Notation 7215: The National Transportation Safety Board has reviewed the Federal Aviation Administration's (FAA) notice of proposed rulemaking (NPRM), "Part 145 Review: Repair Stations," which was published in the Federal Register, Volume 64, No. 118, on June 21, 1999. The FAA proposes to update and revise the regulations for repair stations. According to the NPRM, this action is necessary because many portions of the current repair station regulations do not reflect changes in repair station business practices and aircraft maintenance practices, or advances in aircraft technology.
In general, the Safety Board agrees with the FAA that to ensure that the regulations are appropriate for today's repair station industry, Part 145 should be extensively revised. Where possible, the Safety Board's specific comments are organized by sections to correspond with sections in the NRPM. However, in some instances, the Board's comments extend across several sections of the NPRM.
Manufacturers' Maintenance Facilities
The FAA proposes to eliminate the "limited" ratings for manufacturers and to require that these facilities obtain the appropriate repair station certification. These ratings had previously been granted to allow manufacturers to perfoml maintenance on articles manufactured by them. However, manufacturers' systems for inspection, recordkeeping, and quality control vary considerably from those used by repair stations.
Because maintenance practices and aircraft technologies have evolved since the establishment of limited ratings for manufacturers, the FAA has detern1ined that all repair facilities' systems for inspection, recordkeeping, and quality control should be consistent, and that the issuance of limited ratings for manufacturers is no longer appropriate. The Safety Board concurs with this proposed revision to Part 145.
Deviation Authority
The FAA proposes to include deviation authority to provide flexibility to operations subject to Part 145 that may be safely or satisfactorily conducted as an alternative means of compliance with portions of Part 145. The FAA further indicates that if deviation authority is granted, the FAA would require that operations be conducted to certain conditions and limitations and these would be placed in the Operations Specifications.
Without specific criteria, or examples of the types of conditions or limitations'that would be imposed, the Safety Board questions the practicality of this section of the proposed rule or how consistency in granting deviation authority can be assured. Further, the Safety Board questions the basis for the FAA's contention that limited deviations would be sought and that letters of deviation authority would likely be limited in scope. The Safety Board does not support the inclusion of deviation authority, as currently written, in the final rule.
Ratings and Classes
The FAA proposes to revise the ratings and classes that can be issued to certificated repair stations. In response to the FAA's request for comments as to whether ratings and classes should be prescribed in a separate regulation, the Safety Board believes that the proposed system of ratings and classes can be appropriately prescribed in the proposed revisions to Part 145. The Safety Board supports the proposed revisions to ratings and classes, and specifically the establishment of a new rating for computer systems to account for the technological developments and advances in aircraft design and manufacturing.
However, the Safety Board has expressed concerns in the past about how ratings and classes are applied, the interpretation of those ratings by the FAA, and, as a result, repair stations performing maintenance that exceeds the authority of their rating. The proposed ratings and classes provide no better guidance to certificate holders and FAA inspectors than the current ratings and classes in terms of what ratings are required for specific repair station work.
In its report of the uncontained engine failure/fire of ValuJet Airlines flight 597 in Atlanta, Georgia, on June 8,1995, the Safety Board concluded that the Operations Specifications of the repair station that performed maintenance on the failed engine could reasonably have been read to indicate that the repair station did not have authority under Part 145 to overhaul the type of engine that it did overhaul and that ultimately failed.
The Safety Board asked the FAA in Safety Recommendation A-96-78 to review the air agency certificates and repair station Operations Specifications of all repair stations and ensure that the language used in the Operations Specifications clearly indicates the extent of the repair station's authority. In response to this recommendation, the FAA issued Flight Standards Information Bulletin for Airworthiness 97-17A, "Certificate and Operations Specifications Evaluation of Limited Specialized Services Rated Repair Station."
The bulletin directed principal inspectors to review the Operations Specifications and certificate to determine if the Operations Specifications were appropriate for the rating that had been issued. The review found that 53 repair stations were operating beyond their certificate privileges, 134 repair station Operations Specifications were reissued, 16 repair stations were recertified, and 108 repair stations received rating changes. Although the discrepancies uncovered by this review were corrected, the findings suggest a lack of consistency in how ratings are applied.
The Safety Board suggests that given the proposed revisions to ratings, the opportunity exists for the FAA to provide better guidance to certificate holders and inspectors regarding what ratings are required for specific repair station work. Using the organizational structure of Appendix A: Job Functions, the FAA could prepare a master list of the maintenance capabilities, by make and model of part or article, on which those functions can be performed. Such a list, published as an advisory circular and as a supplement to FAA Handbook 8300.10, would ensure a more consistent application of ratings to maintenance operations.
It would also serve as a reference for the FAA certificate holding district offices (CHDO), which will continually be evaluating changes to capability lists.
An example that illustrates the Board's concern in this area is the maintenance of flight data recorders (FDRs). Most repair stations perfornling maintenance on FDRs currently work under a "limited rating for specialized service." The Safety Board's experience with FDRs indicates that some of these maintenance facilities do not possess the necessary special testing equipment and software to properly maintain the FDRs. Specific guidance is not provided in the proposed regulations as currently written. The Safety Board urges the FAA to include "inspect, test, and validate flight data recorders" in Appendix A: Job Functions.
A repair station should also be required to list flight data recording equipment, by make and model, in its capability list.
Further, principal maintenance inspectors should be provided better guidance concerning the rating appropriate for maintenance, preventive maintenance, or alteration of FDRs.
Repair Station Manual, Quality Assurance, and Capability List
In general, the Safety Board concurs with the proposed revisions to these sections that require repair stations to (1) maintain an approved repair station manual that covers all of the repair station's technical operations, (2) establish quality assurance systems to ensure that maintenance, preventive maintenance, or alterations (including the maintenance and alterations performed by a repair station's contractors) are consistently performed in accordance with all applicable requirements, and (3) maintain a capability list that would specify all articles on which the repair station is capable of performing work.
Under the proposal, prior to working on an article, a repair station woul