Aviation Maintenance Technician
Where did the term come from?
By Fred Workley
Due to changes in aircraft technology, the amount of specialized training required to perform aviation maintenance has increased significantly since the introduction of the term “mechanic.” The highly complex and technical field of contemporary aviation maintenance requires substantially more than the manual skills typically associated with individuals classified as “mechanics.”
The FAA asserts that the term “aviation maintenance technician” more completely describes the types of skills necessary to maintain today’s complex aircraft and more accurately reflects the level of professionalism found in the aviation maintenance industry. Adoption of the term “aviation maintenance technician” would standardize terminology throughout the aviation industry and make Part 65 consistent with 14 CFR Part 147 (which regulates aviation maintenance technician schools), aviation maintenance trade publications, and the civil aviation regulations of many ICAO (International Civil Aviation Organization) member states.
Currently, subparts D and E of 14 CFR Part 65, pertain to mechanics, mechanics holding inspection authorizations, and repairmen. Since the recodification of the Civil Air Regulations into the Federal Aviation Regulations on Aug. 10, 1962, few significant revisions to these subparts have been made.
Blue Ribbon Panel report
The Pilot and Aviation Maintenance Technician Blue Ribbon Panel, in its report titled Pilots and Aviation Maintenance Technicians for the Twenty-First Century: An Assessment of Availability and Quality, noted that current FAA certification requirements do not give aviation maintenance personnel the entry-level experience and skills necessary for work involving transport-category aircraft that employ new technology. The panel further noted that due to the rapid acceleration of technological advances more preparation and training are now required to meet the higher levels of qualification that the aviation maintenance industry demands.
The Blue Ribbon Panel strongly recommended that the FAA develop the means necessary to train aviation maintenance personnel to a level of expertise beyond today’s requirements. The FAA agrees.
The review group conducted a series of panel discussions throughout the United States and, as a result, drafted the Industry/FAA Part 65 Review Group Working Paper, which was completed on Jan. 31, 1991. This paper presented the issues of general agreement within the review group and also presented issues that required further discussion.
During 1991, the FAA also conducted a survey of FAA regional offices on the certification of mechanics, holders of inspection authorizations, and repairmen. The survey was derived from issues that surfaced during FAA participation in listening sessions with aviation industry associations and the ICAO Aircraft Maintenance Engineer Licensing Panel and from issues identified in petitions and enforcement actions.
Results of this survey showed clear support for: (1) replacing the term “mechanic” with “aviation maintenance technician;” (2) developing a system for granting additional privileges and limitations for mechanics; (3) encouraging additional FAA participation with ICAO and other aviation authorities to standardize training and certification of maintenance personnel; (4) using aviation maintenance instructor experience to satisfy recent experience requirements; (5) clarifying §65.75(b), regarding written test requirements; (6) adding the term “facsimile” to §65.16; and, (7) developing a separate certificate or rating for balloon repairmen. The majority of the respondents supported changes in the English-language requirements for both mechanics and repairmen, the continued acceptance of military aircraft maintenance experience as the basis for airframe and powerplant mechanic certification, and changes in the units of time used in current §65.77 to designate experience requirements for mechanics, from months to hours.
The establishment of ARAC
Further impetus for the Part 65 review came with the establishment of the Aviation Rulemaking Advisory Committee (ARAC). The ARAC charter became effective on Feb. 5, 1991, and was renewed on Feb. 21, 1995. The ARAC was established to assist the FAA in the rulemaking process by providing input from outside the federal government on major regulatory issues affecting aviation safety. The ARAC included representatives of air carriers, manufacturers, general aviation, labor groups, colleges, universities, associations, airline passenger groups, and the general public. The ARAC’s formation has given the FAA additional opportunities to solicit information directly from affected parties, who meet and exchange ideas about proposed and existing rules that should either be revised or eliminated. The FAA received significant assistance from the ARAC in this review and in the formulation of the proposals contained in the NPRM that offered Part 66 to replace Part 65.
At its first meeting on air carrier/general aviation maintenance issues on May 24, 1991, the ARAC established the Part 65 Working Group. The ARAC tasked this working group to conduct a review of the certification requirements for mechanics, mechanics holding inspection authorizations, and repairmen. Due to the extensive scope, the working group divided its review of the certification requirements for aviation maintenance personnel into phases.
Once the first phase of this review was complete, the ARAC analyzed the efforts of the working group and made a series of recommendations to the FAA, which resulted in the FAA’s issuance of an NPRM on Aug. 17, 1994. That NPRM proposed: (1) establishing a separate part in the FAR for aviation maintenance personnel; (2) removing gender-specific terms from the original regulation; (3) changing the term “mechanic” to “aviation maintenance technician;” (4) changing the term “repairman” to “aviation repair specialist;” (5) establishing the equivalency of the aviation maintenance technician certificate and the aviation repair specialist certificate with current certificates; (6) allowing facsimiles to be used in the process of replacing lost or destroyed aviation maintenance technician and aviation repair specialist certificates; (7) requiring applicants to demonstrate English-language proficiency by reading and explaining appropriate maintenance publications and by writing defect and repair statements; (8) discontinuing the certification of aviation maintenance personnel who are employed outside the United States and who are not proficient in the English language; (9) requiring all aviation maintenance technician applicants to pass a written test that would examine their knowledge of all applicable maintenance regulations; (10) clarifying the requirement that each applicant for an aviation maintenance technician certificate pass all written tests before applying for oral and practical tests; (11) recognizing computer-based testing methods; (12) specifying all experience requirements in hours instead of months for initial certification; (13) establishing a basic competency requirement for aviation maintenance technicians; (14) allowing aviation maintenance technicians to use equipment-specific training as an additional means to qualify for the exercise of certificate privileges; (15) permitting aviation maintenance instructors to use instructional time to satisfy currency requirements; (16) establishing training requirements for aviation maintenance technicians who desire to use their certificates for compensation or hire; (17) extending the duration of an inspection authorization from one to two years; and (18) expanding the renewal options available to the holder of an inspection authorization.
Part 65 and 66
After further work by the Part 65 Working Group and the rapid completion of the second phase of the review of the certification requirements for mechanics and repairmen, the ARAC recommended that the FAA consolidate the proposals made in the earlier NPRM with those proposals made by the ARAC .
The FAA, in an effort to avoid confusion in the implementation of the final rule, agreed and determined that the changes should be reconciled and consolidated into a single NPRM containing both sets of proposals. The FAA, therefore, withdrew the initial NPRM.
The end result was that the FAA proposed the general use of the term aviation maintenance technician (AMT).
Many of the discrepancies between the second proposal and the earlier NPRM resulted from the previously proposed equivalency of a mechanic certificate to an aviation maintenance technician (AMT) certificate. The current mechanic certificate has airframe and powerplant ratings. The holders of mechanics certificate with an aircraft rating or powerplant rating possess the approval for return-to-service privilege. Information pertaining to inspection authorizations is found solely in the subpart 65.
By establishing a new type of aviation repair specialist certificate based on proficiency in a designated specialty area but not linked to employment, this proposal significantly reorganizes the subpart of previously proposed Part 66 applicable to aviation repair specialists.
As a result of comments received to the earlier NPRM, the proposal to specify practical experience requirements in hours for the issuance of an AMT certificate would be retained; however, the time interval in which currency requirements would be measured would continue to be stated in months. This version would also propose a mandatory recurrent training requirement for AMTs and AMTs (transport) who use their certificates for compensation or hire.
This NPRM would not propose that recurrent training consist of a minimum of 16 hours every 24 months, as stated in the previous NPRM. To afford aviation maintenance personnel greater latitude in the types of training to qualify them for the exercise of certificate privileges, this proposal would change the more restrictive term “equipment-specific training” to “appropriate training.” It would also permit training on the “tasks to be performed” to be used to qualify a person for the exercise of certificate privileges, rather than require training to be on the “equipment on which the work is to be performed.” Completion of training sufficient to permit the exercise of certificate privileges would, therefore, not need to be conducted on the identical make and model of an item on which subsequent work would be performed.
The Part 66 NPRM was put out for public comment but due to negative comments was withdrawn. Since then the aviation maintenance professional Job Task Analysis was completed. Analysis of Part 147-school curriculum has yielded many recommendations for changing the way new technicians are trained.
This article, with information directly from the Part 66 preamble, is presented as a historical perspective of how the term aviation maintenance technician came into common usage. It is not at all clear how these issues will develop in the future and whether there will be any future changes to Part 65.
Fred Workley is the president of Workley Aircraft and Maintenance Inc. in Alexandria, VA, Benton City, WA, and Indianapolis, IN. He holds an A&P certificate with an Inspection Authorization, general radio telephone license, a technician plus license, ATP, FE, CFI-I, and advance and instrument ground instructor licenses.