AC 145-9A

Advisory circular · Guide for Developing and Evaluating Repair Station and Quality Control Manuals

Approved
October 6, 2017
Last reviewed
September 11, 2024
Family
AC 145-9 · 3 versions
Revision
A
14 CFR parts
145
Cited by
1 AD
14 CFR sections
§ 145.207§ 145.211

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 21, 2025.

Show pages 22–33

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5.4.3 Required Procedures. The RSM must include procedures required by § 145.163 for revising the training program. It must also include procedures for submitting those revisions to the responsible Flight Standards office for approval.

5.4.4 Responsibility for Revisions. The procedures should address who (by title) will be responsible for ensuring that revisions are submitted to the principal inspector (PI) at the responsible Flight Standards office for review and approval.

5.4.5 Frequency of Review. The procedures should address how often the program will be reviewed to determine if it is current and adequate for the type of maintenance being performed at the facility. Because the advancements in technology can cause aviation maintenance to change rapidly, a periodic review of training needs would be appropriate.

Repair stations that have established a management review program should include the training program for review during that meeting.

5.4.6 Training Program. The training program may be documented as a section of the RSM or as a separate document within the manual system. If the training program is a separate document, that document will need to include the procedures for submission to the FAA for approval prior to implementing the training.

5.4.7 Training Program Guide. The following questions or concerns are offered as a guide and are intended to help the repair station initiate the procedures in its manual(s). They should not be considered all-inclusive. Each facility is unique and may require additional procedures to verify regulatory requirements and the needs of the repair station.

1. Who (by title) is responsible for submitting the initial training program and its revisions to the FAA?

2. When will the revision be submitted?

3. What are the procedures for submitting revisions to the responsible Flight Standards office for approval?

4. How often will the training program be reviewed for currency and completeness?

5. Who (by title) is responsible for performing the review?

6. How will revisions be recorded and implemented?

7. How will the revised text be identified?

5.5 Work Performed at Another Location.

5.5.1 Reference. Section 145.203.

5.5.2 Special Circumstances: § 145.203(a) (OpSpec D100 is not required). This section states that a repair station may temporarily transport material, equipment, and personnel needed to perform maintenance, preventive maintenance, alterations, or certain specialized services on an article for which it is rated to a place other than the repair station’s fixed locations due to a special circumstance, as determined by the FAA. Examples would be

5-10 an aircraft on the ground or in preparation for a ferry flight (nonroutine maintenance or alteration actions).

Note: Normally, work performed at another location does not include working outside the country where the repair station is located. However, work performed outside the country under a special circumstance may be authorized under § 145.203(a). If work must be performed outside the country, the repair station should obtain required approvals from the country where the work will be performed and notify their responsible Flight Standards office.

5.5.2.1 If the repair station wishes to perform maintenance away from the fixed location for special circumstances, it may put a procedure in its manual for the types of special circumstances that it may need to perform. The RSM should address the following:

1. The types of and limitations on the work that would be considered special circumstances (e.g., emergency repairs, aircraft on the ground, and ferry flight preparation).

2. The estimated length of time away from the fixed location.

3. The procedure to ensure adequate personnel are chosen, including the person(s) responsible for performing, supervising, inspecting (including inspections regarding receiving/incoming, preliminary, hidden damage, in-process, and final), and approving the work for return to service.

4. If necessary, the procedure for ensuring the location will have the necessary housing and facilities for accomplishing the work.

5. The procedure for transporting any equipment, tools, materials, and data to the work site. If the equipment, tools, materials, and/or data will be obtained at the location, include the procedure used for ensuring they are received and controlled under the repair station’s quality system for the duration of their work.

6. The procedures used for storing any equipment, tools, materials, and data for the duration of the project.

7. The procedure used in notifying the responsible Flight Standards office of the request to work away and what type of information will be included in the request. Examples of information could include identifying the customer and describing the work requested or anticipated, and the location at which the work will be performed.

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8. The title of the person who will notify the responsible Flight Standards office of the special circumstance and how that notification will be made.

9. How the repair station will receive the FAA’s determination of acceptance or denial for the request to work away from the fixed location for the special circumstance.

5.5.2.2 By requesting the general determination of special circumstances and obtaining verification from the FAA (written response), the repair station will not need to request permission on a case-by-case basis. The repair station would follow its procedures and notify the FAA each time work was performed away from the fixed location for those special circumstances.

5.5.2.3 If the repair station will not perform work away from location on a recurring basis and does not include a procedure in its manual for work away from the fixed location for special circumstances, then it must submit each request to the FAA for evaluation on a case-by-case basis prior to performing the requested work. The FAA will make a determination and inform the repair station of any parameters that it must follow to perform the requested work.

The request should provide the following information:

1. The types of and limitations on the work that would be considered special circumstances (e.g., aircraft on the ground, ferry flight preparation, maintenance that must be performed prior to moving an article due to an unsafe condition, etc.).

2. The estimated length of time away from the fixed location.

3. The procedure used to ensure the location will have the necessary housing and facilities for accomplishing the work when necessary.

4. The procedure used for transporting any equipment, tools, materials, and data to the work site. If the equipment, tools, materials, and/or data will be obtained at the location, include the method for ensuring they are received and controlled under the repair station’s quality system for the duration of their use on the project.

5. The procedure used for storing any equipment, tools, materials, and data for the duration of the project.

6. The FAA will make a determination and provide a written response to the repair station, which may include additional parameters or limitations that it must follow to ensure compliance with parts 43 and 145.

5.5.3 Recurring Work: § 145.203(b) (OpSpec D100 is required). If the repair station is performing maintenance away from the fixed location on a recurring basis (part of everyday business rather than under special circumstances), the RSM includes the

5-12 procedures for accomplishing the maintenance, preventive maintenance, alterations, or specialized services at a place other than the repair station’s fixed location. This type of work could include fuel cell repair, Nondestructive Testing (NDT), mobile field services, etc., where most, if not all, of the work is completed away from the repair station’s fixed location. Procedures to govern work performed at another location in accordance with § 145.203(b) are required if the repair station performs work at another location on a recurring basis. This business practice will provide flexibility and mobility to meet industry needs and should not be restricted “only” to special circumstances. The procedures listed below are suggested, and those listed that support regulatory requirements will be noted as such with the regulation in parentheses. The manual procedures should address the following:

1. Procedures for generating work orders from the repair station’s fixed location for the scope, nature, and location (refer to § 145.209(i)).

2. Procedures for communication between and among personnel in the field and the repair station’s fixed location. The communication methodology needs to ensure the ability to transmit voice and data on a consistent basis. The ability to transmit verbal instruction and written documents is essential to establishing and maintaining continuous compliance with parts 43 and 145.

3. Procedures for analyzing the qualifications of and dispatching or obtaining personnel required for the scope and type of work anticipated and performed.

Consider the following:

• General knowledge (through training and experience) and capability requirements (refer to §§ 145.151 and 145.163);

• The requirement for individual certification for supervisors and persons authorized to approve work for return to service (refer to §§ 145.153 and 145.157); and

• Ensuring persons performing inspection activities are listed on the roster and meet the requirements of § 145.155.

4. Procedures for ensuring employment summaries (refer to § 145.161(a)(4)) and rosters (refer to § 145.161(a)) are kept current and that the RSM reflects the appropriate duties, responsibilities, and authority of management (supervisory, inspection, and approval for return to service personnel) for persons authorized to work away from the fixed location (refer to § 145.209(a)).

5. Procedures for verifying the extent and nature of available housing and facilities (refer to § 145.209(c)).

6. Procedures for providing or obtaining the calibrated equipment needed to make final airworthiness determinations on the work performed (refer to § 145.211(c)(viii)).

7. Procedures for providing or obtaining necessary equipment, tools, and tooling needed to accomplish the work scope.

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8. Procedures for providing or obtaining the necessary maintenance data

(e.g., maintenance manuals, overhaul manuals, instructions for continued airworthiness (ICA), Service Bulletins (SB), Supplemental Type Certificate (STC) data, and other information pertinent to the maintenance, preventive maintenance, and alteration activities that is acceptable to or approved by the Administrator) (refer to §§ 145.109, 145.205, and 145.211).

9. Procedures for providing or obtaining the proper replacement items

(e.g., parts, subassemblies), materials (e.g., raw metals, solvents), and services

(e.g., heat treat, welding). If the items are not dispatched from the fixed location, include the procedures used for receiving, performing incoming inspection, handling, and storage of items that will be used or installed (refer to §§ 145.109 and 145.211).

10. If hazardous material (hazmat) may or will be involved, the procedure for ensuring proper compliance with § 145.165 regarding an employer training program and air carrier notification.

11. Procedures for performing initial, in-process, and final inspections of the articles being worked on, if different from the procedures used at the fixed location. If different forms are used to record activities, they would be included in the forms section of the repair station’s manual (refer to § 145.211(c)(3)).

12. Procedures for obtaining, storing, and retrieving records of maintenance performed for the owner of the article being maintained (e.g., logbook) and for the repair station (refer to § 145.209(i)). If different maintenance records will be used for the repair station, they must be included in the forms section of the repair station’s manual (refer to § 145.211(c)(3)).

13. Procedures to ensure the RSM is current and available at the location where the work is being performed, and that the work is being performed in accordance with procedures in the manual.

14. Many repair stations transport equipment, tools, personnel, data, etc., from one location to another on a recurring basis. The use of mobile maintenance units is only one way to facilitate the movement from one location to another.

Many repair stations that do transport the items listed above do so by “staging” a vehicle type of transportation throughout the United States in support of recurring work away from the fixed location. The “staging” of these units should not be considered a standalone or satellite repair station.

15. Although not a regulatory requirement, many repair stations ensure procedures for the work away from the fixed location on a recurring basis (refer to § 145.203(b)) using a “staging” or completely mobile method of transporting equipment, tools, personnel, data, etc., are identified within the manual system. Some examples of procedures using a mobile method of transporting are:

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• Is there a procedure the fixed location repair station can use to determine the location of each unit?

• Is there a procedure for identifying who (by title) will be responsible for the units

(i.e., point of contact (POC))?

• Are there procedures addressing any audits the main fixed location repair station may conduct on the units to ensure that the units, personnel, equipment, tools, materials, data, etc., remain in compliance with the regulation, RSM, QCM, and training program requirements?

• Who (by title) will be responsible for conducting such audits and who (by title) will review the audit results and take any actions, if necessary, to correct discrepancies identified in the audits?

Note 1: The rule does not allow continuous, uninterrupted operations at another fixed or permanent location (facility) without applying for a new repair station or satellite certificate at that location.

Note 2: A combination of storing equipment, tools, parts, etc., and having repair station personnel positioned at a fixed or permanent location (facility) while performing maintenance on a daily basis at that location indicates a continuous, uninterrupted operation. (This does not imply that personnel who are assigned to a specific mobile maintenance unit are considered permanently positioned.) A continuous operation exists when a repair station permanently moves tools, equipment, and personnel to another fixed location and performs maintenance, preventive maintenance, alterations, or specialized services at that fixed location. A repair station that conducts these types of operations no longer meets the intent of § 145.203. If the repair station is to continue operations in this manner, then it must apply for certification as a satellite or standalone repair station.

5.5.4 Permanent Fixed Location. Additionally, work that is to be performed at another location does not include other authorizations, such as having a line maintenance authorization to perform work for an air carrier. Work performed at locations away from their fixed base allows repair stations the flexibility to meet industry needs and to be mobile when necessary. Repair stations must still maintain a permanent fixed location even if the majority of their work is done at another facility or location.

5.6 Maintenance, Preventive Maintenance, and Alterations Performed for Air Carriers Under 14 CFR Parts 121, 125, 129, and 135.

5.6.1 Reference. Section 145.205.

5.6.2 Requirements. Repair stations that perform maintenance, preventive maintenance, or alterations for an air carrier or commercial operator that has a Continuous Airworthiness Maintenance Program (CAMP) under part 121 or 135 must follow the air carrier’s or commercial operator’s program and applicable sections of its maintenance manual. In this case, this section of the manual should describe the procedures to ensure that

5-15 maintenance is performed in accordance with the air carrier’s program and maintenance manual. The procedures should ensure that the air carrier has provided the repair station with the information necessary to ensure compliance with this requirement. The air carrier or commercial operator may provide the repair station with the applicable sections of its maintenance program or manuals at the time the work is performed. On the other hand, the purchase order or other contractual documents from the air carrier could clearly state the source of the data (manufacturer’s or air carrier’s manual) used to perform the requested maintenance, along with any other requirements of its program or maintenance manual. If the repair station performs an inspection for a certificate holder conducting operations under part 125, the manual should contain procedures to ensure the inspections are performed in accordance with the operator’s approved inspection program. Again, the operator may provide the repair station with the applicable sections of its inspection program or clearly outline the requirements on the purchase order.

5.6.3 Identify Responsibilities. The procedures should identify who is responsible (by title) for keeping all of the operators’ data current and where these manuals/sections will be located if retained at the repair station. The procedures also should explain what air carrier or commercial operator information must be available to maintenance personnel when the work is performed. Additional procedures should be included to ensure that purchase orders are thoroughly reviewed. This review will be necessary to ensure that the air carrier has clearly specified what technical data to use for performing the maintenance. Employees may need additional training to properly perform this review.

The traveler or work-order system of the repair station may be used to integrate this information into the quality control (QC) system. If the repair station transfers requirements from the air carrier or commercial operator to its maintenance personnel by special instructions on the work order or traveler, that section of the QC system should clearly explain how this is accomplished.

5.6.4 Organization. The repair station performing maintenance for an air carrier should have an organization adequate to perform the work. This includes the ability to distinguish the work performed for different operators. Additionally, if the repair station is performing Required Inspection Item (RII) inspections, the organizational structure should provide separation of maintenance and inspection personnel. The air carrier, not the repair station, determines the maintenance actions that are RII. If the repair station’s inspectors are authorized to perform RII for the air carrier, the air carrier will ensure that the inspectors are trained on the air carrier’s RII procedures, including how the inspection is performed and recorded.

5.6.4.1 The inspectors performing RII for the air carrier will be qualified and authorized by the carrier. This authorization is usually in written format, often a card carried by the inspector. The authorization may need to be renewed, depending on the air carrier’s procedures. The procedures in the RSM should include who will maintain a list of current RII inspectors, how an inspector is added to the list, and where the list is located.

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5.6.4.2 The repair station should request information from the air carrier or commercial operator pertaining to at least the following issues:

• RII;

• Training requirements for the work being performed on the operator’s behalf, including who will provide the training;

• Maintenance duty time requirements;

• Special maintenance or alteration instructions per engineering orders, build lists, and other methods, techniques, and practices in the operator’s manual per part 43, § 43.13(c); and

• Recording requirements, including who is responsible for maintaining the files.

5.6.5 Line Maintenance Authorization. The FAA may grant approval to an existing and appropriately rated CRS to perform for an air carrier the type of maintenance that meets the line maintenance definition of § 145.3(d). This approval includes, but is not limited to, locations outside the repair station’s primary housing location required in § 145.103(a). A repair station may hold a line maintenance authorization only if the repair station already provides housing as required by § 145.103(a). A repair station certificated to perform maintenance on the aircraft or engine under a class or limited rating may be authorized to perform line maintenance functions at other locations as listed on OpSpec D107, Line Maintenance Authorization. For a repair station authorized to have multiple locations across geographic boundaries, the PI will develop a surveillance program that encompasses all facilities of the repair station, regardless of location. A line maintenance authorization location may be located at an airport outside the United States; however, the PI will ensure that the surveillance program also encompasses the location.

Note: This may be accomplished by requesting assistance from the responsible Flight Standards offices and/or International Flight Standards Offices (IFO) who perform surveillance activities located in the geographic area where the line maintenance is being performed.

5.6.5.1 To be issued a line maintenance authorization, the repair station must show the capability to perform the limited scope of work defined in § 145.3(d) at each location. After the showing has been made, the repair station will perform maintenance in accordance with § 145.205.

5.6.5.2 Title 14 CFR part 1, § 1.1 defines maintenance as “inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.” Alterations are not included in the regulatory definition of maintenance and are therefore not included in the privileges provided for in § 145.205(d). However, under the current definition of line maintenance provided for in § 145.3(d)(2), a repair station holding a line maintenance authorization may perform scheduled checks that contain servicing and/or

5-17 inspections that do not require specialized training, equipment, or facilities, and may constitute a preventive maintenance action.

5.6.6 Line Maintenance Requirements. The repair station’s equipment, tools, and materials necessary to perform the line maintenance must be located on the premises and under the repair station’s control when the work is being done. If the repair station is going to perform line maintenance, its manual should include procedures to ensure that the necessary equipment, technical data, and trained personnel are available before the maintenance can be performed. This should include who (by title) will be responsible for ensuring that the necessary equipment, technical data, and trained personnel will be available when the work is being performed.

5.6.7 Coordination with the Air Carrier. The repair station’s training program can be conducted in coordination with the air carrier. The specific training an employee receives should be recorded in the employee’s training record. The procedure will need to include who (by title) is responsible to ensure that training is conducted and recorded. The repair station should maintain a list of individuals who are trained by the air carrier to perform line maintenance. Although air carrier maintenance requirements may be incorporated into the repair station’s training program, the repair station must follow its training program requirements with respect to conducting the training, recording the training in employee training records, and qualifying those individuals authorized to perform line maintenance for an air carrier. Air carrier training does not relieve the repair station from the requirement to ensure its personnel are trained for the maintenance it is rated to perform.

5.6.8 Initiate Development. Addressing the following concerns (if applicable) will initiate development of the procedures for performing maintenance for an air carrier:

1. Who is responsible (by title) for keeping a file of the air carrier’s procedures, including the necessary technical data?

2. Who is responsible (by title) for review and amendment of purchase orders for complete and correct instructions? Is that person trained?

3. Who will maintain the list of current RII inspectors?

4. Does the RSM include procedures to ensure that the necessary equipment, trained personnel, and technical data will be available for line maintenance?

5. Who is responsible for coordinating the training program with the air carrier?

6. Does the repair station roster include authorization for individuals performing line maintenance and RII?

7. How does the repair station ensure that personnel comply with its manual and appropriate sections of the air carrier’s manual, regardless of location?

Note: The authority to perform line maintenance for an air carrier is not a rating but an authorization. A CRS must have established housing and facilities that meet the requirements of part 145 for the ratings issued in order to make application for a line maintenance authorization. If line maintenance is the only

5-18 maintenance a repair station is authorized to perform, the repair station must still meet the housing and all other applicable requirements of part 145. Housing need not be on the airport where the line maintenance is performed, but the street address must be listed on the repair station’s Air Agency Certificate and OpSpecs.

5.6.9 Notifications of Hazmat Authorizations. Procedures should address that:

1. Prior to performing maintenance on or on behalf of a part 121 or part 135 certificate holder, the repair stations must acknowledge that they have received notification from that certificate holder required under part 121, § 121.1005(e) or part 135, § 135.505(e).

2. Prior to performing work on or on behalf of the part 121 or part 135 air carrier, the repair station has notified its employees, contractors, or subcontractors that handle or replace aircraft components or other items regulated by Title 49 of the Code of Federal Regulations (49 CFR) parts 171 through 180 of each certificate holder’s OpSpec authorization permitting or prohibiting the carriage of hazmat in accordance with § 145.206.

3. Prior to performing maintenance, repair stations that meet the definition of a hazmat employer under 49 CFR part 171, § 171.8 must have a hazmat training program that meets the training requirements of 49 CFR part 172 subpart H.

4. Repair station employees may not perform or directly supervise a job function listed in § 121.1001 or § 135.501 for, or on behalf of, the part 121 or part 135 operator, including loading of items for transport on an aircraft operated by a part 121 or part 135 certificate holder, unless that person has received training in accordance with § 145.165.

Note: Refer to the FAA’s Office of Hazardous Materials Safety (ADG) website for additional information: http://www.faa.gov/about/office_org/headquarters_offices/ ash/ash_programs/hazmat/.

5.7 Contract Maintenance Information.

5.7.1 References:

• Section 145.201.

• Section 145.209(h).

• Section 145.211(c).

• Section 145.217.

5.7.2 Contract Maintenance Functions. The regulations enable a repair station to contract maintenance, preventive maintenance, or alteration for which it holds a rating, in accordance with § 145.201(a)(2). Contract maintenance functions, which require FAA approval under § 145.217(a), are only required if the repair station extends its privileges to the contractor and provides for return to service under § 43.9. In this circumstance, the

5-19 originating repair station chooses to exercise the privileges of its certificate and assumes responsibility for the work performed by the contractor.

5.7.2.1 To be considered a contract maintenance function that requires FAA approval, the repair station must meet both of the following conditions:

1. Entering into an agreement with another person or entity (FAA certificated or noncertificated) to perform maintenance functions on an article; and

2. The repair station chooses to exercise the privileges of its certificate and assumes responsibility for the work performed by the contracted person or entity.

5.7.2.2 In order for the repair station to contract a maintenance function, the repair station must:

1. Be certificated and appropriately rated to perform the maintenance functions to contract out.

2. Take regulatory responsibility for issuing an approval for return to service under § 43.9 for the maintenance function performed by the contractor.

3. Obtain approval of the listed maintenance functions in accordance with § 145.217 and make that list available to the FAA in accordance with the procedures in § 145.209.

4. Ensure and have procedures that qualify the sources to which it contracts those maintenance functions in accordance with § 145.201(a)(2) (QC system).

5. Have procedures and maintain a current list of those contractors in accordance with § 145.217 and make the list available to the FAA in accordance with § 145.209.

6. Ensure that it has procedures to perform the incoming inspection, final inspection, and return to service of articles in accordance with the pertinent subparagraphs of § 145.211(c)(1).

7. Provide a procedure that confirms by inspection or test that the work (i.e., maintenance function) was performed satisfactorily and the article is Airworthy before approving it for return to service.

8. Ensure the contract allows the FAA to make an inspection and observe the performance of the person’s work on the article.

Note: Purchase of maintained parts from another repair station (including exchanges), brokerage, and using another CRS to perform work that is outside the original repair station’s ratings are not maintenance functions requiring FAA approval. These are instances where the purchasing repair station is not exercising the privileges of

5-20 its certificate. When a repair station requests work or sells a previously maintained article (including type certificated (TC) products), it is acting solely as a distributor. Although the purchasing repair station may induct the part through its receiving inspection process, it is merely relying on the work previously performed at another certificated entity and is not exercising the privileges under § 145.201(a)(2).

5.7.3 Contract Maintenance Information Required by § 145.217. The RSM should contain procedures for maintaining and revising the contract maintenance information required by § 145.217. This information is required for contracting to both FAA-certificated and noncertificated facilities. The information required includes the approved maintenance function to be contracted, the name of each outside facility to which the repair station contracts such maintenance, and the type of certificate and ratings held, if any. The QCM/section should describe the system and procedures used for qualifying both FAA-certificated and noncertificated entities and surveilling noncertificated entities who perform maintenance, preventive maintenance, or alterations for the repair station. These procedures may be contained in one manual or in separate documents that are part of the manual system.

5.7.4 Material and Equipment. A repair station must have the material and equipment necessary to perform the functions appropriate to its rating. However, it need not have the tools and equipment for functions it is authorized to contract out pursuant to its FAA-approved maintenance functions. When exercising the privileges of its certificate, a repair station may contract maintenance functions to FAA-certificated facilities and non-FAA-certificated entities only if the maintenance functions are approved by the FAA. The repair station must request approval before it can contract a maintenance function. If the FAA approves the contracted maintenance function, the repair station will determine who performs the maintenance.

5.7.4.1 The types of maintenance functions that the repair station may wish to have approved fall into two categories. First, the types of maintenance functions that must be contracted because the repair station does not have the housing, facilities, materials, or equipment available on its premises and under its control. These may include plating, heat treatment, special NDT or inspection, or the maintenance or alteration of components or subassemblies. This list should be categorized broadly, such as specialized services or components of articles for which the repair station has the overall rating.

5.7.4.2 The repair station may also wish to provide a list of those maintenance functions for which it has the housing, facilities, equipment, and materials in-house, but may need to contract to another facility because of workload or emergency situations. For example, an airframe-rated repair station may have the capability to perform maintenance or alteration on landing gear, but if the in-house facility cannot accomplish the work scope within a specified time, it may want to contract that work to another facility. It would not be able to