SUBJECT: 25 Days and Counting until the New 145 takes effect.

REFERENCE: 14 Code of Federal Regulation (CFR) Part 145 (Federal Register dated: August 6, 2001 Page 44087)

Part 145 Extension (Federal Register dated: September 29, 2003 Page 55819)

SUMMARY: The effective date of the final rule amending 14 CFR parts 91, 121, 135, and 145 published on August 6, 2001, at 66 FR 41088 is delayed until January 31, 2004, with the following exception: Sec. 145.163 remains effective April 6, 2005.

MAJOR HIGHLIGHTS: A currently certificated repair station must submit their Repair Station Manual and their Quality Control Manual (considered to be revisions of their current IPM) to their Certificate Holding District Office before January 31, 2004.

The RSM and QCM are not explicitly approved or accepted by the local FSDO ASI. A manual is deemed acceptable when it meets the requirements of the applicable regulations. The manuals will be reviewed by the FAA to determine conformity to the regulations.

There are two issues that require explicit FAA approval before January 31. The list of contract functions must be approved prior to out sourcing any maintenance after January 31, and the procedures for performing a self-audit (if applicable) needs to be reviewed and accepted by the FAA before January 31.

Maintenance Function: A maintenance function is a step or series of steps in the process of performing maintenance, preventative maintenance, or alterations, which result in approving an article for return to service. Any function that is outsourced to another person (either certificated or not) needs to be approved. It is the function that must be approved not the contractor. The contractor list is only required to be kept in a method acceptable to the FAA and available for viewing.

Self Audit: A self audit is used by a repair station who hold a limited rating and who elects to maintain their capability list as part of their RSM in lieu of keeping their capability list on their Ops Specs.

AEA COMMENTARY: The Association encourages every repair station to have their manuals prepared and delivered to the local FSDO early so that we may help the local FAA offices make this transition as smoothly as possible.

To help those members who have not yet prepared their manuals, AEA has made the AEA Part 145 Manuals Transition Guidance Workbook available for downloading on the member’s only side of Resource One.

FMI: www.aea.net