Avionics News March 2015 - 13

Remember, it is the business and the products it produces
that must meet the requirements of the applicable
regulations, not necessarily the manuals.

In the preamble to the 2001 Part 145 final rule, the
FAA documented its responses to questions asked during
rulemaking. In this case, a comment was received raising
concerns "regarding the content of the training records."
In answering this concern, the FAA responded as follows:
"The FAA notes that the language 'in a format acceptable
to the FAA' refers to the media by which the records will be
submitted, for example electronically." The preamble language clearly defines format with the focus on the "method
of organizing data." Addressing the content of the records,
the FAA further described its intent: "When submitting its
training program for approval, a repair station should delineate the items it intends to include in the records."
So the words of the regulations can be quite powerful.
Take our manuals - the repair station manual, the quality
control manual and the training manual - right? Wrong!
Actually, the repair station training program is a program,
not a manual. As such, it has uniquely different requirements. But more on that later. Let's focus on the two
manuals we are required to have: the repair station manual
and the quality control manual.
Part 145, Section 145.207 sets the basic requirements
for the repair station manual. When breaking the regulations down on the manual, you realize there are some
buried requirements. Contained within section 145.207, a
certificated repair station must:
1. Prepare a repair station manual.
2. Follow the repair station manual.
3. And the repair station manual must be acceptable to
the FAA.
Again, going back to the preamble discussion regarding
the Part 145 regulations, the FAA states:
The FAA has included in this final rule the requirement
that a repair station manual must be acceptable to the FAA.

Unlike the approval process, the FAA will not issue any
formal approval of the manual or revisions to the manual.
However, if the FAA determines that the manual itself or revisions of the manual are not acceptable, the FAA will notify
the repair station and the repair station must make appropriate changes to the manual. The FAA also states that, "The
manual may be in any format acceptable to the FAA, including but not limited to paper or electronic format."
FAA Advisory Circular 145-9 defines acceptable as "data
that meets the requirements of the applicable regulations."
Therefore, an acceptable manual is one that meets the regulations.
Section 145.207 further requires a repair station to:
1. Update its repair station manual so that it is current
and up to date.
2. Make the current repair station manual accessible for
use by repair station personnel required by subpart D
of this part.
The FAA notes that "the manual must be accessible to personnel when the work is being performed; therefore, a manual in a supervisor's office to which repair station personnel
do not have access while work is being performed would not
comply with this final rule."
And finally, section 145.207 requires a repair station to:
1. Provide to its certificate-holding district office the
current repair station manual.
2. Notify its certificate-holding district office of each
revision of its repair station manual.
3. Define the procedures the repair station will follow
for notifying its certificate-holding district office
of each revision of its repair station manual (§
145.209(j).
Continued on page 42

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Avionics News March 2015

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