The Federal Aviation Regulations are Debatable

Alternative methods for traceability could be: bar coding, a ColdFusion form on the FAA’s website, or a traceability registration card requiring the PMA holder to identify where its parts are installed. Years ago I even envisioned bar coding on aircraft registrations and airmen certificates. Think how useful this could be. The mechanic or repair station could scan their certificate, scan the aircraft registration certificate, and scan the OEM, PMA, or TSO part bar code, and “poof” the FAA would know who put what where when and why — resulting in improved safety and reduced workload for both the mechanics or repair stations, and the FAA. If any parts prove to be defective, finding and replacing them would be “a piece of cake.”

With respect to aircraft maintenance records, maintenance recordkeeping prompted a 1995 FAA debate concerning who is responsible for AD compliance and recordkeeping. The aircraft in question turned out to be “somewhat airworthy,” but you couldn’t tell that from the aircraft maintenance records. Among other discrepancies, a dyslexic mechanic had inverted a recurring AD number, effectively changing it from a Cessna AD to a Piper AD, and four other mechanics had copied the Piper AD number and signed it off as being complied with at each of six annuals. I wrote five mechanic Letters of Investigation and 11 pilot Letters of Investigation. Well … “The ship hit the sand.” By the way, you cannot sign off a recurring AD like this, “C/W AD ##-##-##.” I will explain “somewhat airworthy” in another article.

Ok, I have expressed my opinion on PMA, TSO, OEM parts and maintenance records. Now it is your turn in this debate. Send your opinion and/or comments to AMT Magazine. I hope my best friend Bill O’Brien responds as well. People new to aviation learn a lot when old-timers debate. In addition, you may ask me any question you want, and if it is a good one, like Bill O’Brien’s question No. 1, I may write an article on the subject.