Under EASA Part-145.A.30(e), personnel involved in maintenance, airworthiness reviews, safety management, and compliance monitoring must demonstrate competency in safety management principles, including human factors and human performance. Human Factors (HF) training, Safety Management System (SMS) training, and Safety Training Including Human Factors are often treated as interchangeable, but they are not identical requirements.


An HF-only certificate may satisfy a combined Safety Training Including Human Factors requirement only if the training syllabus demonstrably covers both the Human Factors and Safety Management elements expected under the applicable EASA guidance material and is accepted by the organisation and competent authority.


Treating HF-only, SMS-only, and combined Safety Training Including Human Factors as equivalent without verifying syllabus coverage can create a compliance gap during a Part-145 audit.


Methodology: Regulatory references in this article are based on Commission Regulation (EU) No 1321/2014, including 145.A.30(e) (Personnel Requirements – Competency Assessment and Training), together with the associated guidance in AMC1–AMC5 145.A.30(e) and GM1, GM4 and GM5 145.A.30(e), as well as the applicable Part-CAMO requirements and associated AMC/GM related to Human Factors (HF) and Safety Management Systems (SMS).



What Part-145.A.30(e) Actually Requires

Part-145.A.30(e) requires maintenance organisations to establish and control the competency of personnel involved in maintenance activities, airworthiness reviews, safety management functions, and compliance monitoring activities.


The requirement extends beyond certifying staff. Depending on organisational responsibilities, it may also apply to supervisors, planners, engineers, technical support personnel, quality personnel, safety managers, stores personnel, purchasing personnel, and accountable management functions.

The regulation requires competency in both safety management principles and human factors relevant to an individual's role.

EASA separates regulatory requirements into:

  • AMC (Acceptable Means of Compliance) – describes one acceptable method of demonstrating compliance.
  • GM (Guidance Material) – provides additional explanation and interpretation of the regulatory intent.

This distinction matters during audits. An auditor typically reviews whether the organisation complies with the regulation itself and whether training records demonstrate alignment with the associated AMC and GM guidance.


Relevant provisions for this assessment include AMC4 145.A.30(e), GM1 145.A.30(e), and GM2 145.A.30(e).


The introduction of EASA ED Decision 2022/011/R expanded the integration of Safety Management System principles into Part-145 competency requirements. As a result, organisations increasingly need evidence that personnel understand both Human Factors and Safety Management concepts rather than Human Factors alone.


HF Training, SMS Training, and Safety Training Including HF: Three Names, One Compliance Decision

The confusion usually starts with course titles.

Many training records contain certificates labelled:

  • Human Factors Training
  • Safety Management System Training
  • Safety Training Including Human Factors

Although these titles appear similar, they can represent different compliance scopes.


Human Factors Training

Human Factors training focuses on subjects such as:

  • Human performance and limitations
  • Human error
  • Communication
  • Teamwork
  • Shift handovers
  • Work environment influences
  • Fatigue and stress
  • Safety culture from a human performance perspective

HF training addresses how people interact with maintenance tasks and how human performance influences safety outcomes.


SMS Training

Safety Management System training focuses on organisational safety processes, including:

  • Safety policy and objectives
  • Hazard identification
  • Risk assessment
  • Risk mitigation
  • Safety reporting
  • Safety assurance
  • Safety promotion

SMS training addresses how organisations identify and manage operational risks.


Safety Training Including Human Factors

Safety Training Including Human Factors combines both scopes into a single training program. Its content reflects the safety training framework described in AMC4 145.A.30(e), the recommended initial training syllabus provided in GM1 145.A.30(e), and the competency assessment guidance outlined in GM2 145.A.30(e).


Rather than treating Human Factors and Safety Management separately, it addresses:

  • Human performance
  • Human error management
  • Hazard identification
  • Risk management
  • Reporting culture
  • Safety assurance
  • Organisational safety responsibilities

This combined approach reflects the integrated competency expectations now embedded within the Part-145 framework.


When comparing course scopes, verify the syllabus against AMC4 145.A.30(e), GM1 145.A.30(e), and GM2 145.A.30(e), rather than relying on the course title alone.


For organisations seeking a combined solution, the Initial Safety Training Including Human Factors course available through 147training.com is designed to address both Human Factors and Safety Management elements within a single program.

According to FL Technics Training Manager Jonas Karalius, during a 2024 audit, a competent authority challenged an organisation’s approach of meeting the applicable training requirements through two separate certificates: a Human Factors Initial Training Course in accordance with 145.A.30(e) requirements and a separate SMS training course. The organisation was required to demonstrate, on a case-by-case basis, that the combined syllabi fully covered the Safety Training (Including Human Factors) syllabus based on GM1 145.A.30(e) and GM1 CAMO.A.305(g), including the required level and depth of each syllabus item. Without such evidence, the certificates would not be accepted as evidence of compliance.

What About Older HF Certificates?

Many engineers and technicians still hold Human Factors certificates issued before the implementation of ED Decision 2022/011/R. These certificates are not automatically invalid.


However, organisations should review the syllabus content rather than relying solely on the certificate title. If the previous course does not demonstrate coverage of current Safety Management expectations, supplementary training may be required. 


Initial vs Recurrent Training: Who Needs What and When?

This is one of the most frequently asked compliance questions.


Initial Training

Initial training is designed for personnel who:

  • Are entering a Part-145 environment for the first time
  • Are assuming new responsibilities requiring Safety Management competency
  • Have no documented evidence of previous compliant training

Initial Safety Training Including Human Factors establishes baseline competency requirements expected by the organisation.


Recurrent Training

Initial training is not intended to remain static throughout an individual's career. Part-145 organisations must ensure personnel maintain current knowledge of:

  • Human Factors topics
  • Safety Management principles
  • Organisational procedures
  • Lessons learned from incidents and occurrences
  • Regulatory changes

Recurrent training serves this purpose.


Under AMC4 145.A.30(e), recurrent safety training should be of an appropriate duration in each two-year (24 months) period.


The recurrent course does not necessarily need to mirror the initial program in duration. A shorter recurrent format may be acceptable provided it addresses the required learning objectives and organisational competency needs.


Does a Certificate Transfer Between Employers?

A Human Factors certificate does not automatically transfer between organisations. When a technician joins a new Part-145 organisation, the new employer remains responsible for assessing competency.

The organisation may accept previous training if:

  • The certificate remains relevant
  • The syllabus can be verified
  • The training aligns with current organisational requirements

If sufficient evidence cannot be demonstrated, additional initial or recurrent training may be required.


What Documentation Must Be Retained?

A certificate alone is not always sufficient. Part-145 organisations should retain:

  • Certificate records
  • Course syllabus
  • Training duration
  • Completion dates
  • Regulatory references
  • Competency assessment records

During an audit, the ability to demonstrate what was taught can be as important as demonstrating that training occurred.

Based on training records reviewed during enrolment, FL Technics Training has identified a recurring documentation gap involving older Human Factors certificates that do not clearly demonstrate whether the completed training covered the Safety Management content now included within Safety Training (Including Human Factors). Such certificates should therefore be assessed together with the underlying course syllabus rather than accepted solely on the basis of the certificate title

Choosing the Right Course on 147training.com

Selecting the correct course depends on the compliance gap you need to close.


Initial Safety Training Including Human Factors

Recommended when personnel require combined Human Factors and Safety Management training. This course covers:

  • Human Factors topics
  • Safety Management principles
  • Hazard identification
  • Risk management
  • Safety reporting
  • Organisational safety responsibilities

It provides a single training pathway for organisations seeking combined compliance coverage.


Safety Training Including Human Factors (Recurrent)

Recommended for personnel who have already completed initial training and require recurrent competency maintenance. The recurrent program focuses on:

  • Safety updates
  • Human Factors refreshers
  • Organisational learning
  • Continuous competency maintenance

Human Factors in accordance with Part-145

Recommended when the organisation specifically requires Human Factors competency and has separately addressed Safety Management requirements.


Human Factors Continuation/Recurrent Training

Recommended for personnel requiring Human Factors refresher training without a full combined safety program.


Training for Multiple Employees

For organisations wishing to traing multiple employees, 147training.com offers a Course Manager account that allows training managers to:

  • Purchase courses centrally
  • Assign training to employees
  • Monitor completion progress
  • Store and manage the team’s certificates
  • Manage training budgets efficiently with a Wallet-based purchasing system

A wallet is an equivalent of 147training.com own currency and can be used to purchase any online course on 147training.com. Wallets come in various preset values. The purchasing power of a wallet is directly related to its value – the larger the value of the wallet selected, the higher the purchasing power it provides (e.g. pay 500 EUR, get 550 EUR to spend online) [ Learn more about wallets


HF vs SMS vs Safety Training Including HF – Compliance Mapping

Training LabelRegulatory BasisMinimum Syllabus TopicsWho It Applies ToInitial or Recurrent
HF-only TrainingPart-145 competency requirements related to human performanceHuman error, communication, teamwork, fatigue, human performance limitationsCertifying staff, engineers, mechanics, support personnelInitial or recurrent
SMS-only TrainingPart-145 Safety Management requirementsHazard identification, risk management, reporting, safety assuranceSafety personnel and personnel with SMS responsibilitiesInitial or recurrent
Safety Training Including HFCombined Part-145 competency requirementsHuman Factors plus Safety Management topicsPersonnel identified by organisational competency assessmentInitial or recurrent
Recurrent Safety/HF TrainingOngoing competency maintenanceRefresher training, organisational learning, regulatory updatesExisting trained personnelRecurrent

Compliance interpretation may vary between National Aviation Authorities and Competent Authorities. Organisations should confirm acceptability with their authority before relying on any training certificate in a formal audit response.


How Human Factors and Safety Training Requirements Differ Across Aviation Organisations


While this article focuses on Part-145 maintenance organisations, Human Factors (HF) and Safety Management (SMS) training requirements are not identical across all EASA-approved organisations.


Part-145 Organisations

Part-145 organisations operate within a maintenance environment where personnel competency requirements include both Human Factors and Safety Management principles. As a result, organisations often need training that addresses not only human performance and error prevention, but also safety reporting, hazard identification and risk management processes.


For this reason, combined Safety Training Including Human Factors programs have become increasingly common within Part-145 organisations.


Part-CAMO Organisations

Part-CAMO organisations have different responsibilities focused on continuing airworthiness management rather than aircraft maintenance.


Personnel involved in continuing airworthiness management, airworthiness reviews, occurrence reporting and safety activities may require both Human Factors and Safety Management awareness; however, training is typically tailored to CAMO functions rather than maintenance activities. The organisation should determine the required competency based on assigned responsibilities.


Part-CAO Organisations

Part-CAO organisations are generally smaller and operate under a more proportionate regulatory framework.


Depending on the scope of approval, organisations may require Human Factors training, Safety Management training, or a combination of both. The training need is usually driven by organisational responsibilities rather than by a standardised course requirement.


Part-21 Organisations

Part-21 Design and Production Organisations operate under a different regulatory framework from continuing airworthiness organisations.


While Human Factors and Safety Management principles may form part of organisational processes, Part-145-style Safety Training Including Human Factors courses are not normally used as a direct compliance solution.

Training requirements are typically defined within the organisation's own management and competency system.


Part-147 Organisations

Part-147 Maintenance Training Organisations are fundamentally different from Part-145 maintenance organisations.


For most Part-147 personnel, Human Factors training remains the primary requirement because instructors, examiners and training management personnel are involved in teaching, assessment and competence development rather than maintenance production activities.


A dedicated Safety Training Including Human Factors course is normally not required solely because an individual works within a Part-147 organisation.


In many cases, the traditional Human Factors training approach remains appropriate for Part-147 instructors and support personnel, provided it aligns with the organisation's procedures and competency system.


The Key Point

When selecting training, organisations should avoid assuming that a course designed for Part-145 personnel automatically applies to Part-CAMO, Part-CAO, Part-21 or Part-147 staff. The correct training solution depends on the organisation's approval, responsibilities, competency system and the role performed by the individual.


Conclusion

The key compliance question is not what the certificate is called, but what the syllabus covers.


Human Factors training addresses human performance. SMS training addresses organisational risk management. Safety Training Including Human Factors combines both areas into a single competency framework aligned with modern Part-145 expectations.


Before an audit, training managers should verify that certificates, syllabi, and training records collectively demonstrate compliance with current EASA requirements rather than assuming that HF-only and combined Safety Training Including Human Factors are interchangeable.


For organisations seeking a straightforward compliance pathway, the Initial Safety Training Including Human Factors and recurrent training programs available through 147training.com provide a structured solution aligned with current Part-145 competency expectations.


How to Confirm Your Part-145 HF and Safety Training Record Is Audit-Ready

  1. 1.

    Identify whether your role falls under 145.A.30(e).

  2. 2.

    Review the syllabus reference on your training certificate.

  3. 3.

    Verify whether SMS topics are included alongside Human Factors content.

  4. 4.

    Confirm the training aligns with current AMC and GM requirements, including ED Decision 2022/011/R expectations.

  5. 5.

    Retain certificates, syllabus references, duration records, and provider approval details for audit review.