ASNT Level III consulting for FAA repair station NDI programs and in-service inspection

What separates an MRO NDI program from an aerospace shop

The two are audited by different bodies against different documents, and conflating them is why generic aerospace consulting fails an MRO. A manufacturing shop is audited by a Nadcap auditor against AC7114 and by a prime against an approved-process-source program, and it inspects new parts against acceptance criteria written by the designer. A repair station is audited by an FAA aviation safety inspector against 14 CFR Part 145, and it inspects in-service hardware against technique data written by the type certificate holder for damage that accumulated in operation.

The consequences run through every record. A manufacturing shop qualifies a procedure once and runs it against a stable part configuration. An MRO reads a technique from an OEM nondestructive testing manual, a service bulletin or a structural repair manual, and the controlling question is which revision was in force on the day the inspection was performed. Revision control of somebody else's document becomes a primary compliance obligation rather than a library housekeeping task.

Personnel is the one place the two overlap. Both rest on NAS 410, and FAA Advisory Circular 65-31B names NAS 410 and ATA Specification 105 among the acceptable standards for NDI personnel qualification. The overlap ends at the certificate. Everything wrapped around it — who is on the roster, who signs the maintenance release, whether the training program carries an FAA approval, how long the record is kept — comes from Part 145 and has no counterpart in a manufacturing audit.

What the FAA inspector asks for first

An aviation safety inspector reviewing an NDI capability starts with the documents the certificate rests on: the repair station manual and quality control manual required by 145.209 and 145.211, and the employee training program approved under 145.163. Those documents describe what the station said it would do. The rest of the visit tests whether the station does it. Every finding that follows is anchored to a sentence the station wrote about itself and then did not follow.

The quality control manual is the densest target. 145.211(c) requires procedures for inspecting incoming material, preliminary inspection, hidden damage inspection after an accident, establishing and maintaining the proficiency of inspection personnel, maintaining current technical data, qualifying and surveilling noncertificated persons performing maintenance, final inspection and return to service, calibrating measuring and test equipment at stated intervals, and taking corrective action on deficiencies. Two of those — inspector proficiency and calibration intervals — land directly on the NDI function.

Proficiency is where NDI programs are thin. A manual clause stating that inspection personnel maintain proficiency through experience and training satisfies nothing when the inspector asks how method currency is established for a technician who performed no eddy current work for fourteen months. The answer has to be written before it is asked: a defined currency interval per method, a defined remedy when it lapses, and a record showing the remedy applied.

The training program carries an FAA approval, and that is the trap

14 CFR 145.163 requires a certificated repair station to have and use an employee training program approved by the FAA, consisting of initial and recurrent training, sufficient to ensure that each employee assigned to maintenance, preventive maintenance, alterations and inspection functions can perform assigned tasks. Revisions go to the responsible Flight Standards office. Training records are retained for at least two years. That approval requirement is what separates a Part 145 training program from an internal training plan.

The trap is scope. A station's approved program covers general maintenance topics, human factors and company procedures, and NDI is either absent or represented by one line stating that technicians are certified to NAS 410. When the station later adds phased array, or adds a method to its capability list, the approved training program is not amended and the recurrent cycle carries nothing method-specific. The certificates are current and the approved program is silent, and the inspector reads both.

The fix is a mapped program: every NDI method on the capability list appears in the approved program with initial content, recurrent content, a recurrence interval and a record format. Where OEM-specific or equipment-specific training is required by a customer or by the technique data, that appears too. Amendments go through the Flight Standards office rather than being absorbed quietly into an internal syllabus, because an unapproved amendment is a 145.163 finding regardless of how good the training is.

Rosters, inspection personnel and return-to-service authority

14 CFR 145.161 requires rosters of management and supervisory personnel, of all inspection personnel, and of all personnel authorized to sign a maintenance release for return to service. Each entry carries present title, total years and type of experience, prior employment with employers and dates, current scope of employment, and mechanic or repairman certificate type and ratings where held. Changes from termination, reassignment, change of duties or addition of personnel are reflected within five business days.

NDI technicians are the population most often missing from the inspection roster. They perform inspections and sign results, but because they hold NDT certifications rather than airman certificates the station files them with production rather than with inspection. An inspector comparing signed NDI reports against the roster finds names that appear nowhere, and the finding is written against 145.161 rather than against the quality of the inspection. Adding them is administratively trivial and is worth doing before the visit.

Authority boundaries follow from 145.153, 145.155 and 145.157. Supervisory personnel are qualified for the work they oversee; inspection personnel are familiar with the inspection methods, techniques and equipment used and proficient with the inspection aids; and personnel who approve an article for return to service hold an appropriate airman certificate. An NDT Level III certificate does not confer return-to-service authority, and a written practice that implies otherwise creates an authority gap the station has to close explicitly.

The personnel standard: NAS 410 or ATA 105 under AC 65-31B

FAA Advisory Circular 65-31B contains recommendations for the experience, training, qualification, examination and certification of nondestructive inspection personnel working on aircraft, engines, propellers, accessories and components. It names acceptable standards including AIA NAS 410 and ATA Specification 105, alongside CAN/CGSB-48.9712 and ISO 9712. The station selects one, names it in its written practice, and issues every certification against it. The FAA does not itself certify NDI technicians.

The station-level obligation is therefore self-imposed but fully auditable. Having named NAS 410, the station inherits its written practice requirements, its Responsible Level 3 concept, its experience and examination requirements, and its vision requirements — near vision annually and color perception at least every five years under Rev 5 Table V. Having named ATA Specification 105 instead, it inherits that document's structure. Naming neither, and issuing certificates against internal judgment, leaves nothing for the inspector to test the file against.

On-the-job training is where the file usually thins out. AC 65-31B expects documented on-the-job training with an appropriately certified organization and a written program describing how personnel are trained, qualified and certified. The recurring defect is a total hours figure with no method breakdown, no dates and no supervisor signature. A dated per-method log signed by a supervising Level II or Level III, started now with a written reconstruction basis for historical hours, closes it permanently.

Calibration and reference standards in an MRO

14 CFR 145.109(b) requires that all test and inspection equipment and tools used to make airworthiness determinations on articles are calibrated to a standard acceptable to the FAA. 145.211(c) requires the quality control manual to describe calibration of measuring and test equipment with stated intervals. Together these cover ultrasonic flaw detectors, eddy current instruments, bond testers, densitometers, step wedges, penetrant process tanks with controlled parameters and every gauge that feeds an accept or reject decision.

Reference standards are the recurring gap. Eddy current reference standards, ultrasonic calibration blocks, conductivity standards and comparator specimens sit in a technician's kit and are treated as consumables rather than as controlled measuring assets. They are not entered in the calibration register, they carry no identification traceable to a report, and a damaged or worn standard cannot be traced back to the inspections performed with it. That last point is what turns a housekeeping gap into a fleet-level recall question.

The control is a single register carrying every instrument and every reference standard, with unique identification, calibration source, interval, due date, and the requirement that the identification appears on every inspection report produced with it. Where calibration is outsourced, the purchase order names the requirement and the certificate returns with traceability and as-found data. That last condition is what makes a later out-of-tolerance finding bounded rather than open-ended.

OEM technique data and revision control

14 CFR 145.109(d) requires the station to maintain current and accessible documents and data in an FAA-acceptable format, including airworthiness directives, instructions for continued airworthiness, maintenance and overhaul manuals, standard practice manuals, service bulletins and other approved data. For NDI that means the OEM nondestructive testing manual, the structural repair manual, and every service bulletin and airworthiness directive that specifies an inspection method and technique.

Revision control of these documents is a compliance obligation rather than a library task, because the question an auditor asks is which revision was in force on the date of a specific inspection. A station holding a current subscription for the airframe NTM and a lapsed one for an engine manual has a defect that is invisible until someone reconciles inspection dates against revision dates. Reconciliation has to be a scheduled activity with a record, not an assumption resting on a subscription renewal.

Where the technique data allows an alternative method or requires an equivalent technique, the station documents the equivalence and identifies who approved it. This is the point in an MRO program where a Level III adds direct technical value: assessing whether an in-house technique meets the intent of the OEM technique, documenting the basis, and identifying when the answer requires the type certificate holder or the FAA rather than an internal decision.

Records: the two-year floor and what customers ask beyond it

14 CFR 145.219 requires the station to retain records in English demonstrating compliance with part 43 requirements, in a format acceptable to the FAA, for at least two years from the date the article was approved for return to service, and to make them available to the FAA and the NTSB. 145.163 sets the same two-year floor for training records. These are floors. Airline and OEM contracts routinely require longer retention and additional traceability, and the contract governs where it is more demanding.

The structural defect in most MRO NDI record systems is separation. The NDI report lives in an inspection folder organized by date or by technician, and the work order lives in the maintenance record system organized by article. Nothing links them, so producing the complete evidence chain for one inspection means a manual search across two systems. Under an audit that is slow; under a customer investigation into a missed indication it is untenable.

The remedy is a single traceable identifier carried on the work order, on the NDI report, on the technician's certification file reference and on the instrument and reference standard used. Atlantis builds that linkage into the reporting system rather than layering it on afterwards, so that a request for the full chain behind any inspection resolves in one query. The same structure supplies the retention evidence a customer contract demands beyond the regulatory floor.

Where a retained Level III fits in a repair station

An MRO rarely needs a full-time Level III in every method it performs, and the roles a Level III actually fills — approving procedures and techniques, authoring and grading examinations, reviewing certification files, assessing technique equivalence, surveilling contracted NDI vendors — are periodic rather than continuous. That is the shape a retained arrangement fits, and it is the reason outsourcing is common in this sector rather than exceptional.

The boundaries have to be written into the station's own documents. A retained Level III approves procedures and techniques, authors and grades examinations and recommends certification. The station certifies its own personnel, maintains its rosters, signs maintenance releases through appropriately certificated personnel and holds the records. That division is set out on what an outside NDT Level III can and cannot do, and it is written into the written practice rather than left as an understanding between two parties.

Atlantis works with repair stations on both sides of that line: rebuilding the written practice, certification files, training program content and record linkage, then holding the retained Level III role for procedure approval, examination oversight, contractor surveillance and inspector-visit preparation. Certifications held include ASNT Level III across multiple methods. Engagement structure is described on outsourced NDT Level III consulting. Request a quote against your capability list, method scope and station count.

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