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Who precisely may work on an N-reg?

Someone has asked me this question.

FAR 43.3 lists various options.

One of them is:

(d) 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.

which suggests that anybody can do it under supervision. That must be right because the whole of the maintenance business works that way, including airlines. Not everybody is an A&P or EASA66 certified mechanic. A lot of college kids work in these places, under supervision.

Obviously pilot maintenance is a separate thing, which can be done by

  • the pilot (and he signs it off)
  • anybody with a private certificate (and the pilot signs it off)
  • an A&P or A&P/IA (either he or the pilot signs it off)

AD checks and releases to service need to be done by an A&P or A&P/IA in all cases.

However, it is also normal for maintenance including Annuals on N-regs to be done by European companies and an A&P/IA does the return to service. He does not sit there all day watching the work. He inspects the end job. Under what provision is this done?

Administrator
Shoreham EGKA, United Kingdom

The italicized paragraph is explicit, there's no hidden requirement. One key issue is that the FAA A&P must be readily available for in person consultation. The A&P can go away but he needs to be able to show up quickly when there is a problem (i.e. the A&P cannot be on another continent :-) If that requirement is violated, what an owner is doing is illegal. I think most owners get nervous in that circumstance and do the right thing.

Another limiting factor is on the A&P's side: he must take individual responsibility for the work he signs off. A&Ps will not do that for somebody else's work unless they trust and respect the person they are supervising. That relationship takes a while to develop, making it relatively exceptional, and the fear of consequences can actually produce better work than if the A&P does it all himself under time pressure. In addition, two minds often generate better solutions than one, regardless of certificatation.

AD checks and releases to service need to be done by an A&P or A&P/IA in all cases.

Not in all cases. A release to service is the signature of an authorized person in the appropriate log entry. There are some AD's that may be performed and signed off by the pilot owner. For example, there is an AD that requires that the magneto switch be checked by reducing the RPM to idle, momentarily switching the magnetos off, and then back on. This is to verify that the magnetos are not left in the hot ungrounded condition when the switch is off. This AD specifies the pilot - owner may perform the test, in which case they are the one that signs the entry.

The wording of the regulations specify that a return to service is a signed log entry by an authorized person. Who is an authorized person depends on the type of maintenance, preventive maintenance, or inspection being performed. The return to service is only for the work performed and does not mean the aircraft as a whole is airworthy. A non authorized person may work under the supervision of an authorized person, in which case the authorized person provides the return to service for that work. If the work being performed is a required inspection, for example an annual inspection, the person doing the work must be authorized to do so and this can't be performed by an unauthorized person who is supervised.

An annual inspection is not maintenance and can have two possible outcomes, airworthy or not airworthy. In most cases discrepancies are found that must be corrected during the annual inspection to make the aircraft airworthy. Correcting these discrepancies is maintenance and may performed by another person than the one who performed the inspection. The requirement for an annual inspection is met regardless of the outcome, airworthy or not airworthy. The IA is required to sign off the inspection by regulation and can't refuse to do so. In the normal case, the shop or mechanic performs any of the needed maintenance after the inspection and the log entry should reflect the actual maintenance performed along with an annual sign off as airworthy.

If for any reason the owner decides to only have the inspection performed and discrepancies are found by the IA, the IA must sign off the annual as unairworthy in the logbook and provide the owner with a written list of discrepancies. It is important to note that the list of discrepancies is not put into the logbooks but is provided to the owner. The owner may then have the discrepancy repairs performed by a different person, or shop at which time their entry in the logbook and signature returns the aircraft to service. The owner does not have to keep the written list of discrepancies after they have been dealt with.

I have specifically used the unairworthy annual as a technique in the following instances:

1) I had an IA who was going on Vacation for two weeks and would not be able to complete the repairs. I had him sign the annual off after the inspection portion as unairworthy and had other non IA A&P do all the repairs while he was gone.

2) When managing a pre-purchase, many prospective owners and shops want an annual inspection to be performed. If I was representing the seller, I would have the annual performed by the shop of the buyer's choice, but repairs were performed by my mechanics. In many instances, shop policy required them to perform service bulletins that I did not agree with being needed. An example is Beechcraft recommends that the wing bolts be removed every 5 years and nondestructively tested and replaced every 15 years. In the 60+ years of Bonanza production, there has never been a wing bolt failure. I only replace them if corrosion is evident. The buyer is appraised of this prior to agreeing to the inspection that we will not pay for Service Bulletins and this one in particular. It gets listed on the discrepancies, and my A&P signs it off as not required by regulation.

3) My last annual I used this to complete the annual. My IA has to travel 3 hours to my hangar and I have to pay for the travel. He stays in a local hotel and finished the annual but we were waiting on a few parts to complete the job. I had him sign the annual off and give me a list of the remaining work and had a local mechanic finish the job a week later. It made no sense for him to travel 6 hours round trip to finish 2 hours of work.

4) Occasionally there will be a real bastard of an IA that refuses to sign off an annual unless certain work is performed that the owner disagrees with either the price or the necessity of the maintenance. In this case, I recommend that the owner get the unairworthy annual signoff and have the aircraft returned to service by another mechanic. If needed, I get a ferry permit to move the aircraft to another airport.

KUZA, United States

Thanks for the superb detailed reply, NCYankee

There are some suprises there for me...

If the work being performed is a required inspection, for example an annual inspection, the person doing the work must be authorized to do so and this can't be performed by an unauthorized person who is supervised.

That means that any company doing Annuals on N-regs has to use an FAA A&P for the entire Annual. Trainees or non-FAA certified engineers for example cannot do that. That is self evidently not the case everywhere I have been, including certain FAR 145 repair stations. Is there some other section in the FARs that provides for an equivalent qualification to an A&P?

I had an IA who was going on Vacation for two weeks and would not be able to complete the repairs. I had him sign the annual off after the inspection portion as unairworthy and had other non IA A&P do all the repairs while he was gone.

That is extremely interesting too. Does it mean an IA can just sign off the Annual as unairworthy (without even looking at the aircraft) and then you can get an A&P to do the Annual inspection plus whatever remedial work is needed?

Administrator
Shoreham EGKA, United Kingdom

That means that any company doing Annuals on N-regs has to use an FAA A&P for the entire Annual.

The owner assisted FAA annual inspection is the most common, routine and legal instance of work being being performed under A&P supervision. Every year or so there is a magazine article recommending it as a way to save money and learn about your aircraft. As long as the actual inspection part of the work is done and signed off by an IA there is no problem, and that is only a fraction of the work involved.

Be careful when holding the propeller during the compression check :-)

Peter,

The inspection portion is actually a small portion of the activity accomplished on an annual. Most of the work is not the inspection, for example, removing the seats, inspection covers, removing the prop spinner, putting the airplane on jacks, disconnecting the gear doors, draining the oil, replacing the oil filter and other filters,etc. The inspection is the portion where the IA or in the case of a repair station, an Inspector is looking at the internals of the opened up aircraft with their flashlight and mirror, performing any of the required tests and check for discrepancies such as compression checks, verifying AD compliance, etc. The inspector should note anything that is found that does not comply with the airplane meeting its type certificate or STC's that are incorporated on the aircraft. The bulk of the work is servicing the aircraft and making repairs, closing the airplane back up, and ground checking. Most of the elapsed time is in the latter category with extra down time usually due to waiting on parts to come in or items that need to be sent out for repair or overhaul to come back. If the annual is 32 hours, the inspection is usually less than 8 hours. An inspection is not a repair, it is a careful examination of the airplane.

To answer your second question, the IA must perform the annual inspection prior to signing the aircraft off as airworthy or not airworthy. In the second case, they are required by regulation to provide a written list of discrepancies to the owner. The inspection can be accomplished on a simple airplane in less than a day, often three or four hours. A more complex aircraft takes longer to inspect. Once the inspection is done, airworthy or unairworthy, and signed off as such, the annual requirement is satisfied for another year. To get the airplane back into service, any maintenance or preventive maintenance needs to be accomplished and signed off, but this is a separate activity from a legal standpoint. If a major modification or repair is accomplished on an aircraft, any authorized person may perform the work, but it must be inspected by an IA or repair station inspector and a 337 be signed by the person doing the work and the inspector or repair station who inspected it. If it requires a field approval, the FAA must sign off as well, typically before the work is accomplished.

KUZA, United States

A small piece of trivia, most maintenance records only need to be kept for one year or until the work is repeated. This includes the annual.

KUZA, United States

To return to this old thread, would I be correct that the pilot-privileges maintenance on an N-reg, which can be done by a pilot, requires the pilot to have an FAA certificate ?

IOW, a pilot with just an EASA license, flying that N-reg under 61.75, cannot do any pilot maintenance?

The rationale is that the pilot is required to sign the aircraft logbook(s) with his certificate number.

Administrator
Shoreham EGKA, United Kingdom

61.75 gives you a fully valid FAA certificate including its own certificate number. I don’t see why you wouldn’t be able to put that in the logbook?

Isn’t there a catch that says the pilot-owner is whoever is on the Certificate of Registration, making any work by actual pilot-owners of planes in trusts a shady thing at best?

tmo
EPKP - Kraków, Poland
20 Posts
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