Rebluing the FAA’s New Guide for Repair Station and Quality Control Manuals BY CAROL E. GILES M embers of the armed forces, notably the U.S. Air Force (USAF), as well as owners of firearms, are familiar with the term “rebluing.” Rebluing, a term that orig- inated with firearms, is the process used to restore the protective coating that prevents a firearm from rusting. For the USAF, whose mem- bers wear the color of the sky, rebluing is meant to convey con- tinuing military education, fol- lowing professional standards, and reaffirming core values. Rebluing, to me, as a veteran of both the Army and the FAA, is keep- ing pace with the times, correcting inconsistencies, and maintaining a focus on continuous improvement. The term came to me when I reviewed the FAA’s Oct. 6, 2017, Advisory Circular 145-9A Guide for Developing and Evaluating Repair Station and Quality Control Manuals. Aviation Business Journal | 4th Quarter 2017 The Advisory Circular (AC) pro- vides information to repair station certificate holders and applicants on how to develop and evaluate a Repair Station Manual (RSM) and Quality Control Manual (QCM). As with any FAA AC, it describes an acceptable means, but not the only method, to develop a manual and comply with the regulations. The guide, like the intent of rebluing, has improved; but it also has a few opportunities for clari- fication, which I’ll address in this article. The overall revision of the AC is a good step toward correct- ing inconsistencies and demon- strates continuous improvement on the part of the regulator. For the most part, the new AC’s content is the same as its predeces- sor AC 145-9 Chg. 1. Yet, the big- gest difference in the new guide is the lack of document control and revision status. There is no page control sheet or any other method that lists what pages have been revised. In addition, revision bars are lacking throughout the document. This omission is a valid concern, since indicating revisions is a stan- dard process in document develop- ment. Furthermore, this is the same process required by the FAA of its applicants and certificate holders. Obviously, this makes it difficult for the reader to understand what was revised and sends the message: “Do as I say, not as I do.” It is my hope that this omission was due to an oversight and the FAA will see the error and correct it with a revi- sion—sooner, rather than later. A minor change involves restructuring the outline and paragraph numbering; however, Continued on page 62 61
