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.
Editor’s Note: In the February issue Bill O’Brien began a discussion on the new regulations for the Part 145 manual requirements.
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