Repair Stations Threatened
Part 145 recommendations may shut you
By Stephen P. Prentice
If you work for or contract with a repair station, you should note that the Feds have proposed changes to the venerable FAR 145 Repair Station rules. They state that they have proposed these changes as being necessary because ". . . many portions of the current repair station regulations do not reflect changes in repair station business practices and aircraft maintenance practices, or advances in aircraft technology."
I don't know about you, but to me, business practices seem to have remained about the same for many years. The only exceptions I see are upgrades in equipment and a few computers added here and there.
Nonetheless there seems to be this big push to put more pressure on small repair stations to changes their work practices — changes that will do nothing but increase their costs of doing business.
The key changes involve new requirements relevant to station Ratings and Classes, relative to work performed.
Added responsibility for subcontracted work is also a big part of the new proposed rule. It would place direct responsibility more clearly on the repair station for the work of the contractor. They will be required to audit, assure quality control, and verify any work performed. Repair stations will be held strictly responsible for all aspects of the work. Required manuals would be expanded to include further inspection, training and procedural outlines for all work.
Training would be enhanced and include an FAA approved program for initial and recurrent training for all employees using an FAA approved training manual.
As a technician or other employee at a repair station, you should know that many in our industry believe that these changes will have a serious, negative impact on existing repair stations.
Many feel they will be forced to relinquish their status as repair stations, or worse, just go out of business and shut the doors. It's clear that the administrative and training requirements alone may be sufficient to sink many of them. Add to this, other reporting requirements and the already existing drug testing protocols and liability insurance requirements, and you have a guaranteed formula for disaster.
Certified Repair Stations
The theory behind a certified shop is that it is somehow on a higher level and does better work than a non-certified shop. In reality, under the current law there should be no difference in the quality of the work performed.
The subtle difference, of course, is all too obvious. In one case, the repair station approves aircraft for return to service and in the other, an individual mechanic does the approving. This insulates, to a certain extent, the mechanics working at a repair station and puts the other more directly under the general liability and FAA gun.
Some have wondered and still wonder why we need repair stations in the first place? Well, there are some advantages. If you keep in mind that a repair station can have many unlicensed personnel on the payroll, you can begin to see some of the reasoning.
A repair station can have one or two licensed personnel and many more unlicensed workers — the number can vary up and down over a period of time. Unlicensed people, with some exceptions, have to be supervised. How many workers can an A&P supervise?
Of course, FAA is supposed to have continuous oversight of certified facilities but as we all know from recent history, it just does not happen. So, repair stations may have many unlicensed workers and thus cut down on their payroll requirements.
Additionally, a repair station can have certificated "repairmen." As long as the non-licensed person and/or the repairman work under the "supervision" of licensed personnel, they are legal. Problem is, how much supervision do these people need?
Repair Stations Threatened Part 145 recommendations may shut you By Stephen P. Prentice March 2000 Stephen P. Prentice is an attorney whose practice involves FAA-NTSB issues. He...
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