Avionics News March 2015 - 12

In this monthly column, Ric Peri of the AEA's Washington, D.C., office, informs members of the latest regulatory updates.

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A EA V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS

Part 145 Manuals
I

've heard it all regarding Part 145 manuals, including
remarks such as "This is stupid, overwhelming and
redundant, and it compromises safety!"
Yes, it is a lot of work, especially, if you don't do it
right.
Part 145 manuals are a huge time burden for avionics
shops. But they can be managed if the industry underunder
stands the purpose of the manual, and writes and manages
the manual to the purpose.
Twice each year, the Aircraft Electronics Association
conducts a 40-hour training course on the design and
operation of a repair station to help the membership
start up a repair station, transfer ownership of a repair
station or just give it a tuneup.
A good portion of the training course focuses on the
regulations for the design, operation and management
of a maintenance business (the repair station), including
the maintenance standards, and finally, the maintenance
requirements of repair station customers. During the training course, the AEA certainly covers "what is required"
within the regulations. However, the AEA also spends
quite a bit of time on why the regulations require what
they do, and what the intended purpose is.
I recently had a conversation with an associate at an
aviation rulemaking committee meeting regarding the
value of the preamble to a proposed regulation, as well as
the preamble to a final rule. We were discussing the value
of a clear explanation of the purpose and intended outcome
of a proposed regulatory language. His position was that
the public "never reads that stuff," and they are wasted
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avionics news

march

2015

words - the technicians, as well as the authority inspectors,
only care about the regulatory language. I countered that I
spend a lot of time with the preambles because they define
the purpose and intended outcome of the regulation.
For example, the regulations require a repair station to
document, in a format acceptable to the Federal Aviation
Administration, the individual employee training
required by an approved repair station training program
(§ 145.163 (c)).
Part 145 manuals are a huge time burden for avionics
shops. But they can be managed if the industry
understands the purpose of the manual, and writes
and manages the manual to the purpose.

By initial viewing of this requirement, it would appear
the FAA (i.e. your local inspector) would determine the
format, or the forms to which you should keep your
records. When you look up the word format in the dictionary, Merriam-Webster defines it as, "The form, design
or arrangement of something," which thereby supports
the requirement that the FAA must approve your training
forms. However, Merriam-Webster further defines format
to mean, "A method of organizing data (as for storage)."
Certainly, either definition could be applicable; however,
you must go to the preamble of the regulation to determine
the intent of the regulatory authors. In this case, it is the
second definition; the means of storage rather than the
form of documentation.

Avionics News March 2015

Table of Contents for the Digital Edition of Avionics News March 2015