Aerospace training programs answer to two very different masters. AS9100 is a quality management standard: it cares whether your people are competent and whether you can evidence it. FAA Part 145 is federal regulation: it prescribes an approved training program and specific records for certificated repair stations. This guide walks through what each one actually requires, citing the source text, and closes with what auditors and inspectors look for in practice.
The short version. AS9100 clause 7.2 requires you to determine the competence each role needs, ensure people are competent, evaluate whether training worked, and retain documented evidence of competence. 14 CFR 145.163 requires repair stations to have and use an FAA-approved training program of initial and recurrent training that ensures each employee can perform assigned tasks, to document individual training, and to retain those records for a minimum of 2 years.
This guide is a plain-language reference, not legal or certification advice. Always verify against the current standard and regulation text linked below.
What AS9100 is, and where training requirements live
AS9100D, published by SAE International (revised 2016-09-20), is titled Quality Management Systems: Requirements for Aviation, Space, and Defense Organizations. It includes the full text of ISO 9001:2015 and adds aviation, space, and defense industry requirements on top. The people-related requirements sit in three places: clause 7.2 (competence), clause 7.3 (awareness), and clause 7.5 (documented information).
Note for readers a few years from now: the IAQG is transitioning the 9100 series to standalone publication under an IA prefix (IA9100), on a revision cycle aligned with the next ISO 9001 revision. The competence requirements described here carry forward from ISO 9001, so the structure below should remain a reliable map. See Quality Magazine's overview of the IA9100 transition.
AS9100 clause 7.2: the four competence requirements
Clause 7.2 carries the ISO 9001:2015 competence requirements. Paraphrased, the organization must:
- Determine the necessary competence of people doing work under its control that affects the performance and effectiveness of the quality management system.
- Ensure these people are competent on the basis of appropriate education, training, or experience.
- Where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken.The standard's note lists examples of such actions: providing training, mentoring, reassignment, or hiring competent persons.
- Retain appropriate documented information as evidence of competence.
Two phrases carry most of the audit weight. First, evaluate the effectiveness: delivering training is not enough, you need a mechanism that shows the training produced the intended competence. Second, evidence of competence: the retained record has to support the competence claim, not just prove attendance. See this clause 7.2 breakdown for a walkthrough of the requirement structure.
AS9100 clause 7.3: the awareness additions
Clause 7.3 requires that people doing work under the organization's control be aware of eight things. Four come from ISO 9001:2015: the quality policy, relevant quality objectives, their contribution to QMS effectiveness including the benefits of improved performance, and the implications of not conforming. AS9100 adds four more, specific to aviation, space, and defense:
- Relevant QMS documented information, and changes to it
- Their contribution to product or service conformity
- Their contribution to product safety
- The importance of ethical behavior
These are training-program content requirements in practice: an auditor can ask any operator how their work affects product safety, and the answer reflects on your awareness training.
AS9100 clause 7.5: how training records must be controlled
Evidence of competence retained under 7.2 is documented information, so it falls under clause 7.5's controls: identification, format, review and approval (7.5.2), and availability, protection, distribution, storage, change control, retention, and disposition (7.5.3). AS9100 adds a requirement that when documented information is managed electronically, data protection processes must be defined: protection from loss, unauthorized changes, unintended alteration, corruption, and physical damage.
Unlike the FAA rule below, AS9100 sets no fixed retention period for training records. Retention and disposition are defined by the organization, subject to customer and statutory or regulatory requirements, which in aerospace contracts are often longer than you would guess. Check your customer flow-downs before setting a policy.
Who audits AS9100, and what they ask for
AS9100 certification runs through the IAQG's ICOP scheme: accredited certification bodies conduct the audits, auditors work to the AS9101 audit requirements standard (currently revision G), and all audits and certifications are recorded in the OASIS database, the industry's registry of certified suppliers, certification bodies, and authenticated auditors.
On training and competence specifically, auditors typically request role-based training matrices, qualification records, certifications where applicable, and records showing personnel were authorized for the work performed. The pattern to expect: the auditor samples an individual and a task, then follows the thread. How did you determine what competence this role needs? How do you know this person has it? What happened when a gap was found, and how did you verify the fix worked?
FAA Part 145: what 14 CFR 145.163 actually says
For certificated repair stations, the training requirement is 14 CFR 145.163. The current section text, in full:
§ 145.163 Training requirements.
(a) A certificated repair station must have and use an employee training program approved by the FAA that consists of initial and recurrent training. An applicant for a repair station certificate must submit a training program for approval by the FAA as required by § 145.51(a)(7).
(b) The training program must ensure each employee assigned to perform maintenance, preventive maintenance, or alterations, and inspection functions is capable of performing the assigned task.
(c) A certificated repair station must document, in a format acceptable to the FAA, the individual employee training required under paragraph (a) of this section. These training records must be retained for a minimum of 2 years.
(d) A certificated repair station must submit revisions to its training program to its responsible Flight Standards office in accordance with the procedures required by § 145.209(e).
Four practical obligations fall out of that text:
- An FAA-approved program. The training program is submitted for FAA approval at certification (under 145.51(a)(7)) and revisions go to your responsible Flight Standards office (under 145.209(e)).
- Initial and recurrent training. One-time onboarding does not satisfy the rule; the program must keep capability current.
- Capability, not attendance. The program must ensure each employee assigned to maintenance, preventive maintenance, alterations, or inspection functions is capable of performing the assigned task.
- Documented individual training, retained at least 2 years. The format must be acceptable to the FAA, and the record is per employee.
Did the FAA stop approving training programs? No, that was Part 147
A persistent point of confusion: in May 2022 the FAA published a final rule, Aviation Maintenance Technician Schools (87 FR 31391, effective September 21, 2022), stating that the FAA "will no longer approve AMTS curriculum" and will instead ensure school curricula align with the Mechanic Airman Certification Standards through routine surveillance. That rule amended 14 CFR parts 43, 65, and 147. It did not touch Part 145. The eCFR amendment history for 145.163 shows no substantive change since 2018, and FAA approval of repair station training programs remains required today.
Related Part 145 personnel requirements
The training program does not stand alone. Subpart D of Part 145 sets personnel requirements that your training and qualification records have to support:
| Section | Requirement | Training-records implication |
|---|---|---|
| 145.151 | Qualified personnel to plan, supervise, perform, and approve work; abilities of noncertificated employees determined by training, knowledge, experience, or practical tests | Documented basis for each noncertificated employee's assignment |
| 145.153 | Sufficient supervisors; certificated under part 65 in the US; English proficiency | Supervisor qualification records |
| 145.155 | Inspection personnel thoroughly familiar with applicable regulations and proficient with inspection methods, techniques, and equipment | Evidence of inspection proficiency, not just course completion |
| 145.157 | Qualification requirements for personnel authorizing return to service | Authorization records tied to certification and experience |
| 145.161 | Roster of management, supervisory, and inspection personnel with employment summaries; changes reflected within 5 business days | A current roster an inspector can reconcile against training records |
AC 145-10: the FAA's blueprint for a compliant program
The FAA's advisory circular AC 145-10, Repair Station Training Program (with Change 1) describes an acceptable means, though not the only means, of complying with 145.163. It organizes training into five categories: indoctrination, technical, recurrent, specialized, and remedial. And it lists the components the FAA expects a program to contain: needs assessment, definition of areas of study and courses, training methods and sources, instructor qualification, measuring training effectiveness, and training documentation. Notably, the AC treats the FAA's word "capability" and EASA's word "competency" as synonymous for training purposes.
What FAA inspectors look for
FAA aviation safety inspectors review and approve repair station training programs under guidance in FAA Order 8900.1 (Flight Standards Information Management System), which directs inspectors to examine, among other things:
- The needs assessment: job and task analysis, the standards used to assess employee capability, and how identified gaps get filled.
- Capability assessment procedures:objective, consistent, documented in the individual's training record, performed by a qualified assessor, with procedures for crediting prior experience such as part 147 graduation, mechanic certificates, or manufacturer and military training.
- Indoctrination content: regulatory requirements, company manuals and quality control processes, hazmat, human factors, and facility security. The guidance treats maintenance human factors training as an essential part of an approved program.
- Revision procedures: who submits program revisions, when, how they are approved, and how currency is reviewed.
The current text of Order 8900.1 lives in the FAA's Dynamic Regulatory System; section numbering has shifted over the years, so search the order rather than relying on cached citations.
AS9100 vs Part 145 at a glance
| Question | AS9100 | FAA Part 145 |
|---|---|---|
| What is it? | Industry QMS standard (SAE AS9100D, includes ISO 9001:2015) | Federal regulation for certificated repair stations |
| Core training ask | Competence determined, ensured, effectiveness evaluated | FAA-approved program, initial and recurrent, ensures capability |
| Records required | Documented evidence of competence (clause 7.2) | Individual training documented, format acceptable to FAA |
| Retention period | Organization-defined under 7.5.3, per customer and regulatory flow-downs | Minimum 2 years (145.163(c)) |
| Who checks | Accredited certification bodies under AS9101, recorded in OASIS | FAA aviation safety inspectors per Order 8900.1 |
| Approval of program | No external approval; audited for conformity | Yes, FAA approval required (145.163(a), 145.51(a)(7)) |
The common thread: both ask for proof, not attendance
Strip away the framework differences and the two regimes converge on the same demand. AS9100 asks you to evaluate the effectiveness of training and retain evidence of competence. Part 145 asks for a program that ensures each employee is capable of the assigned task, and AC 145-10 lists measuring training effectiveness as a program component. Neither is satisfied by a completion certificate.
That gap, between records that prove delivery and records that prove capability, is what AS9100 training software and Part 145 training software should close: assessment scored against your own procedures, qualification status with evidence attached, and reporting an auditor can trace. For how AmpUp Insights approaches it, start with how it works.
Frequently asked questions
AS9100 clause 7.2 requires organizations to retain appropriate documented information as evidence of competence. AS9100 does not set a fixed retention period for training records; retention and disposition are defined by the organization under clause 7.5.3, subject to customer and applicable statutory or regulatory requirements.
A minimum of 2 years. 14 CFR 145.163(c) requires a certificated repair station to document individual employee training in a format acceptable to the FAA and states that these training records must be retained for a minimum of 2 years.
Yes. 14 CFR 145.163(a) requires a certificated repair station to have and use an employee training program approved by the FAA, submitted at certification under 145.51(a)(7), with revisions submitted under 145.209(e). The 2022 rule that ended FAA curriculum approval applied to Part 147 aviation maintenance technician schools, not Part 145 repair stations.
AC 145-10, Repair Station Training Program, is the FAA advisory circular describing an acceptable means of complying with 14 CFR 145.163. It covers five training categories (indoctrination, technical, recurrent, specialized, remedial) and program components including needs assessment, measuring training effectiveness, and training documentation.
Certification body auditors working under AS9101 typically request role-based training matrices, qualification records, certifications where applicable, and records showing personnel were authorized for the work performed, and they sample individuals to see evidence that competence was determined, verified, and kept current.
No. Training is one way to acquire competence. Clause 7.2 requires the organization to determine required competence, ensure people are competent on the basis of education, training, or experience, evaluate the effectiveness of actions taken, and retain evidence. An attendance record alone does not demonstrate effectiveness.