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5.9.7 Manufacturer’s Drawings and Data. Repair stations that are associated with or part of a Production Approval Holder (PAH) facility often use the manufacturer’s drawings and data to perform maintenance. This data may not meet the requirements of § 43.13(a).
These facilities should also be cautioned that the repair station may not be able to use the parts manufactured by the production side of the facility unless the parts are FAA-approved through a Parts Manufacturer Approval (PMA), Technical Standard Order (TSO), TC, or other means.
5.9.8 National Language. Technical data used by repair stations located outside the United States may be translated into the national language. If the data requires translation before distribution, the procedures must ensure an accurate, timely, and complete translation. Provisions should be made for personnel to review and approve the translated material before distribution. The technical data that needs to be translated may include graphs, diagrams, or other visual aids. The repair station must retain in English any data that demonstrates compliance with the requirements of part 43.
5.9.9 Software Revisions. Those facilities that use computer software for component testing (of airborne systems or equipment, avionics systems, engines, etc.) will need to include procedures describing how revisions/updates are made and how the current software is distributed. The procedures will need to address system security to prevent inadvertent changes to the software and methods to ensure that only the current revision/version of the software is used. Distribution and revision of software is often handled by a group other than those responsible for revision and distribution of paper documents.
5.9.10 Guide. The following questions or concerns are offered as a guide and are intended to help initiate the procedures in the manual; 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 revising and maintaining the technical data?
2. How does the repair station ensure that the data is current?
3. How is the technical data distributed throughout the company?
4. How does the repair station ensure that current technical data is available to the staff?
5. Who (by title) is responsible for control and distribution of the documents from a master library (if used and applicable) to the shop/office libraries located in the facility?
6. If the technical data requires translation, who (by title) is responsible for performing the translation and quality checks? How will the data be revised and distributed?
7. If the repair station uses computer software for component testing, who (by title) is responsible for maintaining the software, and how are revisions made and distributed?
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5.10 Inspection and QC System.
5.10.1 References:
• Section 145.211.
• Section 145.213.
5.10.2 System and Procedures. A CRS must establish a QC system that ensures the airworthiness of articles on which the repair station or any of its contractors perform maintenance, preventive maintenance, or alterations. The CRS must prepare and keep current a QCM that includes the following:
1. A description of the system and the procedures used for:
• Inspecting incoming raw materials to ensure acceptable quality;
• Performing preliminary inspections of all articles that are maintained;
• Inspecting all articles involved in an accident for hidden damage before maintenance, preventive maintenance, or alterations are performed;
• Establishing and maintaining proficiency of inspection personnel;
• Establishing and maintaining current technical data for maintaining articles;
• Qualifying and surveilling noncertificated persons who perform maintenance, preventive maintenance, or alterations for the repair station;
• Performing the final inspection and approval for return to service of maintained articles;
• Calibrating measuring and testing equipment used in maintaining articles, including the intervals at which the equipment will be calibrated; and
• Taking corrective action on deficiencies.
2. References, where applicable, to the manufacturer’s inspection standards for a particular article, including reference to any data specified by that manufacturer.
3. A sample of the inspection and maintenance forms and instructions for completing such forms, or a reference to a separate forms manual.
4. Procedures for revising the QCM required and notifying the responsible Flight Standards office of the revisions, including how often the office will be notified of the revisions.
5.10.3 Guide to Initiate Inspection Procedures. The concerns or questions in the following paragraphs are offered as a guide and are intended to help initiate the inspection procedures in the QCM/section; 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.
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5.10.4 General. Describe the inspection system in detail, from establishing the purchase of aviation articles and how that material is inspected upon receipt, receiving customer’s articles, progressing through each inspection step, and ending in final inspection and approval for return to service. Describe each step in a format easily understood by the employees. A flowchart may be helpful in developing these procedures. This section should also describe the system for controlling and documenting the work in process (work order system).
5.10.5 Service Difficulty Reports (SDR). Section 145.221 requires the repair station to notify the FAA within 96 hours after discovering any serious failure, malfunction, or defect of an article. Many repair stations use FAA Form 8010-4, Malfunction or Defect Report, to comply with this requirement. Information for completion of this form may be found in AC 20-109, Service Difficulty Program (General Aviation), and may be submitted via the Web at http://av-info.faa.gov/sdrx/.
Note: An SDR should be submitted when a failure, malfunction, or defect of an article is identified, other than an in-service condition normally detected during the maintenance, preventive maintenance, or alteration of that article. A “serious failure, malfunction, or defect of an article,” as stated in § 145.221, is intended to identify those articles that exhibit a premature or unusual failure not ordinarily discovered during the maintenance of that article. As an example, an in-flight engine failure, while potentially serious for that flight, would not be considered a serious failure requiring submission of an SDR for the purpose of § 145.211 if the failure was due to damage incurred during the engine’s normal operating environment (e.g., wildlife ingestion or foreign object damage (FOD)). However, if upon disassembly of the engine a failure mode of a subcomponent of that engine that has not been previously observed in normal service is discovered
(e.g., a cracking turbine blade, compressor blade, turbine, or compressor disk, discovered in a location not previously identified, or the suspected manufacturing defect of a part), an SDR should be submitted.
5.10.5.1 Normal wear and defects frequently observed should not be criteria for filing an SDR (e.g., typical seal, bushing, or coating wear), even if the result was a failure of the next higher assembly. Certificate holders should have procedures to identify, investigate, and determine if a failure, malfunction, or defect is the result of normal in-service use or if it is a previously unknown failure mode warranting submission of an SDR.
5.10.5.2 The primary purpose of the Service Difficulty Reporting System (SDRS) is to help identify negative trends so that mitigating actions can be accomplished as soon as possible.
5.10.5.3 The regulation also states that the repair station may submit FAA Form 8070-1, Service Difficulty Report—Aeronautical Equipment, for a certificate holder operating under part 121, 125, or 135. Information on completing FAA Form 8070-1 is attached to the form. The repair station should not report the same failure, malfunction, or defect using more than one
5-30 report. The manual should contain procedures describing how the report will be completed and forwarded to the FAA. A copy of the form and instructions for its completion should be included in the forms section of the manual.
5.10.6 Continuity of Inspection Responsibility. Include procedures for ensuring that the responsibilities of the facility’s inspectors are properly performed if they cannot complete the task. If the facility uses multiple shifts, include procedures to ensure a continuing responsibility for maintenance in progress with status books, shift change logs, or similar documents.
5.10.7 Receiving Procedures. This section of the manual should address the procedures used for accepting consumable materials and customer parts. Procedures included within this section will depend on the size, complexity, and ratings of the facility. The manual should describe generally how material is ordered, stocked, and requisitioned for maintenance or alteration purposes. A general description of how the stock room operates with respect to handling and storage should be included in this section. Additionally, this section may include the method for handling, storing, and using shelf life items and materials.
5.10.7.1 Procedures should include visual inspection of the container and contents for shipping damage, packing, and proper paperwork. This section should include procedures to assist receiving personnel in performing their tasks, whether the article was satisfactory or damaged when it was received. The procedures would normally include how receiving personnel document or record damage due to improper handling and the title of the person notified of the damage.
The description of the procedure may include the routing of materials and parts.
5.10.7.2 Receiving personnel may need to review paperwork received with articles maintained by other facilities contracted by the repair station or parts received from foreign manufacturers. All foreign-produced engines, propellers, and parts received into the part 145 repair station must be in full compliance with the applicable Bilateral Aviation Safety Agreement (BASA) or 14 CFR part 21.
5.10.7.3 Articles produced in the United States and exported would be under the control or jurisdiction of the receiving authority and not under the jurisdiction of the FAA regulatory system. Until these articles are moved back under the control of the U.S. regulatory system, they could not be returned to service under the provisions of part 43 and/or part 145.
5.10.7.4 If the repair station is dual-certificated under another authority, they could perform the approval using the other authority’s certification, such as the European Aviation Safety Agency (EASA).
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5.10.7.5 Section 43.1, Applicability, sets forth the requirements for any approval for return to service. Parts that do not meet the requirements of § 43.1 would not be eligible for an approval for return to service in accordance with § 43.9.
5.10.7.6 Paragraph 5.7 has further information on contracting maintenance functions.
The procedure should also cover how parts are stored and requisitioned for particular work.
5.10.8 Handling of Parts. Section 145.103(a) requires the repair station to provide sufficient space to segregate articles and materials stocked for installation from those articles undergoing maintenance, preventive maintenance, or alterations. Throughout the maintenance cycle, care will be necessary when handling parts and components undergoing maintenance. The procedures in the manual should emphasize that personnel will always need to exercise caution when handling aviation articles. These procedures may be contained in one section of the manual or may be spread out through several sections of the manual. The procedures may discuss segregation and protection of parts, avoiding metal-to-metal contact, contamination, and preservation. Moving articles from one area of the repair station to another requires procedures to ensure that articles are not damaged in transit. Facilities that maintain sensitive electronic equipment will need to describe the necessary precautions to be taken for static discharge.
5.10.9 Tagging and Identification. All articles undergoing maintenance within the facility should be identified in some manner depending on the size, complexity, and ratings of the repair station. Many facilities attach colored tags or work orders to the part. The objective of identification is to ensure that the status of any article can be easily determined.
Articles awaiting repairs may be identified differently than those that are repaired.
Articles that are deemed nonrepairable should be clearly identified, and may need to be stored in a segregated area within the facility. Parts in the store room(s) will need to be identified to ensure traceability to an approved source.
5.10.10 Incoming Inspection. The QCM/section must include procedures that describe the incoming inspection of raw materials used by the repair station for maintenance, preventive maintenance, or alteration. These materials could include hardware, sheet metal, welding rods, etc., as well as component parts. The procedures should define what is considered raw material and describe how the material will be inspected.
Procedures should describe the disposition/action taken when an item passes or fails inspection. The manual should also include procedures for handling suspected unapproved parts (SUP). Some raw materials may require specific documentation or certifications that must be kept on file by the repair station. Procedures should address how this documentation is reviewed and filed. Sometimes raw materials are received in lots that are released from stock in smaller units, such as weld wire, NDT fluids and films, and coating powders. For such situations, the manual will need to include procedures that ensure traceability of the material back to the original lot. The procedures should address the following, as applicable:
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1. What is the title of the person(s) performing these inspections?
2. How will the inspection be performed? Does the inspection include visual, NDT, or dimensional tolerances (if applicable)?
3. What technical data will be necessary to perform this inspection?
4. Is the material checked for damage, identification, and preservation?
5. Does the material have any shelf life limitations? If so, the procedures need to address how the material will be identified and controlled.
6. Describe the action taken if the material meets specification, as well as what action is taken if the material does not meet specification.
7. Does the facility have an area for proper storage of raw materials? Will the material require a secure area until released for use? Will the material require any special environmental considerations during storage?
8. How is the material identified if acceptable or not acceptable?
9. Do the materials require any special testing requirements? If so, what procedures are followed to perform those tests? How is the testing performed?
10. What is the disposition of incoming inspection records?
11. How does the repair station ensure traceability of materials received in lots, such as weld wire, coating powders, and so forth?
12. Does the manual contain procedures for SUP formal training, detecting and reporting SUP?
5.10.11 Preliminary Inspection. The procedures must address what constitutes a preliminary inspection, how that inspection will be performed, and how the article will be identified throughout the maintenance cycle. This inspection is usually an evaluation of an article to determine the customer-requested work scope and the required maintenance or alteration actions. Compliance with SBs and ADs should also be determined. This inspection may involve a teardown or disassembly if the article is an engine, module, propeller, accessory, or subassembly of a larger component. The results of this inspection should be documented and may need to be communicated to the customer.
The forms used to record this inspection should identify the article until the maintenance cycle is completed. For some repair stations this may include attaching the form to the article while it is still in the maintenance cycle. Other repair stations that use more electronic means, such as barcodes, may not need to physically attach the form but use another type of identification so that the status of the article can be determined as needed. Any defects or discrepancies noted during this inspection will need to be documented with corrective actions taken during the maintenance, using a discrepancy numbering system or similar arrangement. The repair station should notify the customer of any defects that are outside the scope of the customer’s authorized repair.
Maintenance providers are responsible only for the work they are contracted to perform, not for all the work that needs to be performed. The procedures should address the following:
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1. Who (by title) will perform this inspection?
2. How will the inspection be performed?
3. When is this inspection performed?
4. Is the repair station properly rated to perform this maintenance?
5. Does the inspection include a functional test before disassembly?
6. How will the inspection be recorded?
7. If the inspection reveals discrepancies, how are they recorded?
8. How does the repair station record corrective actions taken to correct any discrepancies?
9. Do the records show the relationship between the discrepancies found and the corrective action taken?
10. How is the customer notified of discrepancies found that are outside of the contracted work scope? How are those discrepancies resolved?
11. Is the record of this inspection made part of the work order file (work package)?
12. How is traceability of life limits and/or time since overhaul documented?
13. How are the parts identified if acceptable and if not acceptable?
14. What are the procedures to ensure the records (work package) are kept with the parts?
15. Is there a procedure to ensure that current technical data is available before inspection?
16. What are the procedures for detecting and reporting unapproved parts?
17. Is there a procedure for reporting failures, malfunctions, or defects of an article?
5.10.12 Hidden Damage Inspection. This inspection is required on parts that have been involved in an aircraft accident. The inspection includes a search for any secondary damage that could result from an accident, such as fire or heat damage. This inspection is often recorded on the same form used for the preliminary inspection. Sometimes the repair station is not notified that an article has been involved in an aircraft accident.
Inspection personnel should be experienced enough with the article to recognize damage that is suspicious. The repair station could then initiate communications with the customer regarding damage history of the article. The hidden damage inspection should address the following:
1. Who (by title) will perform the inspection?
2. How will the inspection be recorded?
3. If defects are noted, where will they be recorded?
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4. Does the inspection include areas adjacent to obvious damage?
5. Who will communicate with the customer?
6. Is the record of this inspection made part of the work order file?
5.10.13 In-Process Inspection. These inspections may take place during various stages of disassembly, repair, and reassembly of an article. These inspections are usually described in the maintenance manuals or other ICA used to perform the maintenance or alteration and called out on the work order, traveler, or router. Usually, they require the services of a qualified inspector to perform a visual, dimensional, or nondestructive test.
The inspection may require functional tests and/or precision test equipment. Persons performing these inspections should be qualified and listed on the roster.
5.10.13.1 If the article has been shipped to another facility for contracted maintenance, that function must be inspected. The inspector may also review the documentation received from the vendor, such as certification(s) or other maintenance records required by § 43.9. If a noncertificated person performed the maintenance, an inspection and/or test is required to determine whether the maintenance was performed satisfactorily.
1. Who (by title) will perform the inspection?
2. Are the inspectors listed on the roster?
3. How will the inspection be recorded?
4. If defects or discrepancies are noted, where will they be recorded?
5. Do the procedures allow steps to be performed out of sequence? If so, how is this authorized and recorded?
6. If the in-process inspection is not satisfactory, does the manual have procedures governing rework? Any rework must be performed in accordance with approved or acceptable technical data.
7. Does the system include provisions for recording the names of the inspector and the person who performed the work?
8. Are the records of this inspection made part of the work order (records package)?
9. Who determines when an in-process inspection is performed, and how is that determined?
10. Do the procedures describe the inspection of an article and review of documentation for maintenance performed by a contracted facility?
5.10.14 Final Inspection. This inspection is performed on each article before it is approved for return to service. Final inspection should include a review of documents used during the maintenance (travelers, inspection sheets, discrepancy sheets, etc.), as well as an
5-35 inspection of the article. The repair station may develop a checklist to ensure that all activities related to final inspection are performed. The individual performing this inspection must meet the requirements of § 145.155, which requires the person to be thoroughly familiar with the applicable regulations and the inspection methods, techniques, practices, aids, equipment, and tools used to determine airworthiness of the article. The person must be proficient in using the various types of inspection equipment and visual inspection aids appropriate for the article being inspected. The person must be able to understand, read, and write English. As stated in § 145.213, except for individuals employed by a repair station located outside the United States, only an employee certificated under part 65 is authorized to sign off on final inspections and maintenance releases for the repair station.
1. Who (by title) will perform the inspection?
2. How will the inspection be recorded?
3. If the final inspection is not satisfactory, does the facility have procedures governing rework? Any rework must be performed in accordance with approved or acceptable technical data.
4. Is the inspector qualified and certificated?
5. Before the final airworthiness determination is made, are all other maintenance, inspection forms, electronic media, and records checked for completion? How is this indicated?
6. Is the final inspector authorized on the roster of inspection personnel?
7. How is the inspection performed?
8. Once the final inspection is completed, how are the parts identified?
9. Are the final inspection personnel familiar with the regulations and the inspection techniques?
10. Do the inspectors understand, read, and write English?
11. Do the final inspectors have access to current technical data?
12. Are procedures included for when the final inspection results in accepting the part and when it results in rejection of the part?
13. If the repair station performs 100-hour and/or annual inspections, are procedures included for addressing the use of inspection cards and/or forms, checklists, etc., to record the inspection and correct any discrepancies?
Where the operator has an FAA-approved minimum equipment list (MEL), are procedures for the deferral of inoperative equipment included?
14. If the maintenance performed was a major repair or major alteration, are procedures included to ensure that the inspector who inspects the article and approves it for return to service is trained, qualified, and authorized?
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5.10.15 Work Signoff. Many repair stations use rubber stamps or electronic media instead of signatures to annotate the completion of a task on a traveler, work order, process sheet, inspection sheet, or similar document. The intent of the stamp or electronic signoff is to ensure traceability to the name of the person who performed or inspected the work. The stamp or electronic signoff used is often more legible than handwritten initials. If the repair station chooses to use stamps or electronic media, it should have a control program that addresses the following:
1. Who (by title) issues the stamps, badges, or authorizations?
2. What procedures are used to ensure that the method used can be traced to the individual who issued the authorization (a list of names and stamps, or similar document)?
3. Are there procedures to check that the stamps, if used, are still legible?
4. Are there procedures to ensure that the stamp, badge, or authorization is returned to or revoked by the responsible manager upon termination or reassignment of an employee?
5. Are procedures and training on the security of the system used (stamps or electronic)?
Note: Exemptions from the regulations will no longer be required to use electronic media because the rule allows the use of electronic systems. The repair station must have procedures that fully describe the system and its use.
5.10.16 Maintenance Release and Approval for Return to Service.
5.10.16.1 The maintenance release document must meet the requirements of §§ 43.9 and 43.11. Many repair stations have chosen to use FAA Form 8130-3, Authorized Release Certificate—Airworthiness Approval Tag, as a maintenance release for component/part maintenance. Instructions for completion of FAA Form 8130-3 are in FAA Order 8130.21, Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag. Those facilities that are EASA-certificated must use FAA Form 8130-3 as a maintenance release for articles returned to EASA-member countries.
5.10.16.2 Regardless of the format, the contents must include:
1. A description (or reference to data acceptable to the FAA) of the work performed. In either case, there must be enough information provided so that a person unfamiliar with the work would be able to determine the extent of the maintenance and/or alteration performed. If the repair station is also EASA-certificated, the maintenance release must include the revision status of the technical data used to perform the work. The maintenance release also should include a record of the parts used, particularly if the maintenance involved substituting parts, such as PMA parts.
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2. The date the article is approved for return to service.
3. The name of the person who performed the work (in this case, the repair station).
4. 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.
5. 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.
5.10.16.3 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.
5.10.16.4 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, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), to record the work and approve the article for return to service (refer to part 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.
5.10.16.5 Procedures for approval for return to service should include the following (as applicable):
1. Who (by title) is authorized to complete the form? How is the individual authorized?
2. Is the person certificated under part 65 if employed by a repair station located in the United States?
3. 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.)?
4. Does the maintenance release include or reference a list of approved parts?
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5. How does the repair station ensure that it approves for return to service only those articles for which it is rated?
6. 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?
7. Who (by title) is authorized to complete FAA Form 337 and how is that person authorized?
8. What records are given to the customer and what records are maintained on file at the repair station?
9. Have the people that complete the approval for return to service been trained for this position? Is the training documented?
5.11 Required Records and Recordkeeping.
5.11.1 References:
• Section 43.9.
• Section 145.209(i).
• Section 145.219.
5.11.2 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.
5.11.3 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.
5.11.4 Sample Formats. Records may be in different formats depending on the type of work performed. Samples of the inspection and maintenance forms (and instructions for completing such forms) or a reference to a separate forms manual should be included in the manual system.
5.11.5 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.