Module 9 is basic knowledge for an aircraft maintenance licence, demonstrated by examination under 66.A.25 and Appendix I. Part-145 safety training including human factors is a duty on the organisation under 145.A.30(e). Passing one does not discharge the other.

The syllabuses read alike — error models, fatigue, shift handover, just culture. The rules behind them share almost nothing: different Annex, different addressee, different assessment, different clock, different permitted deliverer.

What is Part-66 Module 9 for?

Module 9 exists to be examined. Point 66.A.25(a) states the duty and puts it on the individual:

(a) The applicant for an aircraft maintenance licence shall demonstrate by examination a level of knowledge of the related subject modules in accordance with Appendix I (applicable to category A, B1, B2, B2L, B3 and C licences) or Appendix VII (applicable to category L licences).

— 66.A.25(a)

The Appendix I modularisation matrix marks Module 9 with an X in every column — A1 to A4, B1.1 to B1.4, B3, B2, B2L and C. Since Regulation (EU) 2023/989 replaced Appendix I, the module runs to ten sub-modules:

9.1 General

9.2 Human performance and limitations

9.3 Social psychology

9.4 Factors that affect performance

9.5 Physical Environment

9.6 Tasks

9.7 Communication

9.8 Human error

9.9 Safety management

9.10 The ‘Dirty Dozen’ and risk mitigation

— Appendix I to Part-66, Module 9

The level column reads 2 for every sub-module except 9.3, 9.5 and 9.6, which are level 1, and it carries one value for all categories, so category A and B2 applicants are examined to the same depth. AMC1 Appendix I, Section 2 expands each heading into sub-topics. Sub-module 9.9 carries the safety-management material that also appears on the Part-145 side:

9.9 Safety management

Risk management;

Occurrence reporting;

Safety culture

Just culture;

Identifying, avoiding, and reporting hazards;

Organisational human-factors programme: professionalism and integrity, error-provoking behaviour, reporting errors, disciplinary policy, error investigation, […];

Dealing with emergencies.

— AMC1 Appendix I to Part-66, Section 2

Sub-module 9.10 lists the twelve items of the ‘Dirty Dozen’, then risk-mitigation methods. Both headings came in with the regulation that also reshaped Module 10; the old Module 9A ran 9.1 to 9.9 and ended at hazards in the workplace.

The assessment is fixed, not left to a provider. Appendix II, point 2.9:

2.9. MODULE 9 – HUMAN FACTORS

Category A, B1, B3, B2 and B2L: 28 multiple-choice, no essay questions.

Time allowed: 35 minutes.

— Appendix II to Part-66, point 2.9

Three general points govern it. Point 1.2 gives each question three alternative answers of which only one is correct, on a nominal average of 75 seconds per question. Point 1.7 sets the pass mark for the multi-choice part of each module and sub-module at 75 %. Point 1.11 blocks a retake earlier than 90 days after a failed module examination, reduced to 30 days where a Part-147 organisation delivers retraining tailored to the failed subjects.

Who may run it is closed as well. Point 66.A.25(b) requires the examinations to comply with Appendix II and to be conducted by a training organisation approved under Annex IV (Part-147) or by the competent authority — with a third route open only for category L licences.

What is 145.A.30(e) safety training for?

The Part-145 duty is addressed to the organisation, and it is a competency duty before it is a training duty:

“In addition to the necessary expertise related to the job function, the competency of the personnel must include an understanding of the application of safety management principles, including human factors and human performance issues, which is appropriate to their function and responsibilities in the organisation.” — 145.A.30(e)

Nothing there says “course”. The training appears in the AMC. AMC4 145.A.30(e)(a) 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 continuation safety training — listing nominated persons, line managers and supervisors; certifying staff, support staff and mechanics; planners, engineers and technical records staff; compliance monitoring and safety management staff; specialised services staff; stores and purchasing staff; and ground equipment operators.

The syllabus is GM1 145.A.30(e): topics 1 and 1a on safety management and safety risk management, then safety culture and organisational factors, human error, human performance and limitations, environment, procedures and tools, communication, teamwork, professionalism and integrity, and the organisation’s safety programme. GM1 lets the organisation combine, divide or reorder the subjects, and AMC4(b) allows the syllabus to be adjusted to the nature of the organisation and of each function — the opposite of a fixed examination standard.

Assessment is not an examination either. AMC1 145.A.30(e) has competency assessed by evaluation of on-the-job performance and/or testing of knowledge by appropriately qualified personnel, together with training and experience records; the competency assessment guide sets out the procedure AMC2 requires. The cycle is set by AMC4(c) — training of an appropriate duration in each 2-year period, scaled to compliance monitoring findings and other safety information — and, for certifying and support staff, by 145.A.35(d). Our guide on how often the training falls due works through that interval.

How do the two compare?

	Part-66 Module 9	Part-145 safety training (including human factors)
Legal basis	66.A.25 and Appendix I to Annex III (Part-66); examination standard in Appendix II	145.A.30(e) of Annex II (Part-145); AMC1 to AMC4 145.A.30(e); syllabus in GM1 145.A.30(e); 145.A.35(d) for certifying and support staff
Purpose	Demonstrate by examination the knowledge required for an aircraft maintenance licence	Establish and control the competency of personnel to a standard agreed with the competent authority
Who	The licence applicant — Module 9 is marked applicable to every category and subcategory in the Appendix I matrix	The organisation, for the population listed in AMC4 145.A.30(e)(a), from nominated persons to ground equipment operators
Syllabus	Fixed: sub-modules 9.1 to 9.10 with knowledge levels, expanded by AMC1 Appendix I	Adjustable: GM1 145.A.30(e) topics 1, 1a and 2 to 10, which the organisation may combine, divide or reorder
Assessment	28 multiple-choice questions, 35 minutes, three answers per question, pass mark 75 %, no penalty marking	Competency assessment under AMC1 and AMC2 145.A.30(e) — on-the-job performance and/or testing of knowledge, plus records; no pass mark set in the rule
Frequency	No repeat cycle; point 66.A.25(c) requires the examinations to have been passed within the 10 years before the licence application	Initial before commencing the job function, then an appropriate duration in each 2-year period under AMC4(c); 145.A.35(d) sets the same 2-year period for certifying and support staff
Who delivers	Examination only by a Part-147 approved organisation or the competent authority under 66.A.25(b)	The maintenance organisation itself, independent trainers, or any training organisation acceptable to the competent authority, under AMC4 145.A.30(e)(d)

Can Module 9 be credited?

There is a credit route, and it is not the certificate. AMC4 145.A.30(e)(b) closes with it:

“All personnel identified in accordance with point (a) of this AMC, including personnel being recruited from any other organisation should receive initial safety training compliant with the organisation’s training standards prior to commencing the actual job function, unless their competency assessment justifies that there is no need for such training. […]” — AMC4 145.A.30(e)(b)

The default is initial safety training to the organisation’s own standards, before the job starts. The exception is a competency assessment that justifies no need for it — a documented conclusion the organisation reaches under the procedure AMC2 145.A.30(e) requires, evidenced under 145.A.55(d) and the personnel record. A Module 9 pass is evidence an assessor may weigh; it is not the assessment, and it does not by itself remove the training.

Two limits sit on that exception. First, scope: GM1 145.A.30(e) carries material Appendix I does not name in the same terms — the organisation’s own safety policy and objectives, its internal safety reporting scheme, its investigation process, its feedback loop.

Second, the exception reaches initial training only. The 2-year obligation in AMC4(c) and 145.A.35(d) is unaffected: no credit provision in Part-145 discharges it, and the Module 9 examination has no repeat cycle to be mapped onto it.

Which should you buy?

Decide by the legal basis you are satisfying, and by role.

A Part-66 licence applicant. The examination is what counts, and 66.A.25(b) allows only a Part-147 approved organisation or the competent authority to conduct it. Knowledge preparation may come from anywhere; the sitting may not. Check that the version of Appendix I and Appendix II your competent authority examines is the one your material follows.

A Part-145 organisation training staff. What satisfies 145.A.30(e) is your own procedure, agreed with the competent authority and described in the Maintenance Organisation Exposition (MOE) — AMC4(e) puts the safety training procedures there, and our MOE training chapter guide covers the drafting. Buy training that maps to the GM1 145.A.30(e) topics you have adopted, and record completion under AMC3 145.A.30(e)(a). A course that maps only to Appendix I leaves the organisation-specific topics to you.

Someone who is both — a licence candidate inside an approved organisation. One course can address both syllabuses, but it produces two compliance artefacts on two clocks: an examination result, sat separately, for the licence file; and a training record plus a competency assessment for the personnel record. Check that the provider states which syllabus each lesson maps to.

Related courses. EASA Part-66 Module 9 and Safety Training including Human Factors – Initial follows the Appendix I sub-modules 9.1 to 9.10 alongside the initial Part-145 syllabus; EASA Part-145 Safety Training including Human Factors – Initial covers the GM1 145.A.30(e) topics on their own.