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?
Appendix B B-9 B.12.4 Preliminary Inspection.
1. Who (by title) will perform this inspection, and how will it be performed?
2. When is this inspection performed?
3. How will the inspection be recorded?
4. If the inspection reveals discrepancies, how are they recorded?
5. How is corrective action taken to correct any discrepancies?
6. Do the records show the relationship between the discrepancies found and the corrective action taken?
7. Is the record of this inspection made part of the work order file (work package)?
8. How is traceability of life limits and/or time since overhaul ensured?
9. How are the parts identified if acceptable and if not acceptable?
10. Does the manual include procedures to ensure that the records (work package) are kept with the parts?
11. Does the manual include a procedure to ensure that current technical data is available before inspection?
12. Does the manual include procedures for detecting and reporting unapproved parts?
13. Does the manual include a procedure for reporting failures, malfunctions, or defects of an article?
B.12.5 Hidden Damage Inspection.
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?
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?
B.12.6 In-Process Inspection.
1. Who (by title) will perform the inspection, and how is it performed?
2. How will the inspection be recorded?
3. If defects or discrepancies are noted, where will they be recorded?
4. Do the procedures allow steps to be performed out of sequence? If so, how is this authorized and recorded?
Appendix B B-10
5. If the in-process inspection results are not satisfactory, does the manual have procedures governing rework?
6. Do the forms used in the inspection system record both the name of the person who performed the work and the inspector?
7. Are the records of this inspection made part of the work order (records package)?
8. Who determines when an in-process inspection is performed and how is that determined?
9. Do the procedures describe the inspection of an article and review of documentation for maintenance performed by a contracted facility?
B.12.7 Final Inspection.
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 manual have procedures governing rework?
4. Before the final airworthiness determination is made, are all other maintenance, inspection forms, and records checked for completion? How is this indicated?
5. How is the inspection performed?
6. After the final inspection is completed, how are the articles identified?
7. Does the manual include procedures for when the final inspection results in accepting or rejecting the article?
8. If the repair station performs 100-hour and/or annual inspections, does the manual include procedures addressing the use of inspection cards and/or forms, checklists, etc., to record the inspection and correction of any discrepancies? Where the operator has an FAA-approved minimum equipment list (MEL), are procedures for the deferral of inoperative equipment included?
9. If the maintenance performed was a major repair or major alteration, does the manual include procedures to ensure that the inspector who inspects the article and approves it for return to service is trained, qualified, and authorized?
B.12.8 Work Signoff.
1. Who (by title) issues the stamps, badges, or authorizations?
2. Do the procedures ensure that the method used can be traced to the individual who was issued the authorization (a list of names and stamps or similar document)?
3. Does the manual include procedures to check that the stamps (if used) are still legible?
Appendix B B-11
4. Do the procedures ensure that the stamp, badge, or authorization is returned to or revoked by the responsible manager after termination or reassignment of an employee?
5. Does the training include security procedures for the system used (stamps or electronic)?
B.12.9 Approval for Return to Service.
1. Does the form meet the requirements of part 43, §§ 43.9 and 43.11?
2. Who (by title) is authorized to complete the form? How is he or she authorized?
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., is sick or on vacation)?
4. Does the maintenance release document include or reference a list of approved parts?
5. Do the procedures ensure that only those articles for which the repair station is rated are approved for return to service?
6. Do the procedures describe how the repair station will determine if the repair or alteration is major? If the maintenance was a major repair or major alteration, do the procedures describe how it will be recorded?
7. Who (by title) is authorized to complete FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), 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?
B.13 Required Records and Recordkeeping.
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?
3. Where are the records stored?
4. Who (by title) reviews records for accuracy and completeness before approval for return to service? Is the individual trained?
5. If the repair station uses electronic records, does the manual describe the procedures, including security, backup, and retrieval?
6. Are the records in English, and do they meet (at a minimum) the requirements of § 43.9?
7. What records will be provided to the owner/operator?
Appendix B B-12
8. How will the repair station process records received from contractors?
9. Are procedures for distribution and storage of FAA Form 337 included?
10. How are records of any special inspections, such as hydrostatic tests, functional tests, and so forth, processed?
B.14 Calibration of Measuring and Test Equipment.
1. Who (by title) is responsible for the calibration system?
2. What is the basis for the test intervals, such as manufacturer, standard industry practice, and so forth?
3. Is the calibration technique recommended by the manufacturer or standard industry practice?
4. How is calibrated equipment identified?
5. Is the calibration technique documented?
6. What procedure is used to change calibration intervals?
7. Are actual calibration results recorded to justify changes to calibration intervals?
8. Do the procedures ensure that calibration is traceable to the National Institute of Standards and Technology (NIST), the manufacturer, or an acceptable foreign or international standard?
9. Do the procedures ensure that equipment is removed from service and calibrated when due?
10. Do the procedures include recall of any product inspected if the measuring equipment was out of tolerance when the work was performed?
11. How is equipment that is not submitted for calibration when it is due handled
(e.g., when it is lost or overdue)?
12. How is calibration recorded? Are the actual results at each test point recorded?
13. If automated test equipment is used, is it included in the calibration system?
14. Does the procedure describe the information on the calibration label of the equipment?
15. How is equipment that must be calibrated before each use identified and recorded?
16. How is equipment that does not require calibration identified?
17. Do the procedures address the acceptance of new precision test equipment into the inventory?
18. Do the procedures address calibration performed by an outside contractor?
19. Do the procedures address calibration of employee-owned tools?
Appendix B B-13
20. Who (by title) is responsible for records of calibration received from outside contractors?
21. Do the procedures address calibration requirements, standards, documentation, and traceability of tools that the repair station has leased?
22. Do the procedures describe the review of the contracted calibration facility’s records for traceability, accuracy, and acceptability?
23. 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?
24. If NDT is performed, does the manual include procedures for certification of company-manufactured NDT inspection standards (if any are used)?
B.15 Taking Corrective Action on Deficiencies.
1. Who (by title) is responsible for the program?
2. How is the root cause of the problem determined?
3. Who (by title) will initiate corrective action?
4. How much time will be allowed to implement the corrective action?
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?
Advisory Circular Feedback Form If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by contacting the Flight Standards Directives Management Officer at 9-AWA-AFS-140-Directives@faa.gov.
Subject: AC 145-9A, Guide for Developing and Evaluating Repair Station and Quality Control Manuals Date: _____________________ Please check all appropriate line items:
An error (procedural or typographical) has been noted in paragraph ____________ on page _______.
Recommend paragraph _____________ on page __________ be changed as follows:
______________________________________________________________________ ______________________________________________________________________ In a future change to this AC, please cover the following subject:
(Briefly describe what you want added.)
______________________________________________________________________ ______________________________________________________________________ Other comments:
______________________________________________________________________ ______________________________________________________________________ I would like to discuss the above. Please contact me.
Submitted by: Date: ______________________