Separation of Facilities - Part 145 Repair Station

Al Rosen

Holed-up in a Hotel in South Florida
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#11
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.
 
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Blue Tuna

#12
ratings

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.
 
D

Don Palmer

#13
In the mean time - thoughts anyone?

Hi Cari,

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

I was quoting Rob Nix:

Rob Nix said:
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. :eek:

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

Cari Spears said:
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.
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#14
Blue Tuna said:
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.
 
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Cari Spears

Super Moderator
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#15
Al Rosen said:
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.
 

Al Rosen

Holed-up in a Hotel in South Florida
Staff member
Super Moderator
#16
Cari Spears said:
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.;)
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#17
Muleskinner said:
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.
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#18
Muleskinner said:
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.
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#20
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.
 

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