Separation of Facilities - Part 145 Repair Station

[Cari Spears]

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?

 

[Tammy N]

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.

 

[Don Palmer]

Facilities Floor Plan

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?

 

[Cari Spears]

...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.

 

[Rob Nix]

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 Spears]

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!

 

[Don Palmer]

Designated Inspection Area

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.

 

[Cari Spears]

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.

 

[Blue Tuna]

Here is what I have noticed

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.

 

[Cari Spears]

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?