Avionics News November 2022 - 35

THE VIEW FROM WASHINGTON
Continued from page 17
station must perform this self-evaluation to determine
that the repair station has all of the housing, facilities,
equipment, material, technical data, processes, and trained
personnel in place to perform the work on the article as
required by Part 145 " (section 145.215 (c)). This second
sentence is the basis of an excellent checklist.
Is the article within the scope of the ratings of the
repair station's certificate? This includes the repair station
certificate, ratings and limitations of the operations
specifications.
The remainder of the checklist contains the following
seven items:
1. Housing.
2. Facilities.
3. Equipment.
4. Material.
5. Technical data.
6. Processes.
7. Trained personnel.
The first item, certificate, ratings and limitations, answers
the question: " Are you certificated to perform the work? "
The remaining seven items must be in place to answer if you
are " capable " of performing the work.
Housing is a requirement of Part 145. Essentially, the
housing must be appropriate and adequate for the work
being produced to protect the product or article and the
personnel performing maintenance from an undesirable
environment that might compromise the work meeting the
standards of Part 43.
The facility and equipment lead you back to section
43.13, which tells us that whoever performs maintenance
" shall use the tools, equipment and test apparatus necessary
to assure completion of the work in accordance with
accepted industry practices. If special equipment or test
apparatus is recommended by the manufacturer involved,
he must use that equipment or apparatus or its equivalent
acceptable to the administrator. "
Materials again take us back to Part 43 section 43.13.
Here we see that each person maintaining, altering or
performing preventive maintenance shall use materials of
such a quality that the condition of the aircraft, airframe,
aircraft engine, propeller or appliance worked on will be at
least equal to its original or properly altered condition.
Regarding technical data, once again, the maintenance
performance rules direct that the maintainer shall use the
methods, techniques and practices prescribed in the current
manufacturer's maintenance manual or instructions for
continued airworthiness prepared by its manufacturer, or
other methods, techniques and practices acceptable to the
administrator.
The checklist item identified as processes is tied back
to the technical data. If the required maintenance action
requires the use of a specified process, then having the
ability to either perform the work in-house or contracting
to have the process performed is required. Of course, if you
need to outsource the process due to in-house limitations,
then that maintenance process must be FAA approved.
The final item on the checklist is trained personnel.
This is one of the most-often missed items in class-rated
facilities. With an aging workforce, it is not unusual for
a repair station's knowledge base to be with a few senior
technicians. When they retire, the repair station may not
have any backup knowledge, to which the repair station
would no longer be " qualified " to perform the work.
The requirement to qualify trained personnel is identified
throughout subpart D of Part 145. First, as stated earlier,
from section 145.151, we see that each repair station must
provide qualified personnel to plan, supervise, perform, and
approve for return to service the maintenance, preventive
maintenance, or alterations performed under the repair
station certificate and operations specifications. Further,
section 145.163 leads us to the requirement that a repair
station must ensure each employee assigned to perform
maintenance, preventive maintenance, or alterations, and
inspection functions " is capable of performing " the assigned
task. How the repair station qualifies the employees is to be
documented in the repair station training program.
While I can acknowledge that the regulations only require
a repair station with a limited rating the express requirement
to list its capabilities, the basic regulations require all repair
stations to know and routinely verify its capabilities. There
are a number of sites throughout Part 145 that reinforce this
simple requirement.
When you consider the eight items required of all
maintainers, there are three that can challenge a repair
station. While certificate and ratings as well as housing and
facilities are reasonably static, the repair station limitations,
equipment, technical data, and qualified personnel can be
dynamic and require a regular review. Whether a limitedrated
repair station or a class-rated repair station, we
encourage the repair station to use a capability checklist
to verify and document the facility's capability before
engaging in performing maintenance. q
avionics news * november 2022 35
Avionics News November 2022

Table of Contents for the Digital Edition of Avionics News November 2022
