Working Under Supervision
One way that non-certificated persons (non-A&Ps) can perform maintenance on U.S.-certificated aircraft is under the supervision of a person with a mechanic or repairman certificate. A recent discussion at an NBAA maintenance committee meeting got me thinking on what “under supervision” exactly means.
The verbiage for this is in the federal regulations. 14CFR43.3(d) states, “A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.”
The regulation doesn’t state how many non-certified personnel a person holding a mechanic or repairman may supervise. What is too many? 10? 20? 50? It’s left up to the judgment of the repair station, FBO and their supervising FAA inspectors.
Now consider the part that says, “…the supervisor is readily available, in person, for consultation.” Technology has changed a lot since this rule was written. Would it be within the rules for a non-certificated person to perform maintenance on an aircraft if the person supervising him or her is not physically there? For example, if a pilot is away from his or her home base, and no mechanics are available to perform maintenance on their aircraft, could they perform that maintenance? Today’s technology would allow a mechanic or repairman to supervise the maintenance action via Skype, FaceTime or other similar live video messaging service. The mechanic could view each step taken and ensure all procedures were properly performed. The pilot could consult with the mechanic or repairman during the task. Torques and safety wiring could be witnessed and inspected. One could argue that this type of video “supervision” might be more thorough than that at a repair station where the supervisor might not be around to witness every step the non-certificated person performs.
So, what are your thoughts? Is this embracing technology? Or is it pushing the limits of interpretation? We’d like to hear your thoughts!
Thanks for reading,