Few industry sectors require the consistent level of safety and reliability that commercial aviation does. Societal acceptance of avoidable aviation accidents will continue to decrease, even though it is statistically well established that air travel is the safest mode of transportation commercially available.

All the stakeholders in this economic sector understand the imperative need for passengers to be and feel as safe as possible when boarding an aircraft. Historically, around the world, regulatory agencies, such as the Federal Aviation Administration – FAA - have been established to oversee and regulate organizations involved with all the aspects and facets associated with flight safety. One of the most important, influential and visible stakeholders, involved in flight safety, are the so called “repair stations”. Repair stations vary tremendously in size and scope of activities. Some large repair stations provide the daily work necessary to keep an airline’s fleet operating. Others perform substantial maintenance, which might include more thorough inspection and repairs on airframes and overhauls of highly complex pieces of hardware, such as aircraft engines. Some repair stations offer very specialized services for their customers such as welding, heat treating, and coating on a variety of aircraft parts. However, the vast majority of repair stations perform maintenance on components, normally remote from airports and hangars.

FAA and other National Aviation Authorities (NAA) oversight of certified repair stations require a tremendous amount of resources, centered around personnel with a high degree of specialized knowledge about manufacturing and repair processes, material technology, regulations, quality control techniques and much more. It is a well known fact that, like many other federal agencies, the FAA’s budget is limited and the Agency is always under public and congressional scrutiny especially during the aftermaths of aviation accidents.

In a couple of reports published in 2003 and 2005, the Department of Transportation through the Office of the Inspector General (DOT IG) expressed concerns about the FAA’s oversight of the contract maintenance industry and stated that the agency’s oversight is currently insufficient for the amount of work independent repair stations perform for airlines[1][1] . The FAA has responded to these findings by, amongst other things, introducing a risk-based inspection program that identifies those repair stations doing the most work for airlines and monitoring their operations more closely. At present, it is estimated that the FAA has certified close to 4,600 domestic and 650 foreign repair stations. However, in addition to the FAA certified repair stations, a growing number of non-certificated repair stations are performing safety critical work, according to a recent report issued by the same Office of Inspector General from the US Department of Transportation[2][2]. By definition, the work performed by these non-certificated repair stations is not overseen by the FAA inspectors. Even though the work performed in such non-certificated stations must be performed by FAA certified mechanics and inspected by FAA certified inspectors, there is a dramatic difference between the regulatory requirements for certified and non-certified stations. See table 1.

Table 1

Requirement	Certificated Repair Station	Non-Certificated Facility
FAA Inspections	Annual inspection required	No requirement
Quality Control Systems	Must establish and maintain a quality control system that ensures that repairs performed by the facility or a subcontractor are in compliance with regulations	No requirement
Reporting Failures, Malfunctions and Defects	Must report failures, malfunctions and defects to FAA within 96 hours of discovery	No requirement
Personnel	Must have designated supervisors, inspectors and return to service personnel	No requirement
Training Program	Required starting April 2006	No requirement
Facilities and Housing	If authorized to perform airframe repairs, must have facilities large enough to house the aircraft they are authorized to repair	No requirement