In the recent past I have written about the importance of mechanics following the procedures contained in the appropriate manuals for whatever task that needs to be accomplished. That’s not new advice; it is something every certified aircraft mechanic heard on the first day of instruction. The mechanics who obtained their certificates as part of their military training and experience have heard the same warning about the necessity of following the published procedures.
The Federal Air Regulations require all maintenance performed on any aircraft or component–including engines, propellers and instruments–to be accomplished in accordance with the published procedures. The FARs require the manufacturer of an aircraft, engine, propeller, instrument or any other item installed on an aircraft to provide instructions for continued airworthiness. I have been vocal about the fact that some of the procedures provided by the manufacturers do not accurately describe the steps necessary to accomplish the task. I also know of one manufacturer that knowingly published procedures that were inaccurate or incomplete and waited for the maintenance professionals to identify and report the problems, often with the required corrections, making it much easier for the manufacturer to implement the revision.
Procedures Review Needed
The FAR that governs the accomplishment f maintenance is 43.13, sections a, b and c. These are called performance rules as they cover the actual work on an aircraft, propeller, engine, component or anything else installed on an aircraft. Regardless of where you work within the aviation industry you are required to follow the published procedures. In other words, the rules apply to general aviation, corporate aviation, Part 135 air carriers, Part 121 airlines and Part 145 repair stations, among other categories.
If a mechanic finds the manufacturer-provided manual to be inaccurate, there is a procedure to notify the appropriate party for correction. This rule has been in place for the last 50 years. The burden for compliance with FAR 43 falls with the mechanic who accomplishes or signs for the work performed. The FAA can also take action against the person or certificate holder who created the instructions for continued airworthiness.
During my time on the NTSB I observed many violations of FAR 43.13 section a, b and c. In these cases typically the mechanic was found to be in non-compliance with the regulation. The result was the loss of his certificate for a period of time or a fine.
There is another area that we–the mechanics–are required to control with absolutely no deviation allowed. That is in the accomplishment of an Airworthiness Directive. If an Airworthiness Directive cannot be accomplished exactly as written, then the mechanic must stop, assuming he started to accomplish the Airworthiness Directive, and return the aircraft to the original condition. Next, he must contact the FAA office that issued the Airworthiness Directive to request an alternate means of compliance. This process could take anywhere from a few days to several weeks while the Airworthiness Directive compliance date draws nearer. This can and has caused problems, and it can put additional pressure on both the mechanic and the owner/operator of the aircraft.
A few months ago the FAA asked me to participate in a panel that was looking into the process of service bulletins and Airworthiness Directives. We have accomplished a major review of all the documents we could identify on this subject, including some that were difficult to locate. We are interested in both the current state of the rules and guidance and all the historical information that we could locate. Although the task was a daunting one, it has been very informative.
As I have been traveling around accomplishing my private-sector job I started to ask mechanics about the process I outlined above. I wanted to find out how familiar these mechanics were with the process. The answers I received from the first group of mechanics were not what I had expected, so I questioned more mechanics. The results with the second group were the same. I queried mechanics from general aviation and Part 121 operators and found that most misunderstood some part of the process. The exception was that if the mechanic held Inspection Authorization authority from the FAA he understood the process.
I spoke to several non-certified mechanics working for a Part 121 airline who did not understand the process. I also spoke to several non-certified mechanics from a FAR Part 145 repair station. From this basic survey, I concluded that more work is needed in this area, possibly to identify the need for additional training.
The procedures I outline in the beginning of this article need to be followed by anyone who accomplishes aircraft maintenance, and we need to do more to ensure that we understand and comply with the rules.