May_June_2022 - 12

A R S A INS IG H T
Your Mobile Home
In its 1999 notice of proposed rulemaking that modernized the repair station
certification regulations, the agency affirmatively provided a method for its
Part 145 certificate holders to " work away from the fixed location. "
The 2001 final rule confirmed a repair station's ability
to " temporarily transport " the elements necessary
to perform work " due to a special circumstance, as
determined by the FAA; or...to perform such work on
By Sarah MacLeod
Sarah MacLeod is
managing member
of Obadal, Filler,
MacLeod, & Klein,
P.L.C. and a founder
and executive
director of the
Aeronautical Repair
Station Association.
She has advocated
for individuals
and companies on
international aviation
safety law, policy and
compliance issues for
30 years.
a recurring basis " (see, 14 CFR § 145.203). The words
" temporary " and " recurring " have been applied in different
ways as the concept of " mobile response maintenance "
has evolved.
Mobile response means the maintenance provider
will appear where the aircraft is broken. Many companies
employ mechanics with airframe and powerplant
licenses to supervise, accomplish, and approve
for return to service the work needed to get the aircraft
back in the air. However,
a mechanic can't perform
certain tasks without an
inspection authorization,
nor can that certificate be
used by some fractional
owner operators, air carriers,
or commercial operators
without separate
qualifications. Therefore,
more and more repair stations
have acquired " work
away " capabilities.
The regulations are not
particularly clear on what
is " temporary " and what
can be " permanent " when
it comes to placement of
tools, tooling, equipment,
materials, maintenance manuals and information, and
personnel. Nor has the agency been able to clearly
articulate the work or the " special circumstances "
used in its determination if the work is not recurring.
What is clear are the requirements for a repair station
to work away from its fixed location on a recurring
basis. The certificate holder must have written
procedures for performing work at another location
(see, 14 CFR § 145.209(f)). That means there will be a
quality system (see, 14 CFR § 145.211) that must correct
discrepancies (see, 14 CFR § 145.211(c)(1)(ix)), which
will eventually be instituting a safety management
system involved in the performance of the aircraft
maintenance. This is not a disparagement against
individual mechanics, it is a factual assessment of the
aviation safety system, and the choices private aircraft
operators have in determining what or who performs
work on their aircraft. It is also a comment on the
complexity and sophistication of many " general aviation "
aircraft, which can go beyond the knowledge and
experience requirements of an individual mechanic.
When choosing a " mobile maintenance provider, " it
would behoove operators, usually pilots, to call upon
those that can provide the widest range of technical
FRANCKREPORTER / E+ / GETTY IMAGES
knowledge and services. The maintenance provider
is not responsible for the airworthiness of the aircraft
when it is performing restorative measures, that is the
operator's responsibility, or absent an operation, the
owner. The maintenance provider is only responsible
for the " work performed. " Repair stations with mobile
capabilities can call upon the " home base " and its capabilities
to assess and correct discrepancies. Obviously,
so can an individual mechanic, but there is no quality
system or other business assessment requirements
associated with that certificate.
12 MAY/JUNE 2022
AIRCRAFT MAINTENANCE TECHNOLOGY
May_June_2022

Table of Contents for the Digital Edition of May_June_2022
