A Regulation for Maintenance Organisations
By RC (Bob) Williams
JAR-145 is a regulation first published in 1991 which addresses the requirements to be met by a maintenance organisation that wishes to maintain aircraft, components or equipment used in commercial air transportation.
Under the JAA regulations, only organisations that are certificated under JAR-145 may carry out maintenance of such aircraft, components and equipment. This is unlike FAR in that a JAA airline or air taxi organisation may only maintain its aircraft if it holds a JAR-145 approval. This philosophy is based on the concept that there should only be one standard for maintenance of aircraft used in commercial air transportation.
It also follows that the JAA airline or air taxi organisation need not be JAR-145 approved if it prefers to use another JAR-145 approved organisation on a contract basis. Irrespective of who will maintain the aircraft, the JAA member Authority must approve any maintenance arrangement, once compliance has been established, with the relevant regulations.
JAR-145 has been subjected to six amendments since 1991 and the current version known as the change 2 version reflects the need to ensure if not improve safety standards for the travelling public. It also reflects the changing technology and methodology of the aviation industry. It is worth noting that two further amendments are in process at this time.
Turning to the issue of the impact of JAR-145 on USA-based FAR-145 repair stations — it is worth remembering that 145 was, and still is, developed in co-operation with the FAA and based where ever possible upon FAR-145. In reality JAR-145 is an updated version of FAR-145 and it only remains for the proposed FAR 145 NPRM to get off of the political agenda to re-align the two regulations.
On the assumption that the reader understands FAR-145, the remainder of this article will concentrate on the differences between FAR and JAR-145 as seen from a JAA point of view, starting with the most significant.
JAR-145 required a working quality system rather than the inspection system specified in FAR-145. It's worth noting that FAR-121 Subpart L requires a quality system for air carriers. This difference is not intended to suggest that there is anything wrong with inspection systems. In fact, a repair station can combine the quality with the inspection system.
The advantage of a quality system is the ability , or the intended ability, of such a system to make a complete overview of a repair station in an endeavour to minimise problems from arising — thereby improving efficiency and safety.
The quality system required by JAR-145 is not a total quality system but more of a quality audit and follow-up system. This system operates independently of the routine maintenance and inspection system.
The quality audit element is required to be a pre-programmed audit carried out by designated quality personnel of all aspects of maintenance, including the inspection function, and are generally required every 12 months. The independence of the audit must be assured by using designated quality personnel not responsible for the particular aspect of maintenance being audited. The quality audit process will generate findings/discrepancies from time to time and it is the function of the follow up system to ensure correction of such findings/discrepancies in a timely manner. This means that safety issues must be corrected immediately, significant issues corrected within weeks and less significant issues corrected within months. The performance of the quality system as a whole and the responsiveness of the repair station to findings/discrepancies must be reviewed with the accountable manager at least once per year.