How UK Part-145 Organisations Can Obtain EASA OJT Approval

Since the UK left the European Union, a UK Part-145 approval is not automatically recognised as an EASA Part-145 approval. This matters when a UK maintenance organisation wants to provide On-the-Job Training (OJT) that supports an engineer applying for an EASA Part-66 aircraft type rating. For additional context on EASA licences and OJT approval, see our guide to Kiwa EASA licences and OJT approval.

The basic principle is straightforward. A UK organisation must hold, or obtain, the appropriate EASA Foreign Part-145 approval. It must then operate an OJT programme that is accepted by the relevant authority and controlled through the organisation’s EASA-approved procedures.

There is no universal, standalone EASA OJT certificate that replaces these requirements. Acceptance depends on the applicable Part-66 requirements, the licensing authority’s expectations and the Part-145 organisation’s approved procedures.

OJT is not simply a period of employment. It is not enough for an engineer to work on an aircraft and collect a supervisor’s signature. EASA expects the training to be planned, supervised, recorded and assessed against the applicable Part-66 requirements.

What is EASA OJT?

OJT is practical training completed after the relevant aircraft type training. It allows an aircraft maintenance engineer to demonstrate that they can perform representative maintenance tasks on a particular aircraft type in a real maintenance environment.

For an initial aircraft type rating, OJT normally covers:

• The aircraft type and applicable variant;
• The relevant Part-66 category or subcategory;
• A representative range of maintenance tasks;
• Practical performance under appropriate supervision;
• Completion of task records and supporting evidence;
• Assessment by suitably qualified personnel.

Under Part-66 66.A.45 and Appendix III, OJT is mandatory when an engineer obtains their first type rating in a category or subcategory. Organisations should verify the current regulatory text in EASA’s Easy Access Rules for Continuing Airworthiness.

This distinction is important. OJT is not automatically required every time an engineer adds another aircraft type to an existing category or subcategory. The organisation must still ensure that the engineer has the competence and practical experience required for the privileges being exercised.

Does a UK CAA Part-145 approval allow an organisation to provide EASA OJT?

No. A UK CAA Part-145 approval and an EASA Part-145 approval are separate approvals.

A UK organisation may be entitled to conduct maintenance under its UK approval, but that does not, by itself, mean that it can provide OJT acceptable for an EASA Part-66 licence or aircraft type rating.

For EASA purposes, a UK organisation is generally treated as a foreign Part-145 organisation. Unless it is covered by an applicable bilateral agreement or specific arrangement, it must apply to EASA for the relevant Foreign Part-145 approval. Organisations should consult the official EASA information on Foreign Part-145 organisations before planning an application.

EASA refers to these as Foreign Part-145 Approvals (MOA). They apply to Part-145 organisations located outside the EU that are not subject to an applicable bilateral agreement.

Step 1: Establish which authority is responsible

The first step is to establish whether EASA or another aviation authority is responsible for the approval and acceptance of the proposed OJT programme.

A UK organisation should not assume that its UK CAA approval can be extended to cover EASA OJT. It should establish:

• Whether it requires an EASA Foreign Part-145 approval;
• Whether the proposed OJT activity falls within the scope of that approval;
• Which authority must approve or accept the OJT programme;
• Whether the activity is affected by a bilateral agreement or specific arrangement;
• Which EASA application and continuing-oversight procedures apply.

For most UK organisations seeking to provide EASA-recognised maintenance training, the practical route is to apply to EASA as a foreign Part-145 organisation and include the OJT activity in controlled procedures. The organisation should confirm the precise approval route with EASA and the authority responsible for the engineer’s Part-66 application before submitting its documents.

Step 2: Apply for an EASA Foreign Part-145 approval

The organisation must apply for the appropriate EASA Part-145 approval and demonstrate compliance with the applicable requirements in Annex II to Regulation (EU) No 1321/2014. EASA’s Part-145 information and guidance should be checked for current requirements.

The application normally requires evidence covering:

• The organisation’s legal identity and location;
• The proposed approval scope;
• Management personnel and nominated postholders;
• Facilities and maintenance capability;
• Quality and compliance-monitoring arrangements;
• Personnel competence and authorisation systems;
• Maintenance data and technical records;
• Occurrence reporting;
• Human factors and safety-management arrangements;
• Procedures for subcontracting and specialised services;
• The organisation’s exposition and supporting procedures.

EASA’s Foreign Part-145 material includes documents such as:

• Foreign Part-145 Approvals (MOA) working procedures;
• Guidance material on specific technical requirements;
• EASA Part-145 Appendix IV and ICAO Annex I checklists;
• Management Personnel Résumé, including document reference FO.CAO.00156;
• Management Personnel working instructions, including document reference WI.CAO-00115.

The organisation should check the current EASA Foreign Part-145 publication set before submitting an application. Forms, guidance and document references may change.

Step 3: Include OJT in the organisation’s EASA procedures

Obtaining an EASA Part-145 approval does not mean that every activity carried out by the organisation is automatically acceptable as EASA OJT.

The organisation must describe how OJT will be controlled. This is normally addressed through the Maintenance Organisation Exposition, or through procedures and referenced documents controlled by the exposition.

The procedure should explain:

• Who may approve or authorise an OJT programme;
• How the aircraft type and Part-66 category are identified;
• How tasks are selected;
• How the programme is mapped to Part-66 Appendix III;
• How trainees are supervised;
• Who may act as an OJT assessor;
• How task completion is recorded;
• How incomplete or incorrectly performed tasks are managed;
• How changes to the programme are controlled;
• How records are retained and made available to the relevant authority;
• How the organisation confirms that OJT has been satisfactorily completed.

The organisation should avoid using a generic training checklist that does not clearly identify the aircraft type, task references, trainee, supervisor, assessor and dates. The records should show what was actually performed and how competence was assessed.

Step 4: Create an aircraft-specific OJT programme

An OJT programme should be specific to the aircraft type and relevant licence category. It should not be written as a broad statement that the trainee will gain “experience on type”.

Aircraft and licence details

The programme should identify:

• Aircraft manufacturer and type;
• Aircraft series or variant;
• Engine or configuration, where relevant;
• Part-66 licence category or subcategory;
• Trainee’s name and licence details;
• OJT start and completion dates;
• The organisation conducting the training.

Task selection

The selected tasks should be representative of the aircraft type and the privileges associated with the rating. The programme should contain an appropriate mixture of maintenance activities, such as:

• Removal and installation;
• Inspections;
• Functional checks;
• Operational tests;
• Fault isolation;
• Component replacement;
• Servicing;
• Aircraft system maintenance;
• Structural or zonal tasks, where applicable;
• Electrical, avionic or mechanical tasks appropriate to the category.

Tasks should be taken from current approved maintenance data, such as the applicable Aircraft Maintenance Manual, task cards, wiring manuals or other approved instructions.

Supervision and assessment

The organisation must define who supervises the trainee and who confirms satisfactory completion.

Anyone signing an OJT record should have suitable experience, knowledge of the aircraft and an appropriate authorisation or demonstrated competence for the task being assessed. The supervisor is not merely confirming that the trainee was present. The supervisor is confirming that the task was completed correctly, using the applicable maintenance data and the required safety standards.

Where the supervisor and assessor are different people, the procedure should explain their respective responsibilities.

Step 5: Demonstrate suitable practical training conditions

OJT must be carried out in a genuine maintenance environment. The trainee should have access to:

• A suitable aircraft or aircraft parts;
• Current approved or accepted maintenance data;
• The correct tools and equipment;
• Calibrated test equipment, where required;
• Adequate supervision;
• Applicable safety and human factors procedures;
• Technical records and task documentation.

The organisation should also consider whether enough aircraft activity is available to complete the programme within a reasonable period. A programme that depends on a small number of infrequent tasks may not provide reliable evidence of competence.

If a required task cannot be completed, the organisation should not sign it off merely because the trainee performed a similar activity elsewhere. The procedure should state whether the task may be replaced, deferred or completed at another approved location, and who must approve that decision.

Step 6: Control the OJT records

The OJT record is one of the most important parts of the process. It should allow an independent reviewer to understand exactly what happened.

Each task record should normally include:

• Date of performance;
• Aircraft registration or identification;
• Aircraft type and variant;
• Maintenance task reference;
• Description of the work performed;
• Trainee’s name and signature;
• Supervisor’s name, signature and authorisation details;
• Assessor’s confirmation;
• Any relevant defects, difficulties or repeat work;
• Confirmation that the applicable maintenance data was used.

Electronic records may be acceptable if the organisation can demonstrate document control, access security, traceability and protection against unauthorised alteration.

Records should be retained in accordance with the organisation’s approved procedures and made available to EASA or the relevant licensing authority when required. Engineers can also review our guidance on recording and verifying Part-66 maintenance experience in a CAP 741 logbook.

For additional support with structured maintenance records, explore Part 66 Logbook Analysis.

A note about B2 certification privileges

OJT should not be confused with the separate experience and task-training requirements that apply to certain B2 certification privileges.

The holder of a category B2 aircraft maintenance licence may exercise the certification privileges described in 66.A.20(a)(3)(ii) of Annex III (Part-66) only after satisfactorily completing:

• The relevant category A aircraft task training; and
• Six months of documented practical experience covering the scope of the authorisation to be issued.

The task training must include practical, hands-on training and theoretical training, as appropriate for each authorised task.

This requirement is separate from the OJT requirement for adding an aircraft type rating. Completing an OJT programme does not automatically satisfy the six-month practical-experience requirement. Equally, six months of experience does not automatically replace an OJT programme where OJT is mandatory.

The organisation should identify precisely which regulatory requirement the training or experience is intended to satisfy. A well-written procedure should prevent the same record from being incorrectly used to support different privileges.

What about staff qualified under national rules?

Part-145 contains derogations concerning certifying staff for certain organisations and locations outside the EU.

For organisation facilities located outside EU territory, certifying staff may, in certain circumstances, be qualified in accordance with the national aviation regulations of the state in which the facility is registered, subject to the conditions specified in Appendix IV to Part-145.

For a UK organisation, this does not mean that UK national qualifications automatically create EASA Part-66 privileges. It means that the organisation may be able to use appropriately qualified personnel under the applicable foreign-organisation provisions, provided that all EASA conditions are met.

The organisation must distinguish between:

• The qualification needed to perform or supervise maintenance;
• The qualification needed to issue a maintenance certification;
• The competence needed to supervise OJT;
• The licence and type-rating requirements of the trainee;
• The requirements of the trainee’s EASA Part-66 application.

These requirements are related, but they are not interchangeable.

Common problems with UK OJT applications

Treating UK approval as EASA approval

A UK CAA Part-145 approval does not automatically authorise EASA OJT. The organisation needs to follow the correct EASA approval route.

Using a generic OJT form

A simple form stating that a trainee has “completed OJT” is unlikely to provide sufficient evidence. The records should identify the actual aircraft, tasks, maintenance data, supervisors and assessment.

Selecting too few tasks

The programme must be representative of the aircraft type and relevant licence category. A small number of repeated tasks may not demonstrate sufficient competence.

Failing to control assessors

The organisation should define the competence and authorisation requirements for anyone who supervises or assesses OJT. These responsibilities should not be left to informal arrangements.

Confusing experience with OJT

General maintenance experience may be valuable, but it does not automatically meet the structured OJT requirements in Part-66 Appendix III.

Ignoring the first-rating rule

OJT becomes mandatory when adding the first aircraft type rating in a category or subcategory. The organisation should confirm the trainee’s existing licence categories and ratings before deciding whether OJT is required.

Using obsolete regulatory references

The organisation should ensure that its exposition, training forms and application documents refer to the current versions of Part-66, Part-145 and relevant EASA guidance material.

A practical approval sequence

For most UK Part-145 organisations, the process can be summarised as follows:

• Confirm the regulatory route. Establish whether EASA Foreign Part-145 approval is required.
• Define the proposed OJT scope. Identify the aircraft types and Part-66 categories concerned.
• Prepare the EASA Part-145 application. Include the supporting management and compliance documents.
• Update the exposition. Add procedures for controlling OJT.
• Nominate competent supervisors and assessors.
• Develop aircraft-specific OJT programmes. Use current maintenance data.
• Create controlled task and assessment records.
• Submit the application and procedures to EASA.
• Respond to findings or requests for clarification.
• Conduct OJT only after the relevant approval and procedures are in place.
• Retain complete records. These must support the trainee’s Part-66 application or type-rating endorsement.

Conclusion

For a UK Part-145 organisation, obtaining acceptance for EASA OJT is not simply a matter of adding an OJT form to an existing training manual. The organisation must demonstrate that it can provide structured, aircraft-specific practical training within an approved EASA maintenance system.

The key points are:

• A UK Part-145 approval is not automatically an EASA Part-145 approval;
• EASA Foreign Part-145 approval may be required;
• OJT must be controlled through approved procedures;
• The programme must be mapped to Part-66 Appendix III;
• Supervision, assessment and records must be clearly defined;
• OJT is mandatory only when adding the first aircraft type rating in a category or subcategory;
• B2 task training and six-month practical-experience requirements remain separate obligations where applicable.

A UK organisation that addresses these points before submitting its application will be better placed to obtain EASA acceptance and provide OJT that genuinely supports an engineer’s EASA Part-66 aircraft type-rating application.