The Aeronautical Repair Station Association’s (ARSA) comments on the FAA’s draft Advisory Circular (AC) 145-9, “Guide for Developing and Evaluating Repair Station and Quality Control Manuals,” propose a wholesale rewrite that would take into consideration increased regulatory complexity since the AC was originally adopted in 1981.
The FAA’s intention when its document was originally published was to provide a road map for developing and maintaining a compliant manual system. ARSA argues that the safety assessment system (SAS) and enforcement expectations “mandated” by the inspector handbook are not given full consideration in the publication. “Few of the agency’s current expectations and methods for Part 145 certification are contained in Advisory Circulars 145-9 and 145-10 or any other public guidance,” the association commented. “Advisory circulars on creating the necessary manuals are inadequate for a comprehensive understanding of the responsibilities associated with applying for and holding a repair station certificate under the agency’s safety assessment system.”
At least one other organization pointed out in its comments to the proposal that increased regulatory complexity and technological sophistication has created a multifaceted system not adequately captured in current repair station guidance material.
While the overall structure of the document remains the same, the agency made several additions and modifications. If the AC were published in its current form, changes would reconcile differences with European Aviation Safety Agency (EASA) definitions, consider the growing utilization of “mobile maintenance units” and add guidance on complying with the hazardous materials notification requirement and utilizing Service Difficulty Reports. The draft AC also expands on suggested procedures for managing contract maintenance providers, working away from a fixed location and obtaining line maintenance authorization.
The draft AC has been removed from the Flight Standards Service “open for comment” webpage while the agency considers comments received. An anticipated release date for the AC revision has not been published.