Rebluing the FAA’s New Guide for Repair Station and Quality Control Manuals Continued from page 61 this should not be a showstop- per for using AC 145-9A. Moving to content, the most significant change addresses a long-standing item on industry’s wish list—guidance regarding work performed at another location. As you may know,14 CFR 145.203 allows a repair station to temporar- ily transport material, equipment, and personnel to a place other than the repair station’s fixed location to perform maintenance if the work is necessary due to a special circum- stance or necessary to perform on a recurring basis. In both instances, the repair station’s manual must include procedures for accomplish- ing maintenance at a place other than the repair station’s fixed location. Both the revised AC and the previ- ous version contain guidance and procedures on how to comply with this regulation. However, this revision goes into much greater detail and addresses the use of mobile main- tenance units, an approach that has been around for the last decade. The AC defines these units as “a vehicle deployed by the repair station to transport people, materials, equip- ment, and data from one location to another.” The AC also defines mobile field service as “repair station per- sonnel, materials, equipment, tools, deployed to perform work away from the fixed location for a special circum- stance or on a reoccurring basis.” In the past, the use of mobile maintenance units was not allowed consistently across the United States, which makes this revision a posi- tive step in providing clearly-defined means to comply with the regulation. Even when mobile units were allowed, a prior inconsistency was the interpretation of CFR 145.203, which states “temporarily transport.” Neither the regulation nor preambles define or describe what the FAA means by “temporarily transport,” which created a point of conten- tion between industry and the FAA. With this revision, the FAA defines “temporary/temporarily” as an arrangement without permanency lasting for a limited time. Also, there is a note below this definition that informs the reader that the FAA’s use of the word “temporarily” in the regulation does not mean an unspeci- fied return to base frequency. Importantly, mobile mainte- nance units must not be used in a way that results in continuous uninterrupted operation at another fixed location. If that is the case, the repair station should apply for a satellite or a new certificate. Another improvement is link- ing procedures and guidance to the Safety Assurance System (SAS) Data Collection Tools (DCT) that the FAA uses to conduct its certification projects and oversight. While I did not do a side-by-side comparison of the new AC with the DCT ques- tions (there are approximately 300 questions), I have completed count- less DCTs as part of certification projects and audits and recognize those types of questions well. Another indication that the FAA based the AC on the SAS DCT ques- tions can be found in the Sample Procedure Format Paragraph 2.4. In this paragraph, the FAA provides sample procedures that can be used when describing the preliminary 62 inspection process. The sample specifically refers to interfaces and process measures that are directly related to the SAS questions and the FAA’s safety assurance concepts. Other parts of the AC are inconsis- tent when it comes to ensuring that the content in this document aligns with other FAA Orders and ACs. As the FAA says, this requires “manag- ing the interfaces between docu- ments.” For example, in AC 145-9A, the FAA defines traceability as the ability to verify the history, location or application of an item by means of documented recorded identifica- tion. On the other hand, AC 20-154 Guide for Developing a Receiving Inspection System for Aircraft Parts and Materials defines traceability as “the ability to establish that a part or material was manufactured under Part 21, or previously deter- mined to be airworthy under Part 43.” I recommend the FAA revisit the definition found in the new AC and match it with the one in AC 20-154. There are few other areas where the FAA is not as consistent as it could be. Finding them all might be a good task for a long winter’s night. Yet, at the end of the day, AC 145-9A is a good first start to align advisory material with SAS and to provide the industry some useful examples to help with reblu- ing procedures and manuals. Carol E. Giles is President of The Giles Group, global aviation consultants. Previously, Giles led the FAA’s aviation maintenance division. Aviation Business Journal | 4th Quarter 2017
