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.
Paula Derks: Contrary to the FAA's claim, this proposal does not reflect current repair station aircraft maintenance and business practices, or advances in aircraft technology. It simply does not...
Everyone of us has heard the time-worn expression, “Once in a lifetime opportunity,” that is used to describe a single event or series of events that can have a profound change on one’s...
Regulatory Update: OMB Reviews FAA's NPRM on Part 145 Repair Stations--Ratings and Quality System Requirements
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