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Part 145 Implementation. David E. Cann, FAA. Repair Station Rule Update. Published August 6, 2001 Scheduled to go into effect April 6, 2003 Training Requirement effective two years after rule implementation (April 6, 2005). Implementation Update.
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Part 145 Implementation David E. Cann, FAA
Repair Station Rule Update • Published August 6, 2001 • Scheduled to go into effect April 6, 2003 • Training Requirement effective two years after rule implementation (April 6, 2005)
Implementation Update • Implementation delayed 180 days to October 3, 2003 • Training Program still goes into effect April 6, 2005 • Current Part 145 rule remains in effect until October 3, 2003
Part 145 Guidance Status • AC 145-MAN • Disposition of Comments completed • Final AC formatting in progress for sign-off • FAA Inspector Guidance • Five chapters included in FAA Order 8300.10 revision • Expect all comments to be incorporated by May 2003
FAA/Industry Presentations • June 5 in conjunction with the Aircraft Electronics Association Regional Convention in Amsterdam, The Netherlands • Collaborative Effort To— • Discuss the AC contents • Provide a forum to ask questions • Get both FAA Inspectors and Industry on the same track • It is not to teach the rule or AC contents
FAA/Industry Presentations • Open to both FAA inspectors and industry personnel • Sponsored by several industry associations • No convention registration needed • No convention attendance fees • Do not need to be an association member
Presentation Schedule • May 16—AWP—NATA Convention, Las Vegas, NV • June 5—AEA—Amsterdam, The Netherlands • June 10—ACE—Kansas City, KS • June 17 & 18—AAL—Anchorage, AK • June 24—ANE—Manchester, NH • July 8—AEA—Teterboro, NJ • July 22—ASW—Dallas, TX • August 5—AGL—Chicago, IL • August 19—ANM—Seattle, WA • September 2—ANM—Salt Lake City, UT
Transition to the Final Rule • Rating Changes • Limited “Other” rating has been eliminated • Manufacturer’s Maintenance Facilities (MMF) have been eliminated • Line Maintenance Authorization (not a rating) • Assignment of an Accountable Manager • Definitions different from JAR 145 • May not be the same person
Transition to the Final Rule • Repair Station and Quality Control Manuals • Must be submitted by October 3, 2003 • Acceptance is not needed for certificate holders • FAA will notify repair stations of regulatory conflicts with manuals • Exemptions will be eliminated • Maintenance functions approved prior to contracting work to third party providers
Transition to the Final Rule • 145.53 Issue of Certificate • Provides that all persons who meet the requirements is entitled to a repair station certificate • 145.53(a) applies to all repair stations except those identified in (b) • 145.53(b) applies to repair stations outside the U.S. with which we have a BASA/MIP
Differences Between repair stations located within and outside the U. S. still include: • Demonstrate 145 certification is necessary • Personnel certification requirements • Renewal of air agency certificate • Certification fees • Drug and alcohol program requirement
What’s Ahead? • Finalize inspector and industry guidance • Revise repair station operations specifications • Revise part 145.221, Reports of Failures, Malfunctions, or Defects • Publish notice of proposed rulemaking to address a new rating system and the addition of a quality assurance program
FAA AFS-300 Contacts • Diana L. Frohn, Manager, General Aviation and Repair Station Branch • 202-267-7027 • diana.frohn@faa.gov • Herb Daniel, Part 145 Rulemaking Team Leader • 202-267-3109 • herbert.daniel@faa.gov • Bill Henry, International JAA/EASA Issues • 202-267-3804 • William.henry@faa.gov