Leaky Boat: Part 2

March 1, 2003
Editor’s Note: In the February issue Bill O’Brien began a discussion on the new regulations for the Part 145 manual requirements.

Editor’s Note: In the February issue Bill O’Brien began a discussion on the new regulations for the Part 145 manual requirements. The new rule states that you have to have a training manual submitted by April 6, 2005.

Sub-Part E: Operating rules:
(ref: §145.201)

The opening paragraph of this sub-part should state that the repair station will perform all maintenance, preventive maintenance, or alteration in accordance with Part 43 on any article for which it is rated and within the limitations of its operations specifications (ref: §145.201(a)(1)). Now you must describe the following operations.

  1. A brief description of how an article is received, inspected, repaired, approved for return to service, and released or shipped by the repair station (ref: §145.205(g)).
  2. Explain in detail what happens at each point or station the article stops at as it passes through the repair station.
  3. The description of work performed on the article at each station/stop should answer the who, what, when, why, and how questions.
  4. Make sure the responsible individual at each station is identified, and what forms and data are used, (reference the forms manual for samples).
  5. If a maintenance function is performed by a certificated person outside of the repair station describe how and what function that is contracted for and how the work is inspected when it comes back.
  6. If a maintenance function is performed by a non-certificated person outside the repair station describe how that work is contracted, how these persons meet your repair station equivalent quality control system, and describe how work is inspected when it comes back (ref: §145.201 (a)(2)).
  7. Describe how the contract maintenance functions are maintained and revised; and how the FSDO is notified of the revisions (ref: §145.209(h)(1) and §145.217 (a)(2)(i)).
  8. The manual must describe how maintenance is performed for an air carrier in accordance with §145. 205.
  9. The manual must state that the repair station must follow the approved inspection or maintenance program of the air carrier.
  10. Describe the necessary equipment, trained personnel, and kinds of technical data required to do the work.
  11. All air carrier maintenance must be authorized on the repair station’s operations specifications.
  12. Identify who is responsible (by title) to keep a file of the air carrier’s procedures and technical data.
  13. Describe how the air carrier’s RII list is maintained and who is responsible for its accuracy.
  14. Describe how the repair station is notified of changes to the air carrier’s manual and who is responsible to ensure these changes are made in the repair station’s copy of the air carrier’s manual(s).
  15. Describe how employee training is conducted on new air carrier equipment. Who identifies it and who is responsible for it (reference the training manual).
  16. Describe how air carrier equipment is returned to service (reference the forms manual).
  17. Describe how major repairs or major alterations are performed, and recorded on either a Form 337 or with a maintenance release in accordance with Appendix B of Part 43 (ref: §145.201(b)(2)).
  18. Describe what records are maintained, for how long, where they are kept, and how they are retrieved. If an electronic system is used, how is it backed up and who is responsible for recordkeeping (ref: §145.209(i)).
  19. Describe how life-limited parts are controlled in accordance with §43.10.
  20. Describe the procedures on how to do work at a location other than the repair station by repair station personnel and who is responsible for that work, how the work is to be inspected, and signed off; and how FAA approval is granted for a special circumstance or for recurring work away from the repair station (ref: §145.203 and §145.209 (f)).
  21. If you are a satellite station or the parent, explain how maintenance/inspection personnel and equipment are moved between repair stations.
  22. Explain how revisions are made to this manual and how the FAA will be notified.

Quality control manual:
(ref: §145.211)

Provide an overview of the repair station’s quality control system, from the time the article comes into the repair station to the time it is shipped out, the number of times the article is inspected, and the kinds of inspections, starting with:

  1. The number of quality control inspectors, who they report to, and who has the final word on airworthiness disagreements between inspection and maintenance personnel.
  2. Inspection of raw materials/parts to ensure acceptable quality and who does the inspection, who is responsible, and how is it recorded.
  3. Preliminary inspection of all incoming articles to be maintained, who does the inspection, who is responsible, and how is the inspection recorded.
  4. Inspection for hidden damage of all articles that have been involved in an accident before work is done; who does the inspection, who is responsible, and how it is recorded.
  5. Explain how inspection personnel will maintain proficiency, training, testing, eye exams, physicals, etc.
  6. Procedures to be used to replace inspection personnel who are on vacation, sick, or left the station employment.
  7. Explain what kind of data is to be used, how it is kept current at the time work is performed, reference manufacturer data if applicable, and identify who is responsible for this action.
  8. Explain how non-certificated personnel are qualified to perform a task, how they are surveiled, and who is responsible to ensure they are qualified.
  9. Explain how the article receives its final inspection, testing, and approval for return to service: Who does it, what kind of paper work goes with the article, what kind of paper work stays in the repair station, and who is responsible (ref: the forms manual).
  10. List the tools and test equipment that need calibration, and the intervals when it must be done. Identify the person responsible.
  11. Explain how warranty work (re-work) will be accomplished, how discrepancies are recorded, and corrective action will be taken. Who makes out the service difficulty report? Identify who is responsible.
  12. The rule requires that the quality control manual includes procedures used for taking corrective action on deficiencies (ref: §145.211(c)(ix) and Chapter 15 of AC 145-MAN).
  13. Explain how the quality control manual will be revised and how often the FAA will be notified of the revisions. List the name of the individual who is responsible.
  14. If maintenance is going to be performed outside the repair station facilities, explain how inspections will be performed on that work, how it is recorded, and by whom (ref: §145.203(b)).

Forms manual:
This manual contains all the forms used by the repair station. The lead-in paragraph should identify who is responsible for this manual, how many times a year it is reviewed for accuracy, and how it is revised. There should be a description of each form, what it is used for, instructions on how to fill it out, who signs the form, and how long the form is kept. For employee training purposes, I recommend that you include a completed sample of each form.

Training manual: Ref. §145.163 and §145.209 (e)
The rule states that you have to have a training manual submitted by April 6, 2005. First take a look to make sure that your old training manual stills covers original, recurrent, OJT, and task specific training. Identify in the manual, who is responsible for the training material and content, how the program is revised, and how many times the training is audited for content and accuracy. Give a short narration on how the training program assures that the employee can perform the assigned tasks. If you do these revisions now, you should not have a lot of revisions to do when the new training manual is due in April of ’05.

We have to talk about the new training manual. Section §145.163 requires that you develop a new training manual and submit it to the FAA beginning on April 6, 2005. The rule goes on to say if the repair station was certificated before that date (April 6, 2005) it must submit its training program to the FAA for approval by the last day of the month in which its repair station certificate was issued. Translation, if the repair station was certificated in May 1995, the training manual must be submitted to the FAA by May 31, 2005.

If your repair station was certificated prior to April 2003 in the months of January, February, or March your due date for a training manual submission is still April 6, 2005. This staggered manual submission process makes it easier on the FAA, and grants repair stations up to two years, nine months from the effective date of the Part 145 rule (April 6, 2003) to develop a new training manual dependent upon when they were last certificated. Here are some ideas you might want to incorporate into your training manual to meet the requirements of §145.163.

  1. Who is responsible for the training program and its revisions?
  2. How often will the training program be reviewed for accuracy and currency?
  3. Who will perform the review?
  4. How are revisions to the training program identified?
  5. How is the FAA notified of the revision?
  6. Written or practical tests?
  7. The repair station must document this training and keep those records for at least two years.
  8. Are there procedures in place to ensure that the employees have read and understand the repair station’s manuals?

Capability list: (Ref. §145.209 (d)(1) and §145.215)
A repair station with limited ratings has a choice either to list the makes and models of the articles that it maintains on the operation specifications or on a capabilities list. For ease of making revisions, I recommend using the list. A capabilities list references the makes and models of aircraft or articles that you work on within the limits of your rating(s). For example if you are an engine shop that works only on Lycoming engines, list the engines by Lycoming’s make and model that you work on. (Note: see Part 145 Preamble page 41108 and 41109). However, §145.209 requires that before you submit the list to the FAA you must perform a self-audit to ensure yourself and the FAA that you have the data, equipment, and personnel to perform the work on those engines.

The capability list must also provide procedures for revising the list (§145. 215) such as:

  1. Describe how the FAA office will be notified of the revision;
  2. Describe how the self-evaluation required by §145. 215 (c) will be addressed;
  3. Describe how the self-evaluations will be reported to the appropriate manager for review and action.
  4. Who maintains the capabilities list?
  5. Who will conduct the self-evaluation?
  6. How many times during the year are the self-evaluations conducted?
  7. How is the self-evaluation documented?
  8. Who is responsible to correct any discrepancies found during the self-evaluations?

Management, supervisors, and repairman list/roster (Ref: 145.161)
This list or roster should be separated into three separate lists.

  • Management list required by §145.161(a)(1),
  • Supervisory list required by §145.161(a)(1),
  • Inspection personnel list required by §145.161(a)(2), and a
  • List of personnel authorized to sign a maintenance release as required by §145.161(a)(3).

Each roster or list must include a summary of employment for each individual listed as required by §145.161(a)(4). The list must include the following information:

  1. Present title.
  2. Total years of experience and type of maintenance performed.
  3. Past relevant employment with names of employers and periods of employment.
  4. Scope of present employment.
  5. The type of mechanic or repairman certificate held and the ratings on that certificate, if applicable.
  6. Although not a requirement of, §145.161(a)(4) add a statement that in case of a change, the change(s) to the roster/list will be revised and incorporated within five business days and the FAA office will also be notified within that same period (ref: §145.161(b)).

Contractor’s list: §145.209(h)(2) and §145 217(a)(2)(ii)

With the contractor’s list you have a couple of choices. You can put the contractors on the operations specifications or make a contractor’s list. The operation specifications must be approved by the FAA but if you list the contractors then the FAA only has to accept them. I suggest that you pick the list because it is the easiest to revise.

The list should have a preamble page to describe the contractor process and identify those procedures to maintain and revise contract maintenance information, in accordance with §145.217 contract maintenance. The manual must describe how contracts are maintained with certificated and non-certificated repair facilities and where copies of these contracts are kept. Any contract that is made with a non-certificated repair facility must state that the non-certificated facility must allow the FAA to observe work being performed on the article ref §145.223. In addition the list must answer these questions:

  1. Who is in charge of contract maintenance by title?
  2. Who is responsible for any revisions?
  3. How does the repair station ensure that the non-certificated facility is maintaining its quality control system?
  4. How is receiving inspection conducted on parts from a contract facility?
  5. How are the repair station personnel trained to audit contract facilities?
  6. How are discrepancies with contracted facilities handled?
  7. How are revisions to the list of contractors made and how is the FAA to be notified of changes to the list?
  8. Describe how the repair station will be “directly in charge” of non-certificated facilities.
  9. Ensure that a non-certificated facility maintains a quality control system equivalent to the repair station. The list of contractors must be acceptable to the FAA at all times; if the FAA finds that a contractor is not acceptable then the work of that contractor must be inspected and reworked or reworked by another party if necessary.

Well, we covered just about everything. I hope that my bucket of suggestions and recommendations will provide you with enough help and direction to keep your leaky boat afloat until the FAA accepts your manuals. But you better get busy and get your leaky boat to shore by the due date or your repair station will swim with the fishes. — Good Luck.

About the Author

Bill O'Brien