How much $ does MX make?
#11
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,003
Part 43 says the person that signs the log returns it to service. The PIC may be ultimately responsible for the airworthiness (whereas the mechanic/maintenance is responsible for actually doing the work correctly) when he signs for the aircraft, but that is not a return to service. Part 43 explicitly explains this in 43.5.
An aircraft that has completed maintenance, whether repairs, overhauls, inspections, modifications/alterations, etc, may be approved for return to service by the mechanic, repair station, or other that has done the work. That approval does NOT return the aircraft to service.
14 CFR 43.5 states NOTHING about a mechanic returning an aircraft to service. In fact, it specifically addresses approval for return to service, only. Approval for return to service is NOT return to service.
Now, if you want to argue that "approval for return to service" is different than "return to service", I'd say you are just trying to argue the semantics. If you've approved it to return to service, as soon as you sign off, it's back in service. No one goes after a pilot for "returning an aircraft to service" incorrectly, unless they have done maintenance in accordance with 43.3(h) or (i) and not met the requirements of Part 43. Many times, pilots performing maintenance under these authorizations don't realize all the requirements that must be met in Part 43 when they use this, but this authorization is not applicable for 121 and much of 135. It is a "thing" that maintenance/mechanics have occasionally "returned an aircraft to service" incorrectly, as supported by the regulation.
#12
Well, it does here:
§43.5 Approval for return to service after maintenance, preventive maintenance, rebuilding, or alteration.
No person may approve for return to service any aircraft, airframe, aircraft engine, propeller, or appliance, that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—
No person may approve for return to service any aircraft, airframe, aircraft engine, propeller, or appliance, that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—
Here's another one:
§135.443 Airworthiness release or aircraft maintenance log entry.
(a) No certificate holder may operate an aircraft after maintenance, preventive maintenance, or alterations are performed on the aircraft unless the certificate holder prepares, or causes the person with whom the certificate holder arranges for the performance of the maintenance, preventive maintenance, or alterations, to prepare—
(1) An airworthiness release; or
(2) An appropriate entry in the aircraft maintenance log.
(b) The airworthiness release or log entry required by paragraph (a) of this section must—
(1) Be prepared in accordance with the procedure in the certificate holder's manual;
(2) Include a certification that—
(i) The work was performed in accordance with the requirements of the certificate holder's manual;
(ii) All items required to be inspected were inspected by an authorized person who determined that the work was satisfactorily completed;
(iii) No known condition exists that would make the aircraft unairworthy; and
(iv) So far as the work performed is concerned, the aircraft is in condition for safe operation; and
(3) Be signed by an authorized certificated mechanic or repairman, except that a certificated repairman may sign the release or entry only for the work for which that person is employed and for which that person is certificated.
(c) Notwithstanding paragraph (b)(3) of this section, after maintenance, preventive maintenance, or alterations performed by a repair station located outside the United States , the airworthiness release or log entry required by paragraph (a) of this section may be signed by a person authorized by that repair station.
(d) Instead of restating each of the conditions of the certification required by paragraph (b) of this section, the certificate holder may state in its manual that the signature of an authorized certificated mechanic or repairman constitutes that certification.
(a) No certificate holder may operate an aircraft after maintenance, preventive maintenance, or alterations are performed on the aircraft unless the certificate holder prepares, or causes the person with whom the certificate holder arranges for the performance of the maintenance, preventive maintenance, or alterations, to prepare—
(1) An airworthiness release; or
(2) An appropriate entry in the aircraft maintenance log.
(b) The airworthiness release or log entry required by paragraph (a) of this section must—
(1) Be prepared in accordance with the procedure in the certificate holder's manual;
(2) Include a certification that—
(i) The work was performed in accordance with the requirements of the certificate holder's manual;
(ii) All items required to be inspected were inspected by an authorized person who determined that the work was satisfactorily completed;
(iii) No known condition exists that would make the aircraft unairworthy; and
(iv) So far as the work performed is concerned, the aircraft is in condition for safe operation; and
(3) Be signed by an authorized certificated mechanic or repairman, except that a certificated repairman may sign the release or entry only for the work for which that person is employed and for which that person is certificated.
(c) Notwithstanding paragraph (b)(3) of this section, after maintenance, preventive maintenance, or alterations performed by a repair station located outside the United States , the airworthiness release or log entry required by paragraph (a) of this section may be signed by a person authorized by that repair station.
(d) Instead of restating each of the conditions of the certification required by paragraph (b) of this section, the certificate holder may state in its manual that the signature of an authorized certificated mechanic or repairman constitutes that certification.
§135.425 Maintenance, preventive maintenance, and alteration programs.
Each certificate holder shall have an inspection program and a program covering other maintenance, preventive maintenance, and alterations, that ensures that—
(a) Maintenance, preventive maintenance, and alterations performed by it, or by other persons, are performed under the certificate holder's manual;
(b) Competent personnel and adequate facilities and equipment are provided for the proper performance of maintenance, preventive maintenance, and alterations; and
(c) Each aircraft released to service is airworthy and has been properly maintained for operation under this part.
Each certificate holder shall have an inspection program and a program covering other maintenance, preventive maintenance, and alterations, that ensures that—
(a) Maintenance, preventive maintenance, and alterations performed by it, or by other persons, are performed under the certificate holder's manual;
(b) Competent personnel and adequate facilities and equipment are provided for the proper performance of maintenance, preventive maintenance, and alterations; and
(c) Each aircraft released to service is airworthy and has been properly maintained for operation under this part.
§135.429 Required inspection personnel.
(a) No person may use any person to perform required inspections unless the person performing the inspection is appropriately certificated, properly trained, qualified, and authorized to do so.
(b) No person may allow any person to perform a required inspection unless, at the time, the person performing that inspection is under the supervision and control of an inspection unit.
(c) No person may perform a required inspection if that person performed the item of work required to be inspected.
(d) In the case of rotorcraft that operate in remote areas or sites, the Administrator may approve procedures for the performance of required inspection items by a pilot when no other qualified person is available, provided—
(1) The pilot is employed by the certificate holder;
(2) It can be shown to the satisfaction of the Administrator that each pilot authorized to perform required inspections is properly trained and qualified;
(3) The required inspection is a result of a mechanical interruption and is not a part of a certificate holder's continuous airworthiness maintenance program;
(4) Each item is inspected after each flight until the item has been inspected by an appropriately certificated mechanic other than the one who originally performed the item of work; and
(5) Each item of work that is a required inspection item that is part of the flight control system shall be flight tested and reinspected before the aircraft is approved for return to service.
(e) Each certificate holder shall maintain, or shall determine that each person with whom it arranges to perform its required inspections maintains, a current listing of persons who have been trained, qualified, and authorized to conduct required inspections. The persons must be identified by name, occupational title and the inspections that they are authorized to perform. The certificate holder (or person with whom it arranges to perform its required inspections) shall give written information to each person so authorized, describing the extent of that person's responsibilities, authorities, and inspectional limitations. The list shall be made available for inspection by the Administrator upon request.
[Doc. No. 16097, 43 FR 46783, Oct. 10, 1978, as amended by Amdt. 135-20, 51 FR 40710, Nov. 7, 1986]
(a) No person may use any person to perform required inspections unless the person performing the inspection is appropriately certificated, properly trained, qualified, and authorized to do so.
(b) No person may allow any person to perform a required inspection unless, at the time, the person performing that inspection is under the supervision and control of an inspection unit.
(c) No person may perform a required inspection if that person performed the item of work required to be inspected.
(d) In the case of rotorcraft that operate in remote areas or sites, the Administrator may approve procedures for the performance of required inspection items by a pilot when no other qualified person is available, provided—
(1) The pilot is employed by the certificate holder;
(2) It can be shown to the satisfaction of the Administrator that each pilot authorized to perform required inspections is properly trained and qualified;
(3) The required inspection is a result of a mechanical interruption and is not a part of a certificate holder's continuous airworthiness maintenance program;
(4) Each item is inspected after each flight until the item has been inspected by an appropriately certificated mechanic other than the one who originally performed the item of work; and
(5) Each item of work that is a required inspection item that is part of the flight control system shall be flight tested and reinspected before the aircraft is approved for return to service.
(e) Each certificate holder shall maintain, or shall determine that each person with whom it arranges to perform its required inspections maintains, a current listing of persons who have been trained, qualified, and authorized to conduct required inspections. The persons must be identified by name, occupational title and the inspections that they are authorized to perform. The certificate holder (or person with whom it arranges to perform its required inspections) shall give written information to each person so authorized, describing the extent of that person's responsibilities, authorities, and inspectional limitations. The list shall be made available for inspection by the Administrator upon request.
[Doc. No. 16097, 43 FR 46783, Oct. 10, 1978, as amended by Amdt. 135-20, 51 FR 40710, Nov. 7, 1986]
That approval does NOT return the aircraft to service.
Perhaps you are getting hung up on the mechanic performing the return to service and the certificate holder being ultimately responsible for it. The mechanic is performing the task, the certificate holder is ultimately responsible. In 14 CFR, the reference is made time and time again for return to service/airworthiness release. Many times, the certificate holder, to cover their rear end, will send a pilot up in the aircraft to perform a flight test, so to some extent, that can be considered part of the CH's return of the aircraft to service, however, it's going to come down to what is on the paperwork and what is documented in the company procedures.
Last edited by JamesNoBrakes; 08-20-2017 at 05:43 PM.
#14
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,003
The regulation refers ONLY to APPROVING return to service. Nowhere in the regulation may a mechanic return an aircraft to service.
You attempted to make your point using Part 43, which is the correct reference for approval for return to service.
You're attempting to segue into allowances for pilots under Part 135 to do preventative maintenance. In such cases, the regulation does not allow the pilot to return the part to service while acting in a maintenance capacity; the pilot is still required to make the appropriate maintenance entry for the work done. That entry only APPROVES the work for return to service. It is a maintenance action, equivalent to preventative maintenance performed under Appendix A of Part 43.
When the pilot operates the aircraft, it is returned to service.
A mechanic certificate is a fix-it license, not a drive-it or fly-it license. The mechanic approves for return to service, and the pilot places it in service by operating it.
I'm short on time lately, but reference AC 91-67, linked below, item 6, subparagraph x, which states:
x. Return to Service, Return to service has two applications. An appropriately certificated person approves an aircraft for return to service after an inspection or after maintenance. A certificated pilot, in fact, returns the aircraft toservice after the pilot conducts an appropriate preflight and accepts the aircraft for an intended flight.
Most mechanics are very aware of this, most pilots are not. Your insistence on the matter supports that point. We can do this all day.
https://www.faasafety.gov/files/gsla...%20Chap1-2.pdf
Last edited by JohnBurke; 08-21-2017 at 06:15 AM.
#16
Is that a regulation? You are correct that a part/aircraft goes "back into service" when the flight starts as a revenue flight under the part for which it's conducted, the point though is the mechanic approves the aircraft for that return. That's the airworthiness release, the mechanic/CH saying the aircraft is airworthy. On any and all flights, the PIC accepts the aircraft and is responsible for it's airworthiness, which is what the sentence you quoted refers to. It seems like the semantics issue I brought up before.
#17
:-)
Joined APC: Feb 2007
Posts: 7,339
I'm not a mechanic, but at one of my businesses, I have gotten away with buying gearwrench over any of the tool trucks. I can see where immediate warranty service is a plus, but I find a quick trip to Home Depot can temporarily replace something till I can get it taken care of. I can't see spending 4 or 5 figures on sockets, but I know some diagnostic, and/or specialized equipment you can't avoid paying for.
#18
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,003
The pilot does not "deem" it into service. The pilot puts it in service by operating it.
It has nothing to do with power or the almighty. Calm down.
You know very well it isn't a regulation. It's an advisory circular. I was getting set to launch on a fire and had very little time. You are employed by the FAA, no? You understand that it was an advisory circular. I stated it was an advisory circular. I provided the link, and the quote. Could there possibly be any doubt?
A repairman, mechanic, inspector, or repair station (or pilot performing authorized preventative maintenance) may approve for return to service. That approval does NOT return the item to service.
You have attempted to say otherwise by incorrectly quoting two parts of the regulation, neither of which stated that a mechanic can return a part to service.
A regulation is not required stating that a pilot can or must return a part to service. The limitation is on the mechanic; the mechanic cannot return the part to service by function of a logbook entry. The mechanic may only approve it for return to service. There is no place in the regulation in which a mechanic may do more than approve for return to service.
If the mechanic happens to be a pilot who can fly the aircraft, then the mechanic may go beyond the function of maintenance and further return to service, but that is within the scope of pilot privileges, not maintenance privileges.
The mechanic's signature is only applicable to the work performed. The exception is a statement of airworthiness for the aircraft, and for the engine, as provided during an annual/100 hour inspection, when performed in conjunction with a checklist and the appropriate regulation. When a mechanic provides a signature for work performed, the signature, date, certificate number, and description of the work performed constitutes a statement of approval of airworthiness for the work performed only. This is a central premise to the authority and limitation of authority of the mechanic certificate.
If I sign off on the removal, repair, and replacement of a seat belt and provide a logbook entry for that work, my signature and statement of the repair serves to constitute an approval for the work performed, and nothing more. I do not become responsible for the airworthiness of the aircraft. I have approved that seatbelt repair to return to service and nothing more.
When an annual/100 hour is performed, the mechanic IA who does the work buys all the work previously done on the aircraft, up until the time his ink is in the logbook; he makes a statement of airworthiness and approval for return to service for the entire life of the aircraft up until his signature is complete. The saying is that he "buys the past." At that point, the aircraft is approved for return to service, but has not been put in service, or returned to service. The mechanic's role is done, and the aircraft is not returned to service. Simply approved for return to service.
The pilot returns it to service when he operates the aircraft, whether for pleasure, revenue, sport, or any other purpose.
In fact, I chose that quote because it stated what I've said, word for word. It's not semantics. Far from it. There are two elements to a return to service. The approval for return to service, provided by the mechanic, and the return to service, done by the individual (pilot) operating the aircraft. The sentence was very specific, and stated that the mechanic APPROVES return to service, while the pilot RETURNS to service. Two parts of a return to service. It can't be returned to service without the approval, and the approval does not return it to service.
I stated we can do this all day because it's far from a single paragraph in an obscure old advisory circular. This is not a new concept and has been the position of the FAA for many decades. Again, that you don't understand it reinforces the point that many pilots don't.
Last edited by JohnBurke; 08-21-2017 at 01:28 PM.
#19
Banned
Joined APC: Jan 2015
Posts: 516
If he has the cognitive ability for college, he won't be happy with maintenance. It is a job for poor and/or dumb kids, an E3 in the military. Pay can be anywhere from minimum wage to $54/hr. The key is working for a large company that pays well and they all promote from within, experience has zero value! Even if he lucky enough to make good money, it will always be nights, weekends, and holidays far away from home. He will spend his 20s on second shift. Overall a p1ss poor way to make a living! The FAA is approving enough foreign repair stations to replace ALL maintenance stateside, something to consider.
Last edited by kevbo; 08-21-2017 at 01:54 PM.
#20
If he has the cognitive ability for college, he won't be happy with maintenance. It is a job for poor and/or dumb kids, an E3 in the military. Pay can be anywhere from minimum wage to $54/hr. The key is working for a large company that pays well and they all promote from within, experience is worthless! Even if he lucky enough to make good money, it will always be nights, weekends, and holidays far away from home. He will spend his 20s on second shift. Over all a p1ss poor way to make a living!
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