The bilateral agreements between the National Civil Aviation Agency (ANAC) of Brazil and the Federal Aviation Administration (FAA) of the United States are designed to streamline certification. However, while the rules are "harmonized," they aren't identical, with a number of differences to discuss.

The BASA Framework - Bilateral Aviation Safety Agreement (BASA) and Maintenance Implementation Procedures (MIP).

• Each authority recognizes the other's oversight. A shop in Brazil doesn't need a completely separate "FAA set of rules"; instead, they follow RBAC 145 plus a specific FAA Special Conditions Supplement.

RBAC 145 vs. FAR 145: Key Comparisons

While RBAC 145 was largely modeled after FAR 145 to ensure compatibility, several nuances exist in language, oversight, and specific requirements.

Personnel Requirements

• FAR 145: Focuses heavily on the "Accountable Manager" and "Supervisory Personnel." The FAA requires specific certifications (like an A&P license) for those signing off on work, though the Repair Station itself holds the certificate.

• RBAC 145: Aligns with the Brazilian Labor Law and the CHT (Certificado de Habilitação Técnica). ANAC is often more prescriptive about the specific technical roles and the formal education/registration of engineers (CREA) compared to the more experience-based FAA paths.

The "Supplement" Requirement

This is the most critical practical difference for a shop seeking dual certification:

• To be FAA certified in Brazil: An RBAC 145 shop must create an FAA Supplement to its Maintenance Organization Exposition (MOE). This supplement covers things the FAA cares about that ANAC might handle differently, such as the Drug and Alcohol Testing Program (though international shops have specific exemptions/alternatives here).

• To be ANAC certified in the USA: A FAR 145 shop must create an ANAC Supplement. This ensures the shop uses ANAC-approved data for Brazilian-registered (PT/PP/PS) aircraft.

Language and Documentation

• FAR 145: All records must be in English.

• RBAC 145: Documentation for domestic use can be in Portuguese, but if the shop operates under the Bilateral Agreement for FAA-registered aircraft, the maintenance release and certain technical records must be translated or maintained in English.

Major vs. Minor Alterations

• FAA: Uses Form 337 for major repairs and alterations.

• ANAC: Uses the F-100-01 (Segunda Via do Diário de Bordo) or specific ANAC SEI forms. Under the bilateral agreement, the FAA accepts ANAC’s system for approving data, provided it follows the procedures outlined in the MIP.

Primary Oversight

• FAR 145 (USA): The primary authority is the Federal Aviation Administration (FAA). They hold sole responsibility for the certification, surveillance, and enforcement of repair stations located within the United States and those abroad holding FAA certificates.

• RBAC 145 (Brazil): The primary authority is the Agência Nacional de Aviação Civil (ANAC). ANAC oversees all Brazilian maintenance organizations and ensures they comply with national standards and international bilateral agreements.

Certification Basis

• FAR 145 (USA): The legal foundation is Title 14 of the Code of Federal Regulations (CFR), specifically Part 145. This body of law dictates exactly how a repair station must be structured and operated.

• RBAC 145 (Brazil): The foundation is Brazilian Civil Aviation Law, specifically the Regulamento Brasileiro de Aviação Civil (RBAC) 145. While heavily harmonized with the FAA's version, it is an independent legal instrument under Brazilian sovereignty.

Release Document

• FAR 145 (USA): The standard "birth certificate" for a component or a return-to-service for an aircraft is the FAA Form 8130-3 (Airworthiness Approval Tag).

• RBAC 145 (Brazil): The equivalent release document is the ANAC Form F-145-03 (commonly referred to as the Certificado de Liberação de Aeronave/Componente). Under the BASA, these two forms are generally accepted as equivalent for the movement of parts between the two countries.

Accountable Manager

• FAR 145 (USA): An Accountable Manager is required. This individual must have corporate authority to ensure that all maintenance required by the customer can be financed and carried out to the FAA standard.

• RBAC 145 (Brazil): A Gestor Responsável (Accountable Manager) is required. In Brazil, this role carries significant legal weight, as the individual is personally and legally responsible before ANAC for the technical and administrative integrity of the organization.

Quality System

• FAR 145 (USA): Traditionally focuses on a Quality Control (QC) System. This is often viewed as "inspecting the product" to ensure it meets specifications after the work is done.

• RBAC 145 (Brazil): Operates under a Quality Assurance (QA) System. This approach is more closely aligned with EASA (European) standards, focusing on "systemic auditing" to prevent errors before they occur, rather than just catching them at the end.

Next Steps 

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