In last month’s article, I floated the idea for a nationally recognized organization to administer a Professional Mechanic’s Examination. When an A&P mechanic successfully passes such a test, a nationally recognized testing organization would recognize that mechanic as achieving professional status within the field of aviation maintenance. Over time if enough A&Ps take and pass the test requirements our profession will gain much-needed recognition as a “professional” career field.
I described the “Professional Mechanic Test” as an open book test that contains at least 100 tough, essay questions. The test would be equally divided between General, Airframe, Powerplant, Electrical, and Regulations with an eight-hour limit from start to finish. I also included in the last article 20 sample test questions on FAA regulations and policy in order to pique one’s curiosity on how hard this test would be. As I promised in that article, here are the answers to those 20 test questions on regulations and policy.
QUESTION 1: What is the major difference in maintenance record entries between PMA and TSO parts?
Answer: A Parts Manufacturer Approval part (PMA) is identical to an individual TC part in every way, so it is considered a direct replacement part for OEM parts. For example, if you change a Piper PA-23-250 nose gear actuator with a PMA nose gear actuator, that action only requires a logbook entry under section 43.9. On the other hand, a Technical Standard Authorization (TSO) part is a generic part, like tires, communication and navigation equipment, seat belts, instruments, etc., that could be used on many different makes and models of aircraft. In many cases installing a TSO part “may” require a Form 337 because installing it would be considered a major alteration of the original type design. For example, installing a new TSO glass cockpit in a Cessna 172 would require a Form 337.
QUESTION 2: What rule talks to remanufactured engines?
Answer: There is no FAR that addresses a “remanufactured engine.” There is only one rule, section 91,421 that talks to rebuilt engine records and allows an engine manufacturer or an agency approved by that manufacturer to zero time the logbooks when the engine is rebuilt to like-new standards. Remanufactured is an industry advertising term that is used to sell rebuilt engines with zero time logbooks.
QUESTION 3: What government agency or administration created the Inspection Authorization and when did it happen?
Answer: The Civil Aeronautic Administration (CAA) created the Inspection Authorization (IA) when it published CAR 24.43-1 on June 17, 1956. So it was the CAA and not the FAA who created the IA almost 50 years ago.
QUESTION 4: How long is a mechanic responsible for the work performed on an aircraft?
Answer: A mechanic is responsible only for the airworthy work he or she performed on an aircraft and only that work, until that work is either performed again, altered, damaged, replaced, or meets its life limit if the part worked on is a life-limited part, or until the work is re-inspected. For the average general aviation aircraft operated under Part 91 the longest length of time a mechanic is under the gun is one year or until the next annual inspection is performed and the mechanic’s work is re-inspected.
QUESTION 5: How long is a mechanic responsible for an inspection to an aircraft?
Answer: After performing an inspection, the mechanic is responsible for the continued airworthiness of the aircraft until the ink in the logbook dries. When a mechanic performs an inspection of an aircraft, that mechanic cannot guarantee the airworthiness of the aircraft six months or even six days into the future when that aircraft is no longer in his care. What a mechanic buys off an aircraft as airworthy after he performs an inspection, is every repair, alteration, STC, Form 337, AD, field approval, and service bulletin back to the date on the airworthiness certificate be that date, six weeks old, six months old, six years old, or 60 years ago. Mechanics, when they perform inspections, buy off all the work performed on that aircraft to the moment the airworthiness statement is made in the logbook. An inspection cannot buy off future airworthiness of the aircraft.
QUESTION 6: What is the maximum number of mechanics who can sign off a 100-hour inspection on a Piper Aerostar?
Answer: The total number of mechanics to sign off a 100-hour inspection on any twin engine propeller driven aircraft is five. One mechanic to sign off the airframe, two mechanics to sign off each engine, and two mechanics to sign off for each propeller. Remember, when performing a 100-hour you are working within the privileges of your A&P ratings. That is why whenever you perform a 100-hour inspection you must sign off each of the aircraft’s three kinds of logbooks, (airframe, engines, and propellers) separately. It is only the mechanic with an IA who can sign off an annual inspection to the entire aircraft with one entry in the airframe logbook because he signs off the “aircraft” not individual airframes, engines, or propellers.
QUESTION 7: Give one major difference between aircraft certificated under CAR-3 and FAR 23.
Answer: CAR-3 aircraft like, J3-Cubs and Cessna 150s, did not have mandatory life-limited parts on their original type certificates. FAR 23 aircraft like the Piper Tomahawk and the Beech Skipper do have life-limited parts.
QUESTION 8: When were mechanics first licensed and who was the first U.S. licensed mechanic?
Answer: Mechanics were first “licensed” to work on aircraft on July 1, 1927 by the Aeronautic Branch of the Commerce Department. The first “licensed” mechanic was Frank Gates Gardner, director of the Aeronautic Branch. As a side note, the U.S. government stopped “licensing” mechanics and pilots on June 23, 1938, when Congress passed the Civil Aeronautics Act of 1938. The Civil Aeronautics Act allowed for the government to “certificate” mechanics and pilots. This change from “licensed” to “certificated” mechanic or pilot was promulgated to reduce the increasing tort claims against the U.S. government in civil court when a government “licensed” pilot or mechanic was involved in an accident.
QUESTION 9: What five documents are required to be in an aircraft prior to flight, and what document is the most important?
Answer: The five documents required to be in an aircraft before flight are: Airworthiness, Registration, Radio License (if flight is outside the United States), Operating Manual, and Weight and Balance. The most important document is the registration certificate. If the aircraft is not properly registered then that aircraft cannot be legally operated (Ref: FAR 47.3).
QUESTION 10: What is the difference between a mechanic rating and an inspection authorization?
Answer: A mechanic’s rating is good until it is revoked, suspended, or surrendered to the Administrator. An inspection authorization is also good until it is revoked, suspended, or surrendered to the Administrator and for one calendar year that begins on April 1 and ends on March 31. The IA has a built-in life limit, a mechanic’s rating does not.
QUESTION 11: Name the three kinds of Airworthiness Directives?
Answer: There are three kinds of Airworthiness Directives: The first is the priority or emergency AD which immediately grounds the aircraft. The second is the immediate adopted rule, which allows a grace period measured in cycles, hours, or days before the AD must be complied with or the aircraft is grounded. The last is the Notice of Proposed Rulemaking (NPRM) in which the draft AD is published in the Federal Register and a request is made for public comment.
QUESTION 12: Where is the definition of “airworthy” found?
Answer: The definition of airworthy is found on the Standard Airworthiness Certificate and in the glossary of Advisory Circular (AC) 43.13-1B.
QUESTION 13: What is acceptable data used for?
Answer: Acceptable data is the information used to inspect and make minor repairs and alterations (Ref: FAR 43.13 Performance Rules).
QUESTION 14: What is approved data used for?
Answer: Approved data is the information used to make major repairs or major alterations (Ref: FAR 65.95 and FAA Order 8300.10, Vol. 2, Chapter 1, page 1-1).
QUESTION 15: What rule sets the minimum level of performance for mechanics?
Answer: Only one rule sets the minimum level of performance and that is FAR, Section 43.13, Performance Rules.
QUESTION 16: What AC will tell you how to get a field approval?
Answer: AC 43.210 Stan- dardized Procedures for Requesting Field Approval of Data, Major Alterations, and Repairs. The AC also includes the checklist to make up the Instructions for Continued Airworthiness for a major alteration.
QUESTION 17: What is the difference between rebuild and overhaul?
Answer: An overhaul of an aircraft or component part is use of methods, techniques, and practices acceptable to the Administrator; it has been inspected, repaired as necessary, reassembled, and tested in accordance with approved standards and technical data, or in accordance with current standards and technical data acceptable to the Administrator (Ref: service limits). Rebuild is the same as overhauled with the exception that the aircraft or component part must meet the same tolerances and limits as a new item, or meet approved oversized or undersized dimensions.
QUESTION 18: Is the Illustrated Parts catalog acceptable or approved data?
Answer: The manufacturer’s Illustrated Parts Catalog (IPC) is neither acceptable nor approved data to determine conformity to type design. The IPC is a tool to sell parts. There is no requirement for the IPC to be current or accurate. There is no requirement under the FAR for a manufacturer to produce an IPC as part of its type design requirements. IPCs are very useful references to determine if the aircraft is configured properly but should not be used as acceptable or approved data. So use the IPC, but do not reference it on Block 8 of the Form 337 (Ref: FAA Order 8130.2F, page 41).
QUESTION 19: How many kinds of field approvals are there?
Answer: There are two kinds of field approvals. One is approval of acceptable data. This is the most popular of the two. The second kind of field approval is one based on physical inspection and testing (Ref: FAA Order 8300.10 Vol. 2 Chapter 1 page 1-5, paragraph 19).
QUESTION 20: What are the penalties for falsifying a maintenance record?
Answer: The price to autograph a lie is high. According to FAR 43.12 Maintenance Records: Falsification, reproduction, or alterations, the penalty for falsifying a maintenance record is suspension or revocation of that individual’s mechanic certificate. This means the government will take away your certificate and your ability to earn a living. But this is only the beginning. While the FARs can pull your certificate the civil courts can impose a whopper of a fine, long jail terms, and restitution to affected parties to the point you no longer have a house to live in or a car to drive.
Well there you have it. You had a look at my attempt at creating 20 questions dealing with regulations for the Professional Mechanics Test. Each question was based on the AMT articles I have written and the questions that I ask mechanics during my IA seminars. If you answered 10 of them correctly you still did not pass the test but you are running about average. If you got less than eight questions right, well then my friend you are in trouble, and I recommend that you better start reading the AC and Orders that I referenced to get yourself up to speed. In closing, if anyone is interested in discussing the establishment of an industry developed and managed Professional Mechanics Test, then I am available. I will support anyone’s honest effort whose goal is to ensure that both the industry and the flying public recognize aircraft maintenance as a professional career.