We are a part 145 repair station, and have been found to have discrepancies in our QCM on Contracted Maintenance,Non Certificated repair stations. How do I remain Directly in charge of the work being performed at the Non certificated shop?

Please help: (:(

Do you specify quality system requirements for your non-certificated contractors?

Do you specify that your non-certificated contractors maintain a D&A program?

Do you then test and/or inspect the product repaired by non-certificated contractors prior to approving it for return to service?

1) Yes, we specify Quality System requirements
2) No, we do not specify they maintain a D/A program.
3) Yes, we test and inspect.

We are a part 145 repair station, and have been found to have discrepancies in our QCM on Contracted Maintenance,Non Certificated repair stations. How do I remain Directly in charge of the work being performed at the Non certificated shop?

Please help: (:(

Hello big rob! Thank you for dropping by the Cove! We're sure glad to have you.:bigwave:

First, I am not that proficient in aviation, so discount it as such. I have worked in the environment before though. I have seen (typically medium size operations) that perform a number of different services on aerospace parts. Usually, they have a portion of their services certified due to it's nature, but the other portions are not. Does that sound like your situation?

Now to your question... I'm not sure I understand. if you are the supervisor; you are the supervisor. Why do you feel a need to distance yourself from the non-certified work? I would think you would be more concerned with creating separation in other ways than supervision.

Not sure my question makes sense. :) Let me know what you're thinking.

Sorry badgerman, I was putting together my post while you were helping out.:agree1:

Add edit: I revised the title a bit, so that it might be a little more clear. Let me or any moderator know if it is not suitable.

We do specify that non-certificated contractors maintain a D&A program.

The main difference I see is that we test the product and approve for return to service with non certificated sources whereas with certificated contractors, they can approve for return to service.

Was this an audit nonconformance? Can you ask the auditor for clarification?

Sorry badgerman, I was putting together my post while you were helping out.:agree1:

Add edit: I revised the title a bit, so that it might be a little more clear. Let me or any moderator know if it is not suitable.

I changed it again to add further clarification.

The question deals with (sub) contracted maintenance not "maintenance"......…LOL!

When an FAA approved repair station sub-contracts/out sources repair of a product returned from the field because they don’t have the capability, they can use another approved repair station or a non-approved (certificated) source. The two options require different levels of control from a QMS perspective.

Clear as mud, eh?

Yes, this was an audit non conformance. The auditor is a fast talker and confuses me sometimes. He is helpful but seams to be one that likes verbage to be specific. We try to use certificated stations as much as possible but sometimes it just can't be done.

Thanks for your help. :thanks:

We try to use certificated stations as much as possible but sometimes it just can't be done.

a non certified contractor has no difference from a certified one, except a piece of paper saying it is so, but the control over the contractor should always be in your hands.

a non certified contractor has no difference from a certified one, except a piece of paper saying it is so, but the control over the contractor should always be in your hands.

The term is certificated, not certified.

Here is the pertinent regulation:

Sec. 145.217

Contract maintenance.

[(a) A certificated repair station may contract a maintenance function pertaining to an article to an outside source provided--
(1) The FAA approves the maintenance function to be contracted to the outside source; and
(2) The repair station maintains and makes available to its certificate holding district office, in a format acceptable to the FAA, the following information:
(i) The maintenance functions contracted to each outside facility; and
(ii) The name of each outside facility to whom the repair station contracts maintenance functions and the type of certificate and ratings, if any, held by each facility.
(b) A certificated repair station may contract a maintenance function pertaining to an article to a noncertificated person provided--
(1) The noncertificated person follows a quality control system equivalent to the system followed by the certificated repair station;
(2) The certificated repair station remains directly in charge of the work performed by the noncertificated person; and
(3) The certificated repair station verifies, by test and/or inspection, that the work has been performed satisfactorily by the noncertificated person and that the article is airworthy before approving it for return to service.
(c) A certificated repair station may not provide only approval for return to service of a complete type-certificated product following contract maintenance, preventive maintenance, or alterations.

Here you go...What do you think?

14CFR 145.201 Privileges and limitations of certificate.
(a) A certificated repair station may—

(1) Perform maintenance, preventive maintenance, or alterations in accordance with part 43 on any article for which it is rated and within the limitations in its operations specifications.

(2) Arrange for another person to perform the maintenance, preventive maintenance, or alterations of any article for which the certificated repair station is rated. If that person is not certificated under part 145, the certificated repair station must ensure that the noncertificated person follows a quality control system equivalent to the system followed by the certificated repair station.

(3) Approve for return to service any article for which it is rated after it has performed maintenance, preventive maintenance, or an alteration in accordance with part 43.

(b) A certificated repair station may not maintain or alter any article for which it is not rated, and may not maintain or alter any article for which it is rated if it requires special technical data, equipment, or facilities that are not available to it.

(c) A certificated repair station may not approve for return to service'

(1) Any article unless the maintenance, preventive maintenance, or alteration was performed in accordance with the applicable approved technical data or data acceptable to the FAA.

(2) Any article after a major repair or major alteration unless the major repair or major alteration was performed in accordance with applicable approved technical data; and

(3) Any experimental aircraft after a major repair or major alteration performed under §43.1(b) unless the major repair or major alteration was performed in accordance with methods and applicable technical data acceptable to the FAA.

Part 43 link below........

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=94de2917aafbb4a36348fed19b9b6933&rgn=div5&view=text&node=14:1.0.1.3.21&idno=14

I changed it again to add further clarification.

The question deals with (sub) contracted maintenance not "maintenance"......…LOL!


Yea, I kinda got in a hurry on that one.


When an FAA approved repair station sub-contracts/out sources repair of a product returned from the field because they don’t have the capability, they can use another approved repair station or a non-approved (certificated) source. The two options require different levels of control from a QMS perspective.

Clear as mud, eh?

And the different QMS perspective was what I was trying to get at. I do know that calibration documentation was "prioritized" differently, depending on where the equipment was being handled. I was hoping that Rob could feel comfortable with supervising it all, then handling each area different procedurally.

Thanks for the explanation, Badger. :agree1:

a non certified contractor has no difference from a certified one, except a piece of paper saying it is so, but the control over the contractor should always be in your hands.

As a general notion, I might tend to agree with you. But not in this one. They are... different. If you ever see them, you would know. That is in addition to the evidence provided by Badger and Randy.

a non certified contractor has no difference from a certified one, except a piece of paper saying it is so, but the control over the contractor should always be in your hands.I don't think you understood the situation. We are talking about repair stations certificated by a National Aviation Authority, such as the FAA.

The IAQG is now interested in promoting 9110 for the maintenance, repair & overhaul sector. I am a member of the IAQG MRO Relationship Growth Strategy Team. In the next couple of months, I will have another article published as a sequel to my previous one (http://www.qualitydigest.com/aug06/articles/06_article.shtml). The OP should consider flowing down AS9110 implementation/certification to the non-certificated maintenance contractor as a way to mitigate the risks of doing business with them.