Avionics News January 2023 - 15

The value of a repair station's quality management
system and the confidence that it should provide
to the customer cannot be understated.
As we consider Part 43, I want to draw your attention
to sections 43.3 and 43.7: Persons who may perform
maintenance and those persons authorized to perform
a return to service. Contained within Part 43, there
are nine " persons " (individuals, or businesses, with
a certificate) who may perform maintenance, while
only seven of those " persons " have return to service
authority. Each of those persons authorized for RTS
is limited by other regulations: mechanics in Part 65,
air operators in Part 135, and air carriers in Part 121.
Nonetheless, the repair station is one of nine " persons "
who may perform maintenance and one of seven with
return to service authority.
So, what differentiates the repair station from the
competition?
This is a discussion clarifying the difference between
certification versus qualification. Many people use
these terms incorrectly, making certification and
qualification synonymous. Tens of thousands may be
certificated to perform a maintenance task, but only a
fraction are truly qualified. Thousands of repair stations
may be certificated to perform a maintenance task, but
on any given day, only a few hundred are qualified.
At the AEA Connect Conferences in the U.S. this
year, we discussed the work being done by the FAA
Aviation Rulemaking Advisory Committee working
group on Part 145. I presented a slide that showed the
repair station has a dual responsibility.
The repair station must first be certificated to do the
work, and secondly, capable (or qualified) to do the
work. To show the repair station is " certificated to do
the work, " it must rely on its certificate and ratings.
To show the repair station is " capable of performing
the work, " the repair station shows that it meets the
requirements of Part 145 Subparts A through E and
meets the requirements of Part 43 § 43.13 performance
rules.
Arguably, it is every maintainer's responsibly to
be able to show compliance to their certification
regulations as well as the regulations applicable
to the performance of maintenance. However, few
maintenance providers outside of repair stations or
commercial operators with an approved continuous
airworthiness maintenance program have a quality
management system to show they are capable of
performing a maintenance task.
When I consider the eight other authorized
maintenance providers, why doesn't avionics have any
real competition? After all, within the FAA regulatory
system, eight other " persons " are certificated to perform
maintenance, including some avionics maintenance.
And yet, the avionics industry is alive and well. Why?
In my humble opinion, it is because of the quality
management system. Worldwide, to be in the avionics
business, you need to be a repair station. The repair
station regulations are a quality management system.
In some regulatory regimes, it is a quality assurance
system. In others, it is a quality control system.
Nonetheless, regardless of what level of quality system
the regulatory authority mandates, the regulations are,
by definition, a quality management system.
Why is the quality management system so important?
Because it allows the service provider to show the
customer that they, unlike their competition, are
Continued on page 18
avionics news * january 2023 15
Avionics News January 2023

Table of Contents for the Digital Edition of Avionics News January 2023
