difference working for a shop over at a shop

stingray

Line Up and Wait
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Daniel Michaels
I was recycling through my old AOPA magazines ( I no longer get them), and came across an article on pilot responsabilities in regards to putting plane back in service. Sept 2006 page 56

It says in the article that the pilot helped work on the plane to get it back in the air after it was at the shop way too long. They were working late at night and it does not seem that an A&P or AI was there but other employees were working on the plane. The owner got hit for working on the plane without being under the supervision of an A&P. It did not say however whether or not the other employees were repromanded or the shop for that matter.

Does it matter if you are an employee? If you are an employee of a shop but not yet rated as an A&P can you then work on a certified plane without being in direct contact of the A&P (A&P goes to lunch)? I know that if you are an owner you can work on the plane if you are in direct supervision of an A&P or AI. From the article it did not seem to be a big deal that the employees were not A&P's but were still working on the plane without an A&P being present. Is it different for electronics? They were working on avionics. The pilot got hit for replacing a cover on a box.

Dan
 
First of all, a couple of nitpicks. "A&P or IA" is redundant and not quite right. The regs say that the unlicensed person performing the work shall be under the supervision of a person holding a mechanic's certificate. The IA has nothing to do with it.

Second, an aircraft is not certified. It is certificated. ALL aircraft are certificated. The difference is to what part of the FAR the aircraft is certificated. I'm presuming this aircraft was certificated in what we call the "normal" part of the regs ... Beech, Piper, Mooney, etc.

Now to the crux of it. Part 43 does not say a word about "direct" supervision of anybody, and it doesn't matter if the person doing the work is the owner, pilot, or employee of the shop in question. It merely says that the work being done by uncertificated persons must be supervised "to the extent necessary that to ensure that it is being done properly..."

Typical FAA weaselwords. Your "extent" and my "extent" and the FAA's "extent" may be totally different. But you can bet your hiney on one thing, and that is that if I sign off your work and return the aircraft to service and the damn thing falls out of the sky, it is MY name on the logbook entry, not yours. No matter who does it, it is MY work and MY ticket on the line. If I've been working with Joe Airplaneowner for thirty years doing annuals and say that the left main needs replacing, go have a sammich at the airport cafe and come back to a new tire installation, then my "extent" may be to ask if they also replaced the tube, whether or not they greased the wheel bearings, spin the sucker around to see whether the bearing preload is about right, and go on from there. On the other hand, if this is my first time with you and tires, I may just sit in my easy chair a foot away and watch you work. Next time my "extent" may go out a bit. And out a bit.

The reg goes on in the same paragraph to say that "...the supervisor [must] be available, in person, for consultation." Does that mean the same hangar bay? The same hangar? The same building, the same airport, the same city, or the same county? I'd sort of draw the line at doing things by webcam, but what does "in person" mean? That if you've got a question that I'll drive twenty miles from home to answer it face to face? Or that I have to be roaming the floor without taking a potty break?

Again, it is all interpretation. Interpretation is an FAA word that means "your contorted views against the FAA's good sense".
 
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