ARSA CORNER
AN INTENSIVE LOOK AT PERSONNEL REQUIREMENTS FOR PERFORMING, SUPERVISING AND SIGNING OFF ON WORK UNDER 14 CFR PART 145.
BEYOND THE REPAIR STATION CERTIFICATE
Running a repair station? You’re going to need at least a little help … see what the rules say about who can do what in a 145: Part 43 establishes the rules
for persons that may perform maintenance, preventive maintenance, rebuilding or alteration work on civil aviation products and articles. For a repair station, § 43.3(e) provides that it may perform work in accordance with the provisions in Part 145. That means Part 145 will “rule” the work being performed as well as the qualifi cations of personnel planning, supervising, performing and issuing approvals for return to service on the repair station’s behalf (see § 145.151(b)). In general, § 145.151(c) requires that employees possess knowledge through training and experience to perform the assigned work. Additionally, § 141.151(d) and the repair station training program under § 145.163(b) require the company assess the capability and ability of all employees assigned maintenance functions to ensure compliance with Parts 43 and 145. Subpart D of Part 145 contains additional qualifi cations for specifi ed job functions. In other words, two job functions require the individual employee to have an appropriate certifi cate under part 65 — namely, supervisors and employees authorized to approve the repair station’s work
for return to service. The individual’s certifi cate is not the only or even the most important requirement. A repair station cannot depend upon the issuance of an individual certifi cate to comply with the general requirements in §§ 145.151 or 145.163(b).
Section 145.153 requires that
supervisors be appropriately certifi cated under Part 65 for the work being overseen. That section’s language makes clear that a supervisor will be overseeing the work of persons unfamiliar with their tasks; therefore, it follows that the supervisor must be familiar with how to accomplish the work. Employees who approve work
for return to service on behalf of the repair station must also hold a mechanic or repairman certifi cate issued under Part 65 — see § 145.157. While there are no other articulated qualifi cations for these individuals, they should know the regulations and be thoroughly familiar with the repair station quality system. Obviously, in order to obtain either a mechanic or repairman certifi cate, the individuals must meet the requirements of §§ 65.71 (for mechanics) and 65.101 (for repairmen). Understanding personnel and
certifi cation requirements is a foundational responsibility for repair
REGULATORY COMPLIANCE
TRAINING FROM ARSA Certifi cation and personnel requirements in 14 CFR Part 145 can be pretty dense. Let ARSA talk you through it with a selection from its on-demand training library:
PART 145 — FRIENDS IN
CERTIFICATED PLACES This session explores the maintenance personnel requirements in aviation safety regulations.
arsa.org/145-training-series
station directors of maintenance. Start in § 145.151 and journey across most of Title 14 in order to fi gure out who can do what in a maintenance facility.
Sarah MacLeod is managing member of Obadal, Filler, MacLeod & Klein, P.L.C. and a founder and executive director
of the Aeronautical Repair Station Association. She has advocated for individuals and companies on international aviation safety law, policy and compliance issues for 30 years.
Kimberly R. Villiers is an associate of Obadal, Filler, MacLeod & Klein, P.L.C. assisting with international aviation safety regulation compliance.
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DOMmagazine.com | dec 2016 jan 2017
BY SARAH MACLEOD, EXECUTIVE DIRECTOR & KIMBERLY R. VILLIERS, REGULATORY AFFAIRS COORDINATOR, AERONAUTICAL REPAIR STATION ASSOCIATION
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