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.
Editor’s Note: In the February issue Bill O’Brien began a discussion on the new regulations for the Part 145 manual requirements.
The new Part 145 manual requirements
Ramping Up for the New 145 Public meeting presentations The FAA and industry have been working hard for more than 15 years to perfect the re-write to the rule governing the certification and...
Information that will help the responsible individual