Owner Assisted Annuals are Now Outlawed unless Supervised 100%.

[Half Fast]

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.

Yes, I know that's how the FAA has interpreted the interpretation, but it isn't what the LOI actually says. The LOI says

Even though the introductory text of subparagraph ( c) states that "[p ]reventive maintenance is limited to ​

the following work... ." (emphasis added), in view of the broader definition of preventive maintenance in​

section l. l , we believe that such limitation is not controlling. ​

It does not say that PM must fit into one of the categories; rather, it says that the limitation of Appendix A does not control whether or not a task is PM. If a task fits the PM defintion it's PM, regardless of Appendix A.

Granted, if you can argue that a task can be described as similar to something that's on the list, you'll have a much easier time convincing someone that it's PM. Most times that's practical. For example, @xenadu mentioned replacing a landing light switch. I could argue that task fits this category:

(16) Trouble shooting and repairing broken circuits in landing light wiring circuits. ​

since the switch is part of the circuit. So long as no complex disassembly and reassembly were necessary to access the switch, I think replacing it would be considered PM.

But there are other tasks that can't really be made to fit one of the App A categories but are equally simple and fit the definition well. For example, the overhead PA speaker in my Musketeer can be accessed by removing a handful of screws and the electrical connection is made with two slip-on connections. The speaker is certainly a "small standard part" and replacing it would not require anything close to a "complex assembly operation," but I don't see any category in the App A list that would cover it. Nonetheless, I'd feel comfortable replacing it if it ever failed and I'm confident the A&P-IAs that I use would agree that it fits the PM definition. I would log it as such and I'd be very surprised if that were ever challenged.

The Office of the Chief Counsel has generously allowed us lots of room here.

 

[Bell206]

Yes, I know that's how the FAA has interpreted the interpretation, but it isn't what the LOI actually says.

But that is the key part, how they interpreted it. I’m merely passing on how it has been practiced for years even before Coleal. If you want to experiment with your interpretation rock on. But you’re not the first. Just be ready with a solid reference if you ever get questioned on your PM write up. Waving only the Coleal letter in victory usually gets reversed into a white flag of surrender in the eyes of some APIAs or ASIs.

But there are other tasks that can't really be made to fit one of the App A categories but are equally simple and fit the definition well.

You have to get creative. The light switch is a classic. And so would your speaker example be using the same PM category if you look at from this angle: (16) Trouble shooting and repairing broken circuits in [any] wiring circuits. Think category not line item.

I spent many hours with my owner-assist customers showing them the outer limits of preventive mx. My take was if you couldn’t shoehorn the task into one of the 32 existing categories or couldn’t get a LOE, then you should probably view it as an owner-assist task with your mechanic.

 

[jnmeade]

Or the evapotranspiration that waters the corn, and the bees that fertilize the seed? God, I think…same as IA.

Laugh! Oh my god. What a yuck.
Evapotranspiration is the combination of evaporation (water moving from the ground to the air) and transpiration (water moving from the plant to the air). Neither process has anything to do with "watering" the corn.
Bees have nothing to do with fertilizing anything. They pollinate some plants, but corn is self-pollinating. That is, the pollen (male) from the tassels falls on the silks (female) and that is how the fertilization takes place. Corn plant pollen can drift and pollinate any nearby corn plant but of course much of it falls down and pollinates it's own female receptacles.
Better luck on your next simile.

 

[Sierra_Hotel]

Whoosh.

 

[MRC01]

I searched but didn't find this, so it looks like my post was a duplicate. I'll refer it here.

 

[idahoflier]

The uproar would appear to be over this:

"The certificated mechanic must be available, not just
to answer questions, but to notice mistakes and take over if necessary. In Blakey v.
Sugen, National Transportation Safety Board (NTSB) Order No. EA-5128 (December 10,
2004), the NTSB upheld the suspension of the respondent’s Commercial Pilot Certificate
for performing unsupervised maintenance—specifically, for performing some
maintenance tasks while in earshot of certificated mechanics, but without any mechanic
directly watching him."

The above implies that an A&P must be watching the unlicensed individual performing any work requiring a certificate at all times. This would probably effectively end any shops employing apprentice mechanics as it makes no economic sense to pay an A&P to watch an unlicensed individual performing maintenance.

How devastating is this? IDK? I believe all the individuals employed by the shop I use that are maintaining my aircraft are A&P's. However, I think one shop on my field employee several non-certificated individuals and I can see this interpretation having a major impact on their business. There is already a backlog for GA maintenance in the area. This would only make it worse...

 

[Bell206]

The uproar would appear to be over this:

There is a consensus that certain people are cherry-picking several “supporting comments” out of context and applying those comments to the whole LOI for whatever reason. Read the first/second paragraphs and the last paragraph of the LOI, then read the rest. Context is everything.

There has been a push for remote mx supervision since covid in certain circles, so this LOI shutdowns all those attempts which may have been the reasoning for the initial request. Regardless, seems the people complaining the most either have limited experience supervising mx or support remote supervision in some way. I'm with the consensus, it merely restates all supervision must be in person.

 

[Kristin]

The uproar would appear to be over this:

"The certificated mechanic must be available, not just
to answer questions, but to notice mistakes and take over if necessary. In Blakey v.
Sugen, National Transportation Safety Board (NTSB) Order No. EA-5128 (December 10,
2004), the NTSB upheld the suspension of the respondent’s Commercial Pilot Certificate
for performing unsupervised maintenance—specifically, for performing some
maintenance tasks while in earshot of certificated mechanics, but without any mechanic
directly watching him."

The above implies that an A&P must be watching the unlicensed individual performing any work requiring a certificate at all times. This would probably effectively end any shops employing apprentice mechanics as it makes no economic sense to pay an A&P to watch an unlicensed individual performing maintenance.

How devastating is this? IDK? I believe all the individuals employed by the shop I use that are maintaining my aircraft are A&P's. However, I think one shop on my field employee several non-certificated individuals and I can see this interpretation having a major impact on their business. There is already a backlog for GA maintenance in the area. This would only make it worse...

I will make two observations: One, the question that the interpretation addressed is whether remote, electronic supervision was allowable. The bit that implies actually standing over someone so you can instantly intervene is what is called in the law "dicta". It is not meant to be precedence as it is illustrative of the main point of the opinion.

As for the Blakey decision, it is a bit absurd as it would rule out going to the bathroom without stopping work, or even blinking. If we are applying this principle to Part 43 maintenance, then it seems we have to apply it to Part 145 maintenance, meaning whoever is the inspector, must watch the work that they are assigned to inspect, negating the point of having someone else do the work. With the demise of the Chevron decision, courts don't have to give deference to unworkable interpretations. I don't see that this is a really big deal. I know my local FSDO is fine as long as the supervising mechanic is reasonably handy for consultation, that 20 years after Blakey.

 

[bradg33]

The uproar would appear to be over this:

"The certificated mechanic must be available, not just
to answer questions, but to notice mistakes and take over if necessary. In Blakey v.
Sugen, National Transportation Safety Board (NTSB) Order No. EA-5128 (December 10,
2004), the NTSB upheld the suspension of the respondent’s Commercial Pilot Certificate
for performing unsupervised maintenance—specifically, for performing some
maintenance tasks while in earshot of certificated mechanics, but without any mechanic
directly watching him."

The above implies that an A&P must be watching the unlicensed individual performing any work requiring a certificate at all times. This would probably effectively end any shops employing apprentice mechanics as it makes no economic sense to pay an A&P to watch an unlicensed individual performing maintenance.

How devastating is this? IDK? I believe all the individuals employed by the shop I use that are maintaining my aircraft are A&P's. However, I think one shop on my field employee several non-certificated individuals and I can see this interpretation having a major impact on their business. There is already a backlog for GA maintenance in the area. This would only make it worse...

I'm curious what Blakey actually says. I don't think there's any reg that says that a non-A&P can't totally disassemble an airplane. Putting it back together and returning it to service is an entirely different matter. Probably the typical scenario where bad facts make bad law.

 

[Half Fast]

With the demise of the Chevron decision, courts don't have to give deference to unworkable interpretations.

This wasn't a court decision, though. It was an NTSB decision.

 

[Kristin]

This wasn't a court decision, though. It was an NTSB decision.

NTSB decisions are appealable. The NTSB likely knows that.

 

[Kristin]

I'm curious what Blakey actually says. I don't think there's any reg that says that a non-A&P can't totally disassemble an airplane. Putting it back together and returning it to service is an entirely different matter. Probably the typical scenario where bad facts make bad law.

FAR 43.3(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation.
FAR Part 1: Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

I would say that taking apart the plane is not maintenance. Also, if an owner is doing the things to his plane that is preventative maintenance, then he/she is not working under my supervision, though I need to get them to sign the logbook.

I would argue that defining "the extent necessary" to mean always having one's eyeballs on what is being done by the person being supervised, is an impermissible overreach. The "extent necessary" is obviously a situational determination which can't be made by regulatory fiat and any attempt to do so is absurd.

 

[MauleSkinner]

FAR 43.3(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation.
FAR Part 1: Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

I would say that taking apart the plane is not maintenance. Also, if an owner is doing the things to his plane that is preventative maintenance, then he/she is not working under my supervision, though I need to get them to sign the logbook.

I would argue that defining "the extent necessary" to mean always having one's eyeballs on what is being done by the person being supervised, is an impermissible overreach. The "extent necessary" is obviously a situational determination which can't be made by regulatory fiat and any attempt to do so is absurd.

Are you insinuating that the reg means what it says?!?

 

[Half Fast]

NTSB decisions are appealable. The NTSB likely knows that.

Legally correct. Often financially impractical.

I would argue that defining "the extent necessary" to mean always having one's eyeballs on what is being done by the person being supervised, is an impermissible overreach. The "extent necessary" is obviously a situational determination which can't be made by regulatory fiat and any attempt to do so is absurd.

AGREED!! I suspect your pro bono assistance would be welcomed!

 

[Bell206]

I don't think there's any reg that says that a non-A&P can't totally disassemble an airplane.

Technically, there is 43.3(a). And that disassembly work technically should be documented per 43.9(a). Both rules reference “no person” and “each person” respectively, which "person" is defined as basically everyone and anyone. And disassembly is part of maintenance. Is it enforced? No. But it is something a non-certified, non-pilot person should be aware of if working on a TC’d aircraft.

 

[Kristin]

Legally correct. Often financially impractical.


AGREED!! I suspect your pro bono assistance would be welcomed!

It only takes one to set a precedent, assuming the NTSB is too dense to figure it out, which is a distinct possibility.

I am retired from lawyering, but have difficulty retiring my IA as needy Comanches keep showing up.

 

[Kristin]

And disassembly is part of maintenance.

That is an interpretation, but not one that I would automatically make.

 

[GLMS_NC]

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.

Sure about that?

https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-65/subpart-D/section-65.95 is the section that is relevant.

 

[Klaus M]

There's nothing new in the interpretation. Video Apps and photos are still permitted for inspection purposes as approved by the Administrator. Commercial Aviation businesses such as Repair Stations, Airlines and Charters have General Operation Manuals (GOM). When a common maintenance task needs performed away from base the FAA Approved GOM will have instructions for personnel training and documentation of the training. The FAA will except quite a few different ideas for non-A&P inspections if it's demonstrated to an equal or better level of safety. Quite often aircraft have seat reconfiguration away from base. The GOM will spell out who is company trained to perform the task and Weight & Balance documentation changes.

General Aviation operators (Owner/Pilot) need to understand that their 'Certificated Aircraft' may one day change hands and be used in a commercial application and MUST be maintained as the regulations require. If you want to do your own maintenance the rules provide for that.... it's called Experimental Amateur Build.

Just because you think that no one will ever use your Piper J-3 commercially, you might be surprised. Many flight schools use the smallest aircraft for hire... or commercially. Do you want to rent an Aircraft maintained by non-A&P mechanic? What about your kids, when they go down to the local Flight School and you find out the fuel boy is doing the maintenance? He's "supervised" though.

 

[Half Fast]

.....and MUST be maintained as the regulations require.

Do you want to rent an Aircraft maintained by non-A&P mechanic?

For part 91 operations, the regs very clearly permit quite a bit of maintenance to be performed by a non-A&P, as long as the one doing the work is a pilot and is either the owner or the operator of the aircraft. The regs even allow that owner to fabricate his own parts for the airplane. And nothing in the regs prevents the airplane from later moving to part 135 operations.

So when you rent that plane, it very well could have been maintained in accordance with the regulations AND have been maintained by a non-A&P mechanic. Heck, that non-A&P might have even fabricated a few parts of the plane, something A&Ps are not permitted to do.

 

[Bell206]

That is an interpretation, but not one that I would automatically make.

Not really. Each person who performs work on an aircraft falls under the 43.13 performance standard which in turn points to 3 options: OEM MM, ICA, Admin acceptance. Within those options you will find the removal or disassembly instructions for that work. That is unless its your belief disassembling an aircraft and not making the entries is acceptable to the Administrator? If it has a current AWC, all rules are applicable.

As I mentioned, it’s a technicality that is rarely enforced, but has been a point of contention for a few folks when an overzealous blue-badge stumbled across a week’s worth of work spread across the hangar floor with no obvious mechanic involvement.

that non-A&P might have even fabricated a few parts of the plane, something A&Ps are not permitted to do.

Owners produce parts, but A&Ps can fabricate parts for use in repairs or alterations per Part 21 as well.

 

[Salty]

Not really. Each person who performs work on an aircraft falls under the 43.13 performance standard which in turn points to 3 options: OEM MM, ICA, Admin acceptance. Within those options you will find the removal or disassembly instructions for that work. That is unless it’s your belief disassembling an aircraft and not making the entries is acceptable to the Administrator? If it has a current AWC, all rules are applicable.

Nonsense. Of course it’s acceptable. It’s none of their business.

Aircraft with AWC are disassembled all the time by non certified mechanics. Every time once crashes for example.

 

[Klaus M]

For part 91 operations, the regs very clearly permit quite a bit of maintenance to be performed by a non-A&P, as long as the one doing the work is a pilot and is either the owner or the operator of the aircraft. The regs even allow that owner to fabricate his own parts for the airplane. And nothing in the regs prevents the airplane from later moving to part 135 operations.

So when you rent that plane, it very well could have been maintained in accordance with the regulations AND have been maintained by a non-A&P mechanic. Heck, that non-A&P might have even fabricated a few parts of the plane, something A&Ps are not permitted to do.

I'm sorry about that. When I wrote "Maintenance" should have specified "Other Then Preventative Maintenance". I personally advocate and even train owners how to do their own "Preventative Maintenance".

On-the-other-hand, 21.9(b) says that the owner may NOT SALE the parts 'Owner Produced'. Before you sale your aircraft the parts are to be removed. The FAA does enforce that regulation when the aircraft is placed into commercial service. During a 'Conformity Inspection for Commercial Operation' the non-certified parts are not permitted initially. After placed into service the Owner may produce the parts.

Federal Register :: Request Access

21.9 Replacement and modification articles.​

(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is—
(1) Produced under a type certificate;
(2) Produced under an FAA production approval;
(3) A standard part (such as a nut or bolt) manufactured in compliance with a government or established industry specification;
(4) A commercial part as defined in § 21.1 of this part;
(5) Produced by an owner or operator for maintaining or altering that owner or operator's product;
(6) Fabricated by an appropriately rated certificate holder with a quality system, and consumed in the repair or alteration of a product or article in accordance with part 43 of this chapter; or
(7) Produced in any other manner approved by the FAA.

(b) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person who produces a replacement or modification article for sale may not represent that part as suitable for installation on a type-certificated product.

(c) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person may not sell or represent an article as suitable for installation on an aircraft type-certificated under §§ 21.25(a)(2) or 21.27 unless that article—
(1) Was declared surplus by the U.S. Armed Forces, and
(2) Was intended for use on that aircraft model by the U.S. Armed Forces

 

[dmspilot]

On-the-other-hand, 21.9(b) says that the owner may NOT SALE the parts 'Owner Produced'. Before you sale your aircraft the parts are to be removed.

That's not what it says at all.

 

[Klaus M]

That's not what it says at all.

Don't tell me, I agree with you.
That's the interpretation given by the FSDO in my area. Many of the Dehavilland Beavers have been affected by the particular FSDO's interpretation.

 

[Doc Holliday]

That's the interpretation given by the FSDO in my area.

So post that "interpretation" here, I would enjoy reading it.

 

[MRC01]

There's nothing new in the interpretation....

I think there may be. The Moss Interpretation says on p. 2: The certificated mechanic must be available, not just to answer questions, but to notice mistakes and take over if necessary. The latter half of that phrase is new, and it seems to imply that the A&P must be watching every move the pilot makes, noticing mistakes as they are made, not after the fact. Of course it could be interpreted differently but nobody wants to be the test case.

 

[Doc Holliday]

I think there may be. The Moss Interpretation says on p. 2: The certificated mechanic must be available, not just to answer questions, but to notice mistakes and take over if necessary. The latter half of that phrase is new, and it seems to imply that the A&P must be watching every move the pilot makes, noticing mistakes as they are made, not after the fact.

No, it doesn't say or imply that. The supervising A&P can tell the person "let me inspect this before we close it up", and then if he sees something not right, he can intervene and correct it.

 

[MRC01]

I hope you are right.

 

[Bell206]

The latter half of that phrase is new,

Read the 1st and 2nd paragraphs, then read the last paragraph of the LOI. Its about "in person" and digital sign off. The rest of the fodder is merely supporting info. But whats more telling is "who" is actually publically concerned about it.

Before you sale your aircraft the parts are to be removed. The FAA does enforce that regulation when the aircraft is placed into commercial service. During a 'Conformity Inspection for Commercial Operation' the non-certified parts are not permitted initially.

No, they do not have to be removed prior to sale. OPP parts are the same as PMA parts, so do you remove those as well?

As to the "commercial ops conformity" you do realize 135 and 121 oerators are the largest users of owner produced part by far. The private 91 side has barely scratched the surface using them. So how do you suppose those commercial ops handle the conformity?

Many of the Dehavilland Beavers have been affected by the particular FSDO's interpretation.

What affected parts are you talking about? If its the one I'm thinking about it had zero to due with owner produced parts.

 

[Klaus M]

@Bell206 , Here's one of those times the FAA Principle Maintenance Inspector (PMI) wouldn't sign-off the Conformity Inspection. Purchased a DHC-2 with all three fuel tanks fabricated out of fiberglass and Stainless Steel fittings. A lot of work went into the building of those tanks and they had accumulated over 1000 hours with no evidence of failure. The fiberglass fuel tanks where acknowledged by another FAA PMI in writing at the planes' previous owner's business. The letter even said that a Form 337 was not necessary.

When our PMI was challenged, why can't we couldn't continue to use those tanks? He made the statement that the previous owner can not sale the aircraft with those tanks without a Parts Manufacture Approval (PMA). It was not worth the time and effort to argue so, we purchased three cracked out aluminum tanks and welded them up. They cracked out again within a couple thousand hours, like they do.

 

[Bell206]

Here's one of those times the FAA Principle Maintenance Inspector (PMI) wouldn't sign-off the Conformity Inspection. Purchased a DHC-2 with all three fuel tanks fabricated out of fiberglass and Stainless Steel fittings

Okay, but lets stay on point. Your original comment was about owner-produced parts, they had to be removed, it affected “many” Beavers and was a FSDO interpretation. Now you bring up a single Beaver, with different fuel tanks, a disagreement between 2 PMIs, lack of PMA, and you changed the tanks.

So where we going with this in reference to owner parts and many Beavers?

 

[Kristin]

Not really. Each person who performs work on an aircraft falls under the 43.13 performance standard which in turn points to 3 options: OEM MM, ICA, Admin acceptance. Within those options you will find the removal or disassembly instructions for that work. That is unless its your belief disassembling an aircraft and not making the entries is acceptable to the Administrator? If it has a current AWC, all rules are applicable.

As I mentioned, it’s a technicality that is rarely enforced, but has been a point of contention for a few folks when an overzealous blue-badge stumbled across a week’s worth of work spread across the hangar floor with no obvious mechanic involvement.


Owners produce parts, but A&Ps can fabricate parts for use in repairs or alterations per Part 21 as well.

So all the used parts we get from the boneyards are already illegal when we get them? You are trying to make the regs a lot more black and white than is the reality.

 

[Kristin]

Don't tell me, I agree with you.
That's the interpretation given by the FSDO in my area. Many of the Dehavilland Beavers have been affected by the particular FSDO's interpretation.

FSDO's are often wrong, as are you when repeating it in this instance. Airlines are full of owner produced parts. Airlines are the reasons that they have that provision. They don't want to pay OEM prices for lots of the common things and they will reverse engineer and produce them. When the aircraft comes off lease/sold, all those parts are not stripped off.

 

[Bell206]

So all the used parts we get from the boneyards are already illegal when we get them? You are trying to make the regs a lot more black and white than is the reality.

Where was it said how a part is removed determines its serviceability? Different topic. Besides, how many “aircraft” at a boneyard have effective AWCs?

Just because a rule is routinely not followed or enforced at the 91 level doesn’t mean it doesn’t exist. When those same rules are enforced, like at the 135 or 145 levels, you’ll find the required removal/disassembly records. That’s about as black and white as it gets.

Unfortunately, in reality, it is “common” practice to see various rules not followed at the 91 level which over time make people believe no rule exists simply because there is zero enforcement of it. Yet when the conditions are right and that “nonsense” rule does get enforced, people get all wound up and can’t get it through their head they actually handed the feds the violation on a silver platter.

All’s I’m stating is don’t be that guy or gal.

 

[brien23]

Like most FAA enforcement depends on the local Flight Standards District Office and the inspectors, some will enforce it to the max, others just lip service to the ruling.

 

[Doc Holliday]

Like most FAA enforcement depends on the local Flight Standards District Office and the inspectors, some will enforce it to the max, others just lip service to the ruling.

Enforcements now fall under the Compliance Program. This basically does away with "enforce it to the max" attitude. As long as the airman is being compliant with the FAA, no enforcement can be brought forward and the majority of the time these are settled at the local level. There are a few exceptions, but again, this is not an Inspector action in which one individual can "enforce it to the max".

 

[Kristin]

Where was it said how a part is removed determines its serviceability? Different topic. Besides, how many “aircraft” at a boneyard have effective AWCs?

Just because a rule is routinely not followed or enforced at the 91 level doesn’t mean it doesn’t exist. When those same rules are enforced, like at the 135 or 145 levels, you’ll find the required removal/disassembly records. That’s about as black and white as it gets.

Unfortunately, in reality, it is “common” practice to see various rules not followed at the 91 level which over time make people believe no rule exists simply because there is zero enforcement of it. Yet when the conditions are right and that “nonsense” rule does get enforced, people get all wound up and can’t get it through their head they actually handed the feds the violation on a silver platter.

All’s I’m stating is don’t be that guy or gal.

So removing from one airplane to put in another is not maintenance, but removing one to fix it or inspect what is underneath is maintenance?

Rules are sometimes ambiguous. Sometimes they are written in Washington by people that don't know their a$$ for an aileron. The FSDO's are left to sort it out, in this case, while the interpretation is 20 years old, I was told as recently as about two weeks ago that as the supervisor, I only had to be reasonably available on premises. Of course, as the person endorsing the return to service, it is one me.

 

[Kristin]

Like most FAA enforcement depends on the local Flight Standards District Office and the inspectors, some will enforce it to the max, others just lip service to the ruling.

The FSDO starts the process, and can do an administrative action on their own, but if they are going to go for a certificate action or civil fine, it requires consent and involvement of the region's legal office.

 

[Klaus M]

Like most FAA enforcement depends on the local Flight Standards District Office and the inspectors, some will enforce it to the max, others just lip service to the ruling.

Enforcements now fall under the Compliance Program. This basically does away with "enforce it to the max" attitude. As long as the airman is being compliant with the FAA, no enforcement can be brought forward and the majority of the time these are settled at the local level. There are a few exceptions, but again, this is not an Inspector action in which one individual can "enforce it to the max".

Going back to the title of this thread " Owner Assisted Annuals are Now Outlawed unless Supervised 100%. " Doc, I agree with what you have pointed out and that the FAA is not going to stand behind the A&P and ensure that he is standing over the apprentice.

Just like it's always been, the apprentice needs direct supervision during their training. Once the apprentice has proven their knowledge on a particular task they can enter that in their 'Maintenance Log Book'. Then they need to present that MX Log Book to the FAA to show experience towards taking the A&P test.