Certified Mechanic Requirement

[Dan Thomas]

Be careful with this one. I've heard aof more than a few FSDOs that won't accept this experience

It doesn't count in Canada. Here, a homebuilt is an airplane if you want to fly it. It must be registered and carry a Special C of A - Amateur-Built. The pilot must be licensed and current. It must be insured. It must be flown in accordance with all the regulations.

But if you work on it, it's not an airplane. No credit for the hours. Its owner can do all the maintenance and annual inspections, even if he didn't build it. No mechanic's certification required.

What a mess. An ultralight pilot can count some of his hours toward a PPL, even though most of those guys have picked up a bunch of bad habits through the lack of decent training. But the homebuilder can't count a single minute of his build or maintenance time.

 

[Dan Thomas]

“Cracked exhaust on #3 cylinder” is nowhere as bad as “ Excess ferrous particles in
screen”.

A cracked exhaust on any airplane I ever worked on grounded that airplane. I wouldn't even defer it. Too many airplanes have crashed due to failed exhaust systems.

 

[Silvaire]

I remember when you used to just walk into the FSDO, that's right, just walked right in. No airlocks, no scanners, no bullet proof glass, no appointment.

 

[Checkout_my_Six]

Amazing…ain’t it. Just so you know, if a person with a DOT badge walks in he gets the same quality of care as all the other foot dragers. At least that’s what I get when I visit mine.

I remember when you used to just walk into the FSDO, that's right, just walked right in. No airlocks, no scanners, no bullet proof glass, no appointment.

 

[midwestpa24]

The owners I’ve dealt with however, are commonly uneducated in regards to maintenance standards.

I think that is the biggest argument against owner maintenance. There are a lot of nuances to doing what could be considered routine maintenance, that if done incorrectly could kill. Things that the lay pilot/would-be mechanic would never think of. That's why there is so much training to become an aircraft mechanic. Maintenance induced mishaps in aircraft have a much higher risk of injury and death than a car or motorcycle.

 

[squincher]

I think that is the biggest argument against owner maintenance. There are a lot of nuances to doing what could be considered routine maintenance, that if done incorrectly could kill. Things that the lay pilot/would-be mechanic would never think of. That's why there is so much training to become an aircraft mechanic. Maintenance induced mishaps in aircraft have a much higher risk of injury and death than a car or motorcycle.

Are there no service or technical manuals available, or do aircraft mechanics memorize everything about every aspect of every aircraft they might work on?

 

[mondtster]

Are there no service or technical manuals available, or do aircraft mechanics memorize everything about every aspect of every aircraft they might work on?

Service manuals can vary a lot in their level of detail. You have to know what the appropriate resource to reference is or the correct technique to use is in cases where the manual is silent. When an individual is not trained in what those acceptable practices are, there can be problems.

 

[Bell206]

Are there no service or technical manuals available,

Not for all aircraft. Maintenance/service manuals (ICAs) didn't actually become a regulatory issue or required by the OEM until much later. I believe it was the late 70s or early 80s. Prior to that while some OEMs did provide service documentation, mechanics relied on other documentation like FAA AC43.13-1B, engineer drawings, and other similar references to meet the performance requirements of Part 43. Regardless, no matter how complete an OEM may make their documents not everything is covered. So you look to other industry standards to meet the same Part 43 performance requirements as the OEM manuals. Plus throw in there are additional Part 65 requirements a mechanic must meet before he can perform a task as well.

do aircraft mechanics memorize everything about every aspect of every aircraft they might work on?

No. Nor does the FAA want you to. But they do want you to know where to find that reference or know the process in finding those references.

 

[Dan Thomas]

Are there no service or technical manuals available, or do aircraft mechanics memorize everything about every aspect of every aircraft they might work on?

There are service and parts manuals for just about any airplane built since the early 1950s. It's a legal requirement. Some of the early ones were pretty brief, so the FAA came out with manuals like AC43.13-1B and 2B, which are periodically updated. It's the go-to book for stuff that doesn't get covered in the OEM manuals. There are manuals from the manufacturers of the engine and propeller, overhaul manuals and operator manuals and parts manuals. There will be maintenance procedures in the overhaul/maintenance manuals. Then all of them---airframe, engine and prop manufacturers--have service letters, service bulletins and service instructions to read up on. Continental, for instance, has a Service Bulletin on what lubricants and sealants to use in its engines. In that you will not find, for a further instance, RTV sealant listed anywhere. It's a killer. Ignorance of that has caused engine failures and crashes.

Then there are the maintenance and parts manuals for the magnetos, sparkplugs, alternators, carburetors, fuel injection systems, autopilots, wheels and brakes, and so on. A good shop will have a wide array of these. I did. Money well spent. The aviation regulations mandate that maintenance must be done to those standards, or equivalent standards acceptable to the person at the head of the aviation arm of government.

Nope. It's no motorbike or car or boat. Not a lot of latitude in this business.

 

[Dan Thomas]

Not for all aircraft. Maintenance/service manuals (ICAs) didn't actually become a regulatory issue or required by the OEM until much later. I believe it was the late 70s or early 80s. Prior to that while some OEMs did provide service documentation, mechanics relied on other documentation like FAA AC43.13-1B, engineer drawings, and other similar references to meet the performance requirements of Part 43.

I remember the difference between, say, a 1974 Cessna 172 POH and one for a 1976. It got about four times thicker. The maintenance manuals started getting thicker, too, and now a 172SP manual must be twice the thickness of a 172M manual, and part of that is the injunction, repeated on every page at the head of every procedure, and sometimes twice or three times per page, to "disconnect the battery before touching anything else or this machine will chop your head off" or some such thing. The POH/AFM is the same way. Unless they keep telling you stuff like this they can get sued when you do something stupid. In spite of that, we still see stupid accidents.

 

[Magman]

There was no intent to minimize a cracked exhaust stack.

The aircraft would definitely not be Airworthy with that condition.

My point is some folks would want that reported as the reason for the

Unairworthy designation as the corrective action can be examined relatively easily.

Not so with an engine making metal and not overhauled.

Potential buyers would see red flags with an unknown discrepancy.


Regarding Mx time.

“Satisfactory to the Administrator “ is just as allowable as “ A&P signature.”.

Paychecks, co-workers etc also count .

Applicants should put all their documentation on the table.

FAA is the judge; not the applicant.

 

[pfarber]

Service manuals can vary a lot in their level of detail. You have to know what the appropriate resource to reference is or the correct technique to use is in cases where the manual is silent. When an individual is not trained in what those acceptable practices are, there can be problems.

Service manuals for typical 30-50 year old airplanes are not written for a layperson. They assume that you have knowledge that is learned by OJT or a apprenticeship. Take rigging a simple AC like a 152. Its about 6 paragraphs, maybe 20 sentences. It leaves out a TON of details that you would never know unless you had been shown by a knowledgeable person first.

Allowing owner/pilots to do even preventative maintenance is problematic. SM/MMs are not in the AC, nor are maintenance records. So how can a person sign off the work and return the AC to service without 1. proper tools, 2. proper manuals, 3. a calibration program (every nut is torqued to a spec) and 4. the proper maintenance record entry?

Show of hands: how many owners/operators even know how to run a calibration program? How to exercise a torque wrench? How to properly store a torque wrench??

 

[Bell206]

Allowing owner/pilots to do even preventative maintenance is problematic.

Only for you.

how many owners/operators even know how to run a calibration program?

None. They're not required to. Nor is an A&P working on Part 91 aircraft. So whats your point...again?

How to exercise a torque wrench? How to properly store a torque wrench??

I know dozens of owners that can because I taught them as part of owner-assisted maintenance. Many owners perform their own mx with zero issues in accordance with Part 43. Why is that so hard for you to understand?

 

[Dan Thomas]

Service manuals for typical 30-50 year old airplanes are not written for a layperson. They assume that you have knowledge that is learned by OJT or a apprenticeship. Take rigging a simple AC like a 152. Its about 6 paragraphs, maybe 20 sentences. It leaves out a TON of details that you would never know unless you had been shown by a knowledgeable person first.

What 152 "service manual" have you been reading? The POH?? The 152 manual is a couple inches thick, has 484 pages, and has chapters on the aileron system, the elevator system, the rudder system, the flap system, the trim system, engine and controls, wings, and lengthy descriptions of rigging in every one of those.

http://www.ameacademy.com/pdf/cessna/Cessna_152_1978-1985_MM_D2064-1-13.pdf

The index:



An example of rigging:




Maybe you should read that manual and tell us what is missing.

 

[SkyDog58]

Only for you.

None. They're not required to. Nor is an A&P working on Part 91 aircraft. So whats your point...again?

I know dozens of owners that can because I taught them as part of owner-assisted maintenance. Many owners perform their own mx with zero issues in accordance with Part 43. Why is that so hard for you to understand?

While a "calibration program" (FAA approved or otherwise) is not required in the Part 91 world, one would be mistaken to believe that means that a Part 91 mechanic does not need to have their tools calibrated. They do. Read the following regulation. Emphasis mine.

43.13 Performance rules (general).
(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator, except as noted in § 43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

And in AC 43.13-1B, we have the following passage.

7-40. TORQUES. The importance of correct torque application cannot be overemphasized. Undertorque can result in unnecessary wear of nuts and bolts, as well as the parts they secure. Overtorque can cause failure of a bolt or nut from overstressing the threaded areas. Uneven or additional loads that are applied to the assembly may result in wear or premature failure. The following are a few simple, but important procedures, that should be followed to ensure that correct torque is applied.
NOTE: Be sure that the torque applied is for the size of the bolt shank not the wrench size.
a. Calibrate the torque wrench at least once a year, or immediately after it has been abused or dropped, to ensure continued accuracy.

So whether you are an A&P or an owner doing maintenance, your torque wrench needs to be calibrated.

 

[JAWS]

Wish more owners and mechanics cared about this.

 

[pfarber]

What 152 "service manual" have you been reading? The POH?? The 152 manual is a couple inches thick, has 484 pages, and has chapters on the aileron system, the elevator system, the rudder system, the flap system, the trim system, engine and controls, wings, and lengthy descriptions of rigging in every one of those.

http://www.ameacademy.com/pdf/cessna/Cessna_152_1978-1985_MM_D2064-1-13.pdf

The index:

View attachment 103021

An example of rigging:
View attachment 103022

View attachment 103023

Maybe you should read that manual and tell us what is missing.

How many owners have a calibrated inclinomter? Used are $800 not including the cal cost. So that's at least a grand right there.

Go out to your local owner/operator and show me that they have the proper tools.

Next is the tension guage. Again a fee hundred and still needs cal.

Granted, none of this is preventative maintenance so they cannot do it anyway... But even changing a tire. Do they have an in cal air guage? No, they do not. Now add in the torque wrench etc etc etc

So you just keep randomly googling manual snippets... The adults have work to do.

 

[Dana]

I wonder how many aircraft have crashed because of shoddy owner performed maintenance? It happens, of course, but what are the statistics? Compared to crashes caused mistakes by an A&P? I haven't heard of Canadian aircraft under owner maintenance raining out of the sky.

 

[Bell206]

The adults have work to do.

So why do you keep posting and bothering us as we work?

 

[Dan Thomas]

How many owners have a calibrated inclinomter? Used are $800 not including the cal cost. So that's at least a grand right there.

Go out to your local owner/operator and show me that they have the proper tools.

Next is the tension guage. Again a fee hundred and still needs cal.

Granted, none of this is preventative maintenance so they cannot do it anyway... But even changing a tire. Do they have an in cal air guage? No, they do not. Now add in the torque wrench etc etc etc

So you just keep randomly googling manual snippets... The adults have work to do.

I had all of those. All calibrated on schedule as per MPM in the AMO.

You're not doing any of this stuff anyway. Just what you say about various stuff is starkly revealing. A 152 manual with nothing on rigging? Seriously??

Edit: And if you ARE doing it on anything other than a homebuilt, without the proper and calibrated tools, you're already illegal. Big time.

 

[Dan Thomas]

I wonder how many aircraft have crashed because of shoddy owner performed maintenance? It happens, of course, but what are the statistics? Compared to crashes caused mistakes by an A&P? I haven't heard of Canadian aircraft under owner maintenance raining out of the sky.

I know of one. The carb heat flapper plate in the airbox came loose and blocked the carb intake. Forced landing resulted. Inadequate inspections, of course.

It can and will happen. Still, if I took on another project for myself, it would be an old TC'd airplane eligible for OM, just so I could make parts for it and use stuff from the auto parts shops. I could do all my own work on it as a certified airplane (I'm a Canadian AME) but what for? So I could pay big bucks for parts I could make myself or substitute with new, known good parts? Or pay a certified welder to fix stuff I can weld? Welding here (on TC'd aircraft) is specialized maintenance limited to those with appropriate industrial certifications.

OM accidents will largely be, I believe, caused by failed magnetos and the like. Stuff that people don't understand, and either ignore them until they quit or they'll fool with them and mess them up. Or they'll use cheap fuel hose and suffer failures with it.

 

[Bell206]

I wonder how many aircraft have crashed because of shoddy owner performed maintenance?

Keep in mind the rules governing owner maintenance are not solely based on accident statistics but rather international convention and other agreements. The Canadian owner maintained aircraft is a good example how that works so long as you don't ever want to fly/export those aircraft out of Canada. The reason you can't is they no longer conform to those same international agreements and guidance like ICAO. Aviation rules have been global since the mid-40s. When the potential new FAA category of primary non-commercial was pushed for several years there were a number of discussions on its impact. In the end after it was shelved for various reasons the impact that new category would have on the existing FAA system was not fully developed. While it may seem a simple process from the outside the long term effect to the US aviation system it could be detrimental to the entire GA system as a whole. And I'm a proponent of PNC.

 

[Jdm]

How about if the FAA had a simple program in place to ensure owners are qualified in tackling the maintenance tasks desired? I’m sure they would comply if properly trained and held responsible. Could have a sign off program that includes demonstrating proficiency to a “designated” IA in each of the tasks. If satisfactory, they would receive a sign off for that task. In return, the FAA could open the door for more complicated practices than currently allowed. This would take care of safety concerns and also allow owners more freedom to wrench away.

 

[rotormatic1]

Here’s the program the FAA has in place for you to perform maintenance...

(a) At least 18 months of practical experience with the procedures, practices, materials, tools, machine tools, and equipment generally used in constructing, maintaining, or altering airframes, or powerplants appropriate to the ratingsought; or

(b) At least 30 months of practical experience concurrently performing the duties appropriate to both the airframe and powerplant

 

[Jdm]

Here’s the program the FAA has in place for you to perform maintenance...
(a) At least 18 months of practical experience with the procedures, practices, materials, tools, machine tools, and equipment generally used in constructing, maintaining, or altering airframes, or powerplants appropriate to the ratingsought; or
(b) At least 30 months of practical experience concurrently performing the duties appropriate to both the airframe and powerplant

I think you’ve quoted the eligibility requirements to initiate testing to become a licensed mechanic. Not to perform maintenance.

 

[Dan Thomas]

I think you’ve quoted the eligibility requirements to initiate testing to become a licensed mechanic. Not to perform maintenance.

But without that mechanic's ticket, you can't certify most work anyway. FAR 43.5.

 

[Jdm]

That’s right.

 

[Jdm]

Am I missing something Dan?

 

[Magman]

In some WW2 Training Manuals that I have; Torque Wrenches are referred to as

Tension Wrenches.

Contrary to popular opinion I did not write the manual.

Not sure how common it is but I also have a Left Hand Only click type

Torque Wrench.

A tool I find very useful is a Snap-on Torque Wrench Calibrator.

You use your calibrated Torque Wrench and note a particular setting.

You can put adapters on your Torque Wrench and actually see the applied torque.

A Repair Station I was with dealt with a calibration service.

They would calibrate the torque wrenches and a “ Master Pressure Gage”.

We used the Master Gage to calibrate compression testers and tire gages.

This allowed us to recheck at frequent intervals.

Using their NIST weights allowed us calibrate Tensiometers per mfg. instructions.

 

[Dana]

Here’s the program the FAA has in place for you to perform maintenance...

(a) At least 18 months of practical experience with the procedures, practices, materials, tools, machine tools, and equipment generally used in constructing, maintaining, or altering airframes, or powerplants appropriate to the ratingsought; or

(b) At least 30 months of practical experience concurrently performing the duties appropriate to both the airframe and powerplant

For Light-Sport aircraft, there is a three week course to get a "Light-Sport Repairman-Maintenance" certificate which is essentially an A&P for LSA. There's also a two day course ("Light-Sport Repairman-Inspection" which allows you to preform the annual condition on an ELSA you own.

 

[Bell206]

How about if the FAA had a simple program in place to ensure owners are qualified in tackling the maintenance tasks desired?

Perhaps look at this way. What percentage of owners take full advantage of the current "simple program" (43. Appx A(c)) where owners are qualified to perform maintenance on their aircraft? Or do you believe that if the FAA expands that task list that percentage will drastically increase?

I’m sure they would comply if properly trained and held responsible.

So given owners are currently held responsible for certain aspects of the mx performed on their aircraft, do you believe hangar fairies and other similar creatures will become extinct once an owner mx program is created?

Could have a sign off program that includes demonstrating proficiency to a “designated” IA in each of the tasks.

We now have IAs that sign off 20 minute annuals. Do you think they will change their ways with this new program or will the program simply open up a new revenue stream for them?

This would take care of safety concerns

As mentioned above its not all safety orientated.

 

[Checkout_my_Six]

80% of A&P I/A work is about finding "compliance" with the Type Certificate.....the other 20% involves bucking rivets and wrench turning.

 

[Jdm]

What percentage of owners take full advantage of the current "simple program" (43. Appx A(c)) where owners are qualified to perform maintenance on their aircraft? Or do you believe that if the FAA expands that task list that percentage will drastically increase?

It’ll obviously never happen but for the discussion I’d say maybe 10% to 20%. I don’t think the percentage would increase at all it’d just help to ensure those who are doing the work would have proper training.

do you believe hangar fairies and other similar creatures will become extinct once an owner mx program is created?

Nope. That’s not the internet or a reasonable expectation. It would however, help educate the owners trying to do things right. It would also help save a few pennies for those who interested in doing light maintenance for that reason.

 

[Jdm]

We now have IAs that sign off 20 minute annuals. Do you think they will change their ways with this new program or will the program simply open up a new revenue stream for them?

I thought about that. It’s why I said “designed” IA. Ones the FAA feel are responsible enough to provide this type training on their behalf.

 

[Dan Thomas]

Am I missing something Dan?

Most of us mechanics are missing something

 

[JAWS]

I agree with Bell. Most owners I have dealt with don't exercise the privileges they do have now properly as it is.

 

[Silvaire]

How about if the FAA had a simple program in place ...

Stop right there and think about what you are saying. Are you kidding?

 

[Bell206]

Ones the FAA feel are responsible enough to provide this type training on their behalf.

That would require they become a designee. While I think your 10%-20% estimate is a bit low I don't think there are the numbers to push something like that through. If you had 70%-80% performing a majority of the prevent mx task then maybe. But after all the years I did owner-assist the true money savings for the owners was in the disassembly/reassembly/cleaning side of the maintenance task which they can perform now. And while a number of owners performed/participated in the actual mx task there was no real savings as they didn't have the special tools, took 2x longer, etc. to perform the task. So its not really a slam-dunk money saver except in certain scenarios. But for those owners who want to try then if they are performing all they can do per Appx A then the next level would be to find an AP who will do owner-assist.

 

[Jdm]

I get it. Just a thought.