Good Morning,

I’ve recently been informed that we will have to maintain a dedicated area for repair station activities and that this area will need to be identified in our manual. I was shown examples of how a couple of places accomplish this and most look like a plant layout with different shading or whatever to identify the R&O areas.

My problem is that we repair ballscrews and other items for dozens of industries. We also manufacture new products for just as many industries. We make ballscrews, acme lead screws, spindles, special toolholding devices, reverser screws, etc. So I’m being told that we have to physically separate our facility as if the Repair Station is its own “company”. The problem is we need to use the same areas and equipment to do FAA work as we do any other work.

We are a shop full of mills, lathes, thread grinders, OD, ID and surface grinders. Then we have receiving; where we receive everything – repair evaluations whether they’re ballscrew or acme lead screws or a churning auger – and whether it’s FAA work or some guy whose machine crashed and they found us in the phone book. We only have one receiving area – can I just show how we identify and delineate FAA work from others when the repair evaluations are being logged in?

We will then send the item to the tear down area – which is a couple of benches and a parts washing tank outside of the assembly room. Do I really need to designate a bench as FAA only? Can I just show you how we identify FAA work as such so that our tear down guys know not to tear it down because “John” is the only one who is authorized to tear down FAA work?

Then there’s the assembly room – which is a room full of benches with an assembler at each. Whether the ballscrew is manufactured new or a repair, it’s assembled in this room. Again, can I show you how we ensure that only a designated employee will assemble the unit – or do I really have to have a physically separate area or bench for FAA work only?

I’m not sure if any of the FAA Repair Station work we receive will allow for machining/altering, but if it does, then what do I do about that? How do I “completely physically separate” the manufacturing from the repair – and further separate regular repairs from FAA repairs – when we need to use the same areas and equipment for all of it?

I’ve heard we have to separate our facility from a few people, but none of them has a specialized limited rating – they have class ratings – does that make a difference?

Thanks for your time – again!
Cari

OK, y'all - I've started this thread because this issue was brought to my attention in another thread and I'd like to specifically address this in it's own.

The above is a transcript of the email I sent to an FAA Inspector I know - it repeats most of what I posted in the other thread. He may or may not become our guy when we apply for certification, but he's been very helpful to me while I'm learning all of this stuff. He sometimes takes quite a while to reply, but he always does, and when he does I will post his reply here. In the mean time - thoughts anyone?

I work for a repair station and the way we have always handled the FAA/Non FAA issue is, we processes all customers parts the same. That has worked at 2 of the facilities I have worked for.

Do you have a current floor plan you can share with us?
Good Morning,

I’ve recently been informed that we will have to maintain a dedicated area for repair station activities and that this area will need to be identified in our manual. I was shown examples of how a couple of places accomplish this and most look like a plant layout with different shading or whatever to identify the R&O areas.

My problem is that we repair ballscrews and other items for dozens of industries. We also manufacture new products for just as many industries. We make ballscrews, acme lead screws, spindles, special toolholding devices, reverser screws, etc. So I’m being told that we have to physically separate our facility as if the Repair Station is its own “company”. The problem is we need to use the same areas and equipment to do FAA work as we do any other work.

We are a shop full of mills, lathes, thread grinders, OD, ID and surface grinders. Then we have receiving; where we receive everything – repair evaluations whether they’re ballscrew or acme lead screws or a churning auger – and whether it’s FAA work or some guy whose machine crashed and they found us in the phone book. We only have one receiving area – can I just show how we identify and delineate FAA work from others when the repair evaluations are being logged in?

We will then send the item to the tear down area – which is a couple of benches and a parts washing tank outside of the assembly room. Do I really need to designate a bench as FAA only? Can I just show you how we identify FAA work as such so that our tear down guys know not to tear it down because “John” is the only one who is authorized to tear down FAA work?

Then there’s the assembly room – which is a room full of benches with an assembler at each. Whether the ballscrew is manufactured new or a repair, it’s assembled in this room. Again, can I show you how we ensure that only a designated employee will assemble the unit – or do I really have to have a physically separate area or bench for FAA work only?

I’m not sure if any of the FAA Repair Station work we receive will allow for machining/altering, but if it does, then what do I do about that? How do I “completely physically separate” the manufacturing from the repair – and further separate regular repairs from FAA repairs – when we need to use the same areas and equipment for all of it?

I’ve heard we have to separate our facility from a few people, but none of them has a specialized limited rating – they have class ratings – does that make a difference?

Thanks for your time – again!
Cari

OK, y'all - I've started this thread because this issue was brought to my attention in another thread and I'd like to specifically address this in it's own.

The above is a transcript of the email I sent to an FAA Inspector I know - it repeats most of what I posted in the other thread. He may or may not become our guy when we apply for certification, but he's been very helpful to me while I'm learning all of this stuff. He sometimes takes quite a while to reply, but he always does, and when he does I will post his reply here. In the mean time - thoughts anyone?

...the way we have always handled the FAA/Non FAA issue is, we processes all customers parts the same.
Thank you - this is exactly what I mean. I couldn't possibly take a corner or one room and make it "the" repair station. The FAA repairs will be processed and routed through the shop just like other repairs - though they will be clearly identified as work that must comply with Part 145 (right now we use yellow tags for customer owned repair items - we'll use a different color tag for FAA items). Routers will stipulate "certificated repairman only" and stuff like that - just a lot more control.

This was what I understood to be acceptable from a couple of sources - so I was just going to include our floorplan or whatever in the manual - the whole building is the repair station but we do other stuff too.

Muleskinner - I'll check with the Plant Manager and see if he's done with it yet.

Cari, we just received certification as a repair station (mostly machining engine parts). We DID NOT have to separate facilities or activities (we use the same machines for FAA repairs as for everything else). A few areas required specific identification on our floor plan, i.e. preliminary inspection area, controlled materials inventory, ready for shipment, NC Articles holding. But that was it. I don't recall every seeing or being told of a requirement for separate facilities.

Cari, we just received certification as a repair station (mostly machining engine parts).
CONGRATULATIONS!! I didn't know you guys were becoming certificated.

A few areas required specific identification on our floor plan, i.e. preliminary inspection area, controlled materials inventory, ready for shipment, NC Articles holding...I don't recall every seeing or being told of a requirement for separate facilities.
I was googlin' for repair station manuals not too terribly long ago and saw some of them had floorplans with R&O areas identified. I checked on it back then and was told exactly what you just posted - we would have to clearly identify certain areas but we did not have to have physically separate "manufacturing" and "R&O" - or "FAA" and "non-FAA" - areas.

THANK YOU!

Cari, we just received certification as a repair station (mostly machining engine parts). We DID NOT have to separate facilities or activities (we use the same machines for FAA repairs as for everything else). A few areas required specific identification on our floor plan, i.e. preliminary inspection area, controlled materials inventory, ready for shipment, NC Articles holding. But that was it. I don't recall every seeing or being told of a requirement for separate facilities.

Yes, common machine/shop areas with specifically IDENTIFIED repair station areas where determination of 'Continued Airworthiness' is conducted.

Yes, common machine/shop areas with specifically IDENTIFIED repair station areas where determination of 'Continued Airworthiness' is conducted.
Not sure why you capatalized that word - identification of certain areas was never my debate. In the other thread you said "clearly defined SEPARATION of facilities". I said "We don't need to SEPARATE our facility". A few people chimed in that they were required to have R&O physically SEPARATED from manufacturing in their facility and clearly identify these areas in their manual. Nothing is separate here. The inspection room is where we will determine "continued airworthiness" of FAA repairs - and will be identified as such, but it's also where we perform final inspection of non-FAA repairs and new/manufactured products.

If you are doing manufacturing in the same area as service it may become a problem for any particular FISDO. This must be open to interpretation because they fall down on this issue differently (from one FISDO to another). My experience with MIDO (the manufacturing inspectors for FAA) is the same. I have some clients who do both manufacturing and maintenance at the same bench but not at the same time. The same guy services and manufactures. In this case he either does one or the other. In this case I built their 145 to reflect the service at this location (after all this is FISDO's focus). The same company has a PMA business. The MIDO preference was a seperate work area for the assembly. However, all of the other areas were common. Again I think MIDO may vary on this. If you are going to have MIDO looking at you for PMA type parts then you may want to consult with them first. Your MIDO or you FISDO may be open to work in the same area like the one I used here as an example.

This must be open to interpretation because they fall down on this issue differently (from one FISDO to another).
Perhaps this is the case. Do your clients you're referring to have class ratings, or limited ratings? Do they process manufacturing work differently than repair work? Do they have any non-FAA work?

Maybe these are the things an Inspector considers when he is determining whether or not to have a place separate their facilities. BTW - where can I find this separation of facilities requirement - is it documented somewhere - did I miss it in Part 145 - I'm skimming through it now - or the AC?

We had dedicated personnel to do Teardown, Overhaul and Repair of electronic assemblies (accessories) in a dedicated area of our Limited Rating Repair Station. They were free to use any of the manufacturing equipment or facilities, but they were the only ones who performed the R&O work. This limited the personnel listed on the roster and in the Drug & Alcohol Prevention Program. Of course they were available to help out in manufacturing, if needed. Usually the R&O business would help us meet our $$$s at the end of the month.

Hi Cari,

The example I used came from a repair station that has both class and limited ratings. They do not repair or manufacture "non FAA" related parts. I don't believe you will find anything about separation of facilities in the 145 or the AC145-9. This repair station does not manufacture under Part 145, they will manufacture under Part 21 (Certification Procedures for Products and Parts) which is where PMA parts are covered. Manufacturing under this rule is a different ball game. It takes a separate manual actually called a Fabrication Inspection System Manual (for PMA) I just finished up one and it was approved this past week. Manufacturing is MIDOs ball game not the same inspector who survieils your repair facility (even though they may be in the same physical location). Even in that scenario, I think separation of facilities may be up for grabs.

Hi Cari,

In your thread starter, you asked for thoughts. I was unaware that you were looking for debate. :)

I was quoting Rob Nix:

A few areas required specific identification on our floor plan, i.e. preliminary inspection area, controlled materials inventory, ready for shipment, NC Articles holding.

I said, Yes, common machine/shop areas with specifically IDENTIFIED repair station areas where determination of 'Continued Airworthiness' is conducted.

I might have better communicated my thoughts regarding what Rob had offered if I had stated something like this:

Yes, what Rob described as being his experience, is what is currently required by our repair station PMI.

While maintaining common machine/shop areas as they are, you might consider identifying specific repair station areas where determination of 'Continued Airworthiness' is conducted.

Just a thought. :)

p.s. You certainly have your hands full Cari. I did not intend to muddy the waters. :o

IMO you are getting solid information from Rob, Al and Blue Tuna. :applause:

Not sure why you capatalized that word - identification of certain areas was never my debate. In the other thread you said "clearly defined SEPARATION of facilities". I said "We don't need to SEPARATE our facility". A few people chimed in that they were required to have R&O physically SEPARATED from manufacturing in their facility and clearly identify these areas in their manual. Nothing is separate here. The inspection room is where we will determine "continued airworthiness" of FAA repairs - and will be identified as such, but it's also where we perform final inspection of non-FAA repairs and new/manufactured products.

I don't believe you will find anything about separation of facilities in the 145 or the AC145-9.
Thanks everyone. If this is not a documented regulation, then I'm thinking it is up to the Inspector to decide if there are risks associated with not separating the facility.

Tammy and Rob's repair stations seem to be closer to the type of place we are and amount of FAA work that we will do. The people I called with this question are suppliers of ours that are Part 145 Repair Stations - one is our NDT source and the other is a Ti-coating place - both told me that they did not have to have separate/dedicated areas, they just had to have a layout of the facility in their manual. They both said pretty much what Tammy did - they handle the FAA work just like any other work.

I wish I could invite you all out here for a little tour so you all could see the set up. I'll be sure to let you guys know what my Inspector buddy says. Like I said - he may not be our Inspector, but he works out of the office we will send our application to - so he's as close to the horse's mouth as I can get at the moment.

This limited the personnel listed on the roster and in the Drug & Alcohol Prevention Program.
LOL - Watch for the next thread I start. I've been composing my thread starter - lots of questions about who should be included on the rosters and the Drug & Alcohol Prevention Program.

LOL - Watch for the next thread I start. I've been composing my thread starter - lots of questions about who should be included on the rosters and the Drug & Alcohol Prevention Program.Cari, I'm waiting with bated breath.;)

I was unaware that you were looking for debate. :)
I'm not - I meant I'm debating whether or not to go tell my boss we need a separate area specifically designated for FAA repairs.

You certainly have your hands full Cari. I did not intend to muddy the waters.
Perish the thought - this is the kind of stuff I want to find out about before we bring out an Inspector. If everyone has different situations, then I think I need to investigate further than I did a few months ago. The more I know prior to applying - the smoother our certification process will go.

If I can help you with info just let me know :)

This is the most current floor layout we've got. Our Plant Manager has been working on it because we've sold, bought and rearranged so many machines since this was drawn. For example - we have 3 Fadal CNCs now and sold the Haas, we have 3 CNC Lathes now and we have a huge Mazak 5-axis machining center. Now we've started the process of adding on to the building - we are getting proposals right now.

PS - the third doorway from the top in the front office area is my office door.

This is the most current floor layout we've got. Our Plant Manager has been working on it because we've sold, bought and rearranged so many machines since this was drawn. For example - we have 3 Fadal CNCs now and sold the Haas, we have 3 CNC Lathes now and we have a huge Mazak 5-axis machining center. Now we've started the process of adding on to the building - we are getting proposals right now.

PS - the third doorway from the top in the front office area is my office door.
Floor plan looks good. Machine upgrades and building additions... :) hmm!... sounds like Cari's organization is on the grow. Great! I've reread your original post in this thread.
I’ve recently been informed that we will have to maintain a dedicated area for repair station activities and that this area will need to be identified in our manual. I was shown examples of how a couple of places accomplish this and most look like a plant layout with different shading or whatever to identify the R&O areas.
My FAA Inspector requires we identify, in our manual, dedicated area within the facility for all repair station activities. The floor plan must be current at all times. We have some areas, machining in fact (for making tooling for in-house use only), that are not part of the repair station, and are identified in our floor plan as non-repair station areas. In the manuals floor plan, the non-repair station areas are identified as such, and the physical areas in the various shop locations have yellow painted lines/squares on the floor. We also have limited access rooms and in some cases chained-link fences in shop areas.

Every FAA Inspector must follow Airworthiness Inspector's Handbook 8300.10 - Volume 2 (http://www.faa.gov/avr/afs/faa/8300/8300_vol2/2_162_00.pdf) Chapter 162. Procedures For Certificating Part 145 Repair Stations/Satellites Located Within The United States And Its Territories. Additionally, every FAA Inspector I've ever met and dealt with over the years, has their own unique comfort zone when making Repair Station Approval for Certification. Attaining a FAA Part 145 Air Agency Certificate can be a daunting task. Everything must stack up to regulatory requirement and the unique comfort zone of the FAA Inspector who is expected to put his/her inked signature to the approval. I have yet to hear of an FAA Inspector who has cut a repair station applicant some slack because of size, limited rating or specialized service.

I am a member of Aeronautical Repair Station Association (http://www.arsa.org/) and have attended their Annual Repair Symposium for many years. These Symposiums are action packed. During breaks and evening hours we compare notes with fellow repair station operators. You might want to visit their sight.

On our FAR art 145 Air Agency Certificate and Operations Specifications we have a combination of Class Ratings, Limited Ratings and Specialized Services.

No doubt applications of the rule of separation of facilites may vary from one facility to another, it is really a matter of what your FAA inspector rules on in the matter. I have clients across the U.S. and each region varies to some degree. There is nothing that replaces understanding what your particular FAA inspector is looking for. I have gone to bat for some clients who were right on with the regulations only to meet an inspector who would not budge.

Floor plan looks good. Machine upgrades and building additions... :) hmm!... sounds like Cari's organization is on the grow.
Boy Howdy!! I've been here close to 5 years - we've never been busier. Once the Plant Manager is done revising and I've added a bunch of identification, I'll post it again.
In the manuals floor plan, the non-repair station areas are identified as such, and the physical areas in the various shop locations have yellow painted lines/squares on the floor. We also have limited access rooms and in some cases chained-link fences in shop areas.
This is what concerns me. There won't be any areas that aren't "non-repair station". In the other thread where Paula posted here floor layout, she had gray shaded areas that were dedicated repair station areas, white areas that were non-repair station areas, and then gray and white checked areas where both occurred. If I used her scheme, my whole floor would be gray and white checked. See what I mean?

What do you guys repair and what is your non-repair station work? What is in your limited access rooms and fenced in areas?

Are your products/processes similar to ours at all?

Every FAA Inspector must follow Airworthiness Inspector's Handbook 8300.10 - Volume 2 (http://www.faa.gov/avr/afs/faa/8300/8300_vol2/2_162_00.pdf) Chapter 162. Procedures For Certificating Part 145 Repair Stations/Satellites Located Within The United States And Its Territories. . . I have yet to hear of an FAA Inspector who has cut a repair station applicant some slack because of size, limited rating or specialized service.
I read the whole thing - I still don't see a requirement to physically separate our facility. Others have stated they do not have to and are already certificated. I don't think they were cut slack - I think that there wasn't any reason for their Inspector to require it based on what they are doing.

I read the whole thing - I still don't see a requirement to physically separate our facility. Others have stated they do not have to and are already certificated. I don't think they were cut slack - I think that there wasn't any reason for their Inspector to require it based on what they are doing.

:mg: WOW! You read the whole thing?! I better get started then, I have been meaning to dig into that Handbook, not just Chapter 162.

Every Inspector is different in all aspects of this business, some things are just done in accordance with their interpretation of the requirements.

Cari, what ever your doing, it seems to be working! :applause:

The requirement is not specifically stated, but look at 145.35 (b)(6) in the old regulations. Sec. 145.35 Housing and facility requirements.

(a) An applicant for a domestic repair station certificate and
rating, or for an additional rating, must comply with paragraphs (b) to (h) of this section and provide suitable--
(1) Housing for its necessary equipment and material;
(2) Space for the work for which it seeks a rating;
(3) Facilities for properly storing, segregating, and protecting materials, parts, and supplies; and
(4) Facilities for properly protecting parts and subassemblies
during disassembly, cleaning, inspection, repair, alteration, and
assembly;
so that work being done is protected from weather elements, dust, and
heat; workers are protected so that the work will not be impaired by
their physical efficiency; and maintenance operations have efficient and
proper facilities.

(b) The applicant must provide suitable shop space where machine
tools and equipment are kept and where the largest amount of bench work
is done. The shop space need not be partitioned but machines and
equipment must be segregated whenever--
(1) Machine or woodwork is done so near an assembly area that chips or material might inadvertently fall into assembled or partially assembled work;
(2) Unpartitioned parts cleaning units are near other operations;
(3) Fabric work is done in an area where there are oils and greases;
(4) Painting or spraying is done in an area so arranged that paint or paint dust can fall on assembled or partially assembled work;
(5) Paint spraying, cleaning, or machining operations are done so near testing operations that the precision of test equipment might be affected; and
(6) In any other case the Administrator determines it is necessary.

(c) The applicant must provide suitable assembly space in an enclosed structure where the largest amount of assembly work is done. The assembly space must be large enough for the largest item to be worked on under the rating he seeks and must meet the requirements of paragraph (a) of this section.
(d) The applicant must provide suitable storage facilities used exclusively for storing standard parts, spare parts, and raw materials, and separated from shop and working space. He must organize the storage facilities so that only acceptable parts and supplies will be issued for any job, and must follow standard good practices for properly protecting stored materials.
(e) The applicant must store and protect parts being assembled or disassembled, or awaiting assembly or disassembly, to eliminate the possibility of damage to them.
(f) The applicant must provide suitable ventilation for his shop, assembly, and storage areas so that the physical efficiency of his workers is not impaired.
(g) The applicant must provide adequate lighting for all work being done so that the quality of the work is not impaired.
(h) The applicant must control the temperature of the shop and assembly area so that the quality of the work is not impaired. Whenever special maintenance operations are being performed, such as fabric work or painting, the temperature and humidity control must be adequate to insure the airworthiness of the article being maintained.

I read the whole thing - I still don't see a requirement to physically separate our facility. Others have stated they do not have to and are already certificated. I don't think they were cut slack - I think that there wasn't any reason for their Inspector to require it based on what they are doing.

Ok-Fine! :) Only you and your future FAA Inspector will be able to make final determination regarding physical layout of your facility. Have you invited the FAA to your facility for an informal courtesy visit? That could clarify this matter for you. The great thing about the FAA is that they don't charge you fees for this (yet). Maybe your FAA friend would come out for a tour (free gap analysis) of your facility. They like to do field trips...gets them out of the office. :D

How close are you to making formal application with your local Flight Standards District Office (FSDO)? What's your time frame?

There are six basic steps of the process the FAA has developed for certificating organizations. They are:

Informal inquiry (somewhat like gap analysis and more)
Preapplication Formal application
Document compliance
Demonstration and inspection
Certification

I can elaborate on these process steps if asked. :)

:mg: WOW! You read the whole thing?!
Heavens no - I meant chapter 162. :lol:

Have you invited the FAA to your facility for an informal courtesy visit?
Yes, I have. They will come out for an informal tour once they have received our pre-app (Form 8400-6). After we submit the formal application (Form 8310-3) and our manuals - then they will perform a courtesy inspection. Any discrepancies they find during the courtesy inspection are not held against us, but they will be reinspected during the certification inspection - as you said, it's just like a gap analysis.

BTW - I met this Inspector because I, along with a few people from our organization, have been out to the FSDO (Detroit - Willow Run) we will apply to. We already saw the training presentations and were able to ask lots of questions. We will be able to "request" this guy - and we will - but that doesn't mean he will be the one that receives our pre-app for sure. He is hoping to though - he said, and I am quoting: "This is a rare opportunity for me to work with a group that has no preconceived ideas about how a repair station operates or is certified."

There are six basic steps of the process the FAA has developed for certificating organizations...I can elaborate on these process...
While we were out at the FSDO we went over all of this stuff with them. They provided me with all kinds of links and made sure we went ahead with the not yet released version so we wouldn't confuse ourselves when it was released in the middle of our plans/implementations.

I've also been out to a couple of our suppliers' facilities that are certificated repair stations. Since I am the Purchasing Agent here, they were only too happy to oblige ;) when I contacted them for a tour and a little education. I found out they were repair stations when I was browsing through the Repair Stations Directory - AC140-7P.

Hi Cari,

What's new with your quest for FAA Certification?:)

Hi Cari,

What's new with your quest for FAA Certification?:)
Hi!

I forgot to get back and respond:o

A little busy lately and we have our ISO Surveillance Audit tomorrow. I'll stop in Friday with an update.

Thanks for asking!:agree:

Hi!

I forgot to get back and respond:o

A little busy lately and we have our ISO Surveillance Audit tomorrow. I'll stop in Friday with an update.

Thanks for asking!:agree:

Fare well with your ISO Surveillance Audit Cari. Will be looking forward to getting an update.:)

It's good to be busy!:rolleyes: Right?

It's good to be busy!:rolleyes: Right?

Yes--just like growing old, it beats the h*ll out of the alternative.

You guys got that right! Being busy is a good problem to have. We are smack in the middle of the addition being built and we're moving in two more new thread grinders in January - so I have been a busy little purchasing agent - got to buy drip pans, leveling pads, etc. - got to tool up both machines too - dressing wheels, etc. We are also having a giant filter system delivered sometime in the next couple of weeks - it's a big central filter and chiller for 5 or 6 of our thread grinders - eliminating all of individual ones behind each machine. Whew!:eek:

We are currently interviewing for machinists because we are starting a second shift. I've been here 5 years now - it's never been busier!!

Cari,

I discovered this thread late (day before yesterday) and then had to check on something, so you will be all done and over with your audit. But I'll pass this on anyway.

I an currently working (as a contractor) with -- as they say on some game shows -- a major airline headquartered in the largest (by land area) state East of the Mississippi. They do most of their own maintenance (Part 121). They also do work for other US and international carriers, and are a service center for certain airframe or engine manufacturers (Part 145). Which one applies is identified by the color of the work order tag.

Most paperwork is, of course, on white paper. The paperwork for 145 work is printed on a distinctively different color of paper, and nothing else is printed on that color. That alerts the person that additional things need to be checked before starting. (Does the contract require use of their manual instead of ours? If we use our manual and it has an "alternate" process, can we use that or must we stick with the original? And more ...) It also designates that additional paperwork may be required when the job is complete. Departments that have a lot of 145 work may have segregated incoming and outgoing shelves. Other than that, though, the work is done in the same hangars or shops, using the same workstations and tools that we use for 121 work.

In addition to the different color paper, the people doing the work all have recurring awareness training on the different requirements.

I can't even imagine how horrible it would be if we had to have a separate paint hangar, engine test cell, avionics shop, maintenance hangar, compass rose or other facility dedicated just to part 145 work!

Disclaimer: being a contractor (and maybe not for much longer) I do not and cannot speak for the company; I can merely report on what I see.

Departments that have a lot of 145 work may have segregated incoming and outgoing shelves.
This is an important issue for us. We receive dozens of items for repair evaluation daily - from all different kinds of industries.

The different color paper is an exellent idea. We use routers - all white - we could print them out on colored paper for Part 145 work. What a nice, simple solution.

Thanks!:agree:

Graeme, you present some good ideas here. Of course 'color control' and 'segregated shelving' needs to prove effective for the PMI to buy-off on it. I have no doubt, Cari and her organization is going to work this all out to the good. It's been a very interesting thread to follow, and I for one very much appreciate Cari's willingness to share this with us all. Likewise, someone such as yourself pops into a thread such as this and offers a fresh take on the situation. Thanks! :)


Cari,

I discovered this thread late (day before yesterday) and then had to check on something, so you will be all done and over with your audit. But I'll pass this on anyway.

I an currently working (as a contractor) with -- as they say on some game shows -- a major airline headquartered in the largest (by land area) state East of the Mississippi. They do most of their own maintenance (Part 121). They also do work for other US and international carriers, and are a service center for certain airframe or engine manufacturers (Part 145). Which one applies is identified by the color of the work order tag.

Most paperwork is, of course, on white paper. The paperwork for 145 work is printed on a distinctively different color of paper, and nothing else is printed on that color. That alerts the person that additional things need to be checked before starting. (Does the contract require use of their manual instead of ours? If we use our manual and it has an "alternate" process, can we use that or must we stick with the original? And more ...) It also designates that additional paperwork may be required when the job is complete. Departments that have a lot of 145 work may have segregated incoming and outgoing shelves. Other than that, though, the work is done in the same hangars or shops, using the same workstations and tools that we use for 121 work.

In addition to the different color paper, the people doing the work all have recurring awareness training on the different requirements.

I can't even imagine how horrible it would be if we had to have a separate paint hangar, engine test cell, avionics shop, maintenance hangar, compass rose or other facility dedicated just to part 145 work!

Disclaimer: being a contractor (and maybe not for much longer) I do not and cannot speak for the company; I can merely report on what I see.

You guys got that right! Being busy is a good problem to have. We are smack in the middle of the addition being built and we're moving in two more new thread grinders in January - so I have been a busy little purchasing agent - got to buy drip pans, leveling pads, etc. - got to tool up both machines too - dressing wheels, etc. We are also having a giant filter system delivered sometime in the next couple of weeks - it's a big central filter and chiller for 5 or 6 of our thread grinders - eliminating all of individual ones behind each machine. Whew!:eek:

We are currently interviewing for machinists because we are starting a second shift. I've been here 5 years now - it's never been busier!!

Growth is good, but comes with growing pains.:rolleyes: