It's a gorgeous Wednesday morning in June. The hangar is full. Your 10 mechanics are only grumbling at idle RPM, and you take it as a good sign. The boss is happy because it looks like the repair station will be in the black again this month. You consider hitting him up for a raise if you can make it into the black three months in the row. Life is good, but being a mechanic right down to your bones you know good times can't last, they never do.
As if on cue, the cell phone on your belt buzzes and tickles your love handles. You instantly know it's trouble. Odd, that such a thought would pop into your head about a phone call you didn't even answer yet. It buzzes again. The feeling of dread intensifies. A subliminal message from hell? You dismiss the thought with a smile and mutter something about watching too many X-files on TV, you punch the ON button and say "Good morning, North Philly maintenance, Patrick Poteen here, can I help you?"
You recognize the voice on the other end of the line and your nerve ends freeze. It's your FAA Principal Maintenance Inspector (PMI) and he gives you the good news that he has scheduled a Part 145 Repair Station inspection for your shop on the following Monday and he would like you to be his personal guest at this event. In less than 15 seconds, the good life went bad.
Your brain registers the fact the Feds are coming and the news is as welcome as a midnight toothache. You are upset because the annual nightmare has begun sooner than expected. For the next five days, you will get to work early and leave late so you can properly showcase areas where you comply with the FAR, or prepare an adequate defense of your private indiscretions. Plus, at least a half a day of the next five days must be dedicated to spit shining your excuses. It's payback time. FAA inspections are the price one must pay to hang the FAA Part 145 certificate on the office wall.
You know you are not alone. Every year, the local Flight Standards District Office (FSDO) inspects 5,000-plus Part 145 Repair Stations at least once. Some repair stations are the truly blessed ones because they get to be inspected more often by the local FEDS than others. The blessed ones rate this higher level of government interest because of their bigger size, or complexity, or perhaps a shaky level of past performance or lack of compliance with the FARs.
I would now like to offer you a system to lower your anxiety level about FAA Part 145 inspections. I want to sell you on a system called an Internal Evaluation Program, or IEP. IEP is a voluntary internal review of how your repair station stacks up against the regulations, so you know where the problem areas are before the Feds do. IEP is not a new idea. The FAA published a 38- page Advisory Circular (AC) 145.5 on Internal Evaluation programs in September 1995. The IEP is a system-oriented process that continually evaluates the adequacy of managerial controls and processes in critical systems and continuously improves those systems based on the results of regular evaluations. The IEP results go directly to the repair station manager who then has the responsibility to evaluate and implement corrections as needed. When the AC on IEP came out, many of the large repair stations implemented their own IEP. They were driven to drink from the IEB trough not because a FAA rule requires it--there is none, but they bought into the process because the voluntary and independent IEP meets or exceeds the JAA requirement for the Quality Monitoring (QM) system for JAA certification.
If you've never done an internal evaluation program before, then depending on the size and complexity of your repair station, it should take you on the average of two weeks to set up an IEP and a week to do the evaluation. It's not super hard to do, most of the work has been done for you, especially when Appendix 1 in AC 145-5 gives you a good sample outline of an IEP.
About now, someone is saying, "Three weeks! Are you nuts, O'Brien? Are you out of your bureaucratic mind? I have a payroll to meet!" Next comes the unspoken justification speech, "If it is not required by a rule, then I am not going to spend three weeks doing an audit of my own toolbox when the Feds will do it for free. Besides, I have my fawning, sack cloth and ashes penitent routine down pat, and if my 'Take pity on me act' doesn't work, then we'll just pay the fine, fix the mistakes and it's business as usual."
Okay, folks, it's time for an FAA motivational moment! In order to sell you hard-knuckled mechanics on the need for an IEP that may save lives in the long run and make you more money in the short run, I propose a little contest.
How 'bout if I ask you just two questions that every repair station operator should know? Questions that FAA inspectors usually ask. One question is on new policy and the other is on a rule that goes back to 1938 when the repair station rule first hit the books.
Here's the deal. If you get the right answer to both questions, You beat the Fed at his own game and you can stop reading my article right here and now. You get to turn to the next article without even the slightest tinge of guilt and I will even let you mentally rub my nose in my own defeat. But, if you miss one of the questions, perhaps you should consider implementing an IEP. If you miss both questions, you better get a copy of AC 145-5 and read it.
Hint: The answers to these questions should be found in your Repair Station Manual.
Question #1: Policy based question:
A couple of years ago, the FAA implemented a new policy dealing with additional requirements for field approved alterations? What was that policy, and how does a repair station comply with it?
Question #2: Rule based question:
What is a maintenance release used for?
Policy Answer: The policy is called Instructions for Continuing Airworthiness (ICA). When a field-approved alteration is performed, an ICA must be attached to Block 8 of the FAA Form 337.
Rule Answer: A maintenance release is used to record major repairs only. It is used in lieu of a Form 337, and contains two parts: a signed copy of the work order, and an approval for return to service statement. (Ref: Appendix B of Part 43).
If anyone is reading this, Wow, it is the first time in my life I ever won a contest. Ok you lost, but to show you what a nice guy I am, I will give you another chance to get out of setting up an IEP.
Here are some questions I would ask in each of the 12 major areas.
1. Facilities and equipment.
a) Is your current facility identified in your manual?
b) Is all your required equipment serviceable?
2. Repair station authority and limitations versus actual practices.
a) What ratings do you have?
b) Where are your FAA Repair Station Certificate and operation Specifications displayed?
3. Personnel qualifications, training, and staffing levels
a) How many repair station personnel do you have? Do you have a list of who they are and what they can do?
b) Do you have enough people for the amount of work performed?
4. Manuals and airworthiness Data
a) Are the maintenance library, Airworthiness Directives (AD) and Service Bulletins (SB) current? Who is responsible for keeping the library current?
5. Continuity of work and supervision during personnel changes
a) Does your inspection procedures manual, identify the procedures to use when there is a shift change of personnel?
b) What are the supervisor's duties during the change?
6) Supplier selection, approval, and surveillance
a) Who is responsible for work that is sub-contracted out?
7) Parts and materials handling.
a) How are life-limited parts handled?
8) Inspection and quality control processes
The only real way to evaluate the inspection and quality control process is to follow an aircraft or part through the system while checking the Inspection Procedures Manual (IPM) at each workstation. Now do the same with a part or aircraft repaired away from the facility.
9) Tool adequacy and calibration
a) Are all tools and special equipment properly calibrated?
10) Maintenance release process
a) Check your maintenance release for a Major Repair. Note: Maintenance releases cannot be issued for Major alterations, they require a Form 337.
11) Defect reporting
a) How are Malfunctions and Defects reports submitted?
12) Records and record keeping procedures
a) Are the records used on the floor the same as what is called out in the inspection procedures manual?
Get the Buy in
If you cannot get your highest level of management (the big guy) to buy-in 100 percent on the IEP, forget it. The Internal Evaluation Process is not a one-time thing; it is a full-time thing. It will not work if it is done halfway. It will tap repair station resources and use up valuable time in order to weave an IEP into your company's cultural fabric. And to make that happen it needs your manager's total commitment in the IEP.
Okay, you got him or her on board and he accepts the responsibility. Now brief him that the first IEP on your repair station will be a jerky, clumsy process. Remind him or her that it will take several evaluations to fine tuning the IEP process because this is an on going process. The upside of an IEP is the repair station will benefit right away and performance can be continually improved upon year after year by using it.
The IEP should at least evaluate the following 12 major areas.
1. Facilities and equipment
2. Repair station ratings and operating limitations vs. actual work performed.
3. Personnel qualifications, training and staffing
4. Currency, completeness and accuracy of manuals and data
5. Continuity of work and supervision during shift and personnel changes
6. Supplier selection, approval and audits
7. Parts and material handling (Suspected Unapproved Parts)
8. Inspection and quality control processes.
9. Tool availability, condition, and calibration
10. Maintenance release process
11. Defect reporting.
12. Records and record keeping procedures