Avionics News March 2015 - 42

THE VIEW FROM WASHINGTON
Continued from page 13

The current repair station manual and supplements
are in a format acceptable to the FAA.
Again, going to the preamble, the FAA states that, "The
manual may be in any format acceptable to the FAA,
including but not limited to paper or electronic format."
This focuses the definition of format on "the means of
storage" rather than the form of documentation.
The requirements for the quality control manual are
subtly different. While the repair station manual is developed to describe the infrastructure and staffing of the
repair station, the objective for the quality system is to
produce a safe, quality product.
The requirements begin with the repair station establishing and maintaining a quality control system that ensures
the airworthiness of the articles on which the repair station, or any of its contractors, performs maintenance, preventive maintenance or alterations. (§ 145.211 (a)/(b))
So the repair station must:
1. Establish a quality control system that ensures the
airworthiness of the articles on which the repair station performs maintenance, preventive maintenance
or alterations.
2. The quality control system must also ensure the airworthiness of the articles on which any of the repair
station's contractors perform maintenance, preventive maintenance or alterations.
3. The repair station must maintain the quality control
system.
4. The repair station personnel must follow the quality
control system when performing maintenance, preventive maintenance or alterations.
5. The repair station contractors must follow the quality control system when performing maintenance,
preventive maintenance or alterations on behalf of
the repair station.
Once the repair station establishes a quality control
system, it must prepare and keep current a quality control
manual that documents the quality system in a format
acceptable to the FAA. (§ 145.211 (c))
The third "manual," which is not actually a manual but
rather a program, is the employee training program. (§
145.163) The training program has a few unique requirements. A certificated repair station must:
1. Have an employee training program.
2. Have an employee training program that must consist of initial and recurrent training.
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Have the employee training program (and its revisions) approved by the FAA.
4. Use the employee training program.
Training is not a new concept within the organization
of a repair station. Nearly every section within Subpart
D (personnel) already contained a training and qualification requirement. The regulations require each certificated
repair station to provide qualified personnel to plan,
supervise, perform and approve for return to service the
maintenance, preventive maintenance or alterations. (§
145.151(b))
The requirement for a training program expanded the
basic requirement to require documentation that "each
employee assigned to perform maintenance, preventive
maintenance, alterations and inspection functions is capable of performing the assigned task." If they are not capable, you must "qualify" them through training and/or education. Finally, so that the program is auditable, the repair
station must document the individual employee training.
These training records must be retained for a minimum of
two years. (§ 145.163 (c))
The greatest failure of the three documents are that they
represent either some other repair station or the operation
of this repair station in a bygone era. I am routinely asked
if the AEA provides templates, and it does not. Generally,
templates are developed in the eyes of a "template maker"
representing how a "perfect repair station" should look.
Some focus on whatever it takes to satisfy the respective authority, whether or not it truly represents what they
do, or the operations of a another repair station willing
to share their previously vetted manuals. In every case,
templates fail because they don't represent your particular
business.
When getting back to the basics, your two manuals
should answer three criterion:
1. Does the manual describe your business and operations?
2. Does the manual describe your processes adequately so that the authority can understand what
you do?
3. Does the manual describe your processes adequately enough that you can hire someone in your
absence to continue operations while ensuring the
airworthiness?
Once completed, you can then, and only then, evaluate
your business to ensure it is "acceptable" to the administrator. Remember, it is the business and the products it
produces that must meet the requirements of the applicable
regulations, not necessarily the manuals. q

Avionics News March 2015

Table of Contents for the Digital Edition of Avionics News March 2015