Part 145 Implementation

1
Part 145 Implementation

• David E. Cann, FAA

2
Repair Station Rule Update

• Published August 6, 2001
• Scheduled to go into effect April 6, 2003
• Training Requirement effective two years after
  rule implementation (April 6, 2005)

3
Implementation Update

• Implementation delayed 180 days to October 3,
  2003
• Training Program still goes into effect April 6,
  2005
• Current Part 145 rule remains in effect until
  October 3, 2003

4
Part 145 Guidance Status

• AC 145-MAN
• Disposition of Comments completed
• Final AC formatting in progress for sign-off
• FAA Inspector Guidance
• Five chapters included in FAA Order 8300.10
  revision
• Expect all comments to be incorporated by May 2003

5
FAA/Industry Presentations

• June 5 in conjunction with the Aircraft
  Electronics Association Regional Convention in
  Amsterdam, The Netherlands
• Collaborative Effort To
• Discuss the AC contents
• Provide a forum to ask questions
• Get both FAA Inspectors and Industry on the same
  track
• It is not to teach the rule or AC contents

6
FAA/Industry Presentations

• Open to both FAA inspectors and industry
  personnel
• Sponsored by several industry associations
• No convention registration needed
• No convention attendance fees
• Do not need to be an association member

7
Presentation Schedule

• May 16AWPNATA Convention, Las Vegas, NV
• June 5AEAAmsterdam, The Netherlands
• June 10ACEKansas City, KS
• June 17 18AALAnchorage, AK
• June 24ANEManchester, NH
• July 8AEATeterboro, NJ
• July 22ASWDallas, TX
• August 5AGLChicago, IL
• August 19ANMSeattle, WA
• September 2ANMSalt Lake City, UT

8
Transition to the Final Rule

• Rating Changes
• Limited Other rating has been eliminated
• Manufacturers Maintenance Facilities (MMF) have
  been eliminated
• Line Maintenance Authorization (not a rating)
• Assignment of an Accountable Manager
• Definitions different from JAR 145
• May not be the same person

9
Transition to the Final Rule

• Repair Station and Quality Control Manuals
• Must be submitted by October 3, 2003
• Acceptance is not needed for certificate holders
• FAA will notify repair stations of regulatory
  conflicts with manuals
• Exemptions will be eliminated
• Maintenance functions approved prior to
  contracting work to third party providers

10
Transition to the Final Rule

• 145.53 Issue of Certificate
• Provides that all persons who meet the
  requirements is entitled to a repair station
  certificate
• 145.53(a) applies to all repair stations except
  those identified in (b)
• 145.53(b) applies to repair stations outside the
  U.S. with which we have a BASA/MIP

11
Differences

• Between repair stations located within and
  outside the U. S. still include
• Demonstrate 145 certification is necessary
• Personnel certification requirements
• Renewal of air agency certificate
• Certification fees
• Drug and alcohol program requirement

12
Whats Ahead?

• Finalize inspector and industry guidance
• Revise repair station operations specifications
• Revise part 145.221, Reports of Failures,
  Malfunctions, or Defects
• Publish notice of proposed rulemaking to address
  a new rating system and the addition of a quality
  assurance program

13
FAA AFS-300 Contacts

• Diana L. Frohn, Manager, General Aviation and
  Repair Station Branch
• 202-267-7027
• diana.frohn_at_faa.gov
• Herb Daniel, Part 145 Rulemaking Team Leader
• 202-267-3109
• herbert.daniel_at_faa.gov
• Bill Henry, International JAA/EASA Issues
• 202-267-3804
• William.henry_at_faa.gov