AVIATION SAFETY NEWSLETTER
Thought for the month..... "It is better to be careful 100 times than to be killed once"
Got a paperwork headache? Take MIDO…. So you think that you have it bad trying to satisfy
the FAA with all the rules and regulations that are applied to aviation. Try playing on my side of the fence for
a while. Ask anyone what they expect from an FAA inspector regarding compliance with the Federal Aviation Regulations
and I'm sure that 99.99% would say total compliance. I can't fault this kind of answer. If the same question
were put to me with regard to the police or another regulatory type government employee, I would probably say the
same. After all shouldn't we expect a higher level of compliance from those people who are charged with enforcing
the rules? You bet we should. Ignorance of the spirit of the rule for those people who are supposed to assure
compliance just doesn't fly (pun intended). For the average airplane owner comprehension of the rules is a challenge,
let alone compliance with them. Fortunately there are times when a compassionate inspector may give extra time
and attention to explaining how a person fell short of rule compliance instead of processing the enforcement.
Imagine my dilemma when I received a rebuilt component from the manufacturer that came out of our flying club's airplane and the documentation that came with it didn't satisfy §43.9. For those who aren't familiar with this regulation it is the "Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records…". That rule requires the record to include the name of the person who worked on the article, the date of completion, and the signature and certificate number and type of the person approving the article for return to service. The documentation included everything but the certificate number and type of the manufacturer. Lucky for our club I know who to call and what to ask for when this sort of thing happens. My first call went to the FAA office that oversees manufacturers of aviation products. In this case it is the Manufacturing Inspection District Office (MIDO) who has jurisdiction in that area of the country. Unfortunately manufacturers are governed by a different set of regulations than "repair" facilities and MIDO's govern to those other set of regulations.
Manufacturers are permitted to rebuild and inspect their products (under Part 43 which is a repair rule). Manufacturers and MIDO's know that they are allowed to perform limited work in accordance with Part 43 but the nuances of the repair rules are not as clear to them, mainly because manufacturers and MIDO's focus on manufacturing rules. Rebuilding is considered a manufacturing process. But that doesn't relieve the end user of compliance with, in this case, §43.9 that includes rebuilt articles.
As of this writing, resolution of my problem is (still pending). What can the average mechanic or owner do to fix these kinds of problem? For starters you can do what I did or you can make your first call to the place that repaired/rebuilt your component. Explain to them what your dilemma is (compliance with maintenance recording rules) and let them know what you need to correct it. I know that you won't always get full satisfaction on the first call, I didn't. If you can't get what you need then your next call should be to your local Flight Standards District Office. Talk to an inspector and try to get them to act on your behalf with the repair facility. Sometimes a call from an inspector who knows all the nuances of the situation can better influence the repair facility to do what is right. Not doing anything else after the first attempt to correct the problem isn't the answer. When you are out of compliance in the beginning it doesn't change just because you haven't resolved the problem. You only have to be "killed" once in this business to be on the losing end of the law.
Florissant Valley College
3400 Pershall Rd., St. Louis 63135
GPS: Beyond Direct
AOPA Air Safety Foundation
7 - 9 P.M.
The Successful Cross Country
9:30 A.M. to 2:30 P.M.
Mt. View Airport
Mt. View, MO. (Vaughn Hangar)
Aeronautical Decision Making
7 to 9:00 P.M.
Mid-Coast Training Center
18 Mark Allen Drive
St. Louis Downtown Airport
8th Annual Helicopter Safety Seminar
9 A.M. to 4 P.M
Register at http//faasafety.gov for E-mail notification of safety seminars in the St. Louis District.
Good Maintenance is no accident.
Airworthiness Safety Program Manager
1-800-322-8876 extension 4830