FAA 145 Repair Station Audit Checklist

Repair stations must abide by FAA maintenance Special Conditions when operating as repair stations.

An individual in charge must be on hand at all times to supervise any work on articles affecting airworthiness, such as maintenance, preventive maintenance, alterations or inspections performed on them by noncertificated personnel or at stations that allow FAA inspection at any time.

1. Airworthiness Review
The FAA requires certified repair stations to implement quality systems and procedures that comply with Airworthiness Review requirements, and that ensure personnel have sufficient expertise to perform maintenance tasks assigned them. A system for evaluating personnel is necessary as a mechanism to identify any potential safety risks and address them accordingly.

Each Part 145 organization must maintain internal documents which outline its processes and procedures in accordance with FAA AC-145-9A. While each document may differ slightly depending on your business’s processes and procedures, each 145 company’s quality manual will also differ significantly.

Issues addressed in the NPRM include FAA’s proposal to require supervisors to speak English and their capability list requirements as well as regular audits. There was considerable discontent with proposed changes to ratings systems and transition processes, as well as any proposed modifications of ratings systems and transition processes.

2. Quality Assurance System (QAS)
Repair stations must establish and implement a quality assurance system (QAS) with documented procedures for tracking maintenance activities and measuring its effectiveness, and for certifying repairs (these should include verification of work orders as well as full lists of parts and materials used in repairs), as well as access to aircraft maintenance manuals and airworthiness directives for personnel working on aircraft.

Repair stations must establish procedures to ensure contractor-performed maintenance functions comply with EASA Special Conditions and 14 CFR Part 145. This should include contract agreements that outline the scope of works to be undertaken as well as require EASA-approved repair design data for their completion.

FAA ASIs and AA inspectors assigned to oversee repair stations with EASA approval as well as EASA/AA inspectors responsible for Sampling Inspection System (SIS) visits must receive initial training upon their oversight assignment as well as periodic recurrent training every two years. Training must include information about the Agreement, its annexes, the Maintenance Authorization Guidebook (MAG), any Special Conditions applicable and their implementation (such as any required amendments or special conditions).

3. Aircraft Maintenance Records (AMR)
AMR (Airworthiness Maintenance Reporting) is an integral component of an effective inspection. This process involves inspecting and evaluating repair station’s work to ensure it satisfies requirements, such as having in place quality assurance systems and using FAA approved data for repairs/alterations/modifications/modifications; additionally it also entails identifying and reporting unairworthy conditions.

The SIS team will perform an audit on AMR procedures used at an AA to ensure they comply with Agreement, Annex 2, and relevant regulations. Furthermore, they will assess whether an AMO is complying with its EASA Maintenance Special Conditions.

An AMO must provide documentation proving they have in place a written procedure for conducting preliminary inspections on aircraft prior to beginning repairs in order to identify any damage and conduct hidden damage inspections when preliminary inspections detect hidden damage. Furthermore, contracts should exist with noncertificated persons that allow FAA inspection of their work performed by noncertificated persons.

4. Training
The FAA requires repair stations to develop and implement a training program for their employees. This training must encompass all activities performed at the repair station as well as provide instruction for tasks that employees will likely perform when performing maintenance on aircraft.

Repair stations must include in their contracts with noncertificated personnel an agreement to allow FAA inspection and monitoring of maintenance functions at the facility, so as to ensure noncertificated personnel have all of the knowledge and capabilities to complete repairs in a safe and efficient manner.

EAA and GAMA both expressed concerns with the NPRM’s proposal that requires repair stations to submit details about their training programs for FAA approval, creating an unnecessary regulatory burden. They requested the FAA retain existing language requiring such programs be approved by EASA instead.