Assessing human factors in aviation maintenance training
Human factors in aviation maintenance training is the teaching of how human performance and its limits, such as fatigue, stress, communication and error, affect maintenance work. To assess it, use the Part-66 Module 9 exam to check knowledge, then collect separate evidence of application and behavior. A score on a multiple-choice paper cannot show how a technician works on shift.
This guide is for training managers, chief instructors and quality managers at maintenance training organisations and Part-145 organizations who must show that human factors training works. It uses EASA and FAA texts as of October 2026 and separates what a rule requires from what you may choose. It is not legal or airworthiness advice, so check your competent authority before you change an approved course.
The post adds a map from each Module 9 syllabus heading to the evidence that can support it, a worked exam-style item, and a set of observable behaviors you can adapt. For how to build the checklist itself, see the observation checklist guide for practical sessions.
Key takeaways
- The Part-66 Module 9 exam is 28 multiple-choice questions in 35 minutes with no essay, so it tests knowledge and cannot show whether a technician behaves differently at work.
- Part-145 asks for competency that includes an understanding of the application of human factors, and for recurrent training that includes human factor issues, but the texts reviewed do not say how to assess behavior.
- Four layers of evidence cover the gap: exam scores, scenario-based items, observed behaviors in practical tasks, and follow-up after training.
- The FAA’s advisory circular on maintenance resource management training describes five evaluation steps and warns that organizations often stop at reaction and learning.
What do the rules require for human factors in aviation maintenance training?
EASA rules require human factors knowledge in two places. Part-66 includes Module 9 in the basic knowledge syllabus for licence applicants. Part-145 requires competency, and recurrent training, that cover human factors. None of the texts reviewed for this post sets a method for assessing behavior, so that choice sits with your organization and your competent authority.
The table lists each source, what the text says and how binding it is, as of October 2026.
| Source | What the text says | Kind of text |
|---|---|---|
| Part-66 Appendix I, Module 9 | Ten headings, from 9.1 General to 9.10 “The ‘Dirty Dozen’ and risk mitigation”, each at knowledge level 1 or 2 (Regulation (EU) 2023/989, applicable from 12 June 2024) | Regulation |
| Part-66 Appendix II, point 2.9 | “28 multiple-choice, no essay questions. Time allowed: 35 minutes.” (quoted) for categories A, B1, B3, B2 and B2L | Regulation |
| Part-66 Appendix II, point 1.7 | The pass mark for each multiple-choice module is 75% | Regulation |
| Part-145, 145.A.30(e) | Competency must include “an understanding of the application of safety management principles, including human factors and human performance issues” (quoted in part), appropriate to the person’s function | Regulation, applies from 2 December 2022 |
| Part-145, 145.A.35(d) | Certifying and support staff receive recurrent training that covers safety management “including human factor issues” (quoted in part) | Regulation |
| FAA AC 120-72 (28 September 2000) | Guidelines for developing, implementing, reinforcing and assessing maintenance resource management (MRM) training | FAA advisory guidance |
The sources are Implementing Regulation (EU) 2023/989, which prints Module 9 and its exam line, and Regulation (EU) 2021/1963, which amended the two Part-145 points. Check the current consolidated Part-66 and Part-145 text before you rely on a point number.
Two cautions apply. The UK’s retained copy of Part-66 on legislation.gov.uk, as read in October 2026, still shows a different Module 9 exam: 20 multiple-choice questions and one essay. Texts differ by country, so confirm which one your authority applies. Also, a basic training course that began before 12 June 2024 had to finish, with its exams, before 12 June 2026, so the 28-question format now applies to all new sittings.
What can the Module 9 exam tell you, and what can’t it?
The Module 9 exam can show that a candidate knows human factors concepts and can apply them to a described situation. It cannot show what the candidate does when tired, rushed or unsure on a real task. Treat it as one layer of evidence, not as proof of behavior.
The Part-66 level definitions help here. Level 1 is “a familiarisation with the principal elements of the subject.” Level 2 is “a general knowledge of the theoretical and practical aspects of the subject and an ability to apply that knowledge.” (both quoted) So level 2 headings justify scenario items, while level 1 headings justify recognition items only.
The table maps each heading to what an exam item can check and what needs other evidence. The right-hand column is this post’s suggestion, not a regulatory requirement.
| Module 9 heading (level) | An exam item can check | Other evidence to consider |
|---|---|---|
| 9.1 General (2) | Why human factors matter; events linked to human error | Follow-up interview on willingness to raise concerns |
| 9.2 Human performance and limitations (2) | Explaining limits of human performance in a scenario | Practical task with a planted discrepancy |
| 9.3 Social psychology (1) | Recognizing terms such as peer pressure and teamwork | Observed group task |
| 9.4 Factors that affect performance (2) | Identifying the effect of stress, fatigue or time pressure | Behavior under a time-pressure inject |
| 9.5 Physical environment (1) | Naming environmental factors | Whether the work area is set up before a critical step |
| 9.6 Tasks (1) | Recognizing task features that raise error risk | Use of an independent check on a complex task |
| 9.7 Communication (2) | Choosing a complete handover in a scenario | A real written and verbal handover, assessed as an artifact |
| 9.8 Human error (2) | Classifying error types and choosing defenses | Stopping and reporting when the task card and the aircraft disagree |
| 9.9 Safety management (2) | Describing reporting and risk basics | A written report of a staged event |
| 9.10 The ‘Dirty Dozen’ and risk mitigation (2) | Matching a scenario to contributing factors and defenses | Follow-up observation on the job |
What does a good exam-style human factors item look like?
A good item gives a short situation and asks for the best defense, so the learner must apply the idea rather than recite a list. The example below is original, written for this post, and is not from any official exam or question bank. It is not representative of the Module 9 paper.
Stem: A technician ends a night shift with a panel removed and an inspection half done. The technician tells the incoming colleague “all fine, panel is off” and leaves. The colleague refits the panel without inspecting. Which action by the outgoing technician would best have prevented this?
- A. Remind the colleague to work carefully.
- B. Record the exact state of the task in the work log and hand over using that record. (Correct)
- C. Stay on after the shift until the colleague finishes.
- D. Ask the supervisor to assign a more experienced colleague.
Option B is a defense that does not depend on memory or goodwill. Option A relies on vigilance, which is the thing at risk. Option C does not scale and ignores fatigue. Option D leaves the missing information missing. The item maps to 9.7 Communication and 9.8 Human error. For writing items of this kind, see the guide to scenario-based multiple-choice questions.
How do you assess application and behavior beyond the exam?
Add two kinds of evidence after the exam: a written or oral case analysis that tests application, and observed behaviors in a practical task that tests what the trainee actually does. Each needs a decision rule written before assessment starts, because neither has a regulatory pass mark in the texts reviewed.
How do you assess application with a case analysis?
Give learners a short event narrative and ask for contributing factors, one defense for each and one question they would ask the team. Mark it against a short rubric. Three criteria are usually enough, and each should describe what two assessors can see in the written answer.
| Criterion | Meets the standard when | Common gap |
|---|---|---|
| Factors found | At least two contributing factors are named from the narrative, with the line that shows each | Blames one person and names no condition |
| Defense chosen | Each defense works without relying on someone being more careful | Defense is “be more careful” or “retrain” |
| Question raised | One question would have exposed the error early | Question restates the problem |
Which observable behaviors can you assess in a practical task?
You can assess behaviors that a second person could see or read in a record. Write each as one action, a condition and a standard, as the CBTA guide to competencies and grading explains. The examples below are illustrative and are not taken from any ICAO, EASA or FAA framework.
| Behavior | What an assessor can see | Heading |
|---|---|---|
| Stops when the task card and the part disagree | Work paused before the next step; question raised to the instructor; mismatch written down | 9.8 |
| Restarts after an interruption from the last verified step | Trainee re-reads the card and confirms the last completed step aloud or in writing | 9.4, 9.10 |
| Records the task state at handover | Log entry names open items, tools and removed panels before the trainee leaves | 9.7 |
| Asks for an independent check on a critical step | Request made before closing up, not after | 9.6, 9.8 |
| Says when time pressure or fatigue limits safe work | Concern stated to the instructor before continuing a critical step | 9.4 |
Score each behavior as seen, partly seen, not seen or not observed, and keep the raw note. Two assessors should score a recorded trainee independently before you rely on the scale. That calibration routine is covered in the checklist guide linked above.
Pro tip: Plant One Discrepancy. In a training rig, make one task card step disagree with the component or manual extract in front of the trainee. Whether the trainee stops, and what they say, is stronger evidence for 9.8 than any exam item. Never plant discrepancies on an aircraft in service.
How do you evaluate whether human factors in aviation maintenance training works?
Evaluate the training at several levels, not only by exam scores. The FAA’s advisory circular on maintenance resource management training describes a five-step evaluation: baseline, reaction, learning, behavior and organizational results. It notes that organizations often measure only reaction and learning, and says behavior and organizational results should be assessed too.
The table pairs each step in FAA AC 120-72 with a maintenance example. The AC is guidance from 2000, so check its current status with the FAA.
| Step | What the AC describes | Example for a training organization |
|---|---|---|
| Baseline | A measure of the current environment before training, using consistent measures afterward | A short pre-course questionnaire on how staff report and hand over work |
| Reaction | Questionnaires immediately after training | Course feedback form |
| Learning | Typically a pre/post questionnaire | The same scenario items before and after the course |
| Behavior | Follow-up questionnaires, interviews and observations in the field, called most valuable | Supervisor observation using the behavior table, 2 to 12 months later |
| Organizational results | Performance measures tracked over time, such as ground damage and no-fault-found removals | Trend in reported errors and near misses at the organization |
The AC does not name an instrument for the baseline and does not say who should run the evaluation. Those are your decisions.
How should you record and use human factors assessment results?
Record each behavior judgment with the assessor, the task and the date, and keep it apart from the Module 9 exam result. Use the data to improve the course and to target recurrent training. Decide in advance whether a “not seen” blocks sign-off, and tell the learner before the assessment.
The texts reviewed set no pass mark for behavior, so a rule such as “no critical behavior scored not seen” is your own. Agree it with your competent authority if the result feeds an approved course or competency record. We also suggest treating results as feedback on the program and on learning, not as a personal rating.
Pro tip: Tag Items to a Heading and a Level. Tag every human factors item with its Module 9 heading and its level. A tally shows at once if level 1 headings such as 9.5 and 9.6 are crowding out the level 2 headings where application is expected.
What should you do next?
Start small. Pick two headings, for example 9.7 Communication and 9.8 Human error. Write five scenario items, one case analysis and two observable behaviors, then pilot them with two assessors and a handful of trainees. Compare their scores and rewrite any behavior they read differently.
Then ask your competent authority whether behavior evidence can sit in the course record or the competency file. None of the texts reviewed says that a regulator approves assessment software, so what matters is that your procedures describe how you collect and use the evidence. An item bank with tags, such as the Item Banking and Tag Management listed on the SimpliAssess features page, can hold the heading and level tags.
If you also track completions and certification expiry, SimpliTrain’s aviation page says it supports delivery and tracking of EASA Part-147 Basic Training, Type Training and OJT completion, with a training tracker and certification monitor. The page does not describe how assessments work, so ask for a demo against your human factors evidence plan.
Frequently asked questions
Is human factors training required for aircraft maintenance technicians?
Under EASA rules, yes in two ways. Module 9 is part of the Part-66 basic knowledge syllabus for licence applicants, and Part-145 requires staff competency and recurrent training that include human factors. Outside the EU, rules differ, so check your own aviation authority. This post did not review FAA Part 147 text on the topic.
How many questions are in the Part-66 Module 9 exam?
The EU text as amended by Regulation (EU) 2023/989 lists 28 multiple-choice questions with no essay and 35 minutes for categories A, B1, B3, B2 and B2L. The pass mark for each multiple-choice module is 75%. The UK’s retained text shows a different format, so confirm which applies to you.
What is the Dirty Dozen in aviation maintenance?
The Dirty Dozen is a teaching list of common causes of maintenance error. The FAA lists lack of communication, complacency, lack of knowledge, distraction, lack of teamwork, fatigue, lack of resources, pressure, lack of assertiveness, stress, lack of awareness and norms. It is a training model, though Module 9 names it in heading 9.10.
Can a multiple-choice test assess human factors on its own?
No. A multiple-choice test shows knowledge and, with scenarios, some application. It cannot show behavior on a real task. Add a case analysis, observed practical behaviors and follow-up after training. The FAA’s advisory circular on maintenance resource management training calls follow-up questionnaires, interviews and observations in the field the most valuable evidence of behavior.
How often do certifying staff need human factors training?
Point 145.A.35(d) requires sufficient recurrent training for certifying and support staff that includes human factor issues. The text read for this post describes a two-year period, but the interval and content are matters for your Part-145 procedures and your competent authority. Confirm both against the current consolidated text.
Does a regulator approve the tool I use to assess human factors?
None of the texts reviewed for this post says a regulator approves assessment software. Approval attaches to the organization and its procedures. Your competent authority oversees how you assess, record and use results, so describe your method in your procedures and ask the authority early.
