While repairmen who hold Part 65 certificates are authorized to perform maintenance work, they often receive less respect and opportunity than those who hold a Mechanic certificate under Title 14.
Mechanics who are certificated under Title 14, Subchapter D, Subpart D have long held a lofty perch.
For repair stations and air carriers, the same privileges are given to Repairmen issued certificates under Subpart E, yet the ARSA finds that organizations often must repeatedly defend the authenticity of limited mechanics.
ARSA’s executive director has shared that he is a lawyer because of the TV series Perry Mason (with the irreplaceable Della Street) that features wrongly accused clients being defended by an attorney who brings the real culprit to justice by sharp cross-examination.
“Is it not true…” Mason begins his questioning, followed by a series of “also true” exertions undeniable by the perpetrator. The final effect is to ensnare the witness in an unescapable web of facts.
This sentiment is echoed by ARSA and its allies when defending the value of Part 65 certificates.
For example, is it not true that § 43.3(e) states that repair station certificate holders can perform maintenance, preventive maintenance and alterations?
Well…yes.
And is it also not true that § 145.153(b)(1) allows for supervisors to be certificated as a mechanic or repairman under part 65?
Yes…I guess that’s true.
And so, it would then be true that § 145.157(a) requires persons authorized to approve work on an article for return to service be certificated as a mechanic or repairman under part 65?
Yes…the personnel requirements of the repair station rule allow repairmen to serve as supervisors and hold authorization to approve for return to service.
And finally, is it true that the repair station is granted the authority by § 145.159 to choose to use a repairman that meets the personnel requirements of the part?
Yes…that’s what the rule says.
So, considering all of this, we could say it is true that the rules allows repair stations to hire Repairman Certificate holders in the same certificated roles as mechanics.
The language in the rules uses the two certificate holders interchangeably.
However, the FAA’s guidance to authorized inspectors states, “In no instance should anyone issue a Repairman Certificate with an airframe and/or powerplant rating to circumvent the process of obtaining a Mechanic Certificate.”
At this point in an episode of Perry Mason, the witness would likely break and admit to the falsifications of their previous testimony, giving excuses for their actions. Unfortunately, the fictitious inspector or industry stakeholder on the stand would probably continue to deny the validity of repairman equality under the repair station and air carrier regulations.
Regardless of the obfuscations of those entrenched in the power of the Mechanic Certificate, the rules and the privileges of the “airmen other than flight crewmembers” are clear.
Efforts to bolster the value of a Repairman Certificate—such as acknowledging its holders as “limited mechanics”—are not about adjusting the language of the rules.
Rather, the goal is to open more opportunities for previously non-certified technicians by recognizing:
- Aeronautical knowledge
- Risk management
- Skills equivalent to a similarly situated mechanic
That opportunity begets career development on the foundation of knowledge gained through the training and experience that repair stations and air carriers must afford all technical personnel.
After all, a mechanic’s certificate is only as valuable as the holder’s experience and skill. And with the ongoing AMT shortage, it’s more important than ever to facilitate career development and expand job opportunities in aircraft maintenance.
Defending the Repairman Certificate ensures that the most experienced and capable individuals are given the same privilege as Mechanic Certificate holders to perform approval work for return to service and supervise and mentor new AMTs.
