Part-specific training is not required for work performed under a repair station certificate, the FAA confirmed in response to an Aeronautical Repair Station Association (Arsa) request for clarification.
According to Sarah MacLeod, Arsa’s executive director, an Arsa member contacted the organization after receiving a Letter of Investigation from the FAA stating that his Part 145 repair station was required to use manufacturer part-specific training. “We requested clarification from the FAA and they told us there is no requirement for manufacturer training or even specific part number/dash number instruction,” MacLeod told AIN.
“The FAA concurred by saying, ‘[I]f a person understands the current instructions of the manufacturer, and the maintenance manuals, that person is not required to have specific part number/dash number articles.” Going one step further, the FAA Aircraft Maintenance Division reiterated its determination in a Memorandum.
Arsa has long maintained that Part 145 focuses on the knowledge and ability to perform tasks associated with the maintenance, preventive maintenance or alteration activity. Experience or training on similar methods, techniques and practices, tools, equipment, materials, systems, maintenance requirements and tasks are all relevant. The regulations do not demand the “whens and wheres” of the skills needed to perform specific tasks appropriately; they demand capability.
Misperception of § 145.157(a) led to the mistaken conclusion that the general privileges and limitations of § 65.81(a) applied to an individual authorized by a repair station to approve work for return to service. It was falsely reasoned that part-specific training was required based on the limitation of a certified mechanic. That individual “may not supervise the [work on], or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date….”
Arsa pointed out that the Part 65 certification requirement in § 145.157(a) is only a pre-requisite for granting authorization to approve work on articles for return to service. The Part 65 certificate is not issuing the approval for return to service; that certification is made under the repair station certificate.