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25. Does the standard used to perform the calibration have the required accuracy?
26. If the facility includes an engine or auxiliary power unit (APU) test cell, does the manual include procedures for correlation, calibration, and limitations, if any?
27. For facilities that perform NDT, does the manual include procedures for certification of company-manufactured NDT standards (if any are used)?
28. Do the procedures describe the title of the person who is responsible for maintaining the calibration records and where they are maintained?
5.13 Taking Corrective Action on Deficiencies.
5.13.1 Reference. Section 145.211(c).
5.13.2 Procedures. Section 145.211(c)(1)(ix) states that the QCM must include procedures used for taking corrective action on deficiencies. Corrective action is taken to remedy an undesirable situation. Deficiency correction is normally an integral part of a repair station’s improvement process and could include revisions to procedures that were not working properly.
5.13.2.1 Corrective action would be applicable before the article is approved for return to service and after the article has been approved for return to service.
The RSM should describe the system by which reworks are identified and corrected before an article is approved for return to service. In these cases, a review of the housing, facilities, equipment, personnel qualifications, and procedures should ensure that the deficiency was not a systemic problem. If the review indicates that the procedure is deficient, the corrective action should include a thorough review and improvement of the procedure. If the review indicates that the personnel lacked training or qualifications, corrective action should remedy the deficiency. In either event, the procedures must address how reworks are documented.
5.13.2.2 After the article is approved for return to service, the repair station may avail itself of the self-disclosure program addressed by AC 00-58, Voluntary Disclosure Reporting Program. This AC describes the procedures for voluntary reporting of potential violations of the regulations. Once an article is approved for return to service, discrepancies are often evidence of a potential violation of the regulations, particularly § 43.13. Therefore, the repair station should carefully review AC 00-58 for the appropriate method of notifying the FAA. The repair station should have a procedure for ensuring the quality of the work performed and for handling customer returns or complaints.
5.13.3 Examples. The following scenarios are presented as examples of the intended use of a corrective action program:
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5.13.3.1 Scenario 1. During the final inspection process of an aircraft in the repair station for a major inspection, the chief inspector performs a review of the paperwork. During that review, the inspector discovers that one of the discrepancies found during the inspection has not been corrected. Further review of the paperwork reveals that no repairs were performed to correct this discrepancy. Discussions held with the mechanics working on the aircraft reveal that a part is on order to complete the repair. The chief inspector asks why no one wrote on the paperwork that the part is on order. One of the mechanics replied that there are no instructions anywhere that direct them where to write that a part is on order. The procedure requires the mechanic to describe the actions taken to clear the discrepancy and to sign in the appropriate block. The procedure does not address what action to take if a part is on order. What first appeared as a failure of the mechanic to write that a part is on order turned out to be a lack of written procedures in the manual.
By taking the time to develop a written procedure for the mechanics to follow, the repair station corrected the deficiency.
5.13.3.2 Scenario 2. The repair station overhauls “widgets,” which are components of a turbine engine. Part of the overhaul process involves application of a special coating to the bore of the widget, followed by machining to final diameter.
The repair station contracts the application of this coating to another facility.
During the machining operation, several areas of the coating are chipped completely off the bore. Since this condition is unacceptable, the bore must be stripped and re-coated. After experiencing this condition on several parts, the repair station conducts an investigation into the root cause. A review of the machining process indicated all recommended procedures were followed. The repair station, in coordination with the contracted facility, conducted a review of the process used to apply the coating. The investigation revealed a malfunction of the spray equipment, allowing the coating to be applied incorrectly. The spray equipment was repaired and adjusted, eliminating the problem. What first appeared as a machining problem turned out to be an application problem. By taking the time to conduct a thorough investigation into the root cause, future problems were eliminated.
5.13.4 Inadequacies and Deficiencies. Inadequate procedures, environment, working conditions, training, instructions, or resources may be factors for many deficiencies that are attributed to human error. The involvement of personnel from several levels within the organization (if appropriate) will contribute to the program and ensure quality. Corrective action requires that the root cause or causes of the discrepancy be investigated and determined in order to eliminate such causes. The investigation must be fact-based and typically begins with an analysis of the potential causes of the discrepancy. It is usually helpful to have a small team of informed and involved individuals associated with the article/process. Although human factors may play a part, focus should be placed on physical factors, such as workplace environment, facilities, equipment, and tooling;
process factors, such as clarity of instructions; and training/understanding of methodology for the work to be properly accomplished. Flow or process diagrams of the maintenance process for the affected article are a typical starting place. Typically, each
5-47 item in the process, and interactions between such items, are questioned/analyzed in an attempt to determine which either caused or contributed to the ultimate deficiencies.
Often the interactions result in a cumulative effect that results in the deficiency. Once each potential weakness is identified, the individual/team analyzes each to correct the findings. The product is checked to determine whether the corrective action has accomplished the elimination of the deficiency/discrepancy.
5.13.4.1 A documented procedure for taking corrective action on deficiencies should answer the following:
1. Who (by title) is responsible for the program?
2. How is the root cause of the problem determined? Will any interim steps need to be taken to prevent delivery of deficient products while the corrective action is implemented?
3. Who (by title) will initiate corrective action?
4. How much time will be allowed for the corrective action to be implemented?
5. Who (by title) will perform a followup audit of the corrective action to ensure that it was effective?
6. What records will be maintained of the cause and corrective action taken?
5.13.4.2 For those facilities that elect to conduct regularly scheduled management review meetings, the investigation, cause, and corrective actions taken to prevent recurrence of discrepancies should be topics of discussion during those meetings.
Appendix A A-1 APPENDIX A. FORMS A.1 Reference. Title 14 CFR part 145, § 145.211(c)(3).
A.2 Forms and Instructions. Section 145.211(c)(3) requires that the QCM contain a sample of the inspection and maintenance forms and the instructions for completing such forms, or the manual may refer to a separate forms manual, which provides examples of the forms with instructions.
A.3 Included Samples. The forms included in this section should be samples of any form, tag, and label described in the procedures within the RSMs. The instructions for completing the form may be on the form or on a separate document. The number and content of the forms will depend on the size of the repair station and the complexity and the variety of the articles for which the repair station is rated. Revisions or additions to the form section of the manual should follow the documented revision procedures.
A.4 Factors to Consider. Some factors to consider when developing instructions for completing a form are:
1. How should the form be introduced (at what point during the maintenance process) and when should it be completed?
2. Who is the person or department responsible for starting the form, who will contribute to its completion, and who will finish all required entries on the form?
3. How will the form be completed?
4. What is the purpose of the form and how will it fit into the system?
5. How should revisions to the form be accepted/approved before release (if applicable)?
6. How will the form fit into the recordkeeping system?
7. Which detailed inspection forms and checklists should be used when performing annual, 100-hour, progressive or other approved inspection programs, or engine overhaul? These need not be included in the manual.
These forms should be referenced in the manual, and instructions for completing these forms (if required) may be in a separate document.
8. Do forms that are used for multiple operations or work have adequate space and appropriate instructions, including specific assignment of responsibility, to ensure that they can be filled out properly?
9. Do the instructions direct the user to write N/A (not applicable) or N/R (not required) and initial/date any blocks on the form that are not used?
10. Will retention and storage be done in accordance with § 145.219(c)?
Note: No examples of forms are offered in this AC because forms must be developed to fit the needs of each repair station.
Appendix B B-1 APPENDIX B. CHECKLIST The following checklist is provided as a guide for reviewing the completed manual(s). This checklist was not developed to be all-inclusive and should be modified to fit the type of operation and complexity of the repair station. Some suggested items may not be applicable to all repair stations.
B.1 Manual Revision and Control.
1. Who (by title) will be responsible to initiate, write, and submit revisions to the FAA for review and acceptance?
2. What actions and/or procedures will be initiated by the repair station if the FAA finds that the submitted revisions are unacceptable?
3. How and where is the acceptance of the manual noted, including how the FAA will receive its revisions?
4. How will the revisions be distributed?
5. Does the procedure ensure that each manual holder receives each revision?
6. Will the revised text of each affected page be clearly identified?
7. Do the procedures include control of sections of the manual, such as identification, revision status, page numbering, issue date, and approvals/acceptance?
8. Do the procedures to control sections of the manual address (as applicable) identification, revision status, page numbering, issue date, and approvals of internal personnel responsible for the manual and revisions?
B.2 Organization.
1. Does the manual include an organizational chart that shows (by title) each manager with authority to act on behalf of the repair station?
2. Are the titles for the positions the same throughout the manual?
3. Does the organizational chart show separation of maintenance and inspection departments (if applicable)?
B.3 Personnel.
1. Does the manual describe the duties and responsibilities, including the area of responsibility assigned, of each management position?
2. Does the narrative describe what each person does?
3. Do the procedures ensure that their duties and responsibilities are performed in each person’s absence?
4. Does the manual include procedures for maintaining and revising the rosters required by 14 CFR part 145, § 145.161?
Appendix B B-2
5. Does the manual include procedures for maintaining the employment summaries for each person whose name is on the roster?
6. Does the manual include procedures for applying for additional repairmen and for maintaining the certificates?
7. Does the manual include a procedure for surrendering Repairman Certificates when required by 14 CFR part 65?
8. Do the employment summaries meet the requirements of § 145.161?
B.4 Operations, Housing, and Facilities.
1. Does the manual describe the facility’s floor plan, shops, and equipment?
2. Is a description of the facility (narrative) included?
3. Is the operation of the repair station described?
4. Are any special environmental conditions addressed?
5. Does the description include a generic overview of the type of equipment?
6. If the repair station leases or rents equipment, does the manual contain procedures describing the lease/rent process and who is responsible for managing the program?
7. How does the repair station ensure the equipment is in place and under its control when the work is performed?
8. If the repair station is using special equipment or tools other than those recommended by the manufacturer, does the manual include procedures for determining equivalency?
9. Does the manual include a description of the stock room, how inventory is requisitioned for particular jobs, and how shelf life inventory is maintained?
B.5 Capability List (CL).
1. Who (by title) will maintain the CL?
2. How will the self-evaluation be performed?
3. Who (by title) will perform the self-evaluation?
4. How is the self-evaluation documented?
5. Do the checklists and forms address all of the applicable requirements of part 145 (e.g., housing, facilities, equipment, tools, technical data, and personnel)?
6. How will results of the self-evaluation be reported to management?
7. Does the procedure describe how items are added to and deleted from the list?
Appendix B B-3
8. Are changes to the list clearly indicated on the document?
9. If electronic media is used, are the hardware and software compatible with that of the responsible Flight Standards office?
B.6 Training Program Revision.
1. Who (by title) is responsible for submitting training program 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?
B.7 Work Performed at Another Location.
B.7.1 For a Special Circumstance:
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
Appendix B B-4 describing the work requested or anticipated, and the location at which the work will be performed.
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.
B.7.2 Recurring Work. If the repair station intends to perform work at another location on a recurring basis, include procedures for accomplishing maintenance, preventive maintenance, alterations, or specialized services at a place other than the repair station’s fixed location. This business practice will provide flexibility and mobility to meet industry needs and not be restricted “only” to special circumstances. 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)), and extent of work anticipated away from the location.
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 14 CFR 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)); if inadequate, method (lease/borrow) for obtaining the housing and facilities necessary for compliance with part 43.
Appendix B B-5
6. Procedures for dispatching or obtaining the calibrated equipment needed to make final airworthiness determinations on the work performed.
7. Procedures for providing or obtaining necessary equipment, tools, and tooling needed to accomplish the work scope.
8. Procedures for providing or obtaining the necessary maintenance data (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).
9. Procedures for providing or obtaining the proper replacement items
(e.g., parts, subassemblies) and 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.
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 tracking and recording maintenance performed for the owner of the article being maintained (e.g., logbook) and for the repair station. If different maintenance records will be used for the repair station, they should be included in the forms section of the repair station’s manual (refer to § 145.211(c)(3)).
13. Procedures to ensure the applicable sections of the RSM are 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.
B.7.3 Using Mobile Units. If the work away from the fixed location will be performed using mobile units, the following additional procedures should also be addressed:
1. Method for determining the location of each unit.
2. Method for specifying and updating a point of contact (POC) for each unit.
3. Procedures describing how often the repair station will conduct audits of the units to ensure compliance with part 145 and the method for reporting the results to the applicable manager for review and action, if necessary.
Appendix B B-6 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 type 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.
B.8 Maintenance Performed 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. How does the repair station maintain a current list of Required Inspection Item (RII) inspectors? Who maintains the list?
4. Does the RSM include procedures to ensure that the necessary equipment, trained personnel, and technical data will be available for line maintenance?
5. Does the manual describe the training program for air carrier maintenance and RII?
B.9 Contract Maintenance Information.
1. Who (by title) is responsible for the contract maintenance program?
2. Who (by title) is the individual maintaining the list of contracted facilities and contract maintenance functions?
3. How will the list of contractors be made available to the FAA?
4. When and how will the responsible Flight Standards office be notified of revisions to the list?
5. How will the repair station determine if the contracted facility is properly rated?
6. Do the contract provisions for non-FAA-certificated facilities include provisions for FAA inspection?
7. How does the repair station qualify and audit FAA-certificated and noncertificated entities?
Appendix B B-7
8. Are the individuals who inspect contract maintenance entities trained?
9. How do the receiving inspectors inspect articles returned after maintenance from FAA-certificated and noncertificated entities? Are they trained?
10. Are discrepancies with contracted entities included in the corrective action program?
B.10 Proficiency of Inspection Personnel.
1. How are minimum qualifications for inspection personnel established?
Who makes this determination?
2. How will the inspector maintain proficiency? Training? On-the-job training (OJT)? What methods are used?
3. Do the records of training indicate the method, length, instructor, and dates?
Are they current?
4. Who is responsible for ensuring that inspectors maintain proficiency?
5. Does the final inspector authorize approval for return to service? If so, is this inspector certificated under part 65 (if the repair station is located within the United States)?
6. Will the inspectors require any special training, (i.e., Nondestructive Testing (NDT))? Who will be responsible for the training? How will inspectors continue to meet any required industry standards?
B.11 Current Technical Data.
1. Who (by title) is responsible for revising and maintaining the technical data?
2. How does the repair station ensure that the technical 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 technical documents?
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 computer software is used for component testing, how are revisions made and distributed? Who (by title) is responsible for ensuring that the software is operating properly and that the current revision is in use?
Appendix B B-8 B.12 Inspection System.
B.12.1 General.
1. Does the manual include procedures for reporting malfunctions or defects?
2. Does the manual contain procedures that ensure continuity of inspection responsibility?
3. Does the manual contain procedures for segregation of repairable from nonrepairable articles?
4. Does the manual include a procedure for tagging or identifying articles, including repairable and nonrepairable articles?
B.12.2 Receiving Policy.
1. Who (by title) performs the inspection, and how is it performed?
2. How is the inspection recorded?
3. What actions are required if the container and/or material was damaged?
4. How is the material routed for proper storage?
5. What is the required documentation from contracted facilities?
B.12.3 Incoming Inspection.
1. Who (by title) will perform this inspection?
2. How will the inspection be performed? What technical data will be necessary to perform this inspection?
3. Does the manual include procedures for control of items that have shelf life limitations?
4. Do the procedures describe the action taken if the material meets specification, as well as what action is taken if the material does not meet specification?
5. How is the material identified if acceptable or not acceptable?
6. Do the materials require any special testing requirements? If so, what procedures are followed to perform those tests? How is the testing performed?
7. What is the disposition of incoming inspection records?
8. How is traceability of materials received in lots, such as weld wire and coating powders, ensured?
9. Does the manual contain procedures for suspected unapproved parts (SUP) formal training, detecting and reporting SUP?