New Part 145: It's a final

FAA Feedback


New stuff
1. The rule set up some new definitions we have to learn such as "accountable manager," "article," "directly-in-charge," and "line maintenance."
2. It requires a new repair station manual to be developed that explains how the repair station operates and its procedures to ensure the "article" worked on is properly approved for return to service.
3. Requires a new Quality Control manual that is similar to the currently required inspection procedures manual.
4. Allows for satellite repair stations as long as the satellite repair station is in the same country as the repair station that has managerial control over the satellite.
5. Allows Limited-Rating repair stations the option to develop a Capability list which identifies articles by make and model that the repair station can approve for return to service. These articles must be listed on the repair station’s operation specifications.
6. Sets contract maintenance requirements (outside work) including work performed by a non-certificated person.
7. The rule eliminated the limited rating for manufacturers which was no surprise to anyone.
8. Rewrote the housing requirement for an airframe rating to require permanent housing that encloses the largest type and model of aircraft listed on its operations specifications.
9. New FAA foreign repair stations may be issued a certificate based on certification of the CAA of the country where the repair station is located, if there is a bilateral agreement in effect.
10. Training programs must be approved by the FAA and in place in two years.

Old Stuff
1. The class and other ratings have not been changed.
2. Operating Specifications are the same as before.
3. The foreign repair stations still must pay a fee and must renew in 12 months after the first certification of the repair station and 24 months after that.
4. Certification of repairman has not changed.

I pride myself on my network of aviation spies I have put together over the years. My operatives work both in the industry and inside the FAA. They feed me bits and pieces of intelligence and wild rumors on such things as new regulatory issues and industry developments, which I, in turn, mull over; separating the good stuff from the bad, in an effort to see "the big picture." Some of the time, my "big picture" view of aviation has a bad horizontal hold, but there have been times when my insider information has put me on top of new developments, and, as we all know, knowledge is power. The power trip comes in when I choose whom, when, and where to share the information. I set the stage, usually when we are all taking a coffee break, and then with the quiet confidence of one who knows the fight has been fixed, I prophesy on future developments. This "Oracle of Delphi" technique of mine, in turn, invokes a sense of awe and grudging respect among my peers, which is not a bad thing for a government employee when you have nothing else going for you. But I must admit, despite my vast resources, I was caught flat-footed the other day when I heard the new Part 145 was signed and released on August 6th as a final rule.

Quick history lesson
Repair stations were first created in 1938 by the Civil Aeronautics Act and later re-codified into the Federal Aviation Regulations (FAR) in 1962. So, repair stations have been with us for quite some time and pre-date the FAA by some 20 years. The present drive to update Part 145 started in 1989 with four public meetings to determine what revisions to the rule should be made. As a result of the meetings, some policy changes and Advisory Circulars (AC) were written, but rulemaking was put on hold because we found ourselves in a "Harmonizing" mode in the early 1990s with the new Joint Aviation Authorities (JAA) in Europe. The problems in trying to get us and over 27 other countries to agree on a common set of aviation regulations is daunting enough when you consider that in the last 1,000 years, every member country declared war on every other member country at least once. This one fact makes for some interesting conversations and long delays at arriving at a solution.

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