Repair Station Roster

April 1, 2001

Repair Station Roster

"Supervisor" vs. "Directly-in-Charge"

By Joe Hertzler April 2001

Records of Supervisory and Inspection Personnel, 14 CFR Part 145.43 is the regulation that spells out the requirement to develop and maintain a repair station roster. This month, we will delve into the rule to see exactly what it means and who should be on the roster.
First of all, it is clear that there are two distinct lists or types of employees that must be named on the roster: Inspection personnel and Supervisory personnel.
The Inspection personnel type of employee is pretty straightforward; however, the meaning of Supervisory personnel contained in the current 14 CFR Part 145 regulations is not clear and warrants some detailed discussion just to determine which supervisors should be on the roster. Many of us have been led to believe that only front-line supervisors must be listed on the roster and that all supervisors must be certificated (repairmen or mechanics). It’s not quite that simple.
Let’s look at and discuss some excerpts from 145.39, which spells out the personnel requirements for Part 145.43
14 CFR Part 145.39 (a) An applicant for a domestic repair station—must provide adequate personnel who can perform, supervise, and inspect the work.
14 CFR Part 145.39 (b) The number of repair station employees may vary according to the type and volume of its work.
14 CFR Part 145.39 (c) Each repair station shall determine the abilities of its supervisors and shall provide enough of them for all phases of its activities—the administrator may determine the abilities of any supervisor—Each supervisor must have direct supervision over working groups but need not have over-all supervision at management level—the repair station shall provide at least one supervisor for each 10 apprentices or students, unless the apprentices or students are integrated into groups of experienced workers.
14 CFR Part 145.39 (d) Each person who is directly in charge of the maintenance functions of a repair station must be appropriately certificated as a mechanic or repairman under Part 65—in addition, at least one of the persons so in charge of maintenance functions for a repair station with an airframe rating must have had experience in...for returning aircraft to service after 100-hr, annual, and progressive inspections.

Key points
The applicable key points from 14 CFR Part 145.39 are as follows:
As a repair station, we must hire and keep enough people to perform the work (within our repair station’s authority), including the supervision of work when necessary, and the inspection of all work.
The FAA may scrutinize the repair station’s level of supervision at anytime as well as each individual supervisor’s experience and training history and may request changes.
If a team of workers is made up only of apprentices and students, there may only be 10 for each supervisor.
Each supervisor who is directly-in-charge of the maintenance function must hold a repairman certificate or mechanic certificate. Not every supervisor is "directly-in-charge" of maintenance. This is probably the most important point. A very common misunderstanding is the belief that all supervisors are required to be certificated. However, 145.39 (d) clearly differentiates between supervisors and the "person who is directly-in-charge." It is the supervisor who is "directly-in-charge" that must be certificated, not all supervisors.

Handbook Bulletins
So, what does it mean to be "directly-in-charge" of the maintenance functions of a repair station? Well, the FAA has defined it for us in a Handbook Bulletin (HBAW 00-09A) issued May 8, 2000.
Handbook Bulletins are guidance documents issued by the FAA in Washington, D.C. for the FAA field inspectors. Once received, the field inspectors place the bulletins in an appendix to the FAA Airworthiness Inspectors Handbook (FAA Order 8300.10), which is designed to guide them through basically every job function they have. The Airworthiness Inspectors Handbook and Handbook Bulletins are available to the public and are generally a good source for our own guidance as well.
Moving on, Handbook Bulletin (HBAW) 00-09A is the bulletin issued to your FAA inspector as guidance as to who is "directly-in-charge." The title of the bulletin is Airman Certificate Requirements for Title 14 of the Code of Federal Regulations (14 CFR) Part 145 Repair Station Supervisory Personnel. I recommend a complete read of the bulletin, but in general, directly-in-charge is defined through this excerpt: "...the responsibilities of a person directly-in-charge are not limited to the performance of physical maintenance, preventive maintenance or alterations—with respect to the organizational structure of a certificate holder, persons directly-in-charge include any supervisory personnel who, on airworthiness or maintenance matters, are responsible for issuing decisions or instructions concerning the performance of maintenance functions affecting aircraft airworthiness—" The bulletin goes on to say: "—Persons directly-in-charge may include multiple levels of management in the organizational chain of command, depending on the circumstances of the case."

Designating directly-in-charge
So, who in your organization is directly-in-charge? Well, in several places, the bulletin refers to the term "designated as directly-in-charge" or "designated directly-in-charge" indicating that it is up to the repair station to designate who is directly-in-charge. In the typical business aviation repair station, the person designated as directly-in-charge is going to be the Team Leader, Crew Leader, or Service Manager who makes the specific daily assignments of work tasks to the work force. The level of management that is included in directly-in-charge is completely dependent upon the company. In some cases, the Service Manager will be so far removed from the actual maintenance being performed that he or she has nothing to do with "issuing decisions or instructions" specific to the maintenance function; but instead are concerned with the allocation of resources, utilization of hangar space and job profitability. At a smaller shop, the Service Manager, might be working half of the day from his or her toolbox and actually performing as well as supervising the maintenance function on the aircraft.

Who’s on the roster?
Therefore, the roster for your repair station should include everyone within the repair station who is "responsible for its management" and all "technical supervisors, such as Foreman and Crew Chiefs." However, only those supervisors designated by the repair station as "directly-in-charge" must be certificated.
Also, everyone within the repair station who is designated as Inspection personnel "who make final airworthiness determinations" must be included on the roster.
I would suggest including on the roster, the person’s name, job title, Certificate Type (if required), and designation as supervisor, inspector, or both. Although many companies use the roster as a signature list, I would strongly discourage it. The roster is a dynamic document that must be updated whenever organizational changes occur. Requiring everyone to sign again after each revision seems impractical, especially since it is not required.
The repair station must also have on file a "summary of employment" for each person listed on the roster. I would suggest a place on the employment summary for signatures and initials or a separate signature list.
The diversity of domestic repair stations results in many different organizational structures to which the roster requirement must be tailored to fit. Following Parts 145.43 and 145.39, and Handbook Bulletin 00-09A can guide you with respect to developing your roster. Don’t overlook working with your FSDO either as they can help your operations in customizing a compliant document.

The Source

Additional resources....
Federal Aviation Regulations Part 145.43 and 145.39

Aviation Support & Regulation

Handbook Bulletin 00-09A
Airman Certificate Requirements for Title 14 of the Code of Federal Regulations (14 CFR) Part 145 Repair Station Supervisory Personnel.