Is human factors training mandatory for a Part-145 organisation?

Is human factors training mandatory for Part-145?

Yes. Point 145.A.30(e) requires the competency of personnel to include an understanding of the application of safety management principles, including human factors and human performance issues. That is rule text, not guidance. What the rule never says is that it has to be a course — the form the training takes is set by AMC4 145.A.30(e).

That split explains most of the confusion: the duty is written as competency, not attendance, and the syllabus, population and interval sit in AMC and GM.

Which clause makes it mandatory?

One point, two sentences, both binding:

(e) 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. 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), text of Regulation (EU) 2018/1142

The first sentence creates a procedure and a standard agreed with the competent authority. The second adds an element of content to competency itself, in obligatory terms rather than as a recommendation. Nothing there is discretionary, and nothing mentions training.

AMC1 145.A.30(e), on what an organisation should consider for a proper competency assessment, builds the bridge in one line:

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)

AMC4 145.A.30(e) is the safety training AMC: it names the population, the timing and the delivery options, with GM1 145.A.30(e) as its syllabus. The understanding is mandatory by rule; the way organisations produce it is described in acceptable means of compliance, and point 145.A.120 lets an organisation propose an alternative to that. There is no alternative to the rule itself.

Requirement	Set out in	Status
Competency includes safety management and human factors	145.A.30(e)	Rule
Certifying and support staff trained in each 2-year period	145.A.35(d)	Rule
Who is trained, when, and by whom	AMC4 145.A.30(e)(a), (b), (d)	AMC
The syllabus	GM1 145.A.30(e)	GM

For whom?

The rule reaches personnel involved in maintenance, airworthiness reviews, safety management and compliance monitoring. AMC4 145.A.30(e)(a) starts wider still:

(a) With respect to the understanding of the application of safety management principles (including human factors), all maintenance organisation personnel should be assessed for the need to receive initial safety training.

Personnel involved in the delivery of the basic maintenance service of the organisation should receive both initial and recurrent safety training, appropriate for their responsibilities. This should include at least the following staff members:

− Nominated persons, line managers, supervisors;

− Certifying staff, support staff and mechanics;

− Technical support personnel such as planners, engineers, technical record staff;

− Persons involved in compliance monitoring and/or safety management-related processes and tasks […];

− Specialised services staff;

− Stores department staff, purchasing department staff;

− Ground equipment operators.

— AMC4 145.A.30(e)(a)

The elision drops the examples on the fourth bullet: the application of human factors principles, internal investigations and safety training. The list is a floor rather than a closed set, and it reaches past the people who sign — stores, purchasing and ground equipment operators are named, as are the compliance monitoring staff who audit the training. AMC1 145.A.30(e) reads the same population, whether employed or contracted. Everyone else is covered by the first sentence: assessed for the need. An assessment concluding there is no need is a compliant outcome; no assessment at all is not.

How often?

Two clocks, and only one of them is in the rule. AMC4 145.A.30(e)(b) attaches the first to the start of the job:

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. New, directly employed personnel working under direct supervision may receive training within 6 months after joining the maintenance organisation.

— AMC4 145.A.30(e)(b)

Experience elsewhere is not credit in itself: staff recruited from another organisation are named in that sentence, and what excuses the training is an assessment, not a previous employer’s certificate.

The second clock is the 2-year cycle. For certifying staff and support staff it is rule text:

(d) 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)

For the wider AMC4 population the period, and the measure of how much, come from the AMC:

Recurrent safety training should be delivered either as a dedicated course or integrated within other training. It 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)

Duration is set in relation to your own audit findings and safety information, not by a fixed number of hours; AMC1 145.A.35(d) adds that it may be split into a number of separate elements. Our guide on how often human factors training is required works through both clocks.

Is a course the only way to comply?

No. AMC4 145.A.30(e)(b) allows initial training as a dedicated course or else integrated within other training, with the syllabus adjusted to the nature of the organisation and of each function within it; point (c) repeats the option for the 2-year cycle. Point (d) opens up delivery:

(d) Safety training may be conducted by the maintenance organisation itself, independent trainers, or any training organisations acceptable to the competent authority.

— AMC4 145.A.30(e)(d)

Then there is the exception people reach for: an individual’s competency assessment may justify that there is no need for initial training. It applies to the individual, not the organisation, and it is an outcome of the assessment procedure required by 145.A.30(e) — the written procedure AMC2 145.A.30(e) expects, specifying who assesses, when, and how results are recorded. AMC1 145.A.30(e) then requires a record of each individual’s qualifications and competency assessment, as our guide on competency assessment sets out.

What the exception does not remove is the organisation’s programme. Four obligations survive it: the 145.A.30(e) procedure and standard agreed with the competent authority; the 145.A.35(d) duty for certifying and support staff, which carries no equivalent exception; the recording of training completion under AMC3 145.A.30(e)(a); and AMC4 145.A.30(e)(e), which puts the safety training procedures in the Maintenance Organisation Exposition (MOE). Delivery format is taken up in our guide on online training.

What happens in an audit?

Not a prediction — the mechanics the rules set out. Point 145.B.350(a) requires the competent authority to have a system in place to analyse findings for their safety significance. Points (b) and (c) define the levels:

(b) A level 1 finding shall be issued by the competent authority when any significant non-compliance is detected with the applicable requirements […], with the organisation’s procedures and manuals, or with the organisation’s certificate including the terms of approval, which lowers safety or seriously endangers flight safety. […]

(c) A level 2 finding shall be issued by the competent authority when any non-compliance is detected with the applicable requirements […] which is not classified as a level 1 finding.

— 145.B.350(b) and (c)

The elisions drop the naming of Regulation (EU) 2018/1139 and its delegated and implementing acts, point (c)’s repetition of the list already given in point (b), and four cases that are level 1 whatever their significance, none about training. Notice what the definitions turn on: non-compliance with the organisation’s own procedures and manuals sits alongside non-compliance with the Regulation, so a training procedure written into the MOE and then not followed is exposed twice over.

Either way, the organisation’s duty is the same:

(a) After the receipt of a notification of findings in accordance with point 145.B.350, the organisation shall:

(1) identify the root cause(s) of, and contributing factor(s) to, the non-compliance;

(2) define a corrective action plan;

(3) demonstrate the implementation of corrective action to the satisfaction of the competent authority.

— 145.A.95(a)

Time is where the levels part. Under point 145.B.350(d)(1) a level 1 finding obliges the authority to prohibit or limit the organisation’s activities immediately, and to revoke, limit or suspend the certificate if appropriate, until successful corrective action has been taken. A level 2 finding brings an implementation period under point (d)(2)(i), initially not more than 3 months, extendable once a corrective action plan is agreed; point (d)(3) raises it to level 1 if no acceptable plan arrives or the period is missed.

UK: the same?

The rule wording is. The Aviation Safety (Amendment) Regulations 2023, SI 2023/588, amended UK Regulation (EU) No 1321/2014 and came into force on 1 July 2024, carrying the safety-management wording of 145.A.30(e) into UK Part-145 with the CAA as competent authority. The CAA’s Part 145 SMS implementation page sets 1 July 2026 as the date by which approval holders must have implemented a safety management system.

The UK keeps its own AMC and GM in a login-gated regulatory library, so the AMC and GM detail above is the EASA text and should be checked against the CAA’s material before it is put to a UK surveyor. Our UK Part-145 SMS guide covers the instrument and the deadline; our Module 9 comparison sets the two syllabuses side by side.

Related courses. Safety Training including Human Factors – Initial follows the GM1 145.A.30(e) syllabus; Safety Training including Human Factors – Continuation covers the 2-year cycle in 145.A.35(d).