FAA Part 145 (NDI limited rating) Audit Preparation for Inspection Companies
A FAA Part 145 (NDI limited rating) audit runs in 6 stages, beginning with pre-application discussion with the responsible flight standards office to agree the rating.. Federal Aviation Administration, Flight Standards Service; day-to-day oversight sits with the repair station's responsible Flight Standards office tests the system by sampling finished work backwards to the records behind it, so preparation means reconciling records to jobs rather than rewriting manuals.
Part 145 does not describe NDT techniques; it regulates the organisation that performs them. The FAA issues a limited rating for 'Nondestructive inspection, testing, and processing' under §145.61(b)(9), and §145.61(c) requires the repair station's operations specifications to name the specification used for the specialized service — either a civil or military specification currently used by industry and approved by the FAA, or one the applicant develops and the FAA approves. Around that sit §145.151 personnel, §145.155 inspection personnel proficiency and English literacy, §145.163 an FAA-approved initial and recurrent training program with records kept at least two years, and §145.211(c) a quality control manual that must describe how inspection personnel proficiency is established and maintained and how measuring and test equipment is calibrated, including intervals. What separates firms that clear an audit from firms that collect findings is not the quality of the documentation but whether it describes what actually happens.
Source: 14 CFR §§145.51, 145.55, 145.59, 145.61, 145.151, 145.155, 145.163, 145.211 as published in the electronic CFR via Cornell LII, current text including Docket FAA-2016-8744 Amdt. 145-31 (81 FR 49163, 27 July 2016) for §145.61 and Amdt. 145-32 (83 FR 9176, 5 March 2018) for §145.163. FAA Advisory Circular 65-31B, 'Training, Qualification, and Certification of Nondestructive Inspection Personnel,' dated 2/24/14, initiated by AFS-300, cancelling AC 65-31A of 25 April 2003, read in full — paragraphs 3, 5d, 5u, 6, 8, 9, 10, 11 and 12. Accessed 21 Aug 2026.
| Stage | What happens | What it tests |
|---|---|---|
| Stage 1 | Pre-application discussion with the responsible Flight Standards office to agree the rating sought and the specification that will be named. | Where the paperwork is tested against itself |
| Stage 2 | Formal application under §145.51 with the repair station manual, quality control manual and the employee training program required by §145.51(a)(7). | Where the paperwork is tested against practice |
| Stage 3 | FAA review of the submitted manuals and program for compliance with §§145.207, 145.209, 145.211 and 145. | Where the paperwork is tested against practice |
| Stage 4 | On-site evaluation of housing, facilities, equipment, materials and data under §145.109, and demonstration that inspection personnel meet §145. | Where the paperwork is tested against practice |
| Stage 5 | Issue of the certificate, the ratings and limitations, and the operations specifications naming the approved NDI specification. | Where the paperwork is tested against practice |
| Stage 6 | Continued operational surveillance by the responsible Flight Standards office, with revisions to the quality control manual notified under §145. | Where the paperwork is tested against practice |
| Renewal | Under §145.55(a) a certificate or rating issued to a repair station located in the United States is effective from the date of issue until surrendered and accepted for cancellation, or suspended or revoked — there is no periodic expiry. Under §145.55(b) a certificate issued to a repair station located outside the United States expires on the last day of the 12th month after issue and the FAA may renew it for 24 months; renewal must be requested no later than 30 days before expiry and the prescribed fee paid, otherwise the full §145.51 application procedure applies. Personnel recertification runs on the AC 65-31B intervals: Level I Special not exceeding one year, Levels I and II not exceeding three years, Level III at five-year intervals, with requalification also triggered by six months of inactivity in the method or an expired vision examination. | Diarised from the certificate date, not the last audit |
How long does FAA Part 145 (NDI limited rating) audit preparation take?
Document work — the written practice, procedures and quality manual — takes weeks. What cannot be compressed is documented experience and records history: on-the-job hours accrue in real time, and calibration and certification history cannot be back-filled. Firms that start when the audit is scheduled rather than announced clear it without findings.
What does Federal Aviation Administration, Flight Standards Service; day-to-day oversight sits with the repair station's responsible Flight Standards office look at first?
Records, not manuals. A manual states intent; records show practice. The usual opening move is to take a completed job and trace it back to the technician's certification, the instrument's calibration, the approved procedure and the report — and see whether all four reconcile.
What are the most common FAA Part 145 (NDI limited rating) findings?
The specification named in the operations specifications for the NDI specialized service does not match the specification the technicians actually work to, Quality control manual silent on how proficiency of inspection personnel is established and maintained, which §145.211(c)(1)(iv) requires explicitly, Employee training program treated as generic safety training with no method-specific initial and recurrent NDI content, or training records not retained for the full two years required by §145.163(c), Vision examinations lapsed beyond the one-year period, or colour-perception limitations never evaluated and approved in writing by the responsible Level III. Almost all of them are evidence problems rather than capability problems: the work was done correctly and the proof was not kept, or was kept somewhere the firm could not retrieve during the audit.
Can a consultant attend the FAA Part 145 (NDI limited rating) audit?
Yes, and it changes the outcome. Someone who has sat through the same audit at other firms answers in the auditor's own terms, produces the right record without a search, and stops a clarification turning into a finding. The firm still owns every answer — the consultant does not speak for it.
What happens after a FAA Part 145 (NDI limited rating) finding?
A corrective action with a deadline, and evidence of closure at the next audit. Repeat findings are treated far more seriously than first ones, because they show the corrective-action system itself is not working.
Does FAA Part 145 (NDI limited rating) require a pre-audit or gap assessment?
Not as a requirement, but the arithmetic favours it: a gap assessment finds the same evidence problems the auditor would, without the finding attached, and while there is still time to fix them. Firms entering their first FAA Part 145 (NDI limited rating) audit blind typically collect findings that a sampling exercise would have caught.
What the auditor asks to see
- Application for a repair station certificate and rating, with the attachments required by §145.51(a)
- Operations specifications containing the specification used to perform the specialized service, per §145.61(c)
- Repair station manual, and the quality control manual required by §145.211(c) covering preliminary, hidden-damage and final inspection, establishing and maintaining proficiency of inspection personnel, current technical data, qualifying and surveilling noncertificated persons who perform maintenance, calibration of measuring and test equipment including intervals, and corrective action on deficiencies
- FAA-approved employee training program under §145.163(a), submitted per §145.51(a)(7), with individual training records documented and retained a minimum of two years
- Written NDI qualification and certification program — the written practice — describing training, examination, qualification, documentation, proficiency maintenance, and the steps to decertify, retrain or recertify (AC 65-31B paragraph 9a)
- Personnel records specifying date, time and place of qualification, employing organisation, level, special qualifications or limitations, and the standard under which the individual is qualified, including a copy of any FAA repairman certificate issued to that individual (AC 65-31B paragraph 12)
- Vision examination records — near vision to Snellen 20/25 or Jaeger #1 in at least one eye, corrected or uncorrected, on a periodic basis not exceeding one year; colour perception evaluated once at initial examination with any limitation approved in writing by the responsible Level III
- Calibration records for NDI instruments traceable to a national metrological institute such as NIST
- Contracting arrangements and evidence of qualification and surveillance for any noncertificated person performing maintenance functions, as required by §145.151(d) and the quality control manual
Findings to close before the audit
- The specification named in the operations specifications for the NDI specialized service does not match the specification the technicians actually work to
- Quality control manual silent on how proficiency of inspection personnel is established and maintained, which §145.211(c)(1)(iv) requires explicitly
- Employee training program treated as generic safety training with no method-specific initial and recurrent NDI content, or training records not retained for the full two years required by §145.163(c)
- Vision examinations lapsed beyond the one-year period, or colour-perception limitations never evaluated and approved in writing by the responsible Level III
- Written practice references SNT-TC-1A or NAS 410 but the recertification intervals actually applied do not match the standard the organisation says it follows
- Outside agency used for training, qualification or testing without that use being provided for in the written practice, as AC 65-31B paragraph 9b requires
- No documented qualification and surveillance of the noncertificated NDT contractor performing work under the repair station certificate
- Calibration of NDI measuring and test equipment performed without stated intervals in the quality control manual or without traceability to a national standard
Related: the FAA Part 145 (NDI limited rating) overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.