Progressive Inspections Events

[Stache]

Recently I have been asked the question who can sign off the individual events on Progressive Inspections. I defaulted to the Progressive Inspection procedures manual and what it states as who is responsible for the inspections by name.

I know many Progressive Inspection manuals may not explain this very well, but it is my opinion an A&P can certainly perform the individual tasks under their rating and under the supervision of an Inspection Authorization (IA) holder.

My question to the group is do you think and IA has to sign off the individual events or can and A&P sign off the events as long as the IA signs off the final event in the cycle show compliance for the 12-calendar month period?

 

[Stache]

I have been giving a lot of thought to what has to be in the Progressive Manual and have reviewed several manufacture progressive inspection manuals from Piper, Cirrus, and Cessna that I have. Not even the manufacture manuals cover all the requirements Part 91 Section 91.409(d) where it talks about an IA, must perform and supervise or who is responsible.

This got me thinking about what the CFRs says about mechanic limitations so I went back to Part 65 and looked at the limitations for mechanics and IA again. It is clear in Section 65.85 and 65.87 an A&P cannot perform an Progressive Inspection. In Section 65.95 only an IA can perform the Progressive Inspection and sign it off. So just based on Part 65 limitations it would make sense to me that only an IA is allowed to sign off the individual events showing compliance that the inspection was accomplished. However, I believe under supervision the A&Ps can perform the individual tasks in each event, but sign off the event its self.

This reasoning would meet the requirement of Section 91.409(d)(1) where it says and IA, repair station or aircraft manufacture can perform the Progressive Inspection. The responsible person as I read section 91.409(d)(1) is the IA, repair station or aircraft manufacture and the IA cannot delegate that responsibility to a A&P mechanic for the individual event sign off in my opinion. Part 43 Section 43.15(d) talks about the progressive inspection and if away from home base another IA can perform the inspections NOT and A&P.

So I think I am on solid ground in the rules saying only and IA can sign off the individual events. That is what I wrote in my two books as well. I went back and checked my book references and several of the links are dead now since the FAA changed their web site. I am going to contact FAA legal and ask them to provide me something back in writing the will clear this up, but that is going to take some time to get a response back on.

Would like any feed back to make sure I am understanding this correctly.