The repair station community will help the FAA ensure that its myriad guidance documents align with Part 145, and where gaps or conflicts exist, make recommendations to fix them.
The effort, set up under the FAA’s Aviation Rulemaking Advisory Committee (ARAC), gives industry the opportunity to weigh in on advisory circulars, policy statements and other guidance that the safety agency leans on to enforce its Part 145 regulations. The rules apply to the 4,800 FAA-certified repair stations, including 800 located outside the U.S.
“When guidance documents do not reflect current regulatory requirements and FAA . . . policies, the outcome is an uneven and inconsistent application of agency guidance and standards,” the FAA states. “The Part 145 Working Group will provide recommendations [that support] the goal of consistent and clear guidance documents.”
Revamping guidance so it fits with the agency’s emerging systems-focused oversight philosophy is a key goal.
“The agency’s policies advocate performance-based oversight,” the FAA says. “However, guidance documents, particularly those directed at the agency’s workforce are often prescription-based. The Part 145 Working Group is [being] asked to provide recommendations that will support the applicant’s performance-based decision-making and the agency’s evaluation of those decisions.”
News of the ARAC effort was welcomed by the Aeronautical Repair Station Association (ARSA), which represents MRO shops and is likely to land a seat on the working group.
“We’re thrilled to see progress getting made on what is a vital task for industry—whether the average repair station recognizes it or not,” Sarah MacLeod, ARSA executive director and a past ARAC participant, said. “This is a chance for those of us coping with the agency’s guidance to recommend a method for aligning what the FAA repair station rule actually requires with agency expectations. There’s a long way to go, but this is a good day for maintenance compliance.”
Carol Giles, the former head of the FAA’s Aviation Maintenance Division and now president of The Giles Group consultancy, says there is plenty for the working group to sink its teeth into, noting: “I hope this group will provide some cleanup, alignment and avenues for consistency.”
The group will have 24 months to develop a draft report, and another year to finalize it. Working group reports flow through the ARAC and are delivered to the FAA. The agency is not compelled to act on ARAC recommendations, but the group’s reports often shape related rulemaking and guidance.