Manufacturer's Instructions: How the maintenance should be performed

When it comes to performing maintenance on an aircraft it is a little different than what we do when we need to repair our car.


The critical nature of the business we are in has been joked about in many ways by both industry and consumers. We have all heard the comments about "100 mile an hour tape" and "you can't pull over up there to try to fix it". Comments like that are common and I believe they come from the fact that our industry is so safety critical.

When it comes to performing maintenance on an aircraft it is a little different than what we do when we need to repair our car. I often take my boys out to work on the car and use it as a learning experience where they can try to perform the task and fail without catastrophic results. Not the case with aircraft (obviously). This month we are discussing the regulations that cover how aircraft maintenance is to be performed and whose responsibility it is to ensure the correct maintenance instructions and procedures are used.

Who can perform maintenance?

First let's cover who can work on the aircraft. Many think that in order to work on the aircraft one must be certificated by the FAA. Not so. 14 CFR Part 43.3 spells out in detail who can perform maintenance. Basically, limited to their specific certification the following certificate holders can work on an aircraft: mechanic, repairman, repair station, air carrier, pilot, and manufacturer.

In addition to those who are certificated, a person who is working under the direct supervision of a mechanic or repairman certificate holder may work on the aircraft as well - limited by the limitations of the person supervising them.

This is interesting and at times can be confusing. Like so many things that seem to be obvious, there are a few strange underlying details to the apparent authorizations to perform maintenance. One is the tie back to 14 CFR Part 65, as is the case for the mechanic and the repairman. Part 65 tells us that the mechanic can be rated as an Airframe mechanic and/or Powerplant mechanic (A&P) and if rated as both Airframe and Powerplant, may hold the authority of Inspection Authorization (IA). So you can see that being a mechanic is just the start of it. What type of mechanic you are and what authority you have determines what type of maintenance you can perform.

A repairman is much different. A repairman may only exercise the authority of the repairman certificate while employed by the repair station. The ratings available for the repairman are limited also to the authority of the repair station and the knowledge, training, and experience of the repairman himself. The ratings that appear on a repairman certificate are usually "made up" by the FAA issuing the certificate, based upon the application that was submitted. We seldom find the same ratings on two repairman certificates issued by different FAA offices, but the ratings are usually very clear and unambiguous. (Another minor twist is that in special cases, an experimental aircraft builder can apply for and receive a repairman certificate for that aircraft, but for the purposes of this discussion we will stick with the repair station repairman certificate.)

One may get confused then when they think of the fact that a repair station is called out separately from the repairman in Part 43.3 when the repairman is limited to the rating of the repair station. Well - here is why - a person working under the direct supervision of a mechanic or repairman can perform work on the aircraft (as stated before) however, they cannot approve that work for return to service. A different regulation tells who can approve for return to service following maintenance - 14 CR Part 43.7. The list is a little different here and, basically, does not include the noncertificated person who must also be supervised to work on the aircraft in the first place. So, a repair station will need to have a repairman to supervise and approve for return to service if they employ anyone who is non-certificated to perform maintenance. Here is a list of those who can approve for return to service following maintenance: mechanic, repair station, manufacturer, air carrier, private pilot, repairman (light-sport aircraft type), and sport pilot. Again, each is limited to approval for return to service within their respective authority.

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