Avionics News June 2021 - 15

Your authority, your surveyor, your inspector
reviews your manuals, not to determine if
your manuals are compliant, but rather to
determine if your business is compliant with
the regulations. Your manuals are simply a
window into your business.
of your business. Who are you? What business do you
intend to operate? Where will your business operate?
And how will you staff and operate your business?
When considering 14 CFR §145.209 defining the
repair station manual contents, you see that it is the
basic business plan description - the who, what, where,
and how of your business.
The repair station manual begins with a description
of who you are; paragraphs (a) and (b) describe
your personnel. Paragraph (c) is an overview of
what your services are and where you perform your
services. Following the application process, paragraph
(d) describes the process for keeping your initial
qualifications current and up to date. The " work-away "
procedures in paragraph (e) simply continues the initial
qualification of what and where you perform your
services by assuring your business operates to the same
standards regardless of where you perform your work.
As part of the description of what, where, and how
of your business, when your customer base includes
commercial operators, there is an enhanced regulatory
requirement. Paragraph (f) addresses what, where,
and how you will support the commercial customers.
And finally, with an intent to keep your repair station
application current, paragraph (h) focuses on keeping
your original declaration of contract maintenance intent
current throughout the life of the repair station. The
last element in your business plan is describing your
documentation system - defining the who, what, where,
and how of your business records. Some records are
required by regulations (airworthiness records), while
other records are simply needed to support the efficient
operation of your business.
Your repair station manual is your business plan. It is
the document you use to describe your business to new
employees, potential financiers, potential customers,
and, of course, your authority.
The quality manual is the manual that is most
obviously written to the wrong audience.
Take a deep look at the requirements for a quality
system: 14 CFR §145.211.
The opening paragraph, paragraph (a), requires a
repair station to establish and maintain 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. " There is a logical requirement that the
quality system must meet the criteria of the regulations
that is " acceptable to the FAA. " This is not necessarily
a difficult statement. In essence, your quality system
must include, at a minimum, all of the applicable
elements of paragraph (c) for all work you do in-house,
on the road, or contract to a vendor.
The second paragraph makes it clear that each
employee must follow the quality system.
Clearly, the quality system should be written to
assure that you, your employees, and your vendors
produce to your defined standards. AS9910, the Quality
Management Systems requirements for aviation
maintenance organizations, captures the fundamental
avionics news * june 2021 15
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Avionics News June 2021

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