Avionics News February 2021 - 14

In this monthly column, Ric Peri of the AEA's Washington, D.C., office, informs members of the latest regulatory updates.

B Y

R I C

P E R I
A EA V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS

Product or Process

D

uring the past year, I have received
numerous calls because of the enhanced
oversight of the repair station training
program. Most recently, I was called by a repair station
to ask if it received " X " training should it be able to
get " X " rating. This most recent phone call highlighted
that we have lost sight of the relationship between the
various piece parts of the repair station regulations. And
while the repair station training program is explicitly
a U.S. Federal Aviation Administration requirement,
understanding the interrelationship between the
independent requirements of the repair station
regulations is universal and applies regardless of the
regulatory authority one may be operating under.
The repair station regulations, by their nature,
comprise a quality management system for an aircraft
maintenance business. As such, the regulations touch
on all aspects of a quality management system that
would affect the ultimate production of airworthy
products - all aspects of the business. Implied within
the regulations (and ultimately captured within the
safety management systems) is the interrelationship
between each of the independent aspects of your
business.
In this month's column, let's explore this question: Is
the repair station training program a product or a process?
Employee qualifications are nothing new. Following
14 CFR back to its original publication in 1966, the
regulations required that an " applicant for a domestic
repair station certificate and rating, or for an additional
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february

2021

rating, must provide adequate personnel who can
perform, supervise, and inspect the work for which the
station is to be rated. " Further, the regulations stated
that the " officials of the station must carefully consider
the qualifications and abilities of their employees

In this month's column, let's
explore this question: Is the
repair station training program
a product or a process?
and shall determine the abilities of its uncertificated
employees performing maintenance operations on the
basis of practical tests or employment records. " (14
CFR 145.39)
It is important to note that this language did not
originate in 1966 with the codification of the federal
aviation regulations but can be found in the early civil
air regulations, where the regulations required every
aircraft repair station to show that it had " adequate
certificated personnel qualified to perform or supervise
the type of work involved. " (CAR 52.4004 (e))
Fast forward a few decades. In 1999, the FAA
cited the already established requirement in Parts
121 and 135 that required the " person performing
maintenance or preventive maintenance functions for
these certificate holders have a training program. " And
Avionics News February 2021

Table of Contents for the Digital Edition of Avionics News February 2021
