supervision?

[kgruber]

How much A&P "supervision" is actually required for a pilot to work on his airplane, outside of the preventative maintenance items.

Does he have to hold you hand? Look over your shoulder? Be in the next hangar. Be on the phone? Just sign the logs?

What EXACTLY is required.

 

[Henning]

How much A&P "supervision" is actually required for a pilot to work on his airplane, outside of the preventative maintenance items.

Does he have to hold you hand? Look over your shoulder? Be in the next hangar. Be on the phone? Just sign the logs?

What EXACTLY is required.

Whatever they are comfortable with to provide the signature.

 

[Tom-D]

How much A&P "supervision" is actually required for a pilot to work on his airplane, outside of the preventative maintenance items.

Does he have to hold you hand? Look over your shoulder? Be in the next hangar. Be on the phone? Just sign the logs?

What EXACTLY is required.

That is solely up to the A&P.

the FAR says:

(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. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.

 

[alfadog]

"Be on the phone" is fine provided the A&P is readily available at any time that work is being performed. Other than that, whatever personal observation of what has been done is satisfactory to the A&P. After all, it is his/her cert on the line. And, needless to say, an A&P or IA may not delegate his inspection duties.

 

[RotorAndWing]

"Be on the phone" is fine provided the A&P is readily available at any time that work is being performed. Other than that, whatever personal observation of what has been done is satisfactory to the A&P. After all, it is his/her cert on the line. And, needless to say, an A&P or IA may not delegate his inspection duties.

Here's my take on this. The regulation says "and if the supervisor is readily available, in person, for consultation." I read "in person" as being there, not on a beach with his cell phone if you have a question.

Also, if you are in your hangar performing the work and an Inspector stops by you will need to explain why you are performing the job without proper certification. And he won't buy "My A&P is supervising me from his cellphone".

FWIW.

 

[flyingmoose]

ITs a comfort level on the supervision thing. I have to agree with Rotor also. Just my 2 cents.

 

[frfly172]

In person seems pretty clear to me. I'm sure my mechanic would not sign anything off ,if he wasn't present to observe and inspect the work.

 

[poadeleted20]

How much A&P "supervision" is actually required for a pilot to work on his airplane, outside of the preventative maintenance items.

Enough that the supervisor "personally observes the work being done to the extent necessary to ensure that it is being done properly and ... is readily available, in person, for consultation."

Does he have to hold you hand? Look over your shoulder? Be in the next hangar. Be on the phone? Just sign the logs?

The regulations leave that entirely to the supervisor's discretion, and I've found no case law or advisory guidance on point. Note R&W's post about one A&P-holding former FAA Operations Inspector's opinion on what that is, although there's no telling for sure what any given Airworthiness Inspector will say about it until s/he says it -- could range anywhere from "over the shoulder the whole time" to "check the completed work before signing".

What EXACTLY is required.

The FAA has not said in writing. So, it's like Henning said -- "Whatever they are comfortable with to provide the signature," with the understanding that if there's any problem with the work later, it's the signing mechanic who gets hosed by the FAA.

 

[alfadog]

Here's my take on this. The regulation says "and if the supervisor is readily available, in person, for consultation." I read "in person" as being there, not on a beach with his cell phone if you have a question.

Also, if you are in your hangar performing the work and an Inspector stops by you will need to explain why you are performing the job without proper certification. And he won't buy "My A&P is supervising me from his cellphone".

FWIW.

I do not have actual experience (in school now for my A&P) but I would think it more boils down to "readily available". I agree now that "in person" would mean "in the flesh" and back away from my earlier opinion re "on the phone". However, I think that if you can contact the A&P while working and he is available to come down in person and consult with you as needed then you should be OK. Of course he also needs to inspect your work to whatever degree he feels necessary. I intend to repair my Arrow prior to getting my own A&P under those exact conditions.

 

[Skylane81E]

I was instructed that I needed to be present, but didn't need to be hovering over sholders either.

 

[tmyers]

The ability to supervise without mothering is what has made owner participation in annuals attractive. If your A&P is willing to work with you (not all are) they quickly figure out what you can and cannot do. Your responsibility as the owner is to ask questions when you are not certain and other than that stay out of the way.

 

[Tom-D]

The FAA has not said in writing. So, it's like Henning said -- "Whatever they are comfortable with to provide the signature," with the understanding that if there's any problem with the work later, it's the signing mechanic who gets hosed by the FAA.

Hosed by the FAA? You got to be joking, all they can do is revoke your certificate, It's the civil lawyers we worry about, they can take your house. As R&W stated in his post, it is his opinion and one not shared by my PMI.

 

[Tom-D]

"Be on the phone" is fine provided the A&P is readily available at any time that work is being performed. Other than that, whatever personal observation of what has been done is satisfactory to the A&P. After all, it is his/her cert on the line. And, needless to say, an A&P or IA may not delegate his inspection duties.

Supervision and inspection duties are two different issues in the FARs.

 

[kgruber]

The FAA has not said in writing. So, it's like Henning said -- "Whatever they are comfortable with to provide the signature," with the understanding that if there's any problem with the work later, it's the signing mechanic who gets hosed by the FAA.

Cap't,

I was counting on you to provide FAA legal guidance, since you should be awarded the official "FAA library of congress" compilation award.

OTOH, I hope nobody seeks legal council advice. Let sleeping dogs lie!

 

[poadeleted20]

Cap't,

I was counting on you to provide FAA legal guidance, since you should be awarded the official "FAA library of congress" compilation award.

Sorry to disappoint you -- one cannot provide what does not exist.

OTOH, I hope nobody seeks legal council advice. Let sleeping dogs lie!

Having tripped over a sleeping dog when getting up in the middle of the night, and being bit for my trouble, I'm with you. :wink2:

 

[Jay Honeck]

Funny. I initially read the question as "How much supervision does an A&P need to work on my plane?"

I was gonna say "plenty"... Then I re-read it.

 

[weirdjim]

Aircraft owners, student pilots, mechanics, doctors, teachers, teenagers, alles alles same same.

You closely (as in over the shoulder) observe until you are satisfied that you can be a foot away, then a yard away, then a mile away, then "call me if you need help".

It is building that trust that the person is skilled and experienced enough to do the job without your interference over a series of tasks over time.

After all, we let our students solo from a mile or two away the first time, then send them a hundred miles away without a string tying them to you, don't we?

Jim
.

 

[RotorAndWing]

The FAA has not said in writing.

Yes they have, read the regulation.

The FAA does not need a CC decision or an Order or Memo to define what a regulation means. Does the regulation state the obvious?

 

[poadeleted20]

Yes they have, read the regulation.

I did. It's not at all specific -- "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." That's pretty much a results-based standard, not something an Inspector can walk up and say "that's not good enough" without seeing the final product. And who's to say what "readily available" means (other than the Chief Counsel)? Does that mean able to be there before a dropped wrench hits the floor? Or maybe just able to get there if called and see what's going on before the next step is taken (which could be in five minutes or five hours or five days)? There is simply no written guidance on these issues. And frankly, I'm happy with it that way, as it allows the supervising mechanic some leeway in deciding just how to handle it based on the known skill of the person doing the work and the nature of the work being done as long as the supervising mechanic is willing to take responsibility for the result.

 

[RotorAndWing]

I did. It's not at all specific -- "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." That's pretty much a results-based standard, not something an Inspector can walk up and say "that's not good enough" without seeing the final product.

You keep missing a part that clearly states "in person".

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.

So, there you are, in your hangar in Maryland and you decide to remove and reinstall your prop on your Grumman. After removing the prop to then you are reinstalling when an Inspector walks up. He ask you what you are doing and you tell him, he ask to see your A&P certificate. You tell him you don't hold one but you are working under the supervision of a mechanic. He ask "So where is the mechanic?" and you hold up your cell phone and say "He's on the beach in Barbados".

Honestly, do you think that's gonna fly?

And who's to say what "readily available" means (other than the Chief Counsel)?

The Administrator or his representative.

 

[Tom-D]

So, there you are, in your hangar in Maryland and you decide to remove and reinstall your prop on your Grumman. After removing the prop to then you are reinstalling when an Inspector walks up. He ask you what you are doing and you tell him, he ask to see your A&P certificate. You tell him you don't hold one but you are working under the supervision of a mechanic. He ask "So where is the mechanic?" and you hold up your cell phone and say "He's on the beach in Barbados".

Honestly, do you think that's gonna fly?

There is a common sense limit. But of course there ya go, bla bla bla…..>off the deep end.

 

[poadeleted20]

You keep missing a part that clearly states "in person".

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.

So I call him, and he shows up in person for consultation. Or do you have something in FAR 1.1 which defines "readily available"?

The Administrator or his representative.

The only representative of the Administrator authorized to interpret the regulations is the Chief Counsel, and that's something which has been stated repeatedly in writing by AFS-1 to the Inspectors in the field.

 

[alfadog]

So I call him, and he shows up in person for consultation. Or do you have something in FAR 1.1 which defines "readily available"?

The only representative of the Administrator authorized to interpret the regulations is the Chief Counsel, and that's something which has been stated repeatedly in writing by AFS-1 to the Inspectors in the field.

read·i·ly adverb \ˈre-də-lē\
: quickly and easily

Obviously some room for interpretation but I would think it pretty obvious that an hour or more away is not "quickly" in this context. We are talking "quickly" as in "come over here quickly and take a look at what I am doing".

 

[RotorAndWing]

So I call him, and he shows up in person for consultation. Or do you have something in FAR 1.1 which defines "readily available"?

This is getting comical. You are not answering the question ( typical).

The only representative of the Administrator authorized to interpret the regulations is the Chief Counsel, and that's something which has been stated repeatedly in writing by AFS-1 to the Inspectors in the field.

You have never clearly understood this part and continually perpetuate this myth.

 

[davidm767]

You keep missing a part that clearly states "in person".

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.

I think you are going too deep into this interpretation. What this is saying is that the mechanic can not legally call in a repair and sign off on a task without inspecting the work. And the mechanic can not legally (or ethically) allow an owner to perform tasks at which they were not trained or qualified without first ensuring that they are available in person to ensure the task was complete correctly. Once training has been done, or they have ensured the owner/worker can competently perform the task without direct supervision than the A&P can delegate the task for completion up to...but not including...the inspection for the item to be returned to service.

Add another layer to this...a large Repair Station is completely filled with Non-A&P technicians performing almost ALL of the work. The A&P is available (often in his cube or in another area i.e. inspecting a task), but definitely not over the shoulders of the workers. What happens if he goes to lunch? Does the whole shift stop? No. GRANTED they are under the authority of the repair station license so they are given more flexibility than an owner/A&P situation.

Now, lets add some beans to this casserole...Say I'm removing my canopy top (Grumman Tiger) to replace the window side panels and replace the teflon track runners. The replacing side windows is fully authorized by a private pilot under CFAR 43 Appdx A Preventative Maintenance, and the Teflon runners with the right tool is a very simple job. However both are structual and require an A&P certified technician to sign off on the task. Now if I had a trusty mechanic that I knew and he knew me, would I need him look over my shoulders or be in the hangar while I perform this task?

No. Why? Because I can take a item out of service and make it un-airworthy without a mechanics license, there is a whole thread dedicated to this.

Now, by making the repair, can I place the item back into service? Absolutely not. Only the aircraft mechanic can, and he can delegate as much as he wants knowing full well that if something goes wrong its his certificate.

Now, can I as an owner put the aircraft all back together without having the mechanic look at the quality of work? No, because how else can the mechanic ensure that the job was done right?

So how do I find a happy balance? If the A&P technician does not feel comfortable with the owner performing the task, or if the owner was not provided training on how to complete the task properly, then the technician has a responsibility (legal and ethical) to avail himself in person to provide services.

 

[Tom-D]

Now, can I as an owner put the aircraft all back together without having the mechanic look at the quality of work? No, because how else can the mechanic ensure that the job was done right?

So how do I find a happy balance? If the A&P technician does not feel comfortable with the owner performing the task, or if the owner was not provided training on how to complete the task properly, then the technician has a responsibility (legal and ethical) to avail himself in person to provide services.

How do you find a happy balance? you talk to your supervisor, yes it is that simple.

Any A&P should know who they are supervising well enough to know what they can do, and what they can't.

If they fail in that, they should not be supervising.

 

[RotorAndWing]

I think you are going too deep into this interpretation. What this is saying is that the mechanic can not legally call in a repair and sign off on a task without inspecting the work. And the mechanic can not legally (or ethically) allow an owner to perform tasks at which they were not trained or qualified without first ensuring that they are available in person to ensure the task was complete correctly. Once training has been done, or they have ensured the owner/worker can competently perform the task without direct supervision than the A&P can delegate the task for completion up to...but not including...the inspection for the item to be returned to service.

Add another layer to this...a large Repair Station is completely filled with Non-A&P technicians performing almost ALL of the work. The A&P is available (often in his cube or in another area i.e. inspecting a task), but definitely not over the shoulders of the workers. What happens if he goes to lunch? Does the whole shift stop? No. GRANTED they are under the authority of the repair station license so they are given more flexibility than an owner/A&P situation.

Now, lets add some beans to this casserole...Say I'm removing my canopy top (Grumman Tiger) to replace the window side panels and replace the teflon track runners. The replacing side windows is fully authorized by a private pilot under CFAR 43 Appdx A Preventative Maintenance, and the Teflon runners with the right tool is a very simple job. However both are structual and require an A&P certified technician to sign off on the task. Now if I had a trusty mechanic that I knew and he knew me, would I need him look over my shoulders or be in the hangar while I perform this task?

No. Why? Because I can take a item out of service and make it un-airworthy without a mechanics license, there is a whole thread dedicated to this.

Now, by making the repair, can I place the item back into service? Absolutely not. Only the aircraft mechanic can, and he can delegate as much as he wants knowing full well that if something goes wrong its his certificate.

Now, can I as an owner put the aircraft all back together without having the mechanic look at the quality of work? No, because how else can the mechanic ensure that the job was done right?

So how do I find a happy balance? If the A&P technician does not feel comfortable with the owner performing the task, or if the owner was not provided training on how to complete the task properly, then the technician has a responsibility (legal and ethical) to avail himself in person to provide services.

Simply stated: Non A&P types want this rule as loose as they want it to be.

 

[Tom-D]

Supervision of maintenance tasks should be more training than maintenance.

The biggest issue that I have found for the FAA is finding any person working with out the proper reference manual at hand. It does not matter to them who has the wrench.

OBTW the FAA will not simply walk into your hangar, they will announce. (every body can stop work)

 

[Tom-D]

Simply stated: Non A&P types want this rule as loose as they want it to be.

As it should be.

The FAA is smart enough to know that no two people communicate the same, and is not willing to penalize all for a few.

 

[davidm767]

As it should be.

The FAA is smart enough to know that no two people communicate the same, and is not willing to penalize all for a few.

Some in the FAA, the types that you and I may have had a cup of coffee with definitely fit that bill. However, there are types who are insulated from the real world, want to make a name for themselves, and are more than willing to penalize many for a small personal gain.

The rule...aka the law does offer a lot of flexibility for owners/non certified technicians to do some work. And as a owner it personally pushed me to get my certification, if nothing else but to be more educated about my aircraft and about the skills necessary to keep it flying.

However...on the other side of the line... for the certified technicians who don't hold their end of the bargain by holding fast to the TRUST BUT VERIFY mantra, well they fully deserve to have their necks on the guillotine blocks.

 

[Tom-D]

Some in the FAA, the types that you and I may have had a cup of coffee with definitely fit that bill. However, there are types who are insulated from the real world, want to make a name for themselves, and are more than willing to penalize many for a small personal gain.

The rule...aka the law does offer a lot of flexibility for owners/non certified technicians to do some work. And as a owner it personally pushed me to get my certification, if nothing else but to be more educated about my aircraft and about the skills necessary to keep it flying.

However...on the other side of the line... for the certified technicians who don't hold their end of the bargain by holding fast to the TRUST BUT VERIFY mantra, well they fully deserve to have their necks on the guillotine blocks.

Were the FAA to stop this type of training they would stop all A&Ps from getting the training required to gain certification under FAR 65. then every one would be required to attend a school to get the A&P.

 

[alfadog]

Simply stated: Non A&P types want this rule as loose as they want it to be.

As, no doubt, do some A&P's. Looking back, I know of at least one shop that has a non-A&P doing working while the A&P is nowhere to be found and far from "readily available". I thought this fellow doing the work had an A&P but later learned he did not.

Here is apparently a novel thought - the FAA thinks that only certificated mechanics should be performing major and minor repairs on aircraft but has made very limited provision for what we are discussing here. Wait, isn't that somewhere in the FARs

I have to admit that my viewpoint on this has changed.

 

[Capt. Geoffrey Thorpe]

Makes me want to run out and buy a type certificated airplane.


Not.

 

[Tom-D]

As, no doubt, do some A&P's. Looking back, I know of at least one shop that has a non-A&P doing working while the A&P is nowhere to be found and far from "readily available". I thought this fellow doing the work had an A&P but later learned he did not.

Here is apparently a novel thought - the FAA thinks that only certificated mechanics should be performing major and minor repairs on aircraft but has made very limited provision for what we are discussing here. Wait, isn't that somewhere in the FARs

I have to admit that my viewpoint on this has changed.

I wouldn't run out after the fact and try to find a A&P to sign my book. It shouldn't work like that, but of course there are some that will.

 

[Tom-D]

Enough that the supervisor "personally observes the work being done to the extent necessary to ensure that it is being done properly and ... is readily available, in person, for consultation."

I'm in full agreement with you on this, the statement says " consultation", it does not say help, supervision, or training,

Consultation is defined as a discussion. The FAA has discussions over the phone daily.

The "In person" portion of the statement simply means that my flunky can't be the one supervising. IOWs I can't delicate this responsibility.

 

[alfadog]

I'm in full agreement with you on this, the statement says " consultation", it does not say help, supervision, or training,

Consultation is defined as a discussion. The FAA has discussions over the phone daily.

The "In person" portion of the statement simply means that my flunky can't be the one supervising. IOWs I can't delicate this responsibility.

"In person" means physically present, not on the phone, Skype, etc.

 

[Tom-D]

"In person" means physically present, not on the phone, Skype, etc.

Show me where the regs say that?

| noun
the action or process of formally consulting or discussing:

 

[alfadog]

Show me where the regs say that?

| noun
the action or process of formally consulting or discussing:

It is the normal English definition of the term. There is no need for the regs to define it. What does "He was there in person" mean to you? On the phone?

The definition of consultation is irrelevant. That is not the issue. The issue is where is the supervising A&P physically located when he is consulting or whatever with the non-A&P mechanic. He is present in person, that is where he is.

 

[Tom-D]

It is the normal English definition of the term. There is no need for the regs to define it. What does "He was there in person" mean to you? On the phone?

That is not what the reg says why bring it into the conversation?

The definition of consultation is irrelevant. That is not the issue. The issue is where is the supervising A&P physically located when he is consulting or whatever with the non-A&P mechanic. He is present in person, that is where he is.

If Consultation wasn't the issue why did the FAA write the reg using that term? Why didn't they use the wording " must be "on site" or words to that effect?

The reasoning is easy, when I teach you to rib stich, I use the 43-13 as a reference to how to tie the knot, and move to the next stitch, I show you, allow you to do a few, when I'm satisfied you can make the stitches I am allowed to let you work alone. If when I inspect the work, if you make mistakes we can cut them out and you can do them over.
Riveting is the same, once I'm confident you can do the job you can be allowed to work alone, I'm not required o be on premise when the work is completed.
when you have a problem, call me, we can then decide what course of action to take.

 

[alfadog]

It is the normal English definition of the term. There is no need for the regs to define it. What does "He was there in person" mean to you? On the phone?

That is not what the reg says why bring it into the conversation?

Umm, that is what the reg says "and if the supervisor is readily available, in person". The "and" is important, this is not just another statement that he must be satisfied with the work.