# Presentation: 720669

## Repair Station Q. & A. Session

- Here are some of the most commonly asked questions on repair stations.  These may prompt you to bring up other subjects you may have been wondering about.

## Our answers will be taken from Federal Aviation Regulations and established FAA policy.  Policy guidelines are found in FAA Orders, Notices, and in some cases, Memorandum from National or Regional specialists.  In this section of Q. & A.’s , answers will refer to rules or policy which guide the response.

## Q.

- What ratings should be issued?  Airframe Class Rating or Limited Airframe?  If we have an Airframe Rating, can’t we also work on the engines installed on that aircraft?  Do we need capability lists?
**A**.
- FAR 145.31 defines Class Ratings, and 145.33 covers Limited Ratings. Class Ratings are issued when an applicant has shown the capability for maintaining a wide cross section of makes and models within one or more particular class.  Otherwise, your Principal Inspector will issue a Limited Rating and list the specific models on the Repair Station Operations Specifications.  A capability list could be required to avoid an extremely long listing of models on the FAA Form 8000-4-1.  Capability Lists are FAA Approved documents and must be adequately identified, controlled, and revised as models are added.  (ASO - Memo)

## A. (continued).

- FAA Order 8610.3 addresses the issue of Airframe Rated repair stations performing powerplant inspections and maintenance.  In a nutshell, it states that an airframe rated  repair station may conduct an inspection required by FAR 91.409, which includes engine and prop. inspections, but may not perform any maintenance beyond that inspection without the proper Powerplant Rating.  A repair station with airframe ratings will normally be issued operating specifications to include:
- _Limited Powerplant - _
- Minor maintenance on engine types installed on aircraft under above  ratings shall be limited to routine maintenance, replacement, minor repairs and adjustment of external components and accessories, excluding overhaul, separation, or disassembly of reciprocating engine crankcases or turbine engine modules.  All maintenance to be in accordance with engine manufacturers instructions.

## Q.

- What is a Limited Rating - Specialized Service?
**A.**
- FAR 145.33 defines a Specialized Service as one which requires skills and equipment not normally found in regular repair stations. Specialized service ratings require FAA approved process specifications.  These may be either civil or military ones currently used by industry and approved by the Administrator, or process specifications developed by the applicant and approved by the Administrator.
- Notice 8300.110 and Order 8610.3 also address this subject.  Certain process specifications may be routed by your Principal Inspector to the Aircraft Certification Office for concurrence or approval.

## Q.

- May one repair station subcontract maintenance to another FAA approved repair facility?
**A.**
- Yes.  In this case, the job function performed would be approved for return to service by the contracting repair station and must meet the requirements of FAR 43.9.  _However_, the switching of certification tags and the development of new work orders by a repair station acting as an intermediary, without performing the work does not constitute compliance with applicable sections of FAR Part 43 or 145, and would require corrective action under FAR 43.12.  (Fraudulent maintenance entries may result in the revocation of any certificate held.)

## Q.

**Q.**
- May work be sub-contracted to non FAA approved facilities?
**A.**
- Job functions set forth in Appendix A of Part 145, and identified by an asterisk (*) can be sub-contracted to an outside agency.  If the contract facility is not certificated, the certified repair station’s I.P.M. must list that contract facility and the functions it performs.  The certified repair station must be appropriately rated to perform the function contracted out, and must have appropriate data, qualified personnel, and complete inspection capabilities to ensure the airworthiness of all articles involved.  The certified facility then approves for return to service.

## Q.  -  MAINTENANCE RECORD ENTRIES

- Are repair stations required to provide copies of work orders in addition to meeting the requirements of FAR 43.9 on serviceable parts tags?  What does it take to meet the requirements of FAR 43.9?  Are the terms  “overhauled or rebuilt” sufficient to describe the work accomplished?  (overhaul and rebuilt as defined in FAR 43.2)
**A.****	**Repair stations are required to meet the requirements of FAR 43.9 which includes a description of the work performed.  The requirements of Appendix B to FAR Part 43 must also be met when recording major repairs and major alterations.  Repair stations often use a _“yellow tag” _as a maintenance release, and _refer_ to a work order on file at the repair station.  References to work orders by number only, or the term overhaul which has different meaning thru industry, does not satisfy the requirements of FAR 43.9(a)(1).  THE ENTRY MUST SAY EXACTLY WHAT YOU DID: WHAT PARTS WERE REPLACED, S.B. COMPLIANCE, ETC...  _ATTACHMENT_ OF  WORK ORDERS WHICH LIST THIS DATA, _WILL_ MEET THE REQUIREMENTS.

## Q.  

**Q.  **
- Our repair station holds only an airframe rating.  May we conduct the tests required under FAR 91.411 without any further ratings?
**A.**
- Yes!  If you have all required test equipment, properly trained personnel, and if the tests are on an airframe within the Class or Limited Rating that you hold.  *See FAR 91.411(b)(2)(iv)*.  _However, this is testing only._  Any calibration or adjustment required as a result of the test, must be conducted by an appropriately rated repair station which holds an Instrument Class, or Limited Instrument Rating.  FAR 91.411 refers to pitot-static tests, altimeter testing, and automatic altitude reporting / ATC transponder integration tests.  _See FAR 43 Appendix E_.

## Q.

- May that same airframe rated repair station conduct the FAR 91.413 tests in accordance with FAR 43, Appendix F?
**A. **
- No!  The transponder certification may only be performed by repair stations rated as Radio Class, Limited Radio, Specialized Service, or  an MMF under FAR 145.101.  Air Carriers may conduct the tests under FAR 121 or 135.411(a)(2).  The rules also allow tests to be performed by the manufacturer of the aircraft on which the transponder is installed, if the transponder was installed by that manufacturer.
- (*see FAR 91.413(c))*

## Q.

- The issue of determining a_ major or minor repair _or _alteration_ continues to give us trouble.  Can you clear that up for us?
**A.**
- The determination for major Vs. minor must be made on a case by case
- basis.  We must use the definitions found in FAR Part 1, as well as FAR 43 Appendix A as our guidelines.  Certainly, not all situations are adequately covered.  If you do not feel comfortable  making this determination on your own, ask your Principal Inspector to assist you.  Whatever the two of you decide will be the way to go.
- Remember, a repair returns a product to its original type design configuration, while an alteration changes the design of the product.

## Q.  What is the difference between approved and acceptable data?

**A.  **Acceptable data is used to perform minor repairs or alterations.  Acceptable data includes, but is not limited to, the following data:
**FAA Advisory Circulars - AC 43.13-1A and AC 43.13-2A**
**Manufacturers Maintenance Manuals, Service Bulletins, Kits, etc.**
**Military Specifications, or Technical Manuals, **
- Approved data is required for major repairs or alterations.  The following types of data are considered to be approved:
**Type Certificate Data Sheets  **
**Supplemental Type Certificate Data Sheets**
**Airworthiness Directives**
**Manufacturer’s FAA Approved Data - SRM, Overhaul Manuals, ...**
**Designated Engineering Representative (DER) Data**
**Designated Alteration Station (when the DAS alters the product)**
**FAA Field Approved Data - Block 3 of FAA Form 337**
**SFAR 36 Data - Organization approved for developing repair data**