Authority audits rarely start in the workshop. They start at a table with a stack of records. From my own experience accompanying audits on both sides of the Atlantic, the first two hours decide the tone of the whole visit. Inspectors open the documents that prove the system works on paper — then they walk out to check whether reality matches.
Here are the records that come up first, with the regulation behind each one.
1. Organisation chart and rosters
14 CFR 145.209(a) requires an organisational chart identifying each management position with authority to act on behalf of the repair station, its area of responsibility and its duties. 145.209(b) requires procedures for maintaining and revising the rosters required by 145.161. Under EASA Part-145, the nominated persons and their acceptance by the competent authority play the same role. Typical gap: the chart shows a name that left months ago.
2. Training records
145.163(c) requires individual training records „in a format acceptable to the FAA,“ retained for a minimum of two years. EASA requires human factors continuation training in each two-year period (AMC2 145.A.30(e)). Typical gap: training happened, but the record does not show the content, the date or the trainer.
3. Capability list and scope
145.209(d) requires procedures for revising the capability list and notifying the Flight Standards office. Inspectors compare the list with the jobs in progress on the floor. Typical gap: work performed that is not on the list, or a list that promises more than the tooling supports.
4. Reporting evidence
FAA: 145.221(a) — report serious failures, malfunctions or defects within 96 hours. EASA: occurrences within 72 hours (Regulation (EU) No 376/2014, 145.A.60). Inspectors look for the procedure and for evidence that it has been used. An empty log after a year of operation raises questions rather than confidence.
5. Management system evidence (EASA)
Since 2 December 2024, Part-145 organisations must operate a management system under 145.A.200 covering safety policy, occurrence reporting, safety promotion and safety risk management, with internal safety reporting under 145.A.202. Inspectors ask for the hazard register and how a reported hazard turned into an action.
6. Manual revision status
145.209(j) requires procedures for revising the manual and notifying the responsible Flight Standards office. EASA expects the MOE revision to be approved or managed under the agreed procedure. Typical gap: the floor works to a different revision than the one in the quality office.
A practical preparation sequence
1. Two weeks before: pull the six record sets above and check one sample per set against the floor.
2. One week before: close what can be closed. Document what cannot, with a date and an owner.
3. Day before: one person knows where every record is. Not three.
Sources
- U.S. Government — 14 CFR 145.163, 145.209, 145.221 (current), law.cornell.edu
- Transport Malta — IAN 26 Part-145, Regulation (EU) 2021/1963 (Issue 2, 2023), transport.gov.mt
- Transport Malta — IAN 01 Occurrence Reporting (Issue 7), transport.gov.mt
- Transportstyrelsen — Part-145 Human Factors training guidance, transportstyrelsen.se