Further, an advantage of a repair station is that it does not have to deal with the 337 forms. As stated quite clearly in the FAR (App. B, Part 43), a certificated repair station need only use the customer's work order to document the repair or alteration. That's it.
Finally, one of the hallmarks of a certified shop is the continuous surveillance of the operation by the FAA. Today, each shop has an assigned principal maintenance inspector who regularly audits the facility for quality control.
The Non-Certified Shop
There are substantially more maintenance shops in this country that are "small" rather than large. Many certified repair stations are small facilities. General aviation airports in this country have one or more mechanics who operate a small shop maintaining small aircraft. Some of these shops, that typically employ five to ten people, have repair station status. But, do they really need it?
So, it may make good sense to give up your certification, particularly if the new changes come into effect.
Turning in your repair station ticket would do several things. First, FAA surveillance would be reduced. There would be no need to maintain a repair station manual with inspection and training requirements. No need to designate a chief inspector. Possibly reduced insurance premiums. A smaller administrative burden. You can probably think of a few more benefits. What is the downside you ask? Well, you do lose a little prestige. Some customers may put more stock in a shop that was "certified." In today's business however, many don't think this is an important element. And, as mentioned above, you will have to revert to the 337 form for any major repairs or alterations. If there are any other downsides, I would like to hear about them.
There have been many suggestions made but the most useful one seems to be a two-tier repair station setup. That is modifying the so called "tough" new rules and divide the shops into large and small stations. Old rules can apply to small shops and new rules to big outfits.
The reason being that the big outfits can afford the increased administrative load. As suggested, the dividing line could be turbine equipment and piston, or more logically, gross weight and horsepower (thrust) of the aircraft. The idea would be to separate the big guys from the little guys. The bottom line here is that a one-sized rule can't fit all the shops.
Something has to be done in order to keep all the shops we have now. The result of the recently proposed rules will be less surveillance, fewer audits of work performed, perhaps many workers and repairmen out of work — all in the name of keeping pace with growth? Go figure.
Pick up a copy of the proposed new rule and read it. If you have access to the Internet, you can find information on the new proposed rule at http://www.nata-online.org/ part_145_rewrite_table_of_content. htm. Also, you can visit AMT magazine's Web site at www.amtonline. com for links to the Federal Register.
Although the official time to respond to the NPRM has passed (Notice of Proposed Rulemaking) you can still send in your two cents anytime.
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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