When a mechanic with a powerplant and/or airframe rating from the Federal Aviation Administration (FAA) works on an aircraft for a fixed based operator (FBO), the company might receive payment but the individual is responsible to the government for what was accomplished. On the other hand, if the FBO holds a repair station certificate, the company will be responsible to the government for the work of its employees, including certificated mechanics or repairmen. While an FBO may be commercially responsible to the owner/operator for any work expected or completed, the FAA will look to the certificate holder for the proper performance of that work.
It is extremely important that the owner/operator, FBO, and its mechanics understand their roles and obligations. An owner/operator (usually a pilot) is responsible for operating an airworthy aircraft. That condition can be determined and maintained by reviewing the airworthiness limitations and maintenance records as well as flying the aircraft within its design parameters. If something goes wrong, that same party should be able to describe the problem in enough detail that a knowledgeable technician can figure out whether the problem can be fixed.
The FBO without a repair station certificate must understand that it is dependent upon its certificated mechanics to determine the extent and nature of the work needed and whether or not the individual can complete the actions with the housing, facilities, equipment, and data available from the company. Indeed, a repair station has to make the same determination; it will do so using knowledgeable technicians, some of which will hold either mechanic or repairmen certificates.
In other words, while the pilot is ultimately responsible for operating an airworthy aircraft, s/he won’t be able to do so without the help of the FBO. The FBO needs knowledgeable employees, whether individual mechanics or repair station personnel, working within the parameters of parts 43, 65, and/or 145. Neither the pilot nor the company can perform corrective actions without a certificate from the FAA. Additionally, neither a repair station nor a mechanic can do everything on every aircraft.
Under the FAA rules, the maintenance provider is only responsible for the work it performed, not for any and all work that needs to be accomplished. The owner/operator is responsible for ensuring all work necessary to keep the aircraft airworthy has been or is accomplished.
When the parties work together, things are wonderful; the FBO and its people are praised to the skies. When things go wrong, everyone involved in the process can get a black-eye merely because the expectations of the parties were misunderstood. All parties need to be straight about the roles and responsibilities set forth by the government; then the parties need to be upfront about the result of the work needed versus that which can and will be performed.
For more information visit www.arsa.org.
Sarah MacLeod is executive director of the Aeronautical Repair Station Association (ARSA), an organization she helped found more than 25 years ago.