New Part 145 takes effect this month
Attention repair station operators! You now have less than a month to ensure compliance with the new Part 145, and the Aeronautical Repair Station Association (ARSA) reports that a large percentage of you have yet to do so.
At a recent ARSA Part 145 training session at New Jersey’s Teterboro Airport, the association drew 42 participants, fewer than the 70 expected. Executive director Sarah MacLeod has long urged association members to take advantage of such opportunities and described the apparent lack of interest as “baffling.”
With some 4,000 FAA-certified repair stations worldwide, she noted in the association’s October newsletter that only about 700 people have attended the FAA-sponsored free training, “and about 160 of those were FAA employees.” ARSA began offering its training courses in early 2002.
It isn’t as though the new Part 145 just appeared without warning. There was considerable industry input before publication in August 2001. The draft guidance material has been available since July last year, and the original compliance deadline was extended from October last year to January 31 this year.
Some of the changes are relatively benign. Others have left repair-station operators shaking their heads in confusion, such as a requirement that supervisors, inspectors and persons in foreign countries approving articles for return to service must be able to read, write and understand English. But, MacLeod said, there is no requirement that they be able to speak English. In general, the new Part 145 is an extensive revision.
Among the major changes is the elimination of the old Appendix A that explained the equipment and materials that must be on the premises and under control of
the repair station. It has been replaced by the requirement for an FAA-approved maintenance control function list. It is, said MacLeod, one of the least understood of
The new Part 145 also requires the certification of more people at U.S. repair stations, including supervisors and individuals approving items for service. Currently, only those directly in charge of maintenance are required to be certified.
Further, each U.S. station must have a designated “accountable manager.” This is not a particularly popular change, but the FAA felt every facility should have a designated individual responsible for ensuring that operations conform with Part 145. The final regulation makes it clear that this individual is responsible for, and has authority over, repair-station operations, but does not have personal liability. The accountable manager is the FAA’s primary contact with the station.
There has been some objection to the wording in the new Part 145 that requires that a repair station “report any failure, malfunction or defect.” But MacLeod said that is expected to be rolled back to the original wording, which says “serious defects or other recurring unairworthy conditions” must be reported.
Among the most challenging aspects of the new Part 145 is the mandate to develop a repair-station manual that includes an organizational chart depicting the assigned areas of management, with duties, responsibilities and authority of each. The initial manual and subsequent revisions need only be provided to the FAA.
To comply with the new requirements, repair stations must also have an FAA-approved training program, signed off and in place by April 6 next year.
One change has been met with enthusiasm by repair station operators. It approves the use of electronic signatures, already a widespread industry practice.
While the final ARSA Part 145 training session was scheduled in Seattle on December 11, the association continues to provide assistance with regard to compliance. A Model Domestic Repair Station Manual, designed to help smaller domestic repair stations, is available to members at a cost of $250 and to non-members for $1,000. More details are available on the association’s Web site, www.arsa.org.
While ARSA executives might be disappointed by the lack of repair-station response to training sessions offered by the association and the FAA, the publicity generated has prompted an increase in membership. “We’ve seen a huge increase in membership over the past several months thanks to our activity in increasing awareness of the need to comply with the new regulations,” said ARSA associate attorney Catherine Depret. ARSA now has about 600 members.
But Depret emphasized that the education efforts are not about adding members. “Our primary mission is regulatory compliance, and along with that, the training necessary to comply.”
The new Part 145 is now the association’s focal point, and MacLeod made it clear that repair stations can pay now or they can pay later. The cost of the four-hour class or for the model repair station manual “is minuscule [compared with] the price you will pay on February 1 if you aren’t in compliance with the new rule.”