I know an A&P can legally overhaul a complete engine.
Can he overhaul say a landing gear pump?
The answer is obviously Yes (the pump is so much simpler) unless one adopts the strict argument of the CMM (component maintenance manual) being required. Lyco do provide the MM openly of course. Parker (the gear pump) may or may not (well they obviously have a MM but it may not be publicly released). I have heard this CMM argument for years, mostly from one person in the USA who is close to an aircraft mfg. But others in the USA say it is bollox and any component which is “obvious how it goes together and requires no special processes” is within A&P privileges to overhaul.
A&Ps are excluded from overhauling instruments (avionics) but I don’t see other specific prohibitions.
And this brings me to the second point: if an A&P cannot overhaul (or repair?) an instrument, what precise privileges are needed for instrument overhaul or repair? I know only an FAA 145 company can issue an 8130-3 but (a) you don’t need one for a Part 91 N-reg and (b) it is a widespread fact that a lot of instrument repair is done by non 145 outfits – both USA and Europe.
My understanding is that only a Repair Station can overhaul instruments.
For component overhauls I’ll answer tangentially from my experience, using an example that applies equally to any light aircraft. There are a lot of antique aircraft flying in normal category airworthiness in the US, a certified aircraft never loses certification under FAA rules, for Part 91 operations no manufacturer or airworthiness ‘support organization’ is required, and no documented parts supply or parts traceability is required. These aircraft often have components that no 2017 repair station has touched, little documentation is available, and they have ‘forever’ been repaired in the field. So the A&P does the work and makes a nice sounding logbook entry, generally referencing AC 41.13 (very general FAA approved data). Later, the A&P IA who signs the annual inspection is not very interested. Until the size of the plane gets above SEP, that’s how it often works.
I know a guy (an A&P) who built a (restored, actually 90% new) prize winning Great Lakes biplane from a small pile of antique components, including an engine, and an original airframe data plate. When he finished it after 5 or 6 years of work the IA suggested that it was best described as a fabric recover job (which requires filing a 337 signed by the IA), plus a field engine overhaul. Knowing both the A&P and IA involved, the FSDO was apparently happy with that and issued a replacement for the lost airworthiness certificate.
As I’ve already stated in the past, an FAA A&P cannot “work on” Instruments or propellers.
Only FAA Certified Repair Stations with the properly registered capabilities can [legally] “work on” or overhaul those items for which he has registered capabilities with the FAA .
Nothing complex or difficult to understand with this.
Here’s the Intro to the relevant FAR :
2-1182 GENERAL.
A. Definitions.
1) Air Agency Certificate. Federal Aviation Administration (FAA) Form 8000-4, Air Agency Certificate, is the authority granted by the FAA for a repair station to conduct business. The certificate states the following information:
· Repair station number;
· What the repair station’s ratings are to include;
· Class ratings;
· Limited ratings;
· Limited specialized service ratings;
· The name (and any doing business as (DBA)) and location of the repair station;
· Date the certificate was issued; and
· The expiration date, as applicable.
The full text is here : CHAPTER 11 CERTIFICATION OF A TITLE 14 CFR PART 145 REPAIR STATION
Peter wrote:
(b) it is a widespread fact that a lot of instrument repair is done by non 145 outfits – both USA and Europe.
Really ? I know of none.
That said, not ALL Avionics are considered “Instruments” .
The most obvious are VHF & GPS Nav/Coms . It is perfectly legal for an FAA certified A&P to change an internal battery in a GNS430 for example. That said, the FCC requires that the technicien holds a radio technicien’s licence to work on radio emitters, but not receivers, IIRC . Of course, the FAA requires that the technician (or A&P) has the specific Documentation, tooling & experience.
OK; those are FAA 145 Repair Station requirements. But that wasn’t my original question which was on A&P privileges, the CMM, and whether it being published is relevant (note that the vast majority of aviation MMs are not public).
This also touches onto whether the latest MM is required to do any work on a particular aircraft type i.e. do you need a monthly ATP CD subscription ($1000/year) even if every CD since 2005 has been exactly the same… the position many people in the industry hold is YES, but I will start a new thread on it, unless somebody else does.
As regards who has repaired e.g. a vac AI but could not supply any docs, I am not going to post their names 
If the customer is told only at the very end, he is faced with a fait accompli, given that the instrument may be worth 10k.
It is perfectly legal for an FAA certified A&P to change an internal battery in a GNS430 for example. That said, the FCC requires that the technicien holds a radio technicien’s licence to work on radio emitters,
However, a GNS430 is an emitter too; it transmits on VHF. So how can an A&P change the battery? And if he did the radio tech course then he doesn’t need to be an A&P – is that correct?
Silvaire wrote:
On a more prosaic level, how about an FAA A&P installing these
Yep, a compass is considered an “instrument” and thus is considered off limits to A&Ps .
Actually, some even consider that swinging a compass can only legally be performed by an appropriately rated Repair Station.
