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Qualifications for doing avionics work (EASA-reg and N-reg)?

Peter wrote:

Not if the destination aircraft is also N-reg, unless somebody likes to collect 8130-3 forms

Great, thanks Peter :)

EGHS

Peter wrote:

But one can get around that by doing the 91.413 check afterwards at a 145 facility.

How do you legally fly the aircraft to the Repair Station?

YPJT, United Arab Emirates

Not if the destination aircraft is also N-reg, unless somebody likes to collect 8130-3 forms

See e.g. here

EASA-reg is a different thing – a huge amount of debate here previously… e.g. here and here but much of it is inconclusive due to differering views and EASA reg interpretations by different avionics installers.

Administrator
Shoreham EGKA, United Kingdom

Avionics can indeed be installed / signed off by an FAA IA/A&P. In fact when we have had avionics installed by an EASA Avionics outfit, our IA has done the paperwork on their behalf and it is only recently that I realised they could do the paperwork/work themselves.

One thing though, in one aircraft we have a lot of avionics kit we want to transfer to another – G430W/GMA340/GTX330 etc., now I understand this needs to go to Garmin for ‘recertification’ and new paperwork (8130) before it can be installed in the other (identical) aircraft. Is this the case?

EGHS

Peter wrote:

who can do avionics work on an N-reg, and it has been confirmed that – as above posts basically say – that the work needs to be done by or under the supervision of an A&P i.e. avionics installation work goes under the heading of “airframe”.

Correct.

As an A&P/IA working independently, I take a hybrid approach to avionics Installations :

I have a very reputable, fully dedicated FAA Avionics Licensed company in the US design, produce CAD working drawings & documentation and produce fully built out be-spoke wiring harnesses for each project. These harness are absolutely First-Rate , fully digital labeling and bench tested before delivery.

My job is then to remove the old equipment, isolate wiring that stays in place and then physically installe the new which is pretty much plug & play with just ground & power lugs to be cut and crimped.

The end result is far better than the typical light GA “Dyke & Splice” retro-fits that I see day-in-day-out …

Last Edited by Michael at 16 Jun 05:54
FAA A&P/IA
LFPN

Recently I have had some discussions off-forum about who can do avionics work on an N-reg, and it has been confirmed that – as above posts basically say – that the work needs to be done by or under the supervision of an A&P i.e. avionics installation work goes under the heading of “airframe”.

There is a lot of disinformation going around saying that you must have a 145 shop to do it, or that there is some “avionics A&P” qualification. Both are not true.

The only advantage of being an FAA 145 company is as per NCYankee’s posts above i.e. if disturbing the static pipework. But one can get around that by doing the 91.413 check afterwards at a 145 facility. Well, there is another advantage: they can print off fresh 8130-3 forms (within their approval limits) for the old stuff they remove so you can get more money for it on US Ebay

This is an important concession for N-reg owners who are much more free to use freelance avionics installers. Practically speaking an A&P needs to inspect the finished job, since he obviously isn’t going to be checking every wire.

(I have merged 2 old threads)

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

It does suggest that an A&P can install a transponder, so long as the installation is then tested by a 145 company.

I don’t believe that the transponder needs to be installation checked IAW 91.413 after maintenance or new replacement as long as there is a reasonable possibility of the data correspondence error would not be affected. IOW, if the transponder has a green tag (8130-3) from an avionics 145 shop or the manufacturer, an A&P can install it (electrical connections only) without another test being performed other than the self test. Replacing the encoder would require a retest by a 145 shop or if the encoder was an integral part of the transponder (which some are, this is a bad idea IMHO).

KUZA, United States

Thanks for posting that, NCYankee.

It does suggest that an A&P can install a transponder, so long as the installation is then tested by a 145 company.

Administrator
Shoreham EGKA, United Kingdom

An A&P can work on a static system and inspect it. See the text of the appendix quoted below and note that the tasks in section (a) do not specify they must be performed by a repair station, while section (b) requires the altimeter tests to be performed by an appropriately rated repair facility (AKA a repair station).

Appendix E—Altimeter System Test and Inspection

Each person performing the altimeter system tests and inspections required by Sec. 91.411 shall comply with the following:
(a) Static pressure system:
(1) Ensure freedom from entrapped moisture and restrictions.
(2) Determine that leakage is within the tolerances established in Sec. 23.1325 or Sec. 25.1325, whichever is applicable.
(3) Determine that the static port heater, if installed, is operative.
(4) Ensure that no alterations or deformations of the airframe surface have been made that would affect the relationship between air pressure in the static pressure system and true ambient static air pressure for any flight condition.
(b) Altimeter:
(1) Test by an appropriately rated repair facility in accordance with the following subparagraphs.

A transponder is an appliance. An A&P may not repair it, but if one is repaired with the proper documentation or a replacement unit is installed, they may sign off the work.

Sec. 65.85 Airframe rating; additional privileges.

(a) Except as provided in paragraph (b) of this section, a certificated mechanic with an airframe rating may approve and return to service an airframe, or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations). In addition, he may perform the 100-hour inspection required by part 91 of this chapter on an airframe, or any related part or appliance, and approve and return it to service.
Sec. 91.411 Altimeter system and altitude reporting equipment tests and inspections.

(a) No person may operate an airplane, or helicopter, in controlled airspace under IFR unless—
[(1) Within the preceding 24 calendar months, each static pressure system, each altimeter instrument, and each automatic pressure altitude
reporting system has been tested and inspected and found to comply with appendices E and F of part 43 of this chapter;
(2) Except for the use of system drain and alternate static pressure valves, following any opening and closing of the static pressure system, that system has been tested and inspected and found to comply with paragraph (a), appendix E, of part 43 of this chapter; and]
(3) Following installation or maintenance on the automatic pressure altitude reporting system of the ATC transponder where data correspondence error could be introduced, the integrated system has been tested, inspected, and found to comply with paragraph (c), appendix E, of part 43 of this chapter.
(b) The tests required by paragraph (a) of this section must be conducted by—
(1) The manufacturer of the airplane, or helicopter, on which the tests and inspections are to be performed;
(2) A certificated repair station properly equipped to perform those functions and holding—
(i) An instrument rating, Class I;
(ii) A limited instrument rating appropriate to the make and model of appliance to be tested;
(iii) A limited rating appropriate to the test to be performed;
(iv) An airframe rating appropriate to the airplane, or helicopter, to be tested; or
(v) deleted
(3) A certificated mechanic with an airframe rating (static pressure system tests and inspections only).
(c) Altimeter and altitude reporting equipment approved under Technical Standard Orders are considered to be tested and inspected as of the date of their manufacture.
(d) No person may operate an airplane, or helicopter, in controlled airspace under IFR at an altitude above the maximum altitude at which all altimeters and the automatic altitude reporting system of that airplane, or helicopter, have been tested.

Note that if a transponder is repaired or replaced, but the signal lines to the encoder and the encoder have not been mucked with, then correspondence error would not be introduced and the integrated test would not need to be performed. If the encoder was changed, then the integrated correspondence test would need to be performed by a repair station.

Sec. 91.413 ATC transponder tests and inspections.

(a) No persons may use an ATC transponder that is specified in 91.215(a), 121.345(c), or Sec. 135.143(c) of this chapter unless, within the preceding 24 calendar months, the ATC transponder has been tested and inspected and found to comply with appendix F of part 43 of this chapter; and
(b) Following any installation or maintenance on an ATC transponder where data correspondence error could be introduced, the integrated system has been tested, inspected, and found to comply with paragraph (c), appendix E, of part 43 of this chapter.
(c) The tests and inspections specified in this section must be conducted by—
(1) A certificated repair station properly equipped to perform those functions and holding—
(i) A radio rating, Class III;
(ii) A limited radio rating appropriate to the make and model transponder to be tested;
(iii) A limited rating appropriate to the test to be performed;
[(iv) deleted]
(2) A holder of a continuous airworthiness maintenance program as provided in part 121 or Sec. 135.411(a)(2) of this chapter; or
(3) The manufacturer of the aircraft on which the transponder to be tested is installed, if the transponder was installed by that manufacturer.
KUZA, United States

I could be wrong. Hopefully NCYankee will be along soon to answer definitively.

EDAZ
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