Avionics News August 2012 - 15

In order to receive consistent conformity with the standard, the design and operation of a repair station must be identical to the model we are judging consistency against. Each repair station is unique and is responsible to ensure its design and operation conform to the standard.

part A defines the overall applicability and certification requirement for a repair station. Subpart B defines the who, what and how a repair station is certified. Subparts C, D and E define the minimum standards for the design and operation of a certificated maintenance business. In the repair station world, we have standardization – we have Part 145. The Inspector As I stated earlier, I have yet to find an FAA employee who does not attempt to assure that repair stations are in conformity with the standard. Here, we start to see challenges to consistency. As a government agency with more than 30,000 employees, it does, as would be expected, struggle with consistency. A typical repair station doesn’t interface with 30,000 employees; we really are affected by the 5,200 employees of Flight Standards and the 1,300 employees in Aircraft Certification. Is consistency from 6,500 people unreasonable? The challenge may be that the inspector work force is lacking a standard, as it has two. I think we can all agree that Part 145 is the standard for the design and operation of a repair station. But, the inspector work force has a competing standard: the FAA Order 8900.1. • This order directs the activities of aviation safety inspectors responsible for the certification, technical administration and surveillance of air carriers, certain other air operators conducting operations in accordance with the appropriate part of Title 14 of the Code of Federal Regulations (14 CFR), certificated airmen and other aviation activities (FAA Order 8900.1 V 1, C 1, Para 1-3 A). Should the inspector find a conflict between Part 145,

the applicable advisory circulars and the FAA inspector policy, he or she must follow an administratively burdensome, time-consuming and overall discouraging process in order to deviate from policy direction. • Inspectors, supervisors and managers who find that specific requirements in this order do not apply to a specific case should forward a request for permission to deviate from the requirements through the applicable regional Flight Standards division to the appropriate AFS headquarters division (FAA Order 8900.1 V 1, C 1, Para 1-3 A). I have found very few conflicts between FAA employee policy and the aviation regulations. When we have discovered a conflict, FAA headquarters has been reasonably responsive in correcting the discrepancy. However, we do see significant conflict in the means of compliance. The regulations state what is required. An advisory circular states the how and recommends an acceptable means of compliance, should the applicant choose to follow it. Most ACs contain the following or similar language to reinforce the purpose of the AC: “Like all AC material, this AC is not mandatory and does not constitute a regulation. It is issued for guidance and to outline a method of compliance with the rules. This is one means but not the only means for developing a receiving inspection system. In lieu of following the method(s) prescribed herein, the applicant may elect to follow an alternate method.” Experience tells us that where an AC may allow for deviations, the FAA Order 8900.1 does not, and often
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2012

Avionics News August 2012

Table of Contents for the Digital Edition of Avionics News August 2012