On Oct. 3, ARSA submitted comments to the FAA regarding its draft Advisory Circular 145-9A, “Guide for Developing and Evaluating Repair Station and Quality Control Manuals.” The association requested the agency completely withdraw and rewrite the draft and offered assistance constructing a new version.
In support of this request, ARSA noted the AC was drafted prior to a significant rewrite of 14 CFR part 145 and an overhaul of repair station certification procedures. As a result, the comments determine: “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.”
The association’s comments further highlight the AC fails to comport with the agency’s orders on developing guidance documents. This inconsistency would make it difficult for certificate holders to efficiently utilize the document to develop or update their manuals.
Despite ARSA’s withdrawal request and its offer to start the rewrite process by providing a “strawman” for industry and agency review, the association still offered suggestions for improving the current draft. Should the agency be determined to continue with its use, the following general repairs should be made:
(1) Reorganization. The document must make rule-based requirements clear and extraneous information should be identified as “best practices,” not requirements.
(2) Simplification. All suggestions for formatting should be removed. The style choices made in a manual are a lot less important than writing something that can and will be followed.
(3) Flexibility. The AC must make clear that manuals are living documents. In order for one to be followed it must be easy to use and revise.
(4) Applicability. The AC must be sure to cover the needs of all sizes, manners and types of repair stations. Small businesses cannot be buried in unnecessary paperwork; their simplicity must be considered along with the needs of the large, international heavy maintenance providers.
To read the full comments, click here.
Stay tuned to ARSA for developments.
July 14, 2016
On July 14, ARSA requested an additional 90 days to analyze and comment on Draft Advisory Circular 145-9A, “Guide for Developing and Evaluating Repair Station and Quality Control Manuals.”
The association is deeply concerned that the proposed guidance is not supported by the plain language of the regulation. Furthermore, the apparent aim of the revisions is to force all repair stations to utilize industry “best practices,” which will have a significant impact on small-to-medium sized enterprises with limited resources.
ARSA is currently reviewing the guidance. Repair stations are encouraged to review the draft and submit comments using the Draft Document Comment Grid provided by the agency.
To see all the ways ARSA is working as the voice of the aviation maintenance industry – including information about the association’s model manuals – visit the ARSA Works page.
