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 44–55

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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.

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5.11.6 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 signatures or identifiers, such as stamps, barcodes, 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, Statement of Compliance with Airworthiness Standards, should be included in the records package.

DER-approved technical data will normally require additional FAA approval when used for major alterations. (Refer to FAA Order 8110.37, Designated Engineering Representative (DER) Handbook, for DER authorization.) Supplemental forms in a work package may include, but are not limited to:

• A list of replacement parts;

• Inspection methods sheets;

• SB and/or AD compliance sheets;

• Copies of manufacturer’s technical data; and

• Functional test and/or calibration results.

5.11.7 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 for component/part maintenance, the records must include a copy of the completed form. Order 8130.21, subparagraph 1-7c states that FAA Form 8130-3 should not be used to release an aircraft for return to service. 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.

5.11.8 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.

5.11.9 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.

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5.11.10 Electronic Recordkeeping Systems.

5.11.10.1 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.

5.11.10.2 Before introducing an electronic system, a computer operation procedures manual should be established. The manual should include the following:

1. 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.

2. A procedure for conducting a review of the computerized personal identification codes system to prevent password duplication (if applicable).

3. Procedures for periodic audits of the computer system to ensure the integrity of the system and each workstation.

4. 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.

5. A description of the training procedure and requirements needed for access to the computerized system.

6. Procedures addressing periodic backup of records and files.

5.11.10.3 The repair station must provide a copy of the procedures for implementing an electronic recordkeeping system to the responsible Flight Standards office.

The FAA addresses guidelines and requirements for electronic signatures in AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals.

5.11.10.4 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.

1. Who (by title) is responsible for maintaining the recordkeeping system?

2. What documents are included in a typical records package? What additional forms may be included?

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3. Where are the records stored?

4. What method is used to organize the records?

5. Are the records easily retrieved?

6. Who (by title) reviews records for accuracy and completeness before approval for return to service? Is the individual trained?

7. If FAA Form 8130-3 is used, does the repair station include a completed copy in the records package?

8. If electronic records are used, procedures for security, backup, and retrieval of files must be established.

9. Are the records in English, and do they meet (at a minimum) the requirements of § 43.9?

10. What records will be provided to the owner/operator?

11. How will the repair station process records received from contractors?

12. Are procedures included for distribution and storage of FAA Form 337?

13. How does the repair station document any special inspections, such as hydrostatic tests, functional tests, and so forth?

5.12 Calibration of Measuring and Test Equipment.

5.12.1 References:

• Section 43.13(a).

• Section 145.109(b).

• Section 145.211(c).

5.12.2 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 CRS 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.

5.12.3 Measuring Test 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. The repair station is responsible for the calibration program, whether calibration is performed in-house or contracted to outside sources. The calibration should be traceable to a standard acceptable to the FAA, which can include standards recommended by the manufacturer, the National Institute of Standards and Technology (NIST), providers who are certified by International Organization for Standardization (ISO) accreditation or International Laboratory Accreditation Cooperation (ILAC)-accredited laboratory, or other national authority.

5-42 The measuring test equipment should identify the intervals at which the equipment will be calibrated. These intervals are usually established by the manufacturer or the repair station. The repair station should maintain records of the calibration for at least 2 years or the length of the calibration term, if greater than 2 years.

5.12.4 Traceability. The purpose of traceability of the measuring test equipment calibrations is to identify calibrations were performed with accuracy and credibility. A traceable calibration standard is achieved when each measurement standard is verified through the history, location, or application of the item by means of documented recorded identification. Each calibration provider between the recognized national standard with the primary standard to the measuring test equipment (each link in the chain) should be documented. Traceability and calibration records should be made available for FAA review. The reference standards used to calibrate the measuring test equipment should be traceable to at least an accredited laboratory or a recognized national standard for proper traceability requirements acceptable to the FAA. The repair station is ultimately responsible to ensure that the measuring test equipment has the traceability documentation.

5.12.5 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 for airworthiness determination, these tools should be included in the calibration program. 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.

5.12.6 Training. Repair station 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.

5.12.7 Calibration Controls. Procedures will need to address how and when the equipment is recalled for calibration and who (by title) will be responsible for ensuring that the equipment is returned and controlled properly. 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.

5.12.8 Calibration Records.

5.12.8.1 Calibration records should include the following:

• Who (by title), if calibrated in-house, or the entity who performed the calibration;

• The date of the calibration;

• The date the next calibration is due;

• The standard used to perform the calibration;