Owner Assisted Annuals are Now Outlawed unless Supervised 100%.

Legal Interp just published outlawing any remote maintenance by non-certificated mechanics. Any non-cert mechanic or owners will have to be directly supervised 100% of the time by a certificated mechanic.
Not really. That LOI simply reiterates the same guidance that has been around for decades. It only deals with the supervision side of which does not include all the work a pilot can perform under prevent mx. So it doesn't stop owner-assisted work. The issue presented was does the supervising mechanic have to be personally present at the same area as the work being performed or could he use technology like "face-time" or other technology to supervise the work. The LOI merely answer that question and nothing else new.
 

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There's no "100% of the time" in the LOI. That's clickbait/rage bait.

The question was whether supervision had to be in person or whether it could be virtual, e.g. through Facetime. Considering the reg says "in person", I don't know why there would be an expectation that it wouldn't actually have to be "in person."

So we're upset that "in person" actually means "in person"?
 
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As a heavy participant in assisting my ia and AP in working on my plane (I doubt there are many log entries that I didn’t assist on in at least some small way), this doesn’t concern me a bit. I fully agree that they should be present to inspect the plane personally.
 
Yeah the way I read this it is the same as it has been: supervising A&P must be present and involved in the process. Blakely v Sugen says it can't just be an A&P on premises (as in available to ask questions) so a shop can't hire one A&P to sit in the office all day while non-A&Ps do all the work. Exactly how much supervision you require is up to the A&P and their comfort level signing off on your work.

The implication is they at least peek at what you're doing at major checkpoints in the procedure. Probably worth documenting that they did so?

Anyway the sky is not falling. I always thought it was super sketchy to interpret a FaceTime call as sufficient supervision and seems the FAA agrees. Though what a pilot and their A&P do behind closed doors is their own business
 
The article is a good read. I agree with Mike that this will have downstream ripples that will only drive costs higher. Granted I don’t know how prevalent this is the the small GA world.
 
I agree with Mike that this will have downstream ripples that will only drive costs higher.
How, in any aviation capacity? The LOI doesn't change anything. The actual regulation (43.3) has been written that way for many years. And if you go back to CARs, it was even more restrictive. Besides how would MB even know since he's only worked on his own aircraft?
 
for the 10x100000th time there is no such thing as an owner assisted annual. No part of the annual can be delegated, the IA must perform every step. FAR 65.91 is clear.

But what about cleaning/ removing the interior / inspection panels etc. That is part of the inspection. A person can unknowingly remove a key part of a descrepency like say cleaning a fuel stain or removing an unservicable fastener.
 
Owner assisted annual is kind of like a pre-buy inspection. It's something that isn't defined by or any part of the FAA regulatory system. It's more of a community terminology for an agreement/situation between a mechanic and owner.

There is no regulation that says I can't wash the airplane- that's part of annual. There's nothing that says I can't remove inspection covers, remove seats, or generally take anything on the airplane apart. There's a whole list of things I am allowed to do as a pilot owner that may be part of the annual. A pilot owner can do any of these things and(hopefully) knock a few hours of labor off his final bill. Not only that but he may have the opportunity to hang around while his airplane is getting worked on and learn a few things in the process.
 
Two issues:

A non certificated tech has to be supervised for all work they do. They are neither an owner or operator even if the they have a private pilot certificate. As such there is no work they can perform unsupervised.

An owner operator with a private certificate may perform preventative maintenance. Many preventative maintenance operations are permitted in conjunction with an annual inspection unsupervised.
 
In 2015 (Tim Amalong/Velocity Air) the FAA issued a LOI stating the FAA position. They split the
baby because in 43 A it's specifically states before the inspection the airplane must be cleaned and access panels can be opened. The FAA counsel stated that this wide latitude is given so that owners can learn about thier airplane... but they also say that it's up to the IA if the owner actually can do it.... so legally it's the IAs call in their view.

I completely disagree. The annual is not a teachable moment. it's to ensure the AC is in a safe and airworthy condition. If an owner wants to learn about their AC there are 364 other chances in the year to do so.

Bottom line is that an IA is putting his name on that inspection. I wouldn't want anything outside my direct hands on work to get in the way.

Also, with the new MOSS LOI supervision is now much more defined... so that also leans towards my opinion.
 
I don’t know the rules, don’t pretend to know the rules, and don’t want to know the rules.

That said, from my layman’s point of view…
Opening an inspection cover is one thing. Closing it is another.
 
Legal Interp just published outlawing any remote maintenance by non-certificated mechanics. Any non-cert mechanic or owners will have to be directly supervised 100% of the time by a certificated mechanic.

https://www.ainonline.com/aviation-...nterpretation-disallows-remote-mx-supervision
Your subject line is unsupported by the article (or even your synopsis).
for the 10x100000th time there is no such thing as an owner assisted annual. No part of the annual can be delegated, the IA must perform every step. FAR 65.91 is clear.

But what about cleaning/ removing the interior / inspection panels etc. That is part of the inspection. A person can unknowingly remove a key part of a descrepency like say cleaning a fuel stain or removing an unservicable fastener.
Anybody can make a plane unairworthy.
 
I don’t know the rules, don’t pretend to know the rules, and don’t want to know the rules.

That said, from my layman’s point of view…
Opening an inspection cover is one thing. Closing it is another.
Really? Opening and closing an inspection cover is easy peasy compared to replacing any cowling not requiring removal of the propeller, which is Part 43 preventative maint. New engine cowlings aren’t predrilled.
 
People need to stop asking the FAA questions. All it does is narrow a gray area to a definite answer, which has a negative impact.
This was asked by a FSDO Manager, not a random pilot. Probably due to some shop in his area using remote supervision.

I don't see this as being a big deal. I don't know of any mechanics supervision or inspections being done using FaceTime or similar.
 
There is no regulation that says I can't wash the airplane- that's part of annual. There's nothing that says I can't remove inspection covers, remove seats, or generally take anything on the airplane apart.

Not to mention changing the oil, cleaning and rotating the spark plugs, replacing the air filter, lubricating the control surfaces, setting the tire air pressures, greasing the wheel bearings, etc., etc.
 
But what about cleaning/ removing the interior / inspection panels etc. That is part of the inspection. A person can unknowingly remove a key part of a descrepency like say cleaning a fuel stain or removing an unservicable fastener.
Just how many days/weeks/months must the plane go without cleaning to make your inspection valid? Suppose I washed it a day before you start?

This is silly.



Bottom line is that an IA is putting his name on that inspection.
Big deal. My life depends upon that plane operating correctly. I value my life more than your name.



I wouldn't want anything outside my direct hands on work to get in the way.
And that’s why you won’t be working on my plane.
 
Bottom line is that an IA is putting his name on that inspection. I wouldn't want anything outside my direct hands on work to get in the way.
The moment the plane leaves the IA, anyone on the ramp while it's parked, or in the hangar can do anything to the plane they want and the IA has no control over that, yet the IA "put his name on that inspection". You seem to think that signature is some sort of magic spell.
 
I remember putting in a high res video connection in a hospital…~25 years ago.

If a Dr can help/supervise surgery, remotely, then maybe a mechanic can get help the same way.
 
I think fundamentally the problem lies in the value of the 24” rule. When QA did their final inspection in the Navy, they had to look at everything within 24”. This was a good thing.

What makes an IA different is the “inspection authority”. It’s an undefined bigger view. It’s notional process to put you in a “inspection” mindset rather than just fix this problem. Ask why and go another level or two into the problem.

The purpose of a annual isn’t just the check list item, a AP can do that vis a vis a 100 hr, but to once a year take bigger view.

A walk around isn’t just to check the things mentioned in the check list, but to get your eyes on as much as possible to just find an anomaly.

It’s why a 145 repair station doesn’t need an IA, a second set of eyes is regulated. That second set that wasn’t so involved can hopefully see the trees in the Forrest.

The faa isn’t checking personal receipts of a random maint job to make sure the guy who signed was actually present. UNLESS there’s a mishap.

If you assist as an owner… are you doing it to save money primarily? Oh goodie, now my IA won’t see this, whew. That’s bad.

Are you doing it to get involved? Be a part? Exercise as much due diligence as you can? Save a few bucks in the process? That’s good.

I’ve done a LOT of vehicle maint in the parking lot of parts stores with a wheel on a curb…. One day I was lucky enough to get a car lift. With that thing over my head, a little distance to step back and take a larger look, WOW. What a difference. There’s something to be said for being there.
 
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Here I thought we were talking about opening up the plane....and closing things after the IA does his thing? ....no?
 
This is just getting ridiculous, lets call it an affliction - Chronic Overinterpretation Syndrome. It starts with a guy who simply has no confidence in himself to read a regulation and not be filled with doubt or fear that there is some conspiratorial trap laying in wait to snare him. So he asks for clarification which just leads to another page or two of interpretations to be further scrutinized and interpreted. A never ending cycle. Then we have people like Mike Busch, who really loves to talk a lot, chide in referring to regulations as if it's the Bible or the Constitution analyzing what the "framers" mindset must have been back in the days when they chiseled this into stone.

Oh cripes, give me a break please.
 
Interesting thread. Working as A&P on a heavy check line at first airline circa 1980, if you got a work card to close a panel you were expected to perform a general visual inspection in that area before you closed. You were responsible if you closed a panel with obvious damage or still disassembled equipment inside.

Now a days, there are often defined inspection requirements for specific Mx environments and certainly in QA and NDT groups. Some of the more recent came about with the advent of Electrical Wiring Interconnection System (EWIS) requirements.

In my day job, I provide on call Engineering support to folks working on company airplanes anywhere on the planet. Our group operates 24x7. When dealing with a temporary repair for any sort of damage, I always include a step for them to perform a General Visual Inspection (GVI) in the area of the damage. It must be signed off. I always do that because people in a rush under pressure can get tunnel vision. That is opposed to a DVI (Detailed Visual Inspection) which may have specific, magnification, lighting, distance requirements and may involve a mirror or touching.

I get a lot of photos and videos. They are great for understanding the scope of the damage and may suggest what approach to take for a temporary repair, however there are limits. The reality is I am in a cloth box in city A, the airplane may be on another continent in city B. Within the guidelines of our operating rules I can write a temporary repair, Minor, that needs to be accomplished before further flight. Make no mistake, I cannot in any way perform a QA function from my cloth box (aka cubicle). Who knows which airplane those photos actually came from? I can't see anything from all angles or check behind something with a mirror.

So, If I have any questions or concerns related to the safety or integrity of the repair I write an inspection step which must be signed off by the AMT performing the work before it flies. Most of these read like verifying no looseness, no obscuration etc. A common one is verifying circuit breaker no longer trips after XYZ is disconnected.

Like everything in aviation, the devil is in the details!
 
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At the end of the day, the rules say what they say, and owners and A&Ps/IAs operate within those rules, or stretch them a little, in private. Ultimately, the A&P/IA has to put his signature in the book. If he's OK "bending" the rules a little with an owner he trusts (like letting an owner do a lot of the "grungy" work for an annual in his own hangar), so be it.

To me, it's much like jaywalking or the cloud clearance requirements or "cost sharing" among close friends and family. In other words, there are nuanced rules that some people are just OK working within the fringes of. Not every A&P will be OK with that, and that's fine.

All that said, I do think the idea of "remote" inspections and supervision is a stretch in a lot of cases, and I think the FAA is correct to reject that concept at this point in time. Remove video supervision is far different from an owner installing say a fuel pump in his own hangar, and then having the A&P come down the next day to personally inspect it before it all goes back together.
 
for the 10x100000th time there is no such thing as an owner assisted annual. No part of the annual can be delegated, the IA must perform every step. FAR 65.91 is clear.

But what about cleaning/ removing the interior / inspection panels etc. That is part of the inspection. A person can unknowingly remove a key part of a descrepency like say cleaning a fuel stain or removing an unservicable fastener.
It is 100% legal for an owner to completely disassemble his own plane. He can remove inspection panels, remove instruments, take the engine off, even remove the wings. Oh, sure, it's now unairworthy, but so far it's perfectly legal to do. People parting out airplanes do it all the time. Insurers do it all the time when recovering it from a landing in a field. Salvage companies. Etc.

Reassembling it, inspecting it, and signing it off as airworthy, of course, is a different story. But disassembling it? Anybody can do that.

Whether the IA is comfortable with having the owner remove panels, etc., is a different issue.
 
for the 10x100000th time there is no such thing as an owner assisted annual.
And for the 10x100000th time… you’re wrong again. If you would have dug a bit more in the LOIs you would have found the Hochberg LOI which addresses “owner-assisted annuals” and how to sign off the work of the "assister". So if the owner performs only non-maintenance tasks, i.e., cleaning, no separate write up would even be required. :rolleyes:

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While I think you have aviation experience, based on your PoA posts its minimal on the mx side. If I had to guess, if in fact you do have an A&P, you’ve had it for less than 3 years so aren’t even eligible for an IA yet. It's obvious you lack experience. Your call, but if you were to ask questions vs make BS statements you might just gain some knowledge and have a good career working on aircraft.
 
A non certificated tech has to be supervised for all work they do.
Correct. For example, 43.3(d) also applies to Part 145 CRS supervision as well. And in a repair station one certified supervisor can have up to 10 uncertified person they are over. What some are missing from this discussion in addition to the “in person” requirement is “readily available” requirement. This is the key part. And the FAA has guidance on the use of “readily” which in most cases means “without hesitation.” And that can only happen when in person.
 
...No part of the annual can be delegated, the IA must perform every step. FAR 65.91 is clear...
Of the INSPECTION. It has nothing to do with the peripheral tasks required to accommodate that inspection.
 
The bickering about the "supervision" requirement is just like the bickering over "common purpose" and cost sharing, and the bickering over logging issues. There are the strictly-interpreted rules, and then there is what people actually do in practice. Like virtually ever other industry, the rules are rarely strictly followed with zero deviation.

Outside of Part 121 and 135, how you manage your owner-assisted maintenance and annuals is between you and your A&P. Some A&Ps simply won't do owner-assisted, some will. Some will "strictly enforce" the supervision requirements, some won't. In other words, everyone will make their own decisions. If you have an A&P and have an owner-assisted relationship already, what I wouldn't do is go rocking the boat.
 
Of the INSPECTION. It has nothing to do with the peripheral tasks required to accommodate that inspection.
Nonsense. The ia must not be even given a sandwich for lunch during the inspection unless he supervises in its making. He must oversee the slaughter of the hog for the ham sandwich, and the reaping of the wheat to make the bread.

He must also be inside the plane to swing the gear and also outside the plane observing the gear swing.
 
Nonsense. The ia must not be even given a sandwich for lunch during the inspection unless he supervises in its making. He must oversee the slaughter of the hog for the ham sandwich, and the reaping of the wheat to make the bread.

He must also be inside the plane to swing the gear and also outside the plane observing the gear swing.

What about the growing of the corn fed to the hog?
 
I wish you could take training and get a "Repairman's Certificate" for a certified aircraft you own. In my view it would be more limited than for an experimental but if you can change the tires, rewire landing lights, replace seat belts, replace fuel lines, etc then why can't you swap an alternator? Or replace a broken landing light switch?

For that matter let manufacturers offer maintenance training like they can for "primary category" aircraft and let owners do the approved procedures per the approved directions with approved parts.
 
but if you can change the tires, rewire landing lights, replace seat belts, replace fuel lines, etc then why can't you swap an alternator? Or replace a broken landing light switch?
For the simple reason most FARs provide compliance with international aviation treaties and agreements. So any deviation from those standards creates issues with those aircraft maintained as you suggest. For example, the Canadian Owner Maintained class of aircraft cannot be flown or exported outside of Canada due to not following the ICAO standard.

Could that change? Sure. But, in general, the current repairman programs only pertain to E/AB, LSA, and Certified Repair Stations. However, if MOSAIC goes in the direction some believe it will, there might be a path to what you suggest for a select group of TC'd aircraft as a certified mechanic with the proper training.
 
then why can't you swap an alternator? Or replace a broken landing light switch?

Maybe you can, maybe you can't. Interpretations vary.

FAA legal has issued an LOI stating that the definition of preventive maintenance is controlling, and not CFR Part 43 Appendix A, which is to be considered a list of examples, not a comprehensive and limiting list.

From the LOI,
As with the other paragraphs of Appendix A (i.e. , on major repairs and major alterations), the lists are
better viewed as examples of the tasks in each category-they cannot be considered all-
inclusive. There are, no doubt, many "simple or minor preservation operations [tasks]"
and many "replacement of small standard parts not involving complex assembly
operations" performed daily, especially on small general aviation aircraft, that the agency
would consider to be preventive maintenance, though they are not included in the 32 listed items.


Per the CFR definition, "Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations."

Now, is the alternator a small standard part? Maybe, though that might be a stretch, but since R&Ring it requires removing and reinstalling the prop, it can hardly be claimed that it doesn't require "complex assembly operations." I'd guess that one's out. What about a landing light switch? Well, the switch itself is almost certainly a small standard part, but for any given plane I don't know whether accessing it requires complex assembly operations.

The FAA seems to have left quite a bit of latitude for owner/operators to decide whether something falls under PM, and I'd like to leave it that way so please don't ask the FAA for clarification. I've never heard of anyone getting gigged for deciding wrongly and logging something as pilot-performed PM (maybe it's happened), but I suspect that the worst outcome would be requiring an A&P to either inspect or redo the work and then make a new log entry.

Of course, if an owner doesn't closely guard the airplane around the clock, lots of things seem to get fixed by hangar fairies who only work under cover of darkness and never log anything......
 
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The FAA seems to have left quite a bit of latitude for owner/operators to decide whether something falls under PM,
It does, but as noted in the LOI any tasks are to be viewed as examples of each 32 categories which doesn’t mean you can expand the number of categories. This is how the prevent mx guidance and other noted guidance has been practiced for years.

Coleal simply brought that existing practice to the forefront mainly due to the inconsistencies in AC43-12 since day one. Depict any Part 1 defined PM task into one of those Appx A(c) 32 categories, make/sign the 43.9 record entry, and you should see minimal pushback even from IAs. But make your own category and all bets off on several levels.

However, there are other ways to legally expand those PM tasks outside those categories by the use of a Letter of Exemption. For example, while a PPC can remove/install seats per prevent mx, they couldn’t correct the EWB if they wanted to leave a seat out as that is considered a minor alteration. A PPC could request an FAA LOE to legally perform the EWB correction as part of the seat removal which is similar to scope from 43.3(h).

I've never heard of anyone getting gigged for deciding wrongly and logging something as pilot-performed PM (maybe it's happened), but I suspect that the worst outcome would be requiring an A&P to either inspect or redo the work and then make a new log entry.
Depends on the extent of the task performed. Have personally seen certificate actions, but the more serious actions from improper prevent mx were mostly against the aircraft AWC. Suspension of the AWC was usually the result until the aircraft was reviewed by an AP, IA or DAR. However, I did hear of one AWC revocation but that was due to extenuating circumstances. Its these type issues that made me a proponent of requiring each private owner/operator to make a signed entry prior to each annual inspection the aircraft was maintained per the AWC Block 6.
 
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