Part 43 and It’s Managerial Implications
When we talk about aviation maintenance, we speak of repairs, alterations and the act of preserving an aircraft in its original airworthy condition. An airworthiness certificate is given to an aircraft after countless hours of design, research and testing. And in order to keep this certificate valid; an aircraft must be maintained in accordance with a certain specification. These specifications are brought to us by the Federal Aviation Administration. The Federal Aviation Regulation part that spells out these rules is found in part 43. These acts are performed to prevent harm to pilots, passengers, and even innocent bystander that may become involved in an incident due to improper maintenance. As maintenance managers, we must understand these implications that must be followed, so that we may ensure that our facility is performing to the standards set upon us by the FAA.
The Federal Aviation Act of 1958 allowed for the regulation of air commerce in such manner as to best promote its development and safety (Adamski and Doyle 4-8).
This brought about a rulemaking process to insure that all aspects of aviation could be regulated in a way as to provide maximum safety to all. This was the initial birth of 14 CFR 43, or Part 43 of the FAR’s which is ironically titled Maintenance, Preventive Maintenance, Rebuilding, and Alteration (Federal Aviation Regulations [FAR], VII, 1997).
This part has been primarily written for individuals or repair facilities that may be performing some sort of maintenance, preventive maintenance, rebuilding and or alterations. It refers to a number of qualified individuals that include holders of mechanic, repairman, air carrier, or even a pilot’s certificate, that may perform an array of the procedures listed in this part. So when it comes down to it, we as maintenance managers must know and live by FAR prt. 43 in order for our employees to work and perform in a legal and safe manor.
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As the title implies, this part of the Federal Aviation Regulations prescribes rules of governing the maintenance, preventive maintenance, rebuilding, and alteration of any aircraft having a U.S. airworthiness certificate; any foreign-registered aircraft used to carry mail under pt.121, 127 or 135; and airframe, aircraft engines, propellers, appliances, and components of such aircraft. This is exclusive of aircraft holding an experimental airworthiness certificate, unless the aircraft was previously issued a different kind of certificate (FAR, 1998, p.11).
So if we were working as a manager in the U.S., this part would definitely apply to our facility, which repairs and maintains aircraft found in this category.
Part 43 also identifies persons that are authorized to perform and return an aircraft, airframe, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration. “The approval for return to service will be made in accordance with FAR 43.9(a)(5).
A&P mechanics are authorized to conduct and approve for return to service aircraft inspected in accordance with the owner or operator’s program under a number of options. It can be done under performance rules for inspection to which determines whether an aircraft meets all requirements for airworthiness. Or by an inspection program under FAR 43 App. D. All work must be done in accordance with “airworthiness limitations” (King 38).
This means that a manager must know who is performing the prescribed work in his shop, and make sure that any work completed is done in a specific, approved fashion.
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A manager must know what types of inspections are being performed to aircraft in his/her shop. Individuals holding the appropriately rated certificate can only perform those inspections in which they are allowed to do. Managers must be fully aware of what part of the FAR’s their shop is performing inspections under. Different parts of the regulation require adherence to specific rules found, but not specific to Part 43. If an aircraft comes in for an annual inspection, the manager must have an IA available to do the inspection, but if the inspection is a 100-hour, a certified mechanic is only needed in order to return the aircraft to service. A manager must realize that someone not certified cannot work under a certified mechanic when doing a 100-hour inspection. So the mechanics helper cannot perform the inspection during times of great workloads. This puts a constraint on the manager to hire and keep the required individuals needed for the type of inspections being performed at his/her facility.
Next, the part goes into record keeping aspects after performing the above procedures. Great detail is taken in explaining and recording the work in order to prevent confusion or problems in record keeping. A manager’s job would be to make sure that an employee is adhering to the proper procedures in signing off the work performed. But now a new rule has been proposed to the FAA from the Aviation Rulemaking Advisory Committee that takes the burden off the backs of a technicians, and managers, and rather holds an owner/operator accountable for any such entries similar to the current maintenance falsification rule in FAR 43.12 (Hertzlerm, 1997, p.1).
Appendix A of this section explains the exact examples of what is meant by major alterations, major repairs, and preventive maintenance for both the airframe and powerplant. In this case, managers must be fully aware of this section. Similar to inspections, different individuals may sign an aircraft back to an airworthy condition after a repair or alteration. The first thing that must be done is to figure out if a repair or alteration is major or minor. When a job is delegated between the two, the manager can figure out whether or not he/she will need specific individuals to return the aircraft back to service. A manager must be prepared and know the procedures of a repair before it comes into the shop. A considerable difference in paper work must be accomplished dependent on the repair or alteration. We must understand that a major repair or alteration takes an approval of the FAA in order to be returned to service after the repair or alteration has been completed. This is where a manager must be as cooperative to the local FAA inspector so that when the time comes, headaches may be eliminated when problems exist.
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Appendix B states the procedures that must be followed after the completion of a major repair or alteration. Again, the manager must be aware of the appropriate paper work associated with a specific repair. There are for like a 337, which must be completely filled out and sent to the FAA within a specific time after the work has been completed. Again, if procedures aren’t followed to a key, the manager and as well as the facility is looked down upon by the FAA, and future problems may exist do to improper procedures followed. Lastly, Appendix D states the scope and detail of items to be included in annual and 100-hour inspection. Though some items in App. D are not applicable to all aircraft, it gives a minimum checklist to follow during the above inspections. In this case, managers must observe and make sure that their technicians are using at least the minimum checklist provided by this part. We must understand that different aircraft will be coming in with different types of inspection programs, and different systems, but as long as we perform the minimum requirements, we stay in the clear.
A maintenance manager has many tasks to delegate and control. Tasks that must be accomplished by these individuals stem from controlling shop practices, dealing with customers, and mostly conforming to FAA standards. When something goes wrong in the shop due to poor maintenance, the manager must use his/her skills and intuition in order to fix and control the situation. But mostly, the maintenance manager must adhere to FAA regulation, especially Part 43, which strictly deals with the operations that must be performed in the shop, under a manager’s ultimate authority.
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Bibliography
References
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FederalAviation Administration. (1998).
Federal Aviation Regulations and Aeronautical
Information Manuel. New Castle, WA: ASA.
Hertzler, J. V. (1997).
New Record Keeping Requirement. Aviation Maintenance
Regulatory Report. Retrieved March 10, 1999 from the World Wide Web:
http://avtrak.com/publications/7-31.htm
King, F. H. (1986).
Aviation Maintenance Management. Carbondale, IL: Southern
Illinois University Press.