If your repair station was certificated prior to April 2003 in the months of January, February, or March your due date for a training manual submission is still April 6, 2005. This staggered manual submission process makes it easier on the FAA, and grants repair stations up to two years, nine months from the effective date of the Part 145 rule (April 6, 2003) to develop a new training manual dependent upon when they were last certificated. Here are some ideas you might want to incorporate into your training manual to meet the requirements of §145.163.
- Who is responsible for the training program and its revisions?
- How often will the training program be reviewed for accuracy and currency?
- Who will perform the review?
- How are revisions to the training program identified?
- How is the FAA notified of the revision?
- Written or practical tests?
- The repair station must document this training and keep those records for at least two years.
- Are there procedures in place to ensure that the employees have read and understand the repair station’s manuals?
Capability list: (Ref. §145.209 (d)(1) and §145.215)
A repair station with limited ratings has a choice either to list the makes and models of the articles that it maintains on the operation specifications or on a capabilities list. For ease of making revisions, I recommend using the list. A capabilities list references the makes and models of aircraft or articles that you work on within the limits of your rating(s). For example if you are an engine shop that works only on Lycoming engines, list the engines by Lycoming’s make and model that you work on. (Note: see Part 145 Preamble page 41108 and 41109). However, §145.209 requires that before you submit the list to the FAA you must perform a self-audit to ensure yourself and the FAA that you have the data, equipment, and personnel to perform the work on those engines.
The capability list must also provide procedures for revising the list (§145. 215) such as:
- Describe how the FAA office will be notified of the revision;
- Describe how the self-evaluation required by §145. 215 (c) will be addressed;
- Describe how the self-evaluations will be reported to the appropriate manager for review and action.
- Who maintains the capabilities list?
- Who will conduct the self-evaluation?
- How many times during the year are the self-evaluations conducted?
- How is the self-evaluation documented?
- Who is responsible to correct any discrepancies found during the self-evaluations?
Management, supervisors, and repairman list/roster (Ref: 145.161)
This list or roster should be separated into three separate lists.
- Management list required by §145.161(a)(1),
- Supervisory list required by §145.161(a)(1),
- Inspection personnel list required by §145.161(a)(2), and a
- List of personnel authorized to sign a maintenance release as required by §145.161(a)(3).
Each roster or list must include a summary of employment for each individual listed as required by §145.161(a)(4). The list must include the following information:
- Present title.
- Total years of experience and type of maintenance performed.
- Past relevant employment with names of employers and periods of employment.
- Scope of present employment.
- The type of mechanic or repairman certificate held and the ratings on that certificate, if applicable.
- Although not a requirement of, §145.161(a)(4) add a statement that in case of a change, the change(s) to the roster/list will be revised and incorporated within five business days and the FAA office will also be notified within that same period (ref: §145.161(b)).
Contractor’s list: §145.209(h)(2) and §145 217(a)(2)(ii)
With the contractor’s list you have a couple of choices. You can put the contractors on the operations specifications or make a contractor’s list. The operation specifications must be approved by the FAA but if you list the contractors then the FAA only has to accept them. I suggest that you pick the list because it is the easiest to revise.
The list should have a preamble page to describe the contractor process and identify those procedures to maintain and revise contract maintenance information, in accordance with §145.217 contract maintenance. The manual must describe how contracts are maintained with certificated and non-certificated repair facilities and where copies of these contracts are kept. Any contract that is made with a non-certificated repair facility must state that the non-certificated facility must allow the FAA to observe work being performed on the article ref §145.223. In addition the list must answer these questions:
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