Remote sign offs?

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4RNB

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4RNB
In this digital world, is it possible to perform work supervised by an A/P or IA on video or live feed that they can view and approve/sign off work?
Why is this not being done in some fashion?
 
I would say no.

43.3 (d) says -

"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."

The mechanic needs to be physically present with you. The issue with this, is that it's largely going to be at the discretion of the mechanic and what they feel comfortable with doing - it's their certificate on the line. That said, I can just about guarantee that a FSDO inspector won't be too happy about "my mechanic is supervising me from his cellphone" if they happen to become aware of the practice.
 
4RNB said:
In this digital world, is it possible to perform work supervised by an A/P or IA on video or live feed that they can view and approve/sign off work?
Why is this not being done in some fashion?
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For the simple reason as noted above, the regulations do not permit it.
 
Bell206 said:
For the simple reason as noted above, the regulations do not permit it.
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How does this square with
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,
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In practice neither an A&P nor IA does in person, real time supervision when I R&R inspection panels, cowlings, seats & carpet for the annual. Is that in violation of the spirt of the reg?
 
TCABM said:
How does this square with


In practice neither an A&P nor IA does in person, real time supervision when I R&R inspection panels, cowlings, seats & carpet for the annual. Is that in violation of the spirt of the reg?
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Are they inspecting and approving the work in person before signing off on it? This would be different than viewing work performed from a computer screen and virtually signing off on it without laying eyes on it in the flesh.
 
Seems someone should ask the FAA to weigh in on this.

MDs can do zoom consults, triage, prescribe remotely. They can make a decision on what needs to be done in person. In the modern world, seems like a mechanic could do the same.

If I ever get my IA, will ask for FAA opinion as I build out the business, grow it, sell it.
 
4RNB said:
Seems someone should ask the FAA to weigh in on this.

MDs can do zoom consults, triage, prescribe remotely. They can make a decision on what needs to be done in person. In the modern world, seems like a mechanic could do the same.

If I ever get my IA, will ask for FAA opinion as I build out the business, grow it, sell it.
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You're a brave soul. I'd be concerned that the answer would come back as
"Not only must the Supervisor be present but must also have his hand touching every wrench, screwdriver, or other tool while it is being used by the supervised person".
or
"Video may not be used between the Supervisor and the Supervised, however it is now required that video be generated for the duration of time someone is being supervised and must be kept available in the .mov format on floppy disks"

----------

On a more serious note, why wait until you're an IA? Ask it now and it might help inform how you plan to build / grow / sell your business.
 
This is a real bad idea imo. There are too many things that can go unnoticed when not in person. A Quick Look by an experienced eye can see things that a rube pointing a camera would miss.
 
FaceTime gives you all but them smell.

Regs predate remote surgery and cell phones.
 
4RNB said:
Seems someone should ask the FAA to weigh in on this.
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iu
 
4RNB said:
Seems someone should ask the FAA to weigh in on this.

MDs can do zoom consults, triage, prescribe remotely. They can make a decision on what needs to be done in person. In the modern world, seems like a mechanic could do the same.

If I ever get my IA, will ask for FAA opinion as I build out the business, grow it, sell it.
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No reason to ask as it pertains to ia work. The regs state no part of the inspection can be delegated. So you have to be hands on and present to do any inspection.
 
TCABM said:
if the supervisor is readily available,
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TCABM said:
Is that in violation of the spirt of the reg?
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The whole gist of the regulation has been the definition of “readily available.” In CAR 18 it was stated as “under direct supervision” vs “readily available” so they did relax the rule a bit in the FARs. However, based on how the FAA has defined “readily” in this instance and others, the supervisor needs to be in an area were the person performing the work can consult with them “without hesitation” and in person.

So depending in how you would define “readily available” would depend on if it was a violation of the rule. And to add, it would be you that is in violation and not the mechanic. Regardless, in the spirit of things, you could still remove the panels, etc. and make the proper entries as prevent mx which would keep you legal if the supervisor was not readily available.

I always ran across this topic with my owner-assist customers. My benchmark was if it could be performed as prevent mx they didn’t need my physical presence in the area.
4RNB said:
Seems someone should ask the FAA to weigh in on this.
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This topic has been discussed with the FAA ad nauseam over the years. But keep in mind you’ll have to convince more than FAA as the majority of the FARs are to satisfy international standards and agreements.

You would be better served to use your efforts to revive the Primary Non-Commercial aircraft that would have allowed owners to perform maintenance on TC aircraft without the need of an A&P. It was very similar to the TCCA “owner-maintained” category. However, the downside is the TCCA rule did not meet those international standards so any owner-maintained aircraft cannot be exported or flown outside of Canada. Which would have been a similar issue with the P-NC category.
 
RyanB said:
Are they inspecting and approving the work in person before signing off on it? This would be different than viewing work performed from a computer screen and virtually signing off on it without laying eyes on it in the flesh.
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I think I missed the signing off part while focusing on the while doing the work part.
Bell206 said:
The whole gist of the regulation has been the definition of “readily available.” In CAR 18 it was stated as “under direct supervision” vs “readily available” so they did relax the rule a bit in the FARs. However, based on how the FAA has defined “readily” in this instance and others, the supervisor needs to be in an area were the person performing the work can consult with them “without hesitation” and in person.

So depending in how you would define “readily available” would depend on if it was a violation of the rule. And to add, it would be you that is in violation and not the mechanic. Regardless, in the spirit of things, you could still remove the panels, etc. and make the proper entries as prevent mx which would keep you legal if the supervisor was not readily available.

I always ran across this topic with my owner-assist customers. My benchmark was if it could be performed as prevent mx they didn’t need my physical presence in the area….
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Thanks for the context; helpful.
 
During the fiasco that was Covid I was still required to do federal & state inspections in person for the work I was doing. However some of the lower level stuff done by in house staff was allowed to be done via video conference. I was appalled by the ways that were quickly invented to show the camera what they wanted to see and not allow it to reveal what needed to be seen.

If it were my certificate in play there is no way I'm signing anything I haven't looked at with my own eyes and touched with my own hands ...
 
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There are “ Inspection Props” that are changed post Annual. One guy even

bought lawnmower battery to do likewise. Yet another used Bondo to

re-contour his prop tips,. Changing tags on seat belts is another practice.

These are things Techs often hear about later. Following only

applies to those honest folks that I believe to be most.

There are minor items that require an A&P to sign that could be overseen

via live video. The diligent owner may welcome this option .

Alternatives might be having a “ Road Warrior Tech” drive 2 hours

to participate or having the “ Hangar Fairies” do covertly.

This seems similar to using a borescope or other electronic means

to inspect a cylinder or wing structure. Do you have to pull parts

to determine the conditions. One foot or 10 miles may make no

difference.

One size does not fit ALL!
 
My thought is it might be a good idea to put an example in.


Replacing a spark plug is allowable Preventative Maintenance

IF the owner of the aircraft is a PPL or higher.


Supervising a Student Pilot via live FT doing the same task is a thought.



Why proficiency in Short Field Landings and Stall Recovery is need to

change a plug is beyond me. Regs have changed and will continue to do so.

“To the extent necessary “ rather than “ in - person “ appears to provide an

equivalent level of oversight . Folks can overtorque a plug even if you are

standing next to them.
 
Magman said:
One size does not fit ALL!
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This is the part a lot of people seem to miss. Everyone claiming video inspections would be dangerous and abused is painting with a broad, one-size-fits-all brush. There are plenty of tasks that could be very, very easily inspected via video, and there are plenty that cannot. There's really no reason it can't be left to the signatory's discretion as to whether they feel they can adequately inspect any given work via video.
 
An example right now that I am dealing with:

My alternator needs replacing along with the wire that runs from the alternator to the battery (really somewhere near the firewall, not the battery directly). Under direction of an AP, I've ordered the correct wire, connections, silicone rubber covers, and crimping tool. Removing the old wire does not seem technically challenging. The tool looks to be simple to understand. Cut new wire, crimp on terminal at right spot, reinstall cable. Could video or take photos of same. Reinstall alternator, safety wire. Again, all could be done on live feed or video. Await review, which could be done on fast forward to key parts, receive remote signify in Planelogix online logbook. AP, or an IA, could provide specific directions to follow, and post check run up could also be recorded.

Surely, this has been done by an owner unsupervised before, or with hangar fairies, and still signed off. It likely would never be discovered if nobody ever knew and flight were safe. Why not just add a more efficient solution to the problem? The signify would only address the specific work done, not anything else.

Note: I have an AP going to do this with me tomorrow, for real in person, not on video. But I have not doubt I could do the work right now and go fly tonight if 11.5V is enough to crank my motor with!
 
bradg33 said:
This is the part a lot of people seem to miss. Everyone claiming video inspections would be dangerous and abused is painting with a broad, one-size-fits-all brush. There are plenty of tasks that could be very, very easily inspected via video, and there are plenty that cannot. There's really no reason it can't be left to the signatory's discretion as to whether they feel they can adequately inspect any given work via video.
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And if some letter of understanding could be issued by the FAA, wouldn't exactly this sort of thing help GA?
 
4RNB said:
An example right now that I am dealing with:

My alternator needs replacing along with the wire that runs from the alternator to the battery (really somewhere near the firewall, not the battery directly). Under direction of an AP, I've ordered the correct wire, connections, silicone rubber covers, and crimping tool. Removing the old wire does not seem technically challenging. The tool looks to be simple to understand. Cut new wire, crimp on terminal at right spot, reinstall cable. Could video or take photos of same. Reinstall alternator, safety wire. Again, all could be done on live feed or video. Await review, which could be done on fast forward to key parts, receive remote signify in Planelogix online logbook. AP, or an IA, could provide specific directions to follow, and post check run up could also be recorded.

Surely, this has been done by an owner unsupervised before, or with hangar fairies, and still signed off. It likely would never be discovered if nobody ever knew and flight were safe. Why not just add a more efficient solution to the problem? The signify would only address the specific work done, not anything else.

Note: I have an AP going to do this with me tomorrow, for real in person, not on video. But I have not doubt I could do the work right now and go fly tonight if 11.5V is enough to crank my motor with!
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You can do all that. You just need the A&P to put hands on at the end to check what you have done and sign off on it.

How does a video A&P tug a wire to check that the crimp is secure? How does he push hoses out of the way to get a good look at the firewall penetration to ensure no chafing? How does he deflect the drive belt to verify the alternator is tensioned correctly?
 
I knew of a guy who was getting his experimental condition inspections signed off that way, he mailed photos and the logs to the original builder who had the repairman certificate and got the signed logbooks back in the mail. Not saying it was right, it wasn't... but they're both dead (old age) now.
 
fabricgator said:
Where do I find that in the regs? I am curious about the entire chapter as I worked for a CRS as an apprentice and am curious about it.
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65.95 Inspection authorization: Privileges and limitations.​


(a) The holder of an inspection authorization may—
(1) Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter) after a major repair or major alteration to it in accordance with part 43 [New] of this chapter, if the work was done in accordance with technical data approved by the Administrator; and
(2) Perform an annual, or perform or supervise a progressive inspection according to §§ 43.13 and 43.15 of this chapter.

notice that it does not say supervise an annual like it does for a progressive. the FAA has alwas held that the IA MUST perform the inspection personally. however, as an IA i do not have to, say, pull the wheel bearings, clean the wheel bearings and repack the bearings, but I DO have to do the inspection of them my shelf. however, either the A&P doing that work or me, if supervising someone doing that work, must log and sign for that work that was done. normally when i sign off an annual, I log all the work that was done and sign off that then under that stamp the inspection wording and sign that off by it shelf.
 
Dana said:
I knew of a guy who was getting his experimental condition inspections signed off that way, he mailed photos and the logs to the original builder who had the repairman certificate and got the signed logbooks back in the mail. Not saying it was right, it wasn't... but they're both dead (old age) now.
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I thought the FAA gave DPEs the option to observe a checkride from the ground in certain circumstances if the candidate presented themselves in an experimental aircraft and the examiner had any reservations.
 
fabricgator said:
Where do I find that in the regs? I am curious about the entire chapter as I worked for a CRS as an apprentice and am curious about it.
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The Aircraft Maintenance Technician - General textbook https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/amtg_handbook.pdf

Chapter 2 is the General Regs chapter.This should be of interest to you.

FAR 65 subpart D is where the actual FAA regs about Mechanics lives. https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-65#subpart-D
FAR 65 subpart E is where the regs for Repairmen lives. https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-65#subpart-E
 
DJTorrente said:
I thought the FAA gave DPEs the option to observe a checkride from the ground in certain circumstances if the candidate presented themselves in an experimental aircraft and the examiner had any reservations.
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Yes, but that's very different from a condition inspection, which is the experimental version of an annual.
 
It seems to me that OP’s thought is not to conduct an entire Annual

Inspection virtually but rather to allow some tasks to be accomplished

in a reasonable manner. My example of the Student Pilot installing a Spark

Plug would be one.

Why they would be allowed to perform the same task once they master

Unusual Attitudes etc and get the PPL is mind boggling. How are they

more qualified?


I’ve spent the the majority of my life dealing with non -A & P types

working on aircraft. The 15 year old that does exactly what they were

instructed to do are easier to deal with than folks that know it all.

That could include CFI’s etc. The key here is SUPERVISION, which is what

live video allows. The Military takes kids and in a few months they are

involved with very complex aircraft. They are not “ on their own” though;

they still are supervised by more qualified people.


My belief is the remote / video use with aircraft is in it’s infancy.

Cell phones that can monitor , record and transmit findings are slowly

working their way into the culture.

Some examples that are or could be used follow.

Borescope Recordings

Recording events such as the Wing Corrosion AD on Cherokees.

Detailing events in a Pre-buy Assessment.

There are some AD’s that require recurrent verification for the

presence of a placard or simple protective device ie Fuel Drain Door

on a Cherokee Six.

Numerous AD’s require verification of part/serial numbers or

a “ yellow dot” or other distinguishing marking.

It is NOT for remotely managing an engine overhaul.



btw- At one time Slick would record ALL their Warranty Maintenance.

I’ll guess this is not for a Family Keepsake!
 
Magman said:
Why they would be allowed to perform the same task once they master Unusual Attitudes etc and get the PPL is mind boggling. How are they more qualified?
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For the simple reason their new pilots certificate grants them "approval for return to service" authority for the work they perform. A student ticket does not. So its really not about who is more qualified or not. Even a new mechanic fresh out of school is a bit short on "qualifications" but his signature does provide an approval for return to service.

However, anybody can work on a TC aircraft and the FARs state as such. Where the rubber meets the road is at the approval for return to service. And given the approval for RTS is so integral to the airworthiness process, any attempt to "simplfy" that approval will only create new problems down the road.

Regardless, as I've said before, a better and more direct solution to the OPs inquiry would be to push through an FAA owner-maintained category of aircraft which would solve a majority of the maintenance related issues faced by Part 91 recreational aircraft owners.
 
Bell206 said:
Regardless, as I've said before, a better and more direct solution to the OPs inquiry would be to push through an FAA owner-maintained category of aircraft which would solve a majority of the maintenance related issues faced by Part 91 recreational aircraft owners.
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If that were to happen then a few of us experimental guys might be drawn to go that way. Nah, I'm just kidding but it was a fun exercise ... :)
 
Daleandee said:
If that were to happen then a few of us experimental guys might be drawn to go that way. Nah, I'm just kidding but it was a fun exercise ... :)
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Ha. Back when primary-non-commercial was the rage just before I retired, there were more than a "few" E/AB guys that were chomping at the bit to get a 172 or F33 under P-NC and conquer the world. Me and another mechanic thought we had our dream retirement gig to assist them. Then it went bust. Oh well. And life goes on. ;)
 
Ed Haywood said:
How does a video A&P tug a wire to check that the crimp is secure? How does he push hoses out of the way to get a good look at the firewall penetration to ensure no chafing? How does he deflect the drive belt to verify the alternator is tensioned correctly?
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I believe the op is suggesting a video call such as FaceTime or the like. The a&p instructs the the owner to do those things while he watches on video. The owner does as he's told until the a&p is satisfied, or the a&p doesn't sign off.

I feel like a compelling argument could be made that replacing an alternator could be considered "the replacement of small standard parts not involving complex assembly operations” and signed off by a pilot owner. Whether the FSDO inspector/ insurance adjuster/ next IA to look at it agrees is another matter. It's certainly less complex and requires fewer special tools than changing a tire. From a safety of flight perspective, it's less critical than most of the the items specifically allowed by appendix A.
 
Jim K said:
I feel like a compelling argument could be made that replacing an alternator could be considered "the replacement of small standard parts not involving complex assembly operations” and signed off by a pilot owner.
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FWIW: the prevailing guidance has you use both the Part 1 definition of prevent mx and the list of “categories” in Part 43 Appx A(c). Even the infamous Coleal LOI notes this. You’ll find this same interaction is used for other maintenance related regulatory lists.

For example, in 43 Appx A(a)(1)(iii) lists “fuselage” as a major alteration. However, when you apply the Part 1 definition of a major alteration to that list item it significantly changes that fuselage “category.” So while I think you may be hard pressed to shoe-horn in an alternator change into one of the Appx A(c) prevent mx categories, you can without a doubt refurbish your complete aircraft, inside and out, to include various minor repairs, solely under your pilot certificate and sign off 90+% of the work.

That said, as I recall one of the reasons MOSAIC has been delayed is they are readdressing the maintenance authorization side of the equation. So its quite possible when they redefine the type of aircraft, they may also allow an increase in maintenance ability by owners on those aircraft with a TC. At least that’s what I read into the NPRM.
 
Bell : Your comment in #30 is worthy of the late, great Bill O’ Brien!

However; the dilemma continues for me.

If I were to personally change the plug or observe the Student Pilot do so makes little difference.

For me it’s a day as i would likely not be able to go elsewhere.

1 hr drive each way , change plug and run up = about 3 hours.

I call that pricey for the task.

Oversight “ to the extent necessary” via FT seems to provide an acceptable level of safety.

If in-person I could smell or taste though!

My preference is to work with folks that request oversight on tasks rather

than allow the Hangar Fairies to do so.

I think most Techs will dump folks that conceal tasks they are not permitted to do.

Many of the people that own Colts and C-150’s have ordinary incomes but want to

abide by the rules. There was a time when buying and operating a light aircraft

was not a bigger deal than buying a used car.
 
Remote sign offs have been going on forever.
In the old days, the term we used was “pencil whipping”. lol
 
To me that term means the task was not done and the the signer has

committed a fraud and a Federal Offense by falsifying Aircraft Records.

Not related to in- person or remote.

Is a borescope remote?

How about if it is transmitted live; across the room or across the state?
 
Magman said:
Why proficiency in Short Field Landings and Stall Recovery is need to
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a huge part of the PPL check ride is about ADM and making good decisions. so while not a perfect filter, one could reasonably assume that is a person is competent enough to learn to fly and show a DPE then there is a certain level of competence exhibited by said PPL.
 
I’ll go with Bell #30.

So. You do believe a person should be proficient in Short Field and

Stall Recover in order to change a Spark Plug?
 
TCABM said:
How does this square with


In practice neither an A&P nor IA does in person, real time supervision when I R&R inspection panels, cowlings, seats & carpet for the annual. Is that in violation of the spirt of the reg?
Click to expand...
Is removing and reinstalling seats, inspection panels and carpet a repair? At best you are R&R non structural fasteners.
 
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