September 15, 2009
AEA VP of Government/Industry Affairs Ric Peri
Wish you had a better understanding of the regulations when talking to your mechanic or the avionics shop? Aircraft Electronics Association Vice President of Government/Industry Affairs Ric Peri answers your frequently asked questions.
Question: Can an A&P install avionics? And can an IA supervise and sign-off a radio installation by an uncertificated person?
Answer: Maybe. But he or she must be fully trained and qualified (something that most A&Ps and IAs are not).
Part 65, Section 65.81 allows a certificated mechanic to perform or supervise the maintenance, preventive maintenance, or alteration of an aircraft or appliance, or a part thereof, for which he or she is rated.
However, section 65.81 specifically prohibits the mechanic from performing “any repair to, or alteration of, instruments.” (Remember that autopilots and other “electronic devices for automatically controlling an aircraft in flight”are instruments by definition.) Appendix A to Part 43 defines the calibration and repair of instruments (including autopilots) as an appliance major repair.
Section 65.81 allows mechanics to supervise other persons; however, they may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which they are rated unless they have satisfactorily performed the work concerned at an earlier date.
Section 65.81 (b) also prohibits a certificated mechanic from exercising the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned.
Part 43, Section 43.13 requires that 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 (if those manuals or instructions do not exist) other methods, techniques, and practices acceptable to the administrator. The regulations do not allow a mechanic to use other methods, techniques, and practices as a means to circumvent the manufacturer’s manuals and instructions.
Section 43.13 (a) also require the mechanic to use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. It specifically requires that “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.”
In addition to the FAA’s rules, the FCC has some requirements. Title 47 of the Code of Federal Regulations, Telecommunication Commission, Part 87—Aviation Services, states that a commercial radio operator license is required to repair and maintain all aircraft stations and aeronautical ground stations (including hand-carried portable units) used to communicate with aircraft.
So, an A&P mechanic can install and/or supervise the installation of avionics equipment, provided that he or she meets all of the same requirements that a technician at a repair station does for the same job.
If he or she does not meet the same personal and professional requirements of an avionics technician, it is the responsibility of the avionics industry to document the unqualified work and report it to your local FAA office. Keep in mind that the FAA can only monitor the individual A&P while the mechanic is performing maintenance; they do not operate from a repair station, so there is no business to audit like there is for a repair station. Your help in identifying these un-safe actions is required.
If your local FAA office does not take action against this un-safe maintenance, the technician should initiate a customer service initiative (CSI) action and raise the issue up the FAA’s chain of command until satisfactory resolution can be made.
Submit your own question via e-mail.
Note: AEA offers this column in order to foster greater understanding of the Federal Aviation Regulations and the rules that govern the industry. AEA strives to make them as accurate as possible at the time they are written, but rules change so you should verify the information. AEA disclaims any warranty for the accuracy of the information provided. This information is not meant to serve as legal advice.
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AOPA thanks our members for their continued support in protecting the freedom to fly.