AVIATION SAFETY NEWSLETTER
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.
Surviving on the Spirit of St. Louis Airport. Thunder Aviation, Hangar 3.
7 - 9PM
St. Louis Soaring Association
Open House and Safety Day
Fifth Annual Helicopter Safety Seminar
MidCoast Training Facility
Surviving on the Spirit of St Louis Airport
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AOPA Air Safety Foundation
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Airworthiness Safety Program Manager
1-800-322-8876 extension 4830