Office of Inspector General

Audit Report

FAA CONTINUES TO FACE 

CHALLENGES IN IMPLEMENTING A 

RISK-BASED APPROACH FOR 

REPAIR STATION OVERSIGHT

Federal Aviation Administration

Report Number: AV-2013-073

Date Issued: May 1, 2013
U.S. Department of

Memorandum

Transportation

Office of the Secretary

of Transportation

Office of Inspector General

Subject: ACTION: FAA Continues To Face Challenges in 

Implementing a Risk-Based Approach for Repair 

Station Oversight

Report No. AV-2013-073

Date: May 1, 2013

From: Jeffrey B. Guzzetti

Assistant Inspector General 

 for Aviation

Reply to 

Attn. of: JA-10

To: Federal Aviation Administrator

Over the past 15 years, major U.S. air carriers increased spending for contract 

maintenance by nearly $2.7 billion.

1 Industry experts expect this trend to continue 

as airlines increasingly attempt to cut maintenance costs and maximize 

profitability. Currently, the Federal Aviation Administration (FAA) is responsible 

for overseeing nearly 4,800 aircraft repair stations2

In July 2003 and September 2008,

used worldwide by U.S air 

carriers.

3

At the request of the former Chairman of the House Committee on Transportation 

and Infrastructure, Subcommittee on Aviation, we evaluated the Agency’s 

progress since our last review. Specifically, we (1) determined whether FAA’s 

oversight includes accurate and timely risk assessments of repair stations, and 

(2) evaluated the effectiveness of FAA’s oversight of foreign and domestic repair 

stations.

we reported that FAA’s oversight did not 

ensure that work completed at repair stations met FAA standards, and we made 

recommendations aimed at improving this oversight. In response to our 2003 

report, FAA implemented a new process intended to provide comprehensive,

standardized, and risk-based oversight of repair stations.

 1 In 1996, air carriers spent over $1.5 billion for contract maintenance services. In 2011, that amount rose to $4.2 billon.

2 Repair stations conduct a range of repairs and maintenance, from critical components—such as landing gear and 

engine overhauls—to heavy airframe checks, which involve a complete teardown and overhaul of the aircraft. 3 OIG Report No. AV-2003-047, “Review of Air Carriers’ Use of Aircraft Repair Stations,” July 8, 2003, and OIG 

Report No. AV-2008-090, “Air Carriers’ Outsourcing of Aircraft Maintenance,” September 30, 2008. OIG reports are 

available on our Web site at http://www.oig.dot.gov/.
2

To conduct our work, we visited or contacted FAA inspection offices and repair 

stations located in the United States, Brazil, China, New Zealand, Peru, and 

Singapore. We randomly selected 27 repair stations4 for review from a FAAprovided list of facilities performing work for U.S. Part 121 airlines.5

We conducted this review in accordance with Government auditing standards 

prescribed by the Comptroller General of the United States. Exhibit A provides 

more details on our scope and methodology. Exhibit B includes a list of FAA 

offices and repair stations we visited or contacted.

In addition, 

as part of this audit, we selected a statistical sample of 119 aircraft work orders for 

which we analyzed, among other things, the adequacy of maintenance 

documentation and reviewed training records. This review allowed us to project 

the total number of systemic deficiencies.

RESULTS IN BRIEF

FAA developed a risk assessment process to aid repair station inspectors in 

identifying areas of greatest concern. Despite FAA’s efforts, its oversight 

emphasizes completing mandatory inspections instead of targeting resources to 

where they are needed based on risk. Of the 16 established repair station 

inspection areas, FAA guidance only requires 7 to be assessed for risk; the other 

9 are inspected annually regardless of risk. Additionally, FAA inspectors do not 

use this system at foreign repair stations. Instead, they review all inspection 

elements annually at these facilities. Further, FAA’s risk assessment tool was 

designed to only include the prior year’s inspection data. As a result, inspectors 

cannot conduct trend analysis due to insufficient historical data. In addition, FAA 

has not provided inspectors with national-level data analyses that would enhance 

their ability to assess repair station performance, though these data were promised 

when the system was implemented 5 years ago. Finally, FAA provided ineffective 

training to inspectors on how to use the oversight system tools, further hindering 

inspectors’ ability to conduct adequate repair station risk assessments. Due to

weaknesses in FAA’s oversight system, inspectors are not effectively targeting 

surveillance to repair stations with the greatest risk.

FAA’s oversight of foreign and domestic repair stations lacks the rigor needed to 

identify deficiencies and verify that they have been addressed. This is because

FAA inspectors typically do not use comprehensive and standardized procedures 

for conducting inspections and reporting inspection findings, resulting in 

inadequate and inconsistent inspection practices. For example, foreign repair 

 4 Our sample of repair stations was derived from a list provided by FAA. Our universe of 559 repair stations included 

all facilities not covered under Bilateral Aviation Safety Agreements-Maintenance Implementation Procedures, and 

those that had at least one 14 CFR Part 121 customer. 5 This refers to large, commercial operators regulated under 14 CFR Part 121, Operating Requirements: Domestic, 

Flag, and Supplemental Operations. These carriers operate larger aircraft with primarily scheduled flights.
3

station officials could not develop a suitable corrective action plan because FAA 

inspectors did not clearly communicate the results of their findings (e.g., cited 

regulations without connecting them to the deficiency the inspector identified). 

Additionally, inspectors overlooked repair station discrepancies and did not ensure 

that corrective actions addressed previously identified problems. For example, an

FAA inspector determined that a repair station failed to maintain a current list of 

required mechanic training 3 years in a row, yet the inspector accepted the repair 

station’s corrective actions each time. Our review identified numerous other 

deficiencies—57 of 119 work orders6

We are making recommendations to improve FAA’s risk-based oversight of 

foreign and domestic repair stations.

we reviewed contained errors—such as 

inadequate maintenance procedure training, use of tools with expired calibration 

due dates, and inaccurate work order documentation. Uncorrected maintenance 

deficiencies such as these could lead to the use of improperly repaired aircraft 

parts on U.S. air carriers. As a result of FAA’s insufficient oversight, some repair 

stations may not be operating in full compliance with Federal aviation regulations.

BACKGROUND

In 2003, we reported that despite the increase in air carriers’ use of external repair 

facilities, FAA concentrated its oversight of airline maintenance on work 

performed at the air carrier’s in-house facilities. In 2008, we reported that while 

FAA moved its safety oversight toward a risk-based system, it still relied too 

heavily on air carriers’ oversight procedures, which are not always sufficient. We 

made several recommendations to FAA aimed at improving its oversight of repair 

stations. In response, FAA developed and implemented a risk-based oversight 

system designed to target its inspector resources to areas with the greatest risk.

FAA inspectors conduct annual safety inspections of all FAA-certificated repair 

stations located within the United States. For those repair stations located outside 

of the United States, the responsibility for oversight varies. FAA inspectors 

assigned to international field offices oversee 564 of the 726 FAA-certificated 

foreign repair stations (see exhibit C). The responsibility for the remaining repair 

stations falls under reciprocal Bilateral Aviation Safety Agreements-Maintenance 

Implementation Procedures (BASA-MIP)7

 6 We reviewed a statistical sample of 119 work orders out of 49,859 from 27 repair stations in our review.

that permit national aviation authorities

located in France, Germany, and Ireland to inspect repair stations on FAA’s 

behalf.

7 A Bilateral Aviation Safety Agreement is a government-to-government agreement that lays out a framework for the 

aviation authorities to cooperate on aviation safety issues. Maintenance Implementation Procedures define the terms 

and conditions under which the authorities accept each other’s maintenance facility inspections, thereby reducing 

redundant regulatory oversight. Repair stations under BASA-MIP procedures were not included in our review.
4

Prior to FAA implementing its risk-based oversight system in 2007, each repair 

station principal inspector performed one required inspection item per repair 

station annually. Each inspector determined which areas to review during these 

inspections, but often did not document areas they inspected. Today, inspectors 

must still perform at least one annual inspection to evaluate the facility and 

determine whether its employees are qualified to perform maintenance functions. 

These inspections now include 16 sub-inspection items, or elements, such as 

quality control, training, manuals, and tools and equipment.

FAA OVERSIGHT DOES NOT PROVIDE FOR ACCURATE OR 

TIMELY RISK ASSESSMENTS OF REPAIR STATIONS

FAA does not have an effective system for accurate and timely risk assessment of 

foreign and domestic repair stations because of critical weaknesses in its repair 

station oversight process. First, less than half of its inspection elements are 

evaluated based on risk, and foreign repair stations are not inspected using this 

system. In addition, tools designed to assist inspectors in assessing risk are not 

effective, and inspectors are not using them. Finally, a lack of effective training 

and availability of consolidated repair station data for inspectors is leading to 

inconsistencies in oversight and hindering FAA’s ability to prioritize surveillance 

based on risk.

FAA Inspectors Use a Limited Risk-Based Approach to Repair Station 

Oversight

FAA’s guidance recommends inspectors conduct annual inspections at repair 

stations covering as many as 16 inspection elements, but not all are evaluated 

based on risk. FAA requires that as many as nine elements be inspected annually, 

regardless of risk. However, FAA’s guidance does not explain why these specific 

elements must be inspected each year. As shown in table 1 below, less than half—

7 of 16—of the inspection elements are actually inspected based on risk.
5

Table 1. Inspection Elements and Frequency of Inspection

Required Annually Based on Risk**

 

Maintenance Process Certificate Requirements

Quality Control Housing and Facilities

Technical Data Manuals

Training Parts and Materials

Air Carrier Requirements* Personnel Records

Contract Maintenance

(certificated repair facility)*

Records Systems

Contract Maintenance 

(non certificated repair facility)*

Tools and Equipment

Domestic EASA Oversight Audit*

Work Away from Station*

* Only inspected if element applies to the repair station

** If no risk is detected, these elements are required to be inspected once every 3 years

Source: FAA

Moreover, inspectors have not conducted inspections of the risk-based elements at 

repair stations within appropriate time intervals. FAA requires inspectors to 

complete these inspections at least once every 3 years so they can determine

whether repair station operations have changed (e.g., the repair station began 

contracting out maintenance to another facility). However, FAA’s inspection 

database for fiscal years 2009 to 2012 showed that FAA inspectors did not 

complete timely inspections at 20 of the 27 repair stations in our sample, leaving 

inspectors unaware of any changes in operations that could impact risk levels. We 

also found that inspectors continued to perform inspections in areas of repair 

station operations where little or no risk was previously detected. For example, 

during fiscal years 2009 to 2012, FAA completed inspections at 24 of 27 repair 

stations where little or no risk was previously identified.

FAA also does not use its risk-based oversight system to inspect foreign repair 

stations. Instead, inspectors review all inspection elements annually, regardless of 

risk. For example, from fiscal years 2009 to 2012, inspectors responsible for 

oversight of 8 of the 13 foreign repair stations in our sample inspected every 

element in a particular year regardless of risk. According to FAA guidance, 

inspectors should use a risk-based oversight approach for all repair stations, both 

domestic and foreign.

8

 8 Except those repair stations under a BASA-MIP agreement.

Yet, over half of the foreign repair station inspectors we 

interviewed on this issue—7 of 12— said they did not use, or did not see the need 
6

for using, a risk-based oversight approach. Because foreign repair stations must be 

re-certified each year, inspectors feel they must inspect all elements during the 

recertification process.

FAA Developed Risk-Based Inspection Tools, but the Tools Are 

Ineffective and Inspectors Do Not Use Them

Since implementing risk-based oversight, FAA has developed two tools for 

inspectors—the Repair Station Assessment Tool (RSAT) and the Risk 

Management Process (RMP). However, limitations in tool versatility, data 

availability, and data quality have precluded inspectors from using these tools,

which in turn has hindered FAA’s ability to conduct effective risk-based oversight.

Repair Station Assessment Tool (RSAT)

The RSAT, while developed to assist inspectors with planning surveillance and 

analyzing risk, has limited effectiveness. The tool is comprised of a Web-based 

spreadsheet that displays 16 inspection elements, which together represent an 

annual repair station inspection (see exhibit D). The spreadsheet is populated with 

inspection results captured as risk assessment scores from the previous year, which 

inspectors use to analyze risk and prioritize their surveillance for the upcoming 

year. Shortcomings with the design and data have created a number of problems 

for inspectors using the RSAT. For example:

• Lack of versatility. Due to its design, inspectors can only complete the 

RSAT once annually as part of their national work program at the 

beginning of each fiscal year, and cannot update changes in risk until the 

following year. As a result, the RSAT tool is not useful to inspectors for 

monitoring changes in risk levels occurring throughout the year. Instead, 

inspectors must consult another inspection database to track changes in risk 

and adjust their oversight priorities.

• Limited data availability. The RSAT was designed to include risk 

assessment data only from the previous year, making it impossible for 

inspectors to conduct any meaningful trend analyses and prioritize their 

resources accordingly. Instead, inspectors must perform searches of various 

FAA databases (e.g., databases for surveillance and enforcement activities) 

to identify any recurring deficiencies at repair stations.

• Questionable data quality. The RSATs we reviewed contained errors and 

incomplete information, further limiting their effectiveness for trending 

deficiencies. As shown in exhibit D, an RSAT should contain data such as 

the number of planned/completed inspections, risk assessment scores for 

each inspection element, and an overall risk assessment score. However, 

112 of 146 RSAT worksheets we reviewed for fiscal years 2010 to 2012 
7

contained discrepancies. For example, 66 RSATs contained a different 

overall assessment score than had been originally recorded in FAA’s 

inspection database. An FAA official attributed these discrepancies, in part,

to problems with transferring data from FAA’s inspection database to the 

RSATs. Figure 1 below shows the type of discrepancies we identified in 

fiscal years 2010 to 2012.

Figure 1. RSAT Worksheet Data Discrepancies, FYs 2010–2012

Source: OIG analysis of FAA data

• Subjective risk criteria. Inspectors must manually assign risk assessment 

scores that can be subject to misinterpretation. For example, to assign a risk 

score, inspectors determine the level of risk at a repair station by selecting a

generic word description and an associated numerical value—from 1 to 

10—as shown in figure 2 below. The numerical value represents the 

definition that most closely corresponds to the conditions observed during 

each inspection.

66

40 28

20

0

20

40

60

80

100

120

140

160

Incorrect Overall 

Assessment 

Score Displayed

Incorrect 

Inspection 

Element Score 

Displayed

Incorrect No. of 

Completed 

Inspections 

Displayed

Blank Worksheets 

(No Data)

No. of Worksheets 
8

Figure 2. RSAT Word Description and Risk Assessment Scores

Source: FAA

• Susceptibility to inconsistent assessments. Inspectors must understand the 

tool’s terminology and effectively assign word descriptions to ensure the 

accuracy of inspection results and to conduct comprehensive trend 

analyses. More than half of the 31 inspectors we interviewed on this issue 

stated they did not understand the word descriptions or did not find them to 

be accurate indicators of problems identified during inspections. This 

confusion leads to inconsistencies in the way inspectors view the severity 

of risk and document their repair station risk assessments. For example, two 

risk assessments by different inspectors9

Risk Management Process (RMP)

of the same repair station in fiscal 

year 2011 resulted in an overall assessment of 1 (“Requirements are not 

met”) by one inspector and a 7 (“Requirements are met and are adequate”) 

by the other. Because of the subjective nature of FAA’s risk assessment 

process, inspectors may not be consistently or effectively identifying risks 

at repair stations.

FAA also provided inspectors with another tool—the RMP—to assist in analyzing 

and mitigating risk; however, we found that inspectors are not using it. The RMP 

is a decision tool—similar to a flow process diagram—that inspectors should use 

to determine the severity and likelihood of recurring deficiencies at repair stations.

However, 24 of 34 inspectors we interviewed on this issue stated they do not use 

the tool primarily because they could not recall the training or did not receive it. 

 9 Typically, FAA assigns two inspectors to oversee repair stations—one to review maintenance and another to review 

avionics processes. Each inspector completes a separate risk assessment.

1-2: Requirements are not met.

3-5: Requirements are marginally met. Documentation 

and controls are deficient.

6-7: Requirements are met and are adequate, appropriate and 

maintained. An adequate control system is in place but some 

discrepancies are noted and being corrected.

8-9: Requirements are met and are adequate, appropriate, 

maintained, documented, and controlled. No deficiencies 

observed.

10: Requirements are met and are considered to be well 

above the minimum industry standards.
9

According to an FAA Aviation Data Systems Branch official, if an inspector used

this decision tool, it would be coded on the RSAT inspection worksheet. Yet, our 

review of 146 RSAT worksheets from fiscal years 2010 to 2012 disclosed that 

none of the inspectors used the RMP to analyze or mitigate risk.

FAA guidance recommends inspectors use the tool to address any hazard that they 

decide is significant enough to justify intensive analysis and tracking. However, 

none of the inspectors included in our review were using the tool. For example, in

2011, an inspector identified deficiencies with a component repair station’s 

training program and improper handling of materials. The inspector rated the 

repair station with the lowest risk assessment score, indicating it did not comply 

with Federal aviation regulations. Part of the RMP process requires the inspector 

to identify the potential consequences10

Ineffective Inspector Training and a Lack of Adequate Data Have

Hindered Risk-Based Oversight Efforts

that could result if the hazard is not 

addressed. Through this analysis, inspectors create action items to ensure the 

repair station has addressed the risk factors. Although FAA guidance suggests that 

inspectors use the RMP tool in instances where significant or systemic hazards 

occurred, the inspector did not use it to mitigate the risks he identified with the 

repair station’s training and material handling programs.

FAA inspectors we interviewed stated they did not know how to use the risk 

assessment tools effectively because they were not formally trained. According to 

FAA headquarters officials, inspectors were trained11

Further, FAA has not provided data analysis enhancements to inspectors that 

would improve their ability to assess repair station risk. When FAA implemented 

its new oversight system in 2007, it stated it would provide inspectors with a 

Repair Station Data Package,

on how to use the system’s 

two new risk-based tools during a course conducted at FAA’s training academy. 

However, nearly all—33 of 36 inspectors we spoke with on this issue—stated 

either they were not trained, did not recall the training, or regarded it as poor. The 

inspectors stated that they only reviewed a PowerPoint presentation provided by 

FAA or resorted to other means of learning how to conduct and document their 

risk assessments, such as asking other inspectors for assistance.

12

 10 FAA defines a potential consequence as an equipment failure, process breakdown, human error, injury/death to 

persons, damage to equipment, noncompliance with regulations or nonconformance with procedures.

which would assist them in collecting and 

analyzing data used to improve their risk assessments. However, inspectors have 

been using the new risk-based oversight approach for 5 years and FAA has not yet 

developed the data package. Currently, inspectors do not have a single point of 

11 FAA Training Course No. 21058, Certification and Surveillance of Part 145 Repair Stations. 12 According to FAA guidance, the Repair Station Data Package is intended to be a collection of comprehensive data 

analyses (e.g., surveillance and enforcement activities) available to inspectors to more easily assist them with 

identifying risks associated with repair station performance.
10

reference for details, history, and trends on the repair stations they oversee, so they 

must rely on their own methods to collect and analyze data.

13

FAA DOES NOT HAVE AN EFFECTIVE OVERSIGHT PROCESS 

FOR FOREIGN AND DOMESTIC REPAIR STATIONS

While FAA 

headquarters officials state the Repair Station Data Package is available, 15 of 25

inspectors we interviewed on this issue either were not familiar with it, felt the 

guidance was not clear, or they did not know how to access the information.

In addition to lacking a fully risk-based oversight approach, FAA’s ability to 

conduct effective and consistent inspections of foreign and domestic repair 

stations is hindered by a lack of standardized inspection processes. As a result, we 

found numerous systemic deficiencies at the foreign and domestic repair stations 

we visited during our review.

Lack of Standardized Processes Has Resulted in Inconsistencies in

FAA’s Surveillance of Repair Stations and Confusion Among Repair 

Station Officials

We identified weaknesses in FAA’s processes for conducting consistent 

inspections, performing sufficient reviews of repair station corrective actions, and 

effectively conveying deficiencies to repair station officials. For example, 

inspectors do not use formalized checklists, do not fully document areas they 

reviewed in FAA’s inspection database, and do not clearly communicate postinspection results so repair station officials can develop comprehensive corrective 

action plans.

Lack of Checklist and Insufficient Documentation of Areas Inspected

Inspectors do not use standardized checklists to guide their surveillance activities, 

which results in inspectors using differing inspection methodologies and 

inconsistently reporting their findings. While FAA guidance suggests areas that 

repair station inspectors should review, the guidance does not specifically require 

them to use an inspection checklist. Instead, inspectors rely on their own 

knowledge of repair stations, or they develop their own checklists to conduct

reviews. Over half of the inspectors we interviewed on this issue—19 of 33 —did 

not use a checklist to perform inspections. In addition, inspectors do not clearly 

identify and document which areas were reviewed in the inspection database. As a 

result, it is difficult to determine whether inspectors focused their resources on 

areas in which previous discrepancies were identified.

 13 Conversely, FAA has provided a data package to its 14 CFR part 121 inspectors to assist them with more consistent 

and accurate analysis of air carrier operations.
11

Insufficient Verification of Corrective Actions

Inspectors do not verify whether repair stations have implemented effective 

corrective actions to address inspection findings. The ability to track the adequacy 

of corrective actions is important to ensure that repair stations operate in 

accordance with FAA standards. Once a repair station submits a corrective action 

plan to FAA, inspectors are responsible for reviewing actions taken and either 

accepting or rejecting the plans based on the sufficiency of the proposed actions.

For example, FAA inspectors for an airframe repair station accepted a corrective 

action plan with projected completion dates even though repair station officials 

stated in their response that they needed further clarification from FAA for four of 

the findings. In addition, a training deficiency (i.e., the repair station failed to 

maintain a current list of required mechanic training) persisted at one repair station 

for 3 years, indicating the repair station’s corrective actions were not effective 

each year. Without verification that repair stations have implemented effective

corrective actions, inspectors cannot be assured that previous deficiencies will not 

reoccur.

Inadequate Communication of Inspection Results

FAA inspectors do not have a standardized means of conveying identified 

discrepancies to repair station officials, which leads to confusion and difficulty in 

implementing practical corrective actions. Some inspectors provided written notes

at the end of the inspection and some merely provided a verbal debrief. Repair 

station officials at 6 of the 13 foreign repair stations we visited stated that FAA 

inspectors did not clearly communicate their inspection findings. In some 

instances, FAA’s written repair station reports contained vague descriptions of 

inspection findings. For example, an inspector provided the following inspection 

finding to the repair station:

“A repair station may perform maintenance, preventative 

maintenance or alterations to an air carrier in accordance with their 

FAR 121 maintenance programme. Personnel need to be trained on 

the requirements outlined in the FAR 121 air carriers (sic) manual.”

In other instances, inspectors included more findings in the written report than was 

verbally conveyed at the conclusion of the inspection. As a result, repair station 

officials are often confused and frustrated as to what actions are needed to address 

FAA inspectors’ concerns. According to repair station personnel, if FAA 

inspectors had provided a written report at the post-inspection briefing, they could 

have reached a consensus on the nature of the findings and proposed corrective 

actions. Officials from one foreign repair station were so frustrated by poor 

communication with its inspectors that they decided it was easier and more 

efficient to fly to the United States to meet with FAA for clarification and 

guidance.
12

Other examples of inconsistent FAA inspector actions that resulted in repair 

station confusion include:

• An FAA inspector required a foreign repair station to include a provision in 

its operating capabilities that authorized it to perform work offsite. While 

repair station personnel repeatedly insisted that they only conduct 

maintenance at their main base, they ultimately relented and complied with 

the inspector’s request. However, when a new inspector was assigned to the 

repair station, he directed them to remove the authorization because it was 

not needed.

• During an FAA inspection of an airframe repair station, an inspector 

determined that the repair station had not changed its manual based on the 

handwritten notes the inspector provided during his previous visit. When 

the inspector questioned why the repair station official had not made the 

suggested changes to the manual, he seemed confused. According to the 

repair station official, he assumed that since the suggested changes were 

presented on handwritten notes and not presented in a written report of 

findings, they were not urgent.

Systemic Deficiencies Persist at Repair Stations

Our review of work order packages at foreign and domestic repair stations 

disclosed systemic deficiencies, including insufficient mechanic training, outdated 

tool calibration, and inaccurate work order documentation. These deficiencies are 

particularly troubling because they occurred in areas that FAA requires inspectors 

to review annually, including training, maintenance processes, technical data, and 

quality control. Overall, our review of 119 randomly selected aircraft work orders 

in these four areas, coupled with our examination of tools and equipment at each 

facility, disclosed 92 systemic deficiencies. Based on the results of our statistical 

sample of 27 repair stations, we estimate that 217,641 (37 percent) of the 

estimated 589,573 work orders from September 2008 to August 2011 from 

domestic and foreign repair stations (where FAA performs its own inspections) 

had deficiencies in these five areas.

14

 14 Our estimate of 217,641 has a precision of +/-28,919, and our estimate of 589,573 has a precision of +/-254,066 at 

the 90-percent confidence level.

As shown in figure 3 below, training for 

repair station personnel was the number one category for errors at the repair 

stations we reviewed.
13

Figure 3. Number of Work Order Deficiencies by Category

Source: OIG analysis of repair station work orders

Training Documentation Issues

Of the 27 repair stations we reviewed, 21 did not maintain accurate training 

records for mechanics and inspection personnel which are required to demonstrate 

that they were properly trained and qualified to perform repairs or inspect aviation 

parts. Repair stations are required to submit their training programs to FAA for 

approval. The program must ensure that individuals performing maintenance are 

capable of performing assigned tasks by completing initial and recurrent training. 

In addition, if a repair station performs work for a commercial air carrier, the 

employees must also be trained in accordance with the air carriers’ requirements.

FAA inspectors are required to review training documentation at repair stations 

annually to determine whether all required training has been completed and 

appropriately documented at each station. Despite these requirements, repair 

station officials did not have documentation to show that employees had been 

trained to perform the assigned tasks required in 45 of 119 work orders in our 

sample. Examples of the training documentation issues include:

• Employees at an engine repair station did not receive the required 

maintenance manual course prescribed by the air carrier.

• Employees that serviced aircraft life vests and rafts did not use the proper 

forms to document training received for hydrostatic testing or charging 

inflation systems.

• Employees at an aircraft paint facility did not receive the required training 

to perform work for two U.S. air carriers.

21

13

10

5

4

No. of Repair Stations with 

Deficiencies by Category 

Training

Tools & Equip

Maintenance 

Process

Technical Data

Quality Control

45

17

16

9

5

No. of Times the Deficiency 

was Identified

Training

Tools & Equip

Maintenance 

Process

Technical Data

Quality Control
14

Based on the results of our statistical sample, we can project that 175,552—or 

30 percent—of the estimated 589,573 work orders from September 2008 to 

August 2011 from domestic and foreign repair stations (where FAA performs its 

own inspections) have discrepancies related to training documentation.15

Tools and Equipment Issues

Nearly half of the repair stations (13 of the 27) we visited had weaknesses in their

tool and equipment programs. FAA guidance requires inspectors to review repair 

station manuals describing the tool and equipment calibration process and verify 

that repair stations are calibrating tools within the required intervals, usually once 

a year. However, our review revealed that specialized tools and equipment were 

used to test and repair aircraft parts beyond their required calibration due dates. 

For example, mechanics at a turbine engine repair station conducted postmaintenance checks on three engines using equipment believed to be properly 

calibrated. However, we examined calibration due dates for test cell equipment 

used to validate the engine repairs and determined that at the time of the engine 

checks, the equipment was overdue for annual calibration. Following 

manufacturers’ specified intervals for calibrating tools and equipment is 

paramount to ensuring that aircraft operate safely and aviation parts are properly

maintained.

Other examples of repair stations that lacked adequate control over their tool and 

equipment programs include:

• A repair station that services safety equipment, such as life rafts, could not 

locate some of its tools and had tools that either exceeded required 

calibration intervals or did not have calibration stickers.

• Officials at an airframe repair station continued to track a wire crimping 

tool that had been missing for 2 years and was overdue for calibration, but 

they never accounted for its whereabouts.

• Employees at a landing gear repair station were not following procedures 

for identifying tools that were owned by individual mechanics, especially

those that require calibration. Repair station procedures required that

personal tools be inscribed with a serial number and employee initials; 

however, we found employees using unidentified personal tools.

According to inspection records, FAA inspectors did not find any tool calibration 

discrepancies at an engine repair facility in the 3 years prior to our visit, yet we 

found four tools past due for calibration. This was also the case at the repair 

 15 Our estimate of 175,552 has a precision of +/-26,365, and our estimate of 589,573 has a precision of +/-254,066 at 

the 90-percent confidence level.
15

station where we found overdue calibration due dates on engine test cell 

equipment. Ultimately, overdue calibration on specialized tools and equipment 

and use of unapproved personal tools could result in the use of aircraft parts that 

do not meet manufacturers’ specifications.

Maintenance Process Issues

We found deficiencies in maintenance practices at 10 of 27 repair stations we 

visited. FAA inspection guidance states that inspectors should identify a repair 

station process to be inspected, identify the documents associated with that process 

(i.e., task cards, work orders, maintenance manuals), and follow the documents 

through the process to determine whether personnel are following repair station 

procedures. Our review disclosed deficiencies where employees did not complete 

work orders to document technical data they used during repairs, used incorrect 

employee stamps to document completion of work steps, or signed off on work 

steps that they were not authorized to complete. In particular, two inspectors at a 

repair station signed off on critical inspection tasks16

Based on the results of our statistical sample, we project that 43,769—or 

7 percent—of the estimated 589,573 work orders from September 2008 to August 

2011 from domestic and foreign repair stations (where FAA performs its own 

inspections) have discrepancies related to maintenance processes.

without the proper 

authorization from the air carrier. This work involved repairs to the nose wheel 

steering cables on a Boeing 717 aircraft. The errors in the work orders indicate the 

repairs were not performed in accordance with the air carrier maintenance 

procedures, raising questions about the quality of the work performed at these 

facilities.

17

CONCLUSION

Effective and consistent oversight of aircraft repairs is a key element to 

maintaining the safety of commercial air carrier operations. With growth in 

aircraft repair station use projected to reach $76 billion by 2021, these facilities 

continue to be an integral part of air carrier maintenance. While FAA has made 

strides in improving its inspections of repair stations by implementing a new 

oversight system, this system falls short of being truly risk based, especially for 

foreign repair stations. FAA must take further steps to improve the effectiveness 

of its risk-based tools and inspector training so that they can target oversight 

towards those repair stations most at risk and better detect systemic deficiencies. 

Until the Agency modifies its inspection system, FAA’s ineffective oversight 

 16 Also known as Required Inspection Items, or RII. RII work steps require a repair station inspector to verify the 

accuracy of the mechanic’s repair.

17 Our estimate of 43,769 has a precision of +/-10,963, and our estimate of 589,573 has a precision of +/-254,066 at the 

90-percent confidence level.
16

could lead to repair stations operating contrary to Federal aviation regulations and 

decreasing the margin of safety.

RECOMMENDATIONS

To enhance its oversight of repair stations, we recommend that FAA:

1. Modify its oversight system so that all inspection elements are considered 

in inspector risk assessments of repair stations.

2. Implement a risk-based system appropriate for oversight of foreign repair 

stations.

3. Modify the risk assessment tool so that inspectors can document changes to 

their surveillance plans as soon as they are made.

4. Develop a control that will ensure inspectors prioritize inspections to those 

repair stations determined to have increased risk.

5. Enhance training for inspectors so they understand the importance of using 

the available tools for assessing and trending risk.

6. Develop the Repair Station Data Package and provide training to all 

inspectors on how to use it.

7. Develop a standardized checklist that all inspectors can use to improve the 

consistency in the way they perform and report their inspection findings.

8. Provide training for inspectors to improve their review and acceptance of 

repair station corrective plans.

9. Provide training to inspectors on how to conduct comprehensive postinspection briefings and require them to issue a draft report of tentative 

findings to repair station officials at the conclusion of inspections.

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE

We provided a draft of this report to FAA on January 25, 2013, and received its 

response on April 4, 2013, which is included in its entirety as an appendix to this 

report. FAA concurred with all nine of our recommendations, and its response 

meets the intent of six of them. In its response, FAA cited the development of a 

new oversight system—the Safety Assurance System (SAS)—to address our 

recommendations. However, because FAA plans to only begin implementing SAS 

sometime in fiscal year 2015—a 2-year delay from its originally planned rollout in 
17

fiscal year 2013—the Agency has developed strategies and established near-term 

milestones to improve its current oversight system in the interim. Until SAS is 

fully implemented, we believe that FAA’s planned interim actions meet the intent 

of recommendations 2, 5, 6, 7, 8, and 9 and include reasonable timeframes.

However, for recommendations 1, 3, and 4, FAA’s interim actions do not address 

our concerns, and we are requesting that FAA reconsider its responses, as detailed 

below.

Specifically, for recommendation 1, FAA stated that it will conduct recurrent 

training to improve the use of the RSAT as it was originally intended until SAS is 

implemented. However, FAA’s response does not address our overarching 

concern that inspectors continue to complete mandatory inspections instead of 

targeting resources where they are needed based on risk. As our report indicates, 

some inspectors do not use the risk assessment process at all, and those that do are 

hindered in their ability to assess risk, due in part to the RSAT’s limitations with

data availability and quality. While additional training will be helpful, it will not 

address the fact that FAA guidance requires only seven inspection elements to be 

assessed for risk while the other nine are inspected annually, regardless of risk. To 

ensure that the Agency effectively targets its inspection resources by risk, we are 

asking FAA to reconsider its position and implement an interim action that is 

responsive to our recommendation.

For recommendation 3, FAA also cited its plans to provide recurrent training to

refamiliarize inspectors and their managers with the RSAT’s capabilities so that 

they may document changes to their surveillance plans as soon as they are made. 

However, while we recognize that inspectors can adjust their surveillance plans at 

any time (i.e., by increasing or decreasing the number of inspections as a result of 

changes in risk), they cannot input these changes in the RSAT after it has been 

prepared at the beginning of each annual inspection cycle. Providing inspectors 

with additional training will not address the fact that the RSAT, in its current form,

does not allow inspectors to track changes in risk in real time at repair stations. 

Therefore, we are asking FAA to reconsider its position and provide interim 

actions that are responsive to our recommendation.

For recommendation 4, FAA indicated that it expects inspectors to prioritize 

inspections to those repair stations determined to have increased risk, and it plans

to conduct recurrent training to emphasize this requirement. While we agree that 

training can help reinforce requirements, we are concerned that FAA still lacks a 

method for verifying whether inspectors actually meet the requirements. Given our 

findings that many inspectors do not effectively prioritize their inspections based 

on risk, we believe an additional control is necessary to ensure compliance with 

this important requirement. Therefore, we are asking the Agency to reconsider its 

response and develop a formalized control or another appropriate interim solution.
18

ACTIONS REQUIRED

We consider recommendations 2 and 5 through 9 resolved, but open pending the 

completion of planned actions. For recommendations 1, 3, and 4, we request that 

FAA either provide additional information or reconsider its position as described 

above. In accordance with Department of Transportation Order 8000.1C, we 

request that FAA provide this additional information within 30 days of this report.

We appreciate the courtesies and cooperation of FAA representatives during this 

audit. If you have any questions concerning this report, please call me at 

(202) 366-0500 or Tina Nysted, Program Director, at (404) 562-3770.

#

cc: DOT Audit Liaison, M-1

FAA Audit Liaison, AAE-100
19

Exhibit A. Scope and Methodology

EXHIBIT A. SCOPE AND METHODOLOGY

We conducted this review between January 2011 and January 2013 in accordance 

with generally accepted Government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable basis for 

our findings and conclusions based on our audit objectives.

Our audit work was conducted at all of the 10 FAA Flight Standards District 

Offices, four International Field Offices/Units, and one Certificate Management 

Office that had oversight responsibility for the repair stations in our review. We 

used a 2-stage statistical sampling methodology to select these 27 aircraft repair 

stations. For Stage 1 we stratified our universe of 68 repair stations that perform 

work for U.S. Part 121 airlines, and are not covered under BASA-MIP inspection 

procedures into two strata. From Stratum 1 we selected 5 states out of 45, and 

from Stratum 2, we selected 5 foreign countries out of 23 for a total of 10 

locations. These 10 locations had 250 repair stations which made up our Stage 2 

universe from which we selected 14 domestic aircraft repair stations out of 223 

and 13 foreign aircraft repair stations out of 27. Samples for both stages were 

selected with probability proportional to the number of air carrier customers with 

replacement. Our sample of repair stations was derived from a list provided by 

FAA. We included in our universe all 559 repair stations that had at least one 

customer.

To evaluate the effectiveness of FAA’s oversight of repair station maintenance, we 

interviewed 37 of 44 FAA inspectors responsible for oversight of repair stations in 

our review to gain an understanding of how they perform risk assessments and 

carry out their maintenance inspections. We used a questionnaire we developed 

with 22 questions. However, not all questions were asked of all inspectors.

Therefore, the number of inspectors who were asked and responded to certain 

questions during our interviews may vary. We interviewed repair station officials 

to gain their perspective on FAA’s oversight. We also analyzed inspection data 

(fiscal years 2009–2012) from FAA’s database and RSAT worksheets (fiscal years 

2010–2012) for all repair stations in our review.

To conduct our reviews at the 27 repair stations, we randomly selected 119 aircraft 

work order packages out of 49,859 from September 2008 to August 2011 to 

perform tests to determine whether mechanics received training to perform repairs, 

complied with prescribed maintenance and quality control processes, used 

appropriate technical data, and adhered to tool and equipment calibration 

standards. We also observed and noted general shop conditions and ongoing repair 

procedures during our tour of each repair station.
20

Exhibit B. Activities Visited or Contacted

EXHIBIT B. ACTIVITIES VISITED OR CONTACTED

FEDERAL AVIATION ADMINISTRATION

Headquarters:

Aviation Safety (AVS) Washington, DC

Flight Standards Service (AFS) Washington, DC

Flight Standards District Offices (FSDO):

Atlanta FSDO Hapeville, GA

Indianapolis FSDO Plainfield, IN

Long Beach FSDO Long Beach, CA

Lubbock FSDO Lubbock, TX

Orlando FSDO Orlando, FL

San Antonio FSDO San Antonio, TX

South Bend FSDO South Bend, IN

South Florida FSDO Miramar, FL

Teterboro FSDO Saddle Brook, NJ

Van Nuys FSDO Van Nuys, CA

International Field Offices or Unit (IFO/IFU):

Beijing IFU Beijing, China

Los Angeles IFO Lawndale, CA

Miami IFO Miramar, FL

Singapore IFO Singapore

Certificate Management Office (CMO):

American Airlines CMO Fort Worth, TX
21

Exhibit B. Activities Visited or Contacted

14 CFR PART 145 REPAIR STATIONS: 

Domestic

Hawker Pacific Aerospace Sun Valley, CA

HRD Aero Systems, Inc. Valencia, CA

MAG Aerospace Industries, Inc. Carson, CA

AAR Aircraft Services, Inc. Miami, FL

Accel Aviation Accessories, LLC Fort Myers, FL

HEICO Components Repair Group Miami, FL

RA Aviation Support Group Inc. Miami, FL

Bombardier Services Corporation Macon, GA

FellFab Corporation Atlanta, GA

BAE Systems Controls, Inc. Fort Wayne, IN

Rolls-Royce Engine Services, Inc. Indianapolis, IN

CAG Industries, LLC Fairfield, NJ

GE Aviation Systems, LLC Whippany, NJ

Zodiac Services Americas, LLC Wall Township, NJ

Chromalloy Component Services, Inc. San Antonio, TX

Leading Edge Aviation Services, Inc. Amarillo, TX

Texas Aero Engine Services, LLC Fort Worth, TX

Foreign

GE Celma Petropolis, Brazil

Rolls-Royce Brasil - Gas Turbine Services Sao Paulo, Brazil

TAP Maintenance & Engineering Brasil Rio de Janeiro, Brazil

Aircraft Maintenance and Engineering Corp. Beijing, China

Boeing Shanghai Aviation Services Co., Ltd. Shanghai, China

MTU Maintenance Zhuhai Company, Ltd. Zhuhai, China

Air New Zealand Engineering Services Auckland, New Zealand 

Air New Zealand Engineering Services Christchurch, New Zealand

Pratt and Whitney Air New Zealand Christchurch, New Zealand

SEMAN-Peru Lima, Peru
22

Exhibit B. Activities Visited or Contacted

14 CFR PART 145 REPAIR STATIONS (cont.): 

Eagle Services Asia PTE, Ltd. Singapore

GE Aviation Service Operation, LLP Singapore

ST Aerospace Services Co. PTE, Ltd. Singapore

OTHER INDUSTRY REPRESENTATIVES OR ORGANIZATIONS:

Aeronautical Repair Station Association (ARSA) Alexandria, VA

Professional Aviation Safety Specialists (PASS) Washington, DC
23

Exhibit C. FAA-Certificated Repair Station Locations

EXHIBIT C. FAA-CERTIFICATED REPAIR STATION LOCATIONS
24

Exhibit D. Repair Station Assessment Tool (RSAT)

EXHIBIT D. REPAIR STATION ASSESSMENT TOOL (RSAT)
25

Exhibit E. Major Contributors to This Report

EXHIBIT E. MAJOR CONTRIBUTORS TO THIS REPORT

Tina Nysted Program Director

Name Title

Kevin George Project Manager

Anne Longtin Senior Analyst

Taniesha Willis Senior Analyst

Nathaniel Caldwell Auditor

Manuel Ramos Auditor

Audre Azuolas Writer/Editor

Petra Swartzlander Senior Statistician

Megha Joshipura Statistician
APPENDIX. AGENCY COMMENTS 26

Appendix. Agency Comments

Federal Aviation

Administration

Memorandum

Date: April 4, 2013

To: Jeffrey B. Guzzetti, Director, Assistant Inspector General for Aviation and Special 

Program Audits

From: H. Clayton Foushee, Director, Office of Audit and Evaluation, AAE-1

Subject: Federal Aviation Administration (FAA) Response to Department of Transportation 

Office of Inspector General (DOT OIG) Draft Report: Repair Station Oversight

The FAA has a rigorous, risk-based system of oversight for repair stations and is taking action to 

rectify performance gaps that contributed to the issues identified in the OIG draft report. 

Specifically, the agency is increasing its management focus upon ensuring that Aviation Safety 

Inspectors (ASIs) make full and correct use of current guidance and oversight tools. In the near 

term, the agency will improve inspector training and policy guidance in order to provide more 

comprehensive and standardized procedures for conducting inspections and reporting inspection 

findings. Over the longer term, FAA is also working to improve the capabilities and 

performance of the risk-based analytical tools available to inspectors. These enhancements will 

result in more consistent inspection practices that will improve the detection of systemic 

deficiencies and increase the effectiveness of repair station safety oversight. 

RECOMMENDATIONS AND RESPONSES

Recommendation 1: Modify its oversight system so that all inspection elements are 

considered in inspector risk assessments of repair stations.

FAA Response: 

Concur. Since 2007, the FAA has used the Repair Station Assessment Tool (RSAT) as part of 

its enhanced repair station oversight program. RSAT is comprised of policies and procedures 

and a supporting automation tool, which enable the FAA to employ system safety methodology 

and to review past findings to plan and aid risk-based oversight. The current RSAT allows the 

inspector to review annually the elements contained in a “main base” inspection. The elements 

are as follows:

1. Parts and Materials; 

2. Certificate Requirements;

3. Records Systems; 

4. Housing and Facilities;
27

Appendix. Agency Comments

5. Tools and Equipment; 

6. Personnel Records;

7. Manuals;

8. Quality Control;

9. Maintenance Process; 

10. Technical Data;

11. Training;

12. Work Away from Station;

13. Contract Maintenance Noncertificated;

14. Contract Maintenance Certificated;

15. Air Carrier and Air Operator Requirements; and

16. European Aviation Safety Agency (EASA) Oversight Audit.

The first seven elements of the inspection above are basic to the repair station and include 

standard quality control elements. For these reasons, the FAA has made the decision to 

automatically generate required inspection of the first seven elements if they have not received 

an inspection in the previous 2 years. Elements 8 through 11 are required inspection items and 

are not based upon the repair stations’ capabilities. Elements 12 through 16 are based upon the 

repair stations capabilities. 

As evidenced by the OIG’s findings, some inspectors would benefit from additional training on 

the RSAT. Accordingly, the FAA will conduct recurrent training/workshops to improve the use 

of the RSAT as it was intended. This will be completed by December 31, 2013.

Based upon our past field experience with RSAT and the recommendations from OIG, the FAA 

will also modify its oversight system. The FAA is developing the next generation of surveillance 

and analytical tools called the Safety Assurance System (SAS). SAS applies to both air carriers 

and repair station certificate holders. SAS information sharing features, which include 

automated data collection tools, will give ASIs a more comprehensive picture of the certificate 

holder’s risk environment. As a result, SAS will improve the ASI’s ability to prioritize and 

develop a risk-based oversight work program. SAS will further enhance the FAA’s ability to 

assess the health of repair station systems and ensure that risk is identified, documented, tracked, 

and effectively managed. 

In July 2012, the FAA provided a briefing on the development and implementation of SAS to the 

OIG and demonstrated how the new system will address the recommendations in the draft audit 

report SAS deployment is scheduled to begin in Fiscal Year (FY) 2015.
28

Appendix. Agency Comments

Recommendation 2: Implement a risk-based system suitable for oversight of foreign repair 

stations.

FAA Response: Concur. RSAT is the FAA’s current repair station risk-based oversight 

program for all repair stations, both within the U.S. and outside the U.S. In the near term, FAA 

is developing a training/workshop for all airworthiness inspectors and managers and to more 

completely convey the expectation that all International Field Offices are required to utilize the 

RSAT protocols. This will be accomplished by December 31, 2013. Once the briefings are 

complete, the FAA will amend current inspector guidance to reinforce the use of the RSAT tool 

and will publish updated guidance by March 28, 2014. 

Over the longer term, FAA is developing SAS tools that will provide enhanced risk assessment 

capabilities for both U.S. and foreign repair stations when they come online. 

Recommendation 3: Modify the risk assessment tool so that inspectors can document changes 

to their surveillance plans as soon as they are made.

FAA Response: Concur. Using RSAT now, an inspector is able to modify the surveillance 

plan. The results of the RSAT assessment may be used to add further required inspections and to 

include follow-up inspections in the annual program. The inspector is also able to cancel or 

terminate these inspections later in the year, if warranted.

The RSAT tool organizes and synthesizes information and provides it to an inspector in a 

manner that enables the inspector to plan surveillance. It is also a tool for the inspector to 

evaluate risk and incorporate the findings into an annual plan. Other factors, such as the 

National Work Program Guidelines, influence the surveillance plan. The program guidelines 

enumerate the minimum inspection requirements for each operator. A third factor may be 

changes in the repair station business, management or personnel. The minimum requirements, 

plus the risk indicators, allow an inspector to develop a surveillance plan. Currently, it can be 

modified by adding specific inspections to address risk indications or eliminate them if 

conditions no longer apply. Inspections can also be terminated if the repair station goes out of 

business or surrenders its certificate. The modifications are done at the local office level. The 

regional office monitors the minimum requirements for repair stations to ensure that each 

certificate holder receives one inspection per year in accordance with the NPG requirements.

During the recurrent training/workshop that is being developed for all airworthiness inspectors 

and their managers, the FAA will re-familiarize the inspectors and their managers with the 

RSAT’s capabilities so that they may document changes to their surveillance plans as soon as 

they are made. The FAA plans on accomplishing the training/workshop by December 31, 

2013, and once the briefings are complete the FAA will amend the guidance to reinforce the 

use of the RSAT by March 28, 2014. 

Additionally, the FAA is developing SAS to allow inspectors the ability to change, and 

document changes to their surveillance plans at any time. SAS policy allows inspectors to 

change planned due dates of all assessments and provides guidance on how and when to do so. 

All plan changes and justifications for those changes are documented in the SAS program. 
29

Appendix. Agency Comments

Recommendation 4: Develop a control that will ensure inspectors prioritize inspections to 

those repair stations determined to have increased risk. 

FAA Response: Concur. The FAA expects that the inspector workforce and local office 

managers will prioritize inspections of repair stations that show increased risk. Inspectors, 

supervisors and local office managers are expected to identify and respond to risk indicators and 

mitigate them through increased or targeted surveillance. If the risk indication is validated and 

the inspections show a regulatory violation, then the inspector will pursue enforcement action. 

FAA’s recurrent training/workshop will emphasize the responsibility to prioritize inspections to 

those repair stations determined to have increased risk. This will be accomplished by 

December 31, 2013.

In the long-term, FAA policy, supported by automation, will require automated triggers or 

parameters in SAS to ensure inspectors prioritize inspections for all repair stations showing 

increased risk. Management controls will exist within SAS to ensure that inspections and other 

resources are assigned to the highest risk areas first. Policy requires a second level review and 

final concurrence by a frontline manager of the overall inspection plan proposed by the 

inspector. In addition, policy requires inspectors to complete a risk assessment of the repair 

station using a list of risk indicators at least once per year. Results of that assessment must be 

documented in SAS automation and used by the inspector to prioritize repair station inspections. 

SAS will require adjustments to the oversight plan if the risk evaluation changes over time. If 

risk increases, surveillance will increase and if risk diminishes, surveillance may be reduced. 

Recommendation 5: Enhance training to inspectors so that they understand the importance of 

using the available tools for assessing and trending risk. 

FAA Response: Concur. During meetings with the OIG, the FAA provided records showing 

that inspectors had received training in the use of the RSAT and other tools for assessing and 

trending risk. However, the audit findings suggest, that inspectors either did not retain the 

information, or that the training did not provide adequate instructions in the use the tools. 

Therefore, the FAA is developing a recurrent training/workshop to be provided to the inspector 

workforce. The FAA, by December 31, 2013, will brief the Flight Standards Regional Division 

managers and maintain completion records to ensure that each inspector, assigned to 14 CFR, 

part 145 oversight, has received the recurrent training/workshop on the use of the RSAT and 

other available tools for assessing and trending risk.

As the FAA moves towards a Safety Management Systems (SMS) and begins its 

implementation, the FAA will again provide courses pertaining specifically to an inspector’s job 

responsibilities. This includes the use of current assessment tools and instructions. These 

courses will be reviewed and may change with the implementation of SAS. They are:

• SMS Training; and 

• SMS Theory and Application. 

In addition to the courses listed above, the FAA is developing training to teach inspectors the 

new concepts and tools that will be found in SAS. The following courses will include 
30

Appendix. Agency Comments

instruction on available tools used for identifying and assessing risk: 

• Introduction to SAS – Provides fundamental knowledge of SAS concepts and tools;

• SAS for Inspectors and Field Office Management – Will include specific lessons and 

exercises in the use of SAS tools used to assess and analyze risk;

• SAS for Repair Stations Located Outside of the United States – Instruction on the 

unique oversight and data collection requirements for repair stations located outside the 

United States such as the use of custom data collection tools to enable inspectors to 

identify and assess risk;

• SAS Analysis, Assessment and Action – Will provide specific instruction in the SAS 

tools used to analyze and assess inspection results and how to use those results to 

identify and assess risk, track corrective actions, and use the data to prioritize future 

inspections; and

• SAS for Managers – Provides managers with an overview of all available risk 

assessment tools within SAS and management’s roles and responsibilities in SAS.

Once these courses are available, they will assist inspectors in understanding the overall 

purpose of SAS and how to use the available tools most effectively. The FAA plans to have 

these training courses completed prior to SAS deployment, scheduled to being in FY 2015. 

Recommendation 6: Develop the Repair Station Data Package and provide training to all 

inspectors on how to use it.

FAA Response: Concur. At present, FAA inspectors have the capacity to produce a data 

package through the Safety Performance Analysis System (SPAS). SPAS is an automation 

system that provides inspectors with information to organize and support their inspection 

activities and planning. However, to accomplish this, inspectors must go to more than one 

location within the SPAS to obtain requisite information. Therefore, during the recurrent 

training/workshop that is being developed for all airworthiness inspectors and their managers, 

the FAA, by December 31, 2013, will include a section that shows how to obtain a data package 

to plan surveillance. 

After this training/workshop, the FAA will revise guidance to include a clearer, step-by-step 

guide so that inspectors can obtain a data package. Additionally, the FAA will amend the 

training course to show how to develop a data package using the information currently 

available in SPAS and will revise FAA Order 8900.1 Volume 6, Chapter 13, Repair Station 

Oversight Process to define and use of data packages by March 28, 2014.

Also, when SAS is deployed in FY 2015, it will provide a repair station data package that 

directly supports the SAS oversight process. In addition, standard data reports will be available 

from the inspector’s homepage in SAS. Training will be provided on how to analyze and 

assess available data in courses such as “SAS Analysis, Assessment and Action” and “SAS for 

Inspectors and Field Office Management.” 
31

Appendix. Agency Comments

Recommendation 7: Develop a standardized checklist that all inspectors can use to improve 

the consistency in the way they perform and report their inspection findings.

FAA Response: Concur. A standardized checklist is presently available in FAA Order 8900.1, 

Volume 6, Chapter 9, Section 2: Team Focused In-depth Inspection of a Part 145 Repair 

Station. The FAA will emphasize the importance of the checklist through the recurrent 

training/workshop being developed for all airworthiness inspectors and their managers by 

including the standardized checklist from the guidance mentioned above and will require that 

airworthiness inspectors use the checklist and ensure this occurs through oversight of the local 

offices. However, based on the recommendation, the FAA will work on a refinement of this 

checklist for the individual inspector and plan on completing this action by March 28, 2014.

The FAA is also actively developing a standard checklist (through data collection tools) that will 

allow individual inspectors to improve consistency in future assessments of repair stations. This 

standardized checklist is part of SAS deployment scheduled to begin in FY 2015. 

Recommendation 8: Provide training for inspectors to improve their review and acceptance of 

repair station corrective plans.

FAA Response: Concur. During the recurrent training/workshop that is being developed for 

all airworthiness inspectors and their managers, the FAA will include a section on how to 

improve the review and acceptance of repair station corrective plans. This briefing will be 

accomplished by December 31, 2013.

Although the FAA has current training on this subject, the draft report results reveal that a 

revision is necessary. This revision will be added to the current FAA Course 21058: 

Certification and Surveillance of Repair Stations. To improve the inspectors’ review and 

acceptance of repair station corrective plans, training in this subject area will be added to Lesson 

11, Certificate Management and Surveillance. The FAA plans to complete the revision of this 

course by February 28, 2014.

Additionally, with the future deployment of SAS, SAS training will instruct inspectors to use 

SAS tools to verify whether corrective actions taken by a certificate holder properly address the 

issues found during design or performance assessments.

Recommendation 9: Develop guidance and training to inspectors on how to conduct 

comprehensive briefings to repair station officials on inspection findings.

FAA Response: Concur. During the recurrent training/workshop being developed for all 

airworthiness inspectors and their managers, a section on how to conduct comprehensive 

briefings to repair station officials on inspection findings will be included in the briefing. The 

FAA plans on accomplishing this by December 31, 2013.

Although the FAA has courses currently that provide information on conducting comprehensive 

briefings to repair station officials on inspection findings, the FAA will evaluate the courses to 

determine their efficacy by December 31, 2013. Additionally, the FAA will determine whether 

or not they should be made mandatory for all airworthiness inspectors. The following courses 

will be evaluated for these enhancements: 
32

Appendix. Agency Comments

• FAA Course 21058 - Certification and Surveillance of Part 145 Repair Stations; and 

• FAA Course 28463 - Basic Compliance Auditing for AVS Personnel, Phase 3. This 

course encompasses training on how to conduct comprehensive in-and out-briefings. 

This course is available to inspectors involved in the auditing process; however, FAA 

will evaluate and determine if it provides sufficient knowledge on conducting 

comprehensive briefings to repair station officials.