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
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...
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