[Denny of Oakland]

A repairman should be assigned to a position in which he/she is responsible for the work of a shop or department that performs maintenance and be authorized to perform required inspections or be authorized to sign the airworthiness release or log entry. (Reference AC 65-24)

To be eligible for a repairman certificate each applicant is required by Section 65.101. You are specially qualified to perform maintenance on aircraft or components thereof, appropriate to the job for which he/she is employed.

The holder of a repairman certificate employed by a certificated repair station, a manufacturer's maintenance facility, or the holder of an air carrier operating certificate may perform or supervise the maintenance, preventive maintenance, or alteration of aircraft or aircraft components appropriate to the job for which the repairman was employed and certificated. Unless the repairman understands the current instructions of the certificate holder by whom he/she is employed and the manufacturer's instructions for continued airworthiness, that person may not perform or supervise duties under his/her repairman certificate.

Having said the above the Part 145 repair station is responsible for the actions of its employees reference Part 145.153 and § 145.155 Inspection personnel requirements.
(a) A certificated repair station must ensure that persons performing inspections under the repair station certificate and operations specifications are--
(1) Thoroughly familiar with the applicable regulations in this chapter and with the inspection methods, techniques, practices, aids, equipment, and tools used to determine the airworthiness of the article on which maintenance, preventive maintenance, or alterations are being performed; and

If you did not understand the Repair Station Manual (RSM) or the Quality Control Manual (QCM) or are thoroughly familiar with the applicable regulations as stated above then the FAA has an obligation to retest you under US Code Section 44709. You should remember the Repairman Certificate is a privilege not a license or right.

If you failed the test the FAA gave you on regulations they you were not thoroughly familiar with the applicable regulations and the FAA is required to revoke your certificate if you do not re-test.

The Part 145 Repair Station received a Letter of Investigation (LOI) because the shop did not follow its RSM/QCM by having the required current manual available during repair in accordance with Part 43.13. If you were the one responsible for not following the RSM/QCM and following its direction you are in violation of the Code of Federal Regulations as is the repair station. Sorry to hear about your situation, but the best thing to do at this point is study the following; Section 65.101, Part 43 and Part 145 and take the re-test as soon as possible.

I do not believe the FAA is out to put all small operators out of business regardless how conscientiously those operators try to do their jobs. We have to remember the rules were written back in 1958 and have not changed much since then with the exception of Part 145.

The rules have NOT become so stringent that it makes them impossible to follow. The rules were written to the minimum standard of 70%. What is wrong with having standards that meet the 70% or C average. I would hope shops are performing at above the C average on the aircraft I fly on.

I also hold an A&P/IA and don’t find the local FAA office spending all their time harassing local operators to avoid travel. Most the FAA guys I know would rather travel and spend time with operators because they used to be opertors before joining the FAA. I just don’t understand the exposure you are talking about. If you meet the C average you are meeting the standard.

I think a lot of people like to bash the FAA for making us maintain the C average and pointing it out when we get caught falling below the average. I have been working with a lot of younger kids wanting to get into aviation. I don't see a problem there either.

If you look at the enforcements the FAA does do its less than 1% of the aviation population. Every trade has problems aviation has a few people who do not want to follow the minimum standard and they make us all look bad.

Just one A&P/IA opinion.