Part 145 Capability List Requirements: What Goes On It, and What Has to Be Behind It

It starts with a phone call. A customer has an article you have never worked, the lead tech says we can handle that, and somebody has to decide whether the shop actually can. For a limited rated repair station, that decision has a name: the capability list.

Here is what the Part 145 capability list requirements say, what sits behind every line, and where shops get written up. As always, your repair station manual, quality control manual, and ops specs govern what your shop must do. None of this is legal advice, and your PMI's reading is the one that counts.

What the list is actually for

Under 14 CFR 145.215, a repair station with a limited rating may perform maintenance, preventive maintenance, or alterations on an article if that article is listed on a current capability list acceptable to the FAA, or on the station's ops specs. The list exists so a shop can add articles inside its existing ratings without amending ops specs every time.

That flexibility is the point, and it is why the rule puts the work up front. You add the line yourself. In exchange, you prove on paper first that you can do the job.

Two tests every line has to pass

An article goes on the capability list only when both of these are true.

• It is within the scope of the ratings on your certificate. The list extends a rating you already hold. It does not create one. If the article falls outside your ratings, the answer is an ops spec change, not a new row.
• You completed a self evaluation first. Per 145.215(c), the station performs a self evaluation under the procedures in 145.209(d)(2) to determine it has the housing, facilities, equipment, material, technical data, processes, and trained personnel to perform the work as Part 145 requires. That documentation is retained on file.

Two housekeeping items ride along. Each article is identified by make and model, or other nomenclature designated by the manufacturer, in a format acceptable to the FAA. And when you add one, your responsible Flight Standards office gets a copy of the revised list per the procedures in 145.209(d)(1).

What the self evaluation has to cover

Take the seven elements from the rule and turn each one into a question you can answer with evidence, not opinion:

• Housing and facilities. Where does this work physically happen, and is the space suitable for it.
• Equipment and tooling. Do you have what the manual calls for, and is the test equipment on your calibration program.
• Material. Can you source the parts and consumables the data specifies, with traceability intact.
• Technical data. Do you hold current data for this article, and is the revision service actually live.
• Processes. Are the special processes in house, or covered by an approved outside source on your contract maintenance list.
• Trained personnel. Is there a documented training record tying a named person to this article, not just a general sense that the crew is sharp.

Your repair station manual also has to describe this self evaluation, including the methods and frequency of the evaluations and how results get reported to the appropriate manager for review and action. Whatever frequency you wrote is the frequency you owe.

Where shops take findings

The list grew by word of mouth. Articles got added because a job came in and somebody typed a row. No evaluation document exists behind them.

The evaluation exists but the evidence does not. The form says trained personnel, and the training record for that article cannot be produced. The gap is the finding, not the form.

The revised list never went to the FSDO. Internally current, externally stale.

Nobody ever removes anything. The fixture got sold, the data subscription lapsed, the one tech who knew that unit retired, and the article still sits on the list. A capability list has to shrink sometimes.

Keeping the evidence with the work

None of this is hard. It is scattered. The evaluation is in a binder, the training records are in a folder, the tech data is a login somebody remembers, and the work orders are somewhere else. When an inspector picks one article and pulls the thread, that scatter turns an afternoon into a week. Same disease as most Part 145 audit prep.

That is the problem Orion is built around. Work orders carry their discrepancies, signatures, and parts in one place, the inspection library ships 11,600 plus tasks across 29 Textron and Cessna models, every signature is an FAA AC 120-78B compliant e-signature with re-authentication and a SHA-256 tamper hash, and full audit logging shows who touched what and when. Orion is modular on published pricing, so you build only the pieces you run.

Want to see the evidence behind a capability line living with the work orders that use it? Schedule a call.