Leaky Boat: Part 1

The rule states that you have to have a training manual submitted by April 6, 2005.

You missed a meeting, and later found out that your boss assigned to you in-absentia to write the required new Part 145 manual for your repair station. You don't have the foggiest notion of how to do it, nor does anyone else in the repair station including your boss. This lack of skill in manual writing is understandable because the current repair station manual was written back in the late '60s.

You are more than a little scared. You know that if you don't meet the manual deadline, the repair station cannot operate. You see yourself, all alone, sitting in a very small leaky boat, in a big ocean, and it looks like rain. Well my friend, don't feel alone, you have plenty of company. I am quite sure there are at least 5,000 other guys in Part 145 repair stations sitting in similar leaky boats and desperately looking for a bucket.

Through this article I will climb into the leaky boat with you and hand you a bucket. My bucket is basically a series of recommendations on how to research, organize, then write your repair station manuals. The bucket also contains a suggested format to follow that should keep you out of trouble. I regret that I cannot give you boilerplate paragraphs that would answer the requirement for each of the new rules. That's impossible. They don't make a bucket big enough. Very few of the 5,000 plus Part 145 repair stations operate in the same manner, provide the same services, and have similar approaches to running a business. Let's get started, the water is up to my ankles.

Research: At the very least do your homework. You will need to gather and read the following documents and publications.

a. Your current repair station inspection procedures manual.
b. List of repair station managers, inspectors, repairman, and their job titles, duties, and responsibilities.
c. All the forms that you presently use, including Form 337, Form 8130-3, maintenance release, parts identification tags, un-airworthy tags, 8120-11 Suspected Unapproved Parts form, Malfunction and Defect forms, etc.
d. If your repair station does work for air carriers you need information on drug and alcohol testing. You can find this information on the Drug Abatement Homepage at http://www2.faa.gov/avr/aam/adap/.
e. AC 21-29B (change) 2 Detecting and reporting SUPS.
f. List of approved and acceptable data, including process specifications if any.
g. AC 43.13-1B and AC 43.13-2A.
h. FAA Airworthiness Inspector's Handbook, Order 8300-10. It is located at http://www2.faa.gov/avr/afs/faa/8300.
i. A copy of the new Part 145 rules. You can find this information on http://www.arsa.org/
j. A draft copy of AC Part 145-MAN. You can find this AC at http://www.opspecs.com/
k. Copy of Part 43, Part 21, and Part 91.
l. AC 120-78, acceptance and use of electronic signatures, record keeping, and electronic manuals, if applicable.

For a medium size repair station of 20 employees, I estimate that it will take you 40 hours to gather and read all the documentation. In short order, you will find out how the repair station is being run vs. how your current manual says it is being run.

Next, I want you to make a "straw dog." A "straw dog" is a less than perfect manual which is developed by taking the procedures in your existing inspection procedures manual that meet the old Part 145 rules, and marrying that information into the sections of the new rule. This can be done fairly quickly if you look at the Part 145 cross reference table on page 41115 of final Part 145 rule that is printed in the Federal Register of Aug. 6, 2001. When you finish, you will have a good start on your repair station manual and if you are lucky you might have filled in some blanks to your quality control manual. But more importantly you now know what you need to do.

After you become the resident expert on your repair station operation you should get together with management and give them the "straw dog." Next brief them on the differences between the manual and how the repair station is presently doing business. Then ask them since the manual has to be changed anyway, do they want to maintain the status quo, or explore more effective or efficient ways to make a buck. For example, do they want to have a satellite repair station, get another rating, go to electronic signatures and manuals, contract out, or rent equipment to other repair stations? Give them a week to decide. Either way they go, get their response in writing, because that piece of paper is really your marching orders on how they want the manuals written.

Organizing your manuals. To be certified under the new Part 145 you must have the following:

a. Repair station manual.
b. Quality control manual.
c. List by type, make, or model as appropriate, each article you are going to work on.
d. Organizational chart and the names of managing and supervisory personnel.
e. Description of the repair station's housing and facilities and its address.
f. List of maintenance functions you want to contract out. (Note: For a definition of "maintenance functions," refer to AC145-MAN as revised.)
g. List of maintenance contractors, along with the function they provide, their ratings if certificated.
h. Training program.

Recommendations: While the above requirements are the mandatory minimum documentation that you have to create, I suggest that you make at least four manuals and three lists. It's really the same requirements so your workload is the same but I think having four separate manuals and three lists would be easier to organize, write, and revise.

The manuals are: repair station manual, quality control manual, forms manual, and training manual.
The lists are:

1: Capabilities list - in lieu of using the operation specifications - for the make and models of articles that you work on;
2: List of maintenance functions that you want to contract out and identify those certificated and noncertificated facilities;
3. List/roster of management, supervisors, persons authorized to sign a maintenance release and certificated repairmen.

On the top of each manual page and list print the name of the repair station, date, revision number, page number, and section or rule it is addressing, if applicable. Do not use sequential numbers in your manuals in order to avoid re-formatting all of the manual's page numbers when a revision is made. Also identify each major section (sub-part) in the manual with its own numbering system (a-1, b-1, etc.). Make sure that a cover letter to the FAA accompanies the manuals.

I also suggest that you put together a regulatory control sheet in the general section of the repair station manual that lists the 33 new rules or tells the reader where in the manuals they are addressed. This regulatory control sheet idea is similar to a Letter of Compliance that you had to develop if you got a repair station certificate in the last six years. But use common sense when you put together the control sheet. If you do not work on Air Carrier equipment, still list §145.205, but say it is not applicable and a short reason why. While it will take some time to develop the regulatory control sheet, it will serve as a checklist so you don't miss a rule and will help the FAA inspector review your manual faster.

When describing a process or procedure to comply with a rule make sure you answer the who, what, when, where, why, and how. Also include a description of the forms needed to complete a procedure. Design into each manual a table of contents, list of effective pages, and record of revisions. But, remember, "Many words rarely equals clarity." Edit your manual at least three times before submitting it to the FAA.

Repair station manual
This is really an autobiography of the repair station, it should not be a work of fiction. Refer to AC 145-MAN as revised for additional guidance and suggestions.

For a quicker manual/list acceptance by the local FSDO, I recommend that its format be laid out just like the five sub-parts in the new Part 145 rule. For example: Sub-part A --- General; Sub-part B --- Certification; Sub-part C --- Housing, facilities, equipment, materials, and data; Sub-part D ---- Personnel; and Sub-part E ---- Operating rules.

The new rule that controls what the repair station manual must contain is §145.209. We will go over it in detail, but while this is not a FAA requirement I recommend that before you jump into writing the sub-parts or chapters in your manual that you first provide the reader with an overview of what services the repair station provides, how it is organized, as well as company goals and objectives. Also include the name of the accountable manager, and department supervisors and their telephone and fax numbers. Why? Not only will the repair station manual be mandatory reading for all new and current employees, but it will be read by other organizations who may want to contract out your services. This is a good spot to fluff up your feathers and tell the world just who and what you are.

Sub-part A: General: ref: §145.209 (a)

1. Describe how each manual is revised, identified, distributed, controlled, who is responsible for these actions, and how each revision is controlled and recorded.
2. Make an FAA control page for each manual and list, so the FAA inspector can sign acceptance of the original manual(s) and revisions.
3. Describe procedures and feedback system to ensure that every manual has received and incorporated the latest revisions.
4. Give the number of manuals that will be used, how they are identified, and where they are physically located.
5. List the name of the individual(s) who are responsible to revise these manuals and lists (ref: §145.209(b)).
6. List the maximum amount of time allowed to revise all of the repair stations manuals (ref: §145.209(j)).
7. Describe procedures on how to revise the manual(s) and list(s) and how often the FAA will be notified of these revisions (ref: §145.209(k)).
8. Make a statement that the repair station will not operate or perform any maintenance unless properly certificated. Also point out where the repair station certificate and operation specifications are displayed (ref: §145. 5).
9. List the repair station's ratings (ref: §145.59 or 61 as applicable).

Sub-part B: Certification:

1. I would include a copy of the certification paperwork (ref: §145.51). This is not required, but might come in handy in the future.
2. Create an organizational chart that: (ref: §145.209(a))
a. Identifies each management position who can act for the repair station;
b. Includes area of responsibility assigned to each management position;
c. Describes duties and responsibilities of each position.
3. Can your brother-in-law understand the chart?
4. Are the titles in the organizational chart consistent with the titles and authority in the rest of the manuals?
5. Does the chart clearly show the separation of maintenance and inspection departments if applicable?
6. Describe how the repair station will address a change to its certificate, either an addition or removal of ratings, or transfer of assets (ref: §145.57).
7. A list, or reference to a list, that identifies by type, make, or model as appropriate of each article to be worked on (ref: §145.51(a)(3)).
8. Location of the quality control manual (§145.51(a)(3)).
9. Location of the training manual (§145.1).
10. Location of a list that identifies work that is contracted out to FAA repair stations or uncertificated persons.
11. A statement that says the repair station certificate must be returned to the FAA if the certificate is surrendered, suspended, or revoked (§145.55).

Sub-part C: Housing facilities, equipment, materials, and data: Ref: §145.101, 103, and 209 (c)

Describe, in paragraph form, an outline of the repair station facilities, its equipment, materials, and data used when the work is being done, and include the following:

1. A scaled drawing of the facilities, listing square footage for each work and segregated areas.
2. Identify all segregated work areas such as painting, battery charging stations, electronic work, parts room, welding, etc.
3. Identify areas where parts are in storage, awaiting maintenance, shipping, or in stock.
4. Identify the ventilation, lighting, temperature, and humidity controls including any special environmental conditions.
5. Identify the number of racks, hoists, trays, stands, benches, hydraulic mules, test equipment, etc.
6. Identify the kind and type of data available and if data is supplied by another party, how that is accomplished and kept current and who is responsible (§145.109(d)).
7. Identify how life-limited parts/stock items will be controlled and who is responsible.
8. Describe the stock/tool room operations, ordering of parts, the calibration of the special tools. How they are accomplished, tracked, and who is responsible (§145.109(b)).
9. If the repair station leases or rents equipment or tools, how is that handled, who is responsible, and how are items transferred.
10. If the repair station makes its own special tools, identify the procedures or data for determining that those tools are equal to the manufacturer's. Who makes that decision? (ref: §43.13 and §145.109(c)).
11. If the repair station has an airframe rating, it must make a statement that the facilities are big enough to fully enclose the largest make and model aircraft that is listed on its operating specifications (ref: §145.103(b)).
12. If work will be accomplished outside of its facilities, the repair station must list procedures, equipment, and facilities acceptable to the FAA (ref: §145.103(c)).
13. Describe how the repair station will operate if the repair station is changing its facilities, location, or housing (ref: §145.105).

Sub-part D: Personnel: (ref: §145.151)
First you have to identify the "accountable manager." This is the individual who holds the wet paper bag of responsibility and he or she must have the authority to make changes in the repair station operation as well as the responsibility for its operation. The accountable manager is also the FAA's point of contact. So pick a good one (ref: §145.151(a)).

Next, list the chain of management and supervisory command and who reports to whom. Who is responsible for what part of the repair station, and who settles conflicts between individual divisions of the repair station? In addition you need to make a statement that the repair station will provide enough qualified supervisory and employee personnel to ensure that all work performed is in accordance with Part 43.

Make reference here to your list or roster of management, supervisory, repairmen, and personnel who can approve an article for return to service. Identify where each of the lists are located. Again, make sure this list matches the organizational chart (ref: §145.151(b)).

Describe how the repair station will determine the abilities of its noncertificated employees that perform maintenance functions. Briefly describe how this determination will be made based on training, knowledge, experience, or practical tests. List the name(s) of those responsible to make this determination (ref:§145.151).

(1) Supervisory personnel requirements: If the repair station is located within the United States, include a statement that each supervisor will be certificated under Part 65. State that each supervisor must be thoroughly trained in, or familiar with the work to be performed, and responsible to oversee the work performed by any individuals who are unfamiliar with the work to be performed (ref: §145.153 (b)).

(2) Inspection personnel requirements: Include a statement that the inspection personnel "understand the applicable regulations of the FAR, and are familiar with methods, techniques, and practices to determine the airworthiness condition of the article that is being inspected" (ref: §145.155).

(3) Supervisory, inspection personnel, and repairmen are required to read, write, and understand English. You might want all of them to take an English skills test. For example, have applicants read a portion of a maintenance manual, and then ask them to write, in their own words in English, what the manual wanted them to do, then explain the procedure in English orally. The person responsible for this requirement must be identified (ref: §145.153, §145.155, §145.157).

(4) This part of the manual should describe how the repair station will select, train, and ensure that each repairman meets the eligibility requirements of §65.101 (ref: §145.159).

(5) If your repair station works on air carrier aircraft or components, put your drug testing requirements here.

Editor's Note: The March issue of AMT will include Part Two of Bill O'Brien's "Leaky Boat" discussing the new Part 145 manual requirements.