Joined by the Regulations
Airlines and repair stations follow the same rules
By Thomas A. Brown
Contrary to reports in the general news media, both repair stations and air carriers must follow the exact same maintenance rules. Although there is an additional layer of regulatory protection when a repair station provides services directly to an air carrier, both parties are responsible for ensuring the quality of the work performed. The work must meet the minimum standards set forth in the Federal Aviation Regulations (FARs), as well as the air carrier's own particular maintenance policy and procedures manual(s).
Section 145.2 of the FARs establishes the requirement for clear communication between the air carrier and the repair station. Unfortunately, neither the FAA nor the industry has ever really set forth guidelines on who should be responsible for what. At first blush, the rules may seem fairly straightforward. The repair station must follow specifically enumerated sections of Part 121, Subpart L, and the air carrier must ensure that the repair stations are following them.
Let's take a look at what those straightforward rules require of the repair stations and air carriers. Sections 121.365 and 367 require both the air carrier and the repair station to have an adequate organization and the programs necessary to perform any of its maintenance contemplated by each entity. The air carrier must have the organization and programs necessary to provide services to the entire fleet maintained under the air carrier certificate; while the repair station need only focus on the particular maintenance being performed for the air carrier under the repair station certificate.
Section 121.371 sets forth the requirements for both the repair station and the air carrier to ensure that each of their personnel performing required inspections are properly trained, qualified, and authorized — whether these functions are performed by employees of the air carrier or of the repair station.
The training requirements for air carriers and their repair stations are set forth in 121.375. Each person who determines the adequacy of work performed must be fully informed about the procedures, techniques, and equipment used, as well as be competent to perform those duties. This means that regardless of who actually employs the person, whether it's the repair station or the air carrier, that person must be fully cognizant of and follow the air carrier's particular maintenance program. It does not mean that the chief inspectors at repair stations need to spend all their time in training. However, each person at a repair station that approves articles for return to service needs to understand the regulatory requirements of the air carrier before taking that action.
Who's in charge? Persons directly in charge of maintenance activities, under Section 121.378, must be appropriately certificated. Although the section starts off with an exception for repair stations, Section 145.39(c) clearly indicates that the air carrier and the repair station are under the same requirements. Actually, Section 121.378 provides a more clear definition of the term "directly in charge," which may actually assist the repair stations in fulfilling their obligations.
The most important rules for air carriers and their repair stations are found in Sections 121.380 and 121.380a, which covers records and their transfer. The responsibility is clear for both parties to make complete and accurate records of not only the work performed, but also the total time in service, the time since last overhaul, and a myriad of other specific information. This general requirement is to ensure that the air carrier has the records necessary to return an aircraft to service.
Using the correct resources
In addition to the requirements in Subpart L, repair stations must perform the work in accordance with the air carrier's maintenance manual. This is where additional guidance, clarification, and communication is desperately needed. An air carrier that has more than one manual containing information on how it maintains its fleet complicates the communication process and may impact the repair station's compliance ability.
The information necessary to perform a particular component repair is going to be significantly different than that needed to perform an aircraft heavy maintenance check. In one case, the specific maintenance and recordkeeping procedures may be the only information exchanged. In another scenario, the air carrier maintenance manuals could actually impact the work that is being performed. Finally, specific procedures required by one air carrier may not be valid for another carrier.
Air carriers and repair stations are truly joined by the regulations. There cannot be enough emphasis placed on direct communications, complete understanding, and absolute cooperation between the maintenance partners that are involved daily in decisions that affect the airworthiness of their products.