Peter wrote:
Now, on the topic of brushes… what privileges are needed to change motor brushes, where there is no repair or overhaul data available?
Peter – You can bang on this all day long if you like, but the FAA FARs are there and they are not going to change just because so & so said this or did that… In this case the relevant bit is FAR 65.81 – “General privileges and limitations.”, copied once more below for your perusal .
In this particular example (gear electro/hydro pump) I have indeed “Repaired” these units on numerous occasions on Cessna retracts. This is possible because there is sufficient information in the MM & IPC to satisfy FAR 65.81 .
I would never consider calling any of these Repairs “Overhauls” because the Overhaul Data is NOT in the MM and IPCs .
That said, many A&Ps and EASA Mechanics having been trained and experience working in Part 145 and/or REpair Station environments tend to shy away from “Field Repairs” such as the gear pump example.
(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§65.85, 65.87, and 65.95.
However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.
(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned
You can bang on this all day long if you like
That statement is way OTT Michael. What I wrote was
what privileges are needed to change motor brushes, where there is no repair or overhaul data available?
to which there should be a straight simple answer, or maybe an answer like “there is no clear answer”. But doing a personal attack is not the way to go – even though several people have discovered that as an admin/mod I don’t simply delete those directed against me because it would appear self-serving and undemocratic! That policy might change after several threads went off the rails recently. All other forums are far more strict.
Back to the topic, is there a legal difference between a Repair and an Overhaul, with these items? I know there is with engines… an Overhaul is IAW an “overhaul manual” and everything lesser is a Repair.
The statement
(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned
is quite ambiguous, in the use of the word “understands”. A stricter lawmaker would have said “is in possession of the current version of”.
Peter wrote:
is quite ambiguous, in the use of the word “understands”.
Yep, FAA regs leave MUCH to interpretation.
So when I write “bang on this” what I really mean is one can spend DAYS debating on EXACTLY what the FAA reg meaning , only to wind up with the obvious: It means different things to different people 
Peter wrote:
is there a legal difference between a Repair and an Overhaul, with these items? I know there is with engines… an Overhaul is IAW an “overhaul manual” and everything lesser is a Repair.
ABSOLUTLY !
Nothing ambiguous in the FAA FARS about this:
OVERHAUL is defined in 14 CFR 43.2(a):
“No person may describe in any required maintenance entry or form an aircraft, airframe, aircraft engine, propeller, appliance, or component part as being overhauled unless-
(1) Using methods, techniques, and practices acceptable to the Administrator, it has been disassembled, cleaned, inspected, repaired as necessary, and reassembled; and
(2) It has been tested in accordance with approved standards and technical data, or in accordance with current standards and technical data acceptable to the Administrator, which have been developed and documented by the holder of the type certificate, supplemental type certificate, or a material, part, process, or appliance approval under part 21 of this chapter."
So, let’s get back to the obvious next Q: can an A&P repair the above discussed items?
I know an A&P can repair an engine. There is a MM available for that.
I know an A&P can repair a whole pile of aircraft related items – because the operation is obvious, doesn’t need any unusual procedures (e.g. heat treatment), and he does not need a MM for that. It is covered by the generic AC43-13 FAA manual.
In between the two positions above, you have lots of other bits… which may or may not need the MM. Is there a list somewhere?
Peter wrote:
In between the two positions above, you have lots of other bits… which may or may not need the MM.
Yep, and each and every A&P will have his own personal view on what he can or cannot do.
Is there a list somewhere?
Not that I’m aware of.
It’s worth pointing out that in the definition of overhaul in the regulation quoted by Michael above, post #24, there is nothing about bringing the component to any particular condition. The only phrase that addresses that issue for an overhaul says that the component must be “repaired as necessary”. With that in mind I suspect the regulatory difference between repair and overhaul is not what your average person would expect.
An operation documented in a logbook as repair could bring the component to a better condition than something documented as an overhaul. An A&P mechanic can either overhaul or repair an engine but the main difference is whether the engine is completely disassembled and inspected. The FAA regulation provides the framework for the defintion of an overhaul but does not dictate the exact work that the individual may choose after inspection and before reassembly, as long as all components are within service limits at reassembly.
