U.S. Department
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St. Louis |
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September 2001 |
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www.faa.gov/fsdo/stlfsdo
Thought for the month.....
A clear conscience is usually a sign of a bad memory
Part 145 rewrite... The FAA is finally getting around to publishing the new repair
station rules. As many of you know, the decision to rewrite the rules under which repair stations operate is not
a new concept. I have been in the FAA since 1991 and I knew about the proposed rule changes way back then. Suffice
it to say what has come out in final rule form is different than what I first read a decade ago. How will this
affect the average user of aviation maintenance facilities is still to be determined
As the saying goes, "the devil is in the details". Repair stations that are presently certified by the
FAA will be required to be recertified no later than April 6, 2003. The FAA has granted a 20-month period for all
the FAA certified repair stations worldwide to come into compliance. Add to that any repair facilities that are
presently undergoing initial certification, and it becomes pretty clear that FAA certifying Inspectors will be
busy.
The new rules have been written to address maintenance and safety issues that repair stations deal with today.
The rules they are replacing were adopted in 1964 when the Piper and Bellanca Aircraft companies were still producing
dope and fabric airplanes. I can't tell you how many times repair station owners have told me that the rules they
are required to follow do not fit today's technology. Whether or not the new rules will be better is yet to be
seen. The FAA Inspectors who will determine compliance, and the people who the rules are imposed on, will both
be experiencing a learning curve.
One of the changes will be to establish and maintain a quality control system that is acceptable to the FAA. Repair
stations have always been required to have a procedures manual that was acceptable to the FAA. But, the old rules
only required a manual to include inspection procedures, without specifying operating procedures. The manual had
to "state in detail" the inspection system used by the repair station. The system utilized by the repair
station was supposed to ensure that only airworthy work was produced. Forty-seven years ago it was easier to get
a repair station to do what the supervising inspector thought was right. Policies are different today. An inspector's
latitude of interpreting a rule is not as broad as it once was. The new repair station rules are now written to
be more specific about operational procedures.
Without a written process in place, and with the passage of a sufficient amount of time, the actual practice of
performing an operation often evolved beyond what was originally intended. This is not to say that with a written
process deviations won't happen, but at least the operational process provided in the manual gives us a means to
get back on track if a deviation should occur.
A lot of new employee training takes place by observation and or demonstration. If a step in a process is missed,
it won't be repeated the next time that employee performs the task. A written procedure provides a means for quality
assurance and standardization. Who hasn't forgotten something because of a distraction only to remember it somewhere
down the road - when it is too late. If it has happened once we can be assured that it will happen again.
Another requirement of the manual contents will mandate repair stations to include the process for recording their
work. The preamble to the new rule says that it is important for a repair station to set forth how it operates.
The FAA is adamant about maintenance personnel recording the work that they do. In my experience, both as someone
who has made a livelihood as an aviation maintenance technician (AMT), and as an FAA Inspector, getting the work
down on paper has frequently been noticed as a weak area. We did not get into this business because we like to
write. Recording work performed gets done, but many times we put it off until we can get to it. There are enough
distractions in our lives that occasionally something will be forgotten if it isn't recorded right away. This is
why it is important that any organized procedure specifically states when the record of work performed will be
made. It shouldn't be assumed that it will get done because it is a requirement of the FAR's. By doing it now because
it is dictated by the "house rules", nothing should be left out of the record. This way after a good
day's work we can go home with a real clear conscience, not one that is the result of a bad memory.
Upcoming Events
Surviving on the Spirit of St. Louis Airport. Thunder Aviation, Hangar 3.
7 - 9PM
September 15th
St. Louis Soaring Association
Open House and Safety Day
Highland Airport
Highland IL
October 6th
Fifth Annual Helicopter Safety Seminar
MidCoast Training Facility
CPS
8AM-1PM
October 17th
Surviving on the Spirit of St Louis Airport
Sponsored by the St Louis Chapter MPA
Click Here for further details
Thunder Aviation Hangar 3
7PM-9PM
December 13th
AOPA Air Safety Foundation
Fuel Awareness
Florissant Valley College
Multi-purpose Room
7PM to 9PM
GOOD MAINTENANCE IS NO ACCIDENT
Steven Long
Airworthiness Safety Program Manager
1-800-322-8876 extension 4830
Steven.Long@faa.gov
