Well fellow mechanics and repairmen, here is your first opportunity to get involved. After 10 years of festering and bubbling in the bureaucratic rule making cauldron in the bowels of the FAA building in downtown D.C., the sometimes dead, sometimes alive, Notice of Proposed Rulemaking (NPRM) on Part 145 Repair Stations is finally out for public comment. For those among us who cruise the information super highway with a certain level of self-satisfaction and disdain for the electronically challenged, the Part 145 NPRM is available at www.faa.gov/avr/arm/N99-09.doc.
For the rest of us, you can call the FAA at (202) 267-9680 and request the FAA Office of Rulemaking to send you a copy. Or you can write the Office of Rulemaking, ARM-1, 800 Independence Ave. S.W., Washington, D.C. 20591. Whether you call or write, you must identify the NPRM with its docket number: FAA-1999-5836.
The devil you do know. . .
This NPRM is not a namby-pamby; nip and tuck revision of a couple of rules here and there in Part 145. This is a full-blown revision of the Part that takes 185 double-spaced, 8 x 11 pages to explain. This folks, is a super nova of regulatory change and change of any kind usually can scare the heck out of people. My Irish ancestors have a saying about change: "The devil you do know (old Part 145) is better than the devil you don't know (NPRM on Part 145)." The moral of the adage is, "Get to know the new devil and then you can decide to be scared or not."
Before I introduce you to the new devil, I want you to understand how important it is to you personally and to our profession to participate in the FAA's rulemaking process. This year, many of you commented on the Part 66 NPRM. But out of a population of 125,000 "active" mechanics, the FAA only received 2,200 comments on the Part 66 NPRM. While I was personally delighted with the number of comments in comparison to other NPRM dealing with maintenance, in reality, less than 2 percent of us commented on the rule that would change our profession and ultimately impact on our career.
The NPRM on Part 145 is another one of those career-changing rules. While you may not work for a repair station now, chances are very good that in this crazy aviation maintenance job market, that before you close your tool box for the last time, you will work in a repair station, or at the very least, you will contract work out to one. So don't blow off this NPRM as something the repair station guys have to deal with. This is a devil you know all about. One last thought: Comments do not have to be negative all the time. FAA would also like to hear what you like about the NPRM, but if you have a negative comment please tells us how you would "fix" it. And yes, all your comments will be read, it's the law.
Interested persons can comment on the NPRM in writing by sending them to U.S. Department of Transportation Dockets, Docket No. FAA-1999-5836, 400 Seventh St. SW., Room Plaza 401, Washington, DC 20590. Comments can also be sent electronically to the following e-mail address: 99-NPRM-CMTS@faa.gov. However, this comment period closes on October 19, 1999, so time is a-wasting.
What follows is a brief overview of the NPRM. This outline should be considered a "horse-de-over" of information only and not the main meal. However, I will take the time to caution you not to be to quick in adopting the opinion of others, be they FAA, or a trade society, or aviation maintenance organizations. Read, and ponder the NPRM carefully because the rest of your career may depend on it.
Part 145 is being revised so U.S. FAA certificated Repair Stations can compete in a more global market place. Some of the major changes are:
1. Limited ratings for Manufacturers' Maintenance Facilities (MMF) will be eliminated and require MMF to obtain the appropriate repair station certificate rating.
2. Deviation Authority Something new, which will allow the Repair Station flexibility in maintenance operations that would be identified in the Repair Station's Operating Limitations. (FAA has requested specific comments from the public on this section of the NPRM.)
3. Ratings: FAA is looking at issuing Ratings and Classes based on certification standards. There will be nine ratings: Airframe, Powerplant, Propeller, Avionics, Computer Systems, Instrument, Accessory Rating, Limited Ratings and Specialized Service Rating.
Class: There are seven Airframe Class ratings:
Class 1: Aircraft other than rotorcraft and aircraft composed primarily of composite material that weigh less than 12,500 pounds maximum certificated take off weight.
Class 2: Aircraft other than rotorcraft and aircraft composed primarily of composite material that weigh more than 12,500 pounds maximum certificated take off weight and including 75,000 pounds maximum certificated take off weight.
Class 3: Aircraft by make and model, excluding rotorcraft and composite aircraft over 75,000 pounds maximum certificated take off weight.
Class 4: Rotorcraft of 6,000 pounds maximum certificated take off weight or less, excluding those rotorcraft composed primarily of composite material.
Class 5: Rotorcraft of 6,000 pounds maximum certificated take off weight or more, excluding those rotorcraft composed primarily of composite material.
Class 6: Aircraft composed primarily of composite material of 12,500 pounds maximum certificated take off weight or less.
Class 7: Aircraft composed primarily of composite material of 12,500 pounds maximum certificated take off weight or more.
Class 1: Reciprocating engines.
Class 2: Turbopropeller and Turboshaft engines
Class 3: Turbojet and Turbofan engines.
Class 1: Fixed-pitch and ground-adjustable propellers.
Class 2: Variable-pitch propellers.
Class 1: Communication equipment.
Class 2: Navigational equipment
Class 3: Pulsed equipment Computer
Class 1: Aircraft computer systems
Class 2: Powerplant computer system
Class 3: Avionics computer systems
Class 1: Mechanical
Class 2: Electrical
Class 3: Gyroscopic
Electronic. Accessory Rating:
Class 1: Mechanical accessories that depend on friction, hydraulic, mechanical linkage or pneumatic pressure for operation.
Class 2: Electrical accessories that depend on or produce electrical energy.
Class 3: Electronic accessories that depend on transistors, lasers, fiber optics, solid state integrated circuits, vacuum tubes or similar devices.
Class 4: Auxiliary Power Units: (APU) installed on aircraft as self-contained units.
These ratings will be issued for aircraft, airframes, powerplants, propellers, avionics, computer systems, instruments, and accessories by make and model.
Specialized Service Rating: These ratings will be issued for any specialized service the Administrator finds appropriate for this rating.
NOTE: If the NPRM is adopted, there will be a huge administrative burden to update ratings and classes both on the FAA district office and industry. The NPRM requests any ideas from the industry to make the transition a little bit easier.
5. Quality Assurance: One of the NPRM changes will be the requirement for a Quality Assurance system in which the Repair Station will monitor its workmanship. Smaller Repair Stations will be able to assign individuals to quality assurance on a part time basis.
6. Capability List: The capability list will identify all the articles by make and model on which the repair station is capable of performing work: The Repair Station's ratings and classes will still be identified on its Operating Specifications. However, the repair station can update its capability list based on a self-evaluation of its training, tools and equipment, data, etc. After that self-evaluation, add a particular make and model article to its capability list, and then be able to perform maintenance on that article without getting its Operating Specifications changed.
7. Contract Maintenance: The NPRM will allow any Repair Station to contract work out on any article for which it is rated. This contract work must be identified in the repair station's manual along with the names of the facilities to which it contracts work and how that work will be accepted. The NPRM also requires the Repair Station to qualify and perform surveillance on that contract facility.
8. Training Program: Simply put, under the NPRM all Repair Stations will have to have an initial and recurrent training program for any person performing maintenance or preventative maintenance.
9. Line Station Maintenance: The NPRM will allow a Repair Station to perform line maintenance on a Part 121 or Part 135 air carrier without meeting all of Part 145 requirements for a rating or, addition of aircraft(s) to the Repair Station's Operation Specification. Repair Stations could provide this service for operators based on the Part 121 or 135 manual or approved program.
10. Record Keeping and Reporting Requirements: Maintenance releases will be revised to require make, model, identification number (serial number if applicable) of the article worked on. This information must be kept for 2 years and can be in paper format or on an automated data processing system acceptable to the Administrator.
11. Repair Stations Outside of the United States: While the thrust of this part of the NPRM is to make foreign and domestic Repair Station almost seamless in regulatory requirements, there are differences. The NPRM is considering, authorizing an advisory panel or other partnership between industry and labor representatives to identify any deficiencies or inequities between foreign and domestic repair station rules. Comments are especially requested from industry on this proposed section of the rule change.
The second opportunity
This second opportunity to get involved is a little bit different than commenting on a NPRM. I need some help in a different area of concern that is not safety related.
As you know, I am a bureaucrat and I work in FAA Headquarters in downtown D.C., about a stone's throw from the Air and Space Museum. About every month or so, on my lunch break, I wander into the museum and look at the airplanes hanging from the ceiling and look at the new displays just to remind myself what kind of business I am in.
What I have noticed during my monthly sabbaticals to Air and Space is that there is no formal recognition given to mechanics — None! Displays of pilot's accomplishments of course, even a display on the evolution of flight attendant uniforms, but not one display explains the contributions of mechanics to the aviation industry. Being Irish, cursed with terminal acne at a young age, and raised in Philadelphia, I am used to rejection, but not on a national level, and I don't like it. Especially since we are coming up on December 17, 2003, on the 100th Anniversary of Powered Flight.
So here is where I need a little help. I need an industry committee that would take the lead on establishing a Charles Taylor (the Wright Brother's mechanic) display in the Air and Space, either here in Washington or the new annex that will be built out near Dulles Airport in Virginia in the not too distant future. The Charles Taylor Memorial committee will have three sub-committees (can you tell that I work for the government?); they are Executive, Research, and Finance.
The Executive committee (five members) will be the coordinating and implementation arm of this project and will have the overall responsibility for managing the success or failure of this undertaking.
The Research sub-committee will have only seven to ten individuals whose primary job will be to research and satisfy the display requirements of the Air and Space museum which are murky and unclear. Their secondary job will be the marketing of the project.
The third subcommittee will have 20 to 25 members and their job will be not only to raise the money to build the Charles Taylor display, but to create a fund that would maintain the display for as long as mechanics work on aircraft. I have asked Marty Bailey, the regional Safety Program Manager for the southern region to initially act as the FAA coordinator to get the committees on their feet. I also suggested that each of the committees should be made up of Charles Taylor "Master Mechanic" award winners, and industry sponsors. The FAA Aviation Safety Program will assign two FAA inspectors to assist in this industry project. If there are any industry sponsors and "Master Mechanics" out there that have the fire in their bellies and are willing to fight the good fight, then call Mr. Bailey at (502) 582-6116, extension 138. Tell Marty, O'Brien sent you.
A mechanic sent this closing thought to me. Maybe you will agree with me that this best defines who we are and what we do.
"When you look up and see the sunburst gleam off shiny wings at altitude. It is a tribute to the pilot's skill that took it there. The white line behind those wings is the signature of a mechanic whose labors keep it there.