should include a record of the parts used, particularly if the maintenance involved substituting parts, such as PMA parts.
(b) The date the article is approved for return to service.
(c) The name of the person who performed the work (in this case the repair station).
(d) The name of the individual authorized by the repair station to approve the article for return to service. As required by § 145.157, for repair stations located within the United States, the person authorized to approve an article for return to service must be certificated under part 65.
(e) If the maintenance was performed on an article that is life-limited, include the total time and total cycles. If the article requires periodic overhaul under an air carrier or commercial operator’s maintenance program, include the time since overhaul.
(3) If the repair station is performing maintenance for an air carrier, the repair station should follow the maintenance release procedures described in the air carrier’s manual. The forms and procedures may differ from those the repair station normally uses.
(4) The approval for return to service may be a separate document, included in the work order, or entered into the aircraft maintenance records. If the maintenance was a major repair, the repair station may use a work order instead of FAA Form 337 to record the work and approve the article for return to service (see section 43, appendix B for details). If the maintenance performed was a major alteration, the repair station must use FAA Form 337 to record the work and approve the work performed for return to service. AC 43.9-1, Instructions for Completion of FAA Form 337 describes how to complete FAA Form 337. If the repair station chooses to use FAA Form 337, a copy of the form and instructions for its completion should be included in the forms section of the manual.
(5) Procedures for approval for return to service should include the following (as applicable):
(a) Who (by title) is authorized to complete the form? How is the individual authorized?
(b) Is the person certificated under part 65 if employed by a U.S. repair station?
(c) Do the procedures ensure that a qualified and authorized person can assume the responsibilities of this task if the person who normally performs it is not available (e.g., sick, on vacation, etc.)?
(d) Does the maintenance release include or reference a list of approved parts?
(e) How does the repair station ensure that it approves for return to service only those articles for which it is rated?
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(f) How does the repair station determine if the repair or alteration is major? If the maintenance was a major repair or major alteration, how will it be recorded?
(g) Who (by title) is authorized to complete FAA Form 337, and how is that person authorized?
(h) What records are given to the customer, and what records are maintained on file at the repair station?
(i) Have the people that complete the approval for return to service been trained for this position? Is the training documented?
4-11. REQUIRED RECORDS AND RECORDKEEPING.
a. References:
• Section 43.9,
• Section 145.209(i), and
• Section 145.219.
b. Describe the System. The RSM must include a description of the required records and the recordkeeping system used to obtain, store, and retrieve those records. The records must be in English and comply with part 43.
c. Requirements. Section 43.9 describes the content, form, and disposition of maintenance, preventive maintenance, and alteration records. The content must include a description of the work performed, the date the work was completed, and the name of the person performing the work. It also must include the signature, certificate number, and type of certificate of the person approving the work for return to service. For major repairs made in accordance with an FAA-approved manual or other approved data, the repair station may use the customer’s work order to record the repair or use FAA Form 337. The repair station must use FAA Form 337 to record major alterations. Instructions for completion of FAA Form 337 are in AC 43.9-1, current edition.
d. Sample Formats. Records may be in different formats depending on the type of work performed. Samples of the various forms that are part of the repair station’s records must be included in the manual or can be maintained in a separate “forms” manual.
e. Air Carrier’s Procedures. Maintenance record entries for an air carrier should be completed in accordance with the air carrier’s procedures. The entries may include the use of forms specifically required by the air carrier. The procedures, forms, and records may differ from those normally used.
f. Contents of Work Package. The procedures should describe the contents of the facility’s work package, if applicable. This work package may include a traveler or router that describes each step of the maintenance or alteration performed. It may contain areas for the Page 50 Par 4-10
signatures or identifiers such as stamps, bar codes, badge numbers, and electronic signatures of the person performing the work and of the inspector. If the facility performs aircraft inspections, the records should include the checklist used to perform the inspections, discrepancy lists, and corrective actions needed and/or taken, including compliance with any ADs and/or SBs. If the repair station performs repairs in accordance with DER-approved technical data, a copy of FAA Form 8110-3 should be included in the records package. DER-approved technical data will normally require additional FAA approval when used for major alterations. (See FAA Order 8110.37, Designated Engineering Representative (DER) Guidance Handbook, for DER authorization. Supplemental forms in a work package may include, but are not limited to:
(1) A list of replacement parts.
(2) Inspection methods sheets.
(3) SB and/or AD compliance sheets.
(4) Copies of manufacturer’s technical data.
(5) Functional test and/or calibration results.
g. Maintenance Release. The repair station must provide a copy of the maintenance release to the owner/operator. If the repair station chooses to use FAA Form 8130-3 as a maintenance release, the records must include a copy of the completed form. The procedures should describe who would review the records for accuracy and completeness before approval for return to service, unless that information is included elsewhere in the manual.
h. Availability. Records must be made available to the FAA and the National Transportation Safety Board (NTSB). Records should be organized for easy retrieval. Procedures should describe the location of the records and the system used to retrieve those records. Some repair stations store records in a remote location. The manual must include procedures describing its retention interval and retrieval process. Storage provisions should include environmental protection as well as security.
i. Requirements. The procedures should include the title of the person responsible for maintaining the records for the repair station and where the records will be located. The records must be maintained for at least 2 years from the date the article was approved for return to service. The customer purchase order or contract may require storage for a longer period of time.
j. Electronic Recordkeeping Systems.
(1) When constructing an electronic recordkeeping system, several elements must be considered and addressed in the RSM or the directions for using the electronic system. Those directions must be available to each person using the system. The electronic system must ensure that the information is confidential and cannot be altered without authorization.
(2) Before introducing an electronic system, a computer operation procedures manual should be established. The manual should include the following:
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(a) Procedures for making required records available to the NTSB and/or FAA personnel. An employee or a representative who is familiar with the computer system may need to assist NTSB or FAA personnel in accessing the computerized information. The computer system must be capable of producing paper copies of the viewed information at the Administrator’s request.
(b) A procedure for conducting a review of the computerized personal identification codes system to prevent password duplication (if applicable).
(c) Procedures for periodic audits of the computer system to ensure the integrity of the system and each workstation.
(d) A procedure to ensure that any records for an aeronautical product are transferred to the owner/operator with the required information in an acceptable format, either electronically or on paper.
(e) A description of the training procedure and requirements needed for access to the computerized system.
(f) Procedures addressing periodic backup of records and files.
(3) The repair station must provide a copy of the procedures for implementing an electronic recordkeeping system to the CHDO. The FAA addresses guidelines and requirements for electronic signatures in AC 120-78.
(4) Addressing the following questions or concerns (as applicable) will help the repair station develop procedures for this section. The repair station may need to develop additional procedures, depending on the size and complexity of the facility.
(a) Who (by title) is responsible for maintaining the recordkeeping system?
(b) What documents are included in a typical records package? What additional forms may be included?
(c) Where are the records stored?
(d) What method is used to organize the records?
(e) Are the records easily retrieved?
(f) Who (by title) reviews records for accuracy and completeness before approval for return to service? Is the individual trained?
(g) If the FAA Form 8130-3 is used, does the repair station include a completed copy in the records package?
(h) If electronic records are used, procedures for security, backup, and retrieval of files must be established.
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(i) Are the records in English, and do they meet (at a minimum) the requirements of § 43.9?
(j) What records will be provided to the owner/operator?
(k) How will the repair station process records received from contractors?
(l) Are procedures included for distribution and storage of FAA Form 337?
(m) How does the repair station document any special inspections, such as hydrostatic tests, functional tests, and so forth?
4-12. CALIBRATION OF MEASURING AND TEST EQUIPMENT.
a. References:
• Section 43.13(a),
• Section 145.211(c), and
• Section 145.109(b).
b. Calibration Procedures. Section 145.211(c) requires that the repair station QCM contain the procedures used for calibrating measuring and test equipment, including the intervals at which the equipment will be calibrated. Section 145.109(b) states that a certificated repair station must ensure that all test and inspection equipment and tools used to determine airworthiness of articles are calibrated to a standard acceptable to the FAA.
c. Measuring Tools and Equipment. This section of the manual should explain the repair station system for controlling and performing calibration of the precision tools and test equipment used to make airworthiness determinations, sometimes referred to as measuring tools and equipment. The repair station is responsible for the calibration program, whether calibration is performed in-house or contracted to outside sources. The calibration must be traceable to a standard acceptable to the FAA, which includes those recommended by the manufacturer and the National Institute of Standards and Technology (NIST) or other national authority. The measuring equipment must be calibrated at regular intervals, which are established by the manufacturer or the repair station. The repair station should maintain records of the calibration for at least 2 years.
d. List of Equipment. The repair station should maintain a list of calibrated equipment by name, model or part number, serial number, date of calibration, and next calibration due date. If the repair station allows employee-owned measuring and test equipment to be used in the facility, these tools must be included in the calibration system. Many facilities choose to maintain the calibration system records and techniques on a computer. A computerized list enables those facilities to manage a large list of equipment requiring periodic calibration. The individual performing the calibration will need to have experience and/or training on the computer system as well as on calibration techniques.
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e. Training. Personnel calibrating tools and equipment will need to have the knowledge, training, or experience necessary to ensure proper calibration. Records of the training or experience will need to be in each employee’s training file or employment summary.
f. Calibration Controls. Procedures will need to address how and when the equipment is recalled for calibration and the title of the person responsible for ensuring that the equipment is returned to the calibration technician. The procedures should also describe how the facility determines calibration status of a new tool or piece of equipment before it is put into service.
g. Calibration Records.
(1) Calibration records should include the following:
(a) The name of the person who performed the calibration.
(b) Date of calibration.
(c) Date next calibration is due.
(d) The standard used to perform the calibration.
(e) The method used to perform the calibration.
(f) The results of the calibration.
(2) The results of the calibration should include the actual readings of the equipment at the test points. If the station intends to revise calibration intervals, pass or fail notations will not suffice. The calibration interval cannot be increased without sufficient recorded data points (calibration history) to justify a change. The procedures should state the title of the person responsible for maintaining the records and where the records will be maintained.
h. Gage Calibration Techniques. If the repair station calibrates its own equipment, a series of gage calibration techniques should be developed. These techniques should describe exactly how the tool or equipment is calibrated, including the standard used, test points, accuracy required, and records. The techniques could be those recommended by the manufacturer or an industry standard acceptable to the FAA. The technique may include provisions to safeguard the equipment from adjustments that would invalidate results (tamper proofing).
i. Identifying Calibrated Equipment. Calibrated equipment should be identified in some manner to prevent the inadvertent use of non-calibrated equipment in the maintenance process.
The identification usually includes the serial number or other identification, date of last calibration, date calibration is due, and the name or initials of the person who performed the calibration. It is important that the equipment’s serial number can be identified if the label is removed or lost. All calibrated tools and equipment should be protected from damage and deterioration during handling, maintenance, and storage.
j. Identifying Non-Calibrated Equipment. The facility may use some equipment that does not require calibration if that equipment is not used to make airworthiness determinations.
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The procedures should describe how that equipment is identified and controlled. Other equipment may have limited calibration, and the limitations should be clearly marked on the equipment or label.
k. Guide to Initiate the Calibration Procedures. The following questions or concerns are offered as a guide and are intended to help initiate the calibration procedures in the QCM.
They should not be considered all-inclusive or applicable to all facilities.
(1) Who (by title) is responsible for the calibration system?
(2) What is the basis for the test intervals (manufacturer, standard industry practice, etc.)?
(3) Is the calibration technique recommended by the manufacturer or standard industry practice?
(4) How is calibrated equipment identified?
(5) Is the calibration technique documented?
(6) What procedure is used to change calibration intervals?
(7) Are actual calibration results recorded to justify changes to calibration intervals?
(8) Is calibration of tools traceable to NIST or manufacturer’s standards, or an accepted foreign or international standard?
(9) If foreign equipment is used, is the calibration standard acceptable to the FAA?
(10) Do the procedures ensure that equipment is removed from service and calibrated when due?
(11) Do the procedures include recall of the product inspected if the measuring equipment was out of tolerance when calibrated?
(12) How is equipment handled if it is not submitted for calibration when it is due (i.e., lost or overdue)?
(13) How is calibration recorded? Are actual results recorded at each test point?
(14) If the repair station uses automated test equipment, is it included in the calibration system?
(15) Does the procedure describe the information on the calibration label of the equipment?
(16) How is equipment that must be calibrated before each use identified and recorded?
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(17) How is equipment that does not require calibration identified?
(18) What are the procedures for calibration of employee-owned tools?
(19) Do the procedures address the acceptance of new precision test equipment into the inventory?
(20) Do the procedures address calibration performed by an outside contractor?
(21) Do the procedures address calibration requirements, standards, documentation, and traceability of tools that the repair station has leased?
(22) Who (by title) is responsible for records of calibration received from outside contractors?
(23) Do the procedures describe the review of the contracted calibration facility’s records for traceability, accuracy, and acceptability?
(24) Is the person performing the calibration qualified? Do the training records or employment records reflect his or her qualifications?
(25) Does the equipment used to perform the calibration have the required accuracy?
(26) If the facility includes an engine or auxiliary power unit test cell, does the manual include procedures for correlation, calibration, and limitations, if any?
(27) For facilities that perform NDT, does the manual include procedures for certification of company-manufactured NDT standards (if any are used)?
4-13. TAKING CORRECTIVE ACTION ON DEFICIENCIES.
a. Reference. Section 145.211(c).
b. Procedures. Section 145.211(c)(1)(ix) states that the QCM must include procedures used for taking corrective action on deficiencies. Corrective action is taken to remedy an undesirable situation. Deficiency correction is normally an integral part of a repair station’s improvement process, and could include revisions to procedures that were not working properly.
(1) Corrective action would be applicable before the article is approved for return to service and after the article has been approved for return to service. The RSM should describe the system by which reworks are identified and corrected before an article is approved for return to service. In these cases, a review of the housing, facilities, equipment, personnel qualifications, and procedures should ensure that the deficiency was not a systemic problem. If the review indicates that the procedure is deficient, the corrective action should include a thorough review and improvement of the procedure. If the review indicates that the personnel lacked training or qualifications, corrective action should remedy the deficiency. In either event, the procedures must address how reworks are documented.
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(2) After the article is approved for return to service, the repair station may avail itself of the self-disclosure program addressed by AC 00-58, Voluntary Disclosure Reporting Program.
This AC describes the procedures for voluntary reporting of potential violations of the regulations. Once an article is approved for return to service, discrepancies are often evidence of a potential violation of the regulations, particularly § 43.13. Therefore, the repair station should carefully review the referenced AC for the appropriate method of notifying the FAA. The repair station should have a procedure for ensuring the quality of the work performed and for handling customer returns or complaints.
c. Examples. The following scenarios are presented as examples of the intended use of a corrective action program:
(1) Scenario 1. During the final inspection process of an aircraft in the repair station for a major inspection, the chief inspector performs a review of the paperwork. During that review, the inspector discovers that one of the discrepancies found during the inspection has not been corrected. Further review of the paperwork reveals that no repairs were performed to correct this discrepancy. Discussions held with the mechanics working on the aircraft reveal that a part is on order to complete the repair. The chief inspector asks why no one wrote on the paperwork that the part is on order. One of the mechanics replied that there are no instructions anywhere that direct them where to write that a part is on order. The procedure requires the mechanic to describe the actions taken to clear the discrepancy, and to sign in the appropriate block. The procedure does not address what action to take if a part is on order. What first appeared as a failure of the mechanic to write that a part is on order turned out to be a lack of written procedures in the manual. By taking the time to develop a written procedure for the mechanics to follow, the repair station corrected the deficiency.
(2) Scenario 2. The repair station overhauls “widgets,” which are components of a turbine engine. Part of the overhaul process involves application of a special coating to the bore of the widget, followed by machining to final diameter. The repair station contracts the application of this coating to another facility. During the machining operation, several areas of the coating are chipped completely off the bore. Since this condition is unacceptable, the bore must be stripped and re-coated. After experiencing this condition on several parts, the repair station conducts an investigation into the root cause. A review of the machining process indicated all recommended procedures were followed. The repair station, in coordination with the contracted facility, conducted a review of the process used to apply the coating. The investigation revealed a malfunction of the spray equipment, allowing the coating to be applied incorrectly. The spray equipment was repaired and adjusted, eliminating the problem. What first appeared as a machining problem turned out to be an application problem. By taking the time to conduct a thorough investigation into the root cause, future problems were eliminated.
d. Inadequacies and Deficiencies. Inadequate procedures, environment, working conditions, training, instructions, or resources may be factors for many deficiencies that are attributed to human error. The involvement of personnel from several levels within the organization (if appropriate) will contribute to the program and ensure quality. Corrective action requires that the root cause or causes of the discrepancy be investigated and determined in order to eliminate such causes. The investigation must be fact-based and typically begins with an analysis of the potential causes of the discrepancy. It is usually helpful to have a small team of Par 4-13 Page 57
informed and involved individuals associated with the article/process. Although human factors may play a part, focus should be placed on physical factors, such as workplace environment, facilities, equipment, and tooling; process factors, such as clarity of instructions; and training/understanding of methodology for the work to be properly accomplished. Flow or process diagrams of the maintenance process for the affected article are a typical starting place.
Typically, each item in the process, and interactions between such items, are questioned/analyzed in an attempt to determine which either caused or contributed to the ultimate deficiencies. Often the interactions result in a cumulative effect that results in the deficiency. Once each potential weakness is identified, the individual/team analyzes each to correct the findings. The product is checked to determine whether the corrective action has accomplished the elimination of the deficiency/discrepancy.
(1) A documented procedure for taking corrective action on deficiencies should answer the following:
(a) What is the title of the person responsible for the program?
(b) How is the root cause of the problem determined? Will any interim steps need to be taken to prevent delivery of deficient products while the corrective action is implemented?
(c) Who (by title) will initiate corrective action?
(d) How much time will be allowed for the corrective action to be implemented?
(e) Who (by title) will perform a follow-up audit of the corrective action to ensure that it was effective?
(f) What records will be maintained of the cause and corrective action taken?
(2) For those facilities that elect to conduct regularly scheduled management review meetings, the investigation, cause, and corrective actions taken to prevent recurrence of discrepancies should be a topic of discussion during those meetings.
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Appendix 1 APPENDIX 1. FORMS
a. Reference. Section 145.211(c)(3).
b. Forms and Instructions. Section 145.211(c)(3) requires that the QCM contain a sample of the inspection and maintenance forms and the instructions for completing such forms.
Or, the manual may refer to a separate forms manual, which provides examples of the forms with instructions.
c. Included Samples. The forms included in this section should be samples of any form, tag, and label described in the procedures within the RSMs. The instructions for completing the form may be on the form or on a separate document. The number and content of the forms will depend on the size of the repair station and the complexity and the variety of the articles for which the repair station is rated. Revisions or additions to the form section of the manual should follow the documented revision procedures.
d. Factors to Consider. Some factors to consider when developing instructions for completing a form are:
(1) How should the form be introduced (at what point during the maintenance process), and when should it be completed?
(2) Who is the person or department responsible for starting the form, who will contribute to its completion, and who will finish all required entries on the form?
(3) How will the form be completed?
(4) What is the purpose of the form and how will it fit into the system?
(5) How should revisions to the form be accepted/approved before release (if applicable)?
(6) How will the form fit into the recordkeeping system?
(7) Which detailed inspection forms and checklists should be used when performing annual, 100-hour, progressive or other approved inspection programs, or engine overhaul inspection sheets? These need not be included in the manual. These forms should be referenced in the manual, and instructions for completing these forms (if required) may be in a separate document.
(8) Do forms that are used for multiple operations or work have adequate space and appropriate instructions, including specific assignment of responsibility, to ensure that they can be filled out properly?
(9) Do the instructions direct the user to write N/A (not applicable) or N/R (not required), and initial/date any blocks on the form that are not used?
(10) Will retention and storage be done in accordance with § 145.219(c)?
Appendix 1
(11) No examples of forms are offered in this AC because forms must be developed to fit the needs of each repair station.