Part 145 Repair Station Rating and Capability List vs. ISO 9001 certificate Scope

[Cari Spears]

Al - thank you so much. I was trying to make things more difficult than they are, as usual. I see now - the OpSpecs is the document that "sums it up".

After following your link to the example - I started google searching for companies listed in the Repair Stations Directory advisory circular. Some of their websites have their certificates and OpSpecs and even their manuals - so I'm a little more enlightened.

Thanks for the nudge in the right direction.

 

[Marc]

You're right - It looks like there aren't many repair station folks who stop by.

 

[Al Rosen]

Some of this I addressed in the other post that was started about capability list. This requirement about auditing the Capability list was "introduced" since my involvement in FAA Repair Stations ended, but I had to periodically update our capability list. If you are the manufacturer of the parts, you might want to add an item at the Final Design Review or Design Transfer. That item might also include verifying that all the approved data is available for maintenance. As far (pun intended) as it's concerned, KISS.

 

[Al Rosen]

Some things to keep in mind for a Limited Rating:

1. If a part is not listed on your OP Spec, you cannot legally perform maintenance on it.
2. To add it to your OP Spec, you must first add it to your Capability List.
3. Submit your Capability List to the FAA.
4. The FAA will revise your Op Specs after verifying you have met all the requirements (approved data, tools & equipment etc.) for maintaining the new part. This could be a facility visit (inspection). This is what I dealt with each time I made a change. The inspector visited with the revised OP Spec, verified we met all the requirements and swapped the new OP Specs for the old ones. (This wasn't difficult for us being the manufacturer.)

The reason I mention this is that it could take some time between you submit the change and the FAA issues you new OP Specs. They are not, exactly, able to turn on a dime. See # 1 above. So plan ahead.

 

[Raptorwild]

Cari, Here is the procedure for our Capability List included in our Repair Station Manual that has been accepted by our Administrator (FAA). I am also going to try to paste the Capability Verification Form.

"The capability list is a separate document from this manual and shall incorporate those items that comply with _________________, Limited Accessory Ratings. It is controlled by revision number and date. A current Capability List is maintained by the General Manager of this repair station.


The Capability List is available for review to all personnel of this repair station. During receiving/inspection, the receiving inspector shall refer to the capabilities list to verify that the article to be serviced is listed. The information is recorded on the Receiving Inspection Log. If the article is not on the list, the General Manager is notified immediately, the article is identified with a Rejected Parts Tag, (Form 6) and placed in the bond locker until further processing. Once the General Manager has verified and/or obtained that the Repair Station has all required tooling, documentation and experienced personnel to service the equipment, then that equipment shall be added to the capabilities list and work would be able to commence on that equipment. If the article cannot be added to the Capability List it is returned to the customer. A capabilities verification form (see Forms Section “C” GI-11) shall be completed to determine if a component can be added to the capabilities list.


The capabilities list shall be reviewed periodically in accordance with the internal audit programs schedule and not to extend a period of more than 90 days. If it is found at that time that the technical data and/or tooling is not current, and current technical data or tooling cannot be obtained, then that article's part number shall be removed from the capabilities list.

The General Manager shall be responsible for any revisions to the capabilities list and shall notify the appropriate personnel of the repair station and the FAA of such revisions. A revised capabilities list shall be sent to the FAA with a highlight sheet showing the revision number, revision date and what equipment was added or deleted from the previous list. The revised capabilities shall be sent to the FAA within 7 working days of the revision date by email, fax or hand delivered."

CAPABILITIES VERIFICATION FORM​

Manufacturer: ______________ Part Number: _____________ Description: ______________






1. Does component fall within the scope of the repair stations' Operational specifications?




2. Does the repair station have the current technical data?




3. Does the repair station have the proper Equipment/tooling?



4. Does the repair station have the proper parts for OHC/repair?



5. Are the repair stations personnel trained for this component?





If items 1-5 above are all marked YES, then this component may be added to the capabilities list and the repair station may proceed with the overhaul and/or repair of this component.



Component was added to the capabilities list on: _______________________



If any one of the items 1-5 above is marked NO, then this component may not be added to the capabilities list and the repair station may not overhaul or repair the component.





APPROVED ______ NOT APPROVED _______



General Manager




This form shall be retained on file by the General Manager, for a period of not less than two years.

 

[Cari Spears]

Thanks Paula - big help!!

You've also inadvertently given me some help with an issue we have been discussing: how to separate the FAA repairs from our regular repairs back in receiving. We receive so many items for repair - and the usual practice is for the tear down guys to take pictures as received, log the item in and give it an eval #, then the item is moved to tear down where they...tear it down. These are the guys that clean all the components up and write up the initial observations like visibly obvious galling, broken balls, stripped threads, etc. Then the estimator comes out to give it the thorough inspection to determine if we can fix it or if it has to be remade.

We don't want our tear down guys doing anything to the FAA repair evaluation items - we want those set aside for the estimators. So, if we do like you guys do and have the capability list back in receiving...maybe with an attachment for a list of customers sending us FAA repairs in case we are sent an item not yet on our capability list...

 

[Al Rosen]

I see that the regulations were re-written to allow maintenance to be performed before the ops specs are revised, as long as the article is within the scope of your ratings and you determine you have all of the housing, facilities, equipment, material, technical data, processes, and trained personnel in place to perform the work on the article as required by part 145 (ref:21cfr145.215)
I appologize for the misinformation in my previous post.

 

[Cari Spears]

Oh yeah, I forgot that I meant to post that, Al. I found that out from one of the potential customers our Mil/Aero Sales Rep is working with. The only thing it doesn't say is a specific timeframe for notification to the FAA.

Paula - is the 7 days in your procedure what your FAA Inspector asked for, or did you guys determine that and the FAA said "OK"?

 

[Raptorwild]

Hi Cari,

Well in fact I just finished revising the RSM to state that we will notify the CHDO within 30 days of revisions made to give us a little break.

145.161(a) A certificated repair station must maintain and make available in a format acceptable to the FAA the following....
The Three Rosters are to be revised within 5 business days of the change in accordance with 145.161(b)

Our Administrator requires us to notify him in the manner we spell out in our Repair Station Manual.

So pretty much what ever works for the repair station!

Keep in mind, I am also the Chief Inspector for another Certificated Repair Station, pulling double duty these days. Not much time to post!

 

[Cari Spears]

Wow - busy girl!!

Thanks so much!