ARSA Insight: Know the Boundaries

June 11, 2024
Brett Levanto, Vice President of Operations, Obadal, Filler, MacLeod & Klein, P.L.C.
Brett Levanto, Vice President of Operations, Obadal, Filler, MacLeod & Klein, P.L.C.

Certificated mechanics are the backbone of aviation. Holding a certificate under part 65 subpart D puts you on an exclusive list of persons authorized to perform, supervise, and approve for return to service maintenance, preventive maintenance, and alterations (§§ 43.3 and 43.7). For a repair station, air carrier, or commercial operator a mechanic’s certificate is one qualification needed for supervising, performing required inspections, and approving work for return to service on behalf of the part 119 or 145 certificate holder.

While it opens many doors, mechanics are constrained by the limits in the safety regulation (§ 65.81(a)). Generally, one cannot supervise without having previously performed the work properly, nor can they perform work without understanding manufacturer instructions and maintenance manuals. More important, mechanics cannot perform major repairs or alterations of propellers or any repair or alteration of instruments.

14 CFR § 65.81 General privileges and limitations.

(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§ 65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned. (Emphasis Added_

This limitation against work on instruments has produced controversy: Suppose a customer requests the removal of a broken instrument and installation of a replacement. As a mechanic with an airframe rating and the requisite understanding of the instructions, can you perform this work under the privileges of your certificate?

The answer to the question isn’t found in § 65.81 or the additional privileges in § 65.85, but in the definition of maintenance in § 1.1 and the “mechanic’s bible” of part 43. The description of maintenance record entries in § 43.9(a)(4) focuses on “the approval for return to service only for the work performed.”

14 CFR § 43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, § 135.411(a)(1), and § 135.419 of this chapter).

(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:

(1) A description (or reference to data acceptable to the Administrator) of work performed.

(2) The date of completion of the work performed.

(3) The name of the person performing the work if other than the person specified in paragraph (a)(4) of this section.

(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed. (Emphasis added.)

In the case of the customer request above, what work will be performed? The removal of an article, which isn’t included in the definition of maintenance, and the replacement of that article, by installation of a new one. Mechanics are prohibited from repairing or altering an instrument. By replacing one on an aircraft, the work is not being performed on the instrument. The replacement of the instrument on the aircraft is the action that must be captured and for which the signature will be made in the § 43.9 record.

Any person subject to the rules of 14 CFR must understand the boundaries, so working inside them can be explained.

Brett Levanto is vice president of operations of Obadal, Filler, MacLeod & Klein, P.L.C. managing firm and client communications in conjunction with regulatory and legislative policy initiatives. He provides strategic and logistical support for the Aeronautical Repair Station Association.

About the Author

Brett Levanto

Brett Levanto is vice president operation for the Aeronautical Repair Station Association (ARSA). He graduated from the George Washington University in 2004 and earned a Master of Public Policy from the College of William and Mary in 2009. For more information visit