Repairman Inspection

[Marc Zeitlin]

There is no reason why we could not take a series of knowledge tests to qualify for a repairman certificate. After all, we pay to take a computer based knowledge test so there is a financial incentive to read part 43 and not blow multiple test attempts. So passing some subject matter tests and an 8 hour course should get the job done.

I'm going to respectfully disagree. I've built a Quickie Q2 and a COZY MKIV. I currently make a living working on canard composite aircraft, and I'm an A&P and do Condition Inspections on other folks' aircraft (RV's included). You can see my CV at my BA website, if you care about my qualifications to make the following statements.

I can barely familiarize a non-builder owner with a Long-EZ/Varieze/COZY/Berkut aircraft in 8 -10 hours, if they hang around the whole day while I'm doing the CI, are interested and ask a lot of questions. It's a brief overview of all the aspects of the plane, at best.

The owner should be intimately familiar with the aircraft plans and build process - that could take 100 hours of study, easy. The owner should be intimately familiar with all of the aircraft's newsletters, updates, mandatory changes, etc. That can take another 100 hours of study (both studies while poking at the airplane so that the owner can see what the words mean and apply to). Next, as you say, the owner should be familiar with the Part 43 Appendix D requirements for inspections, as well as any aircraft particular inspection requirements - I've got a checklist I use that includes over 250 individual items to check for each aircraft.

Merely understanding and memorizing the words in Part 43, Appendix D is about 1% of what's required to be qualified to do a REAL Condition Inspection on these aircraft. Learning the rest of the FAA CFR requirements (Not FAR, Ron :-) ) might be another 1 - 2%. Every one of the E/AB aircraft types has it's own knowledge requirements - someone would have to put together a complex curriculum that would require both class learning as well as hand's on work for every aircraft type. This would be 100's of hours (hence the length of time it takes to get an A&P, much less an IA) and would be far more than some multiple choice computer test.

With all the experience I've got in composite aircraft, if I purchased a rag and tube plane and someone told me that I could learn everything I'd need to know to do a CI on one (even just MY plane) in 8 - 16 hours, I'd say they were deluded, and if I thought I was competent to do so, I'd be deluding myself.

My $0.02.

[rwanttaja]

Have to say I pretty much agree with Marc, here. It's not an issue of knowledge (which is instantly available these days), it's a matter of practical experience. Moreover, it's the ability to *merge* the knowledge and experience when things get a bit hinky.

Oh, for sure, I'd love to have a Repairman Certificate for my Fly Baby so I don't have to depend on an A&P every year. I have been the sole maintainer for one Fly Baby or the other for ~25 years or more. I have removed and replaced cylinders, generators, starters, exhaust systems, rewired electrical systems, revamped the instrument panels, all stuff that requires an A&P in the certified world. I pulled the engine out of my VW "Thing" twenty years ago and rebuilt it.

But do I think I'm qualified to judge the condition of a C-85? No, in all honesty, not really. Frankly, I'm not all that comfortable working on the engine; I sweat just pulling the spark plugs.

Now, if I took a one-week course on small Continental engine servicing, I'd feel a LOT more confident. But we'd still have to factor in the overall practical experience. On another thread, I mentioned how my most-recent A&P was not long out of training. He's been busy the last three years, looking at a lot of airplanes and delving into a lot of engines. This obviously gives him a much better basis for evaluating the condition of most aircraft.

Used to share a hangar with a friend who built an award-winning Long-EZ. Every year, he'd push my Fly Baby outside while he disassembled his EZ for the condition inspection. Then he'd button it back up...except for the cowling. He brought in an A&P every year to inspect the engine. He built every piece of that airplane, but felt better getting a true expert to look at the engine.

In the Ex-AB world, builders can receive the Repairman Certificate to inspect their airplane. It's a precious, well-earned privilege. But in all honesty, building an airplane does NOT teach you how it wears over time...especially the engine, which for most builders is just a big blob they bolt in place and hook hoses and wires to. For example, few builders have to perform internal inspections and repairs on magnetos during the construction process, but the Repairman Certificate entitles them to do so.

Please understand, I fully support the current policies for Ex-AB repairman certificates. Yes, our rate of "Maintenance Error" is greater than the Certified world (about the same as Builder Error, actually) but the percentage of occurrence in the accident lists is still pretty low.

But I was pretty surprised about the institution of the Light Sport-Inspection Repairman Certificate as part of the Sport Pilot reforms. At the time, I was tasked to write a summary of the new rules for KITPLANES magazine. I read the LS-I provision...and couldn't believe it. I actually called the FAA to get the specific confirmation that the 16-hour course would enable an owner to inspect his or her ELSA airplane.

Do I support extension of the program to Ex-AB aircraft that meet the 14CFR Part 1 Light Sport Aircraft definition? I do, and would take the required courses like a shot.

But...like my friend, I'd probably still hire an A&P to look over the engine every year.

Ron Wanttaja

[dusterpilot]

I took the 16-hour course and hold the light-sport aircraft repairman certificate with an inspection rating and perform the annual condition inspections on the two light-sport aircraft I own. (The N-numbers an individual is authorized to inspect are specified on the certificate.) The 16-hour course will NOT teach you everything needed to perform the inspection. The bulk of the course content is focused on the FAA regulations, the aircraft's required paperwork, and how to legally record the inspection in the logs. Very little of the course covers actual hands-on inspection procedures and techniques. Some of it is hands on, but it is like reading the index of the the encyclopedia you need to know. Armed with the certificate, the determination to seek out and learn more about your aircraft, and the common sense to call in an expert when you're smart enough to recognize you're in over your head, the LSA Repairman certificate is a great thing.

[1600vw]

ELSA regs allow one to take a 16 hour course and become eligible for a Repairman Inspection Rating, and that allows you to perform the annual condition inspection on any Experimental Light Sport Airplane you own. Such a course is outlined here:

http://www.sportair.com/workshops/1R...-Airplane.html

It would be exceptionally wonderful to be able to do something similar for EAB (Experimental Amateur Built) aircraft, to include EAB aircraft that you did not build yourself. How would we start pursuing something like this? Is EAA willing to initiate this?

Thanks,

-Dj

I took the 16-hour course and hold the light-sport aircraft repairman certificate with an inspection rating and perform the annual condition inspections on the two light-sport aircraft I own. (The N-numbers an individual is authorized to inspect are specified on the certificate.) The 16-hour course will NOT teach you everything needed to perform the inspection. The bulk of the course content is focused on the FAA regulations, the aircraft's required paperwork, and how to legally record the inspection in the logs. Very little of the course covers actual hands-on inspection procedures and techniques. Some of it is hands on, but it is like reading the index of the the encyclopedia you need to know. Armed with the certificate, the determination to seek out and learn more about your aircraft, and the common sense to call in an expert when you're smart enough to recognize you're in over your head, the LSA Repairman certificate is a great thing.

Lets look at the original post. This person would like to take an EAB that has been already built and get a Repairman's certificate. This certificate was more then likely given to the original builder so he could do his own Condition Inspections. No one else can get another repairman's certificate for that airframe or airplane. It will now take an A&P to do this condition inspection. If the new owner is an A&P he or she is set. If not the new owner will have to hire this out to an A&P.

Tony

[Marc Zeitlin]

Lets look at the original post. This person would like to take an EAB that has been already built and get a Repairman's certificate. This certificate was more then likely given to the original builder so he could do his own Condition Inspections. No one else can get another repairman's certificate for that airframe or airplane. It will now take an A&P to do this condition inspection. If the new owner is an A&P he or she is set. If not the new owner will have to hire this out to an A&P.

Are you this obtuse on purpose?

It is fairly obvious that the OP understood what the regulations currently ARE (which is all that you've restated) - everyone else understood this. What he was asking was whether it would be possible to CHANGE the E/AB regulations so that they more closely resembled the ELSA regulations, which he also stated. That is what the rest of us have been discussing - the notion of changing the E/AB regs to be similar to the ELSA regs, and whether that's a good idea or not.

[rwanttaja]

Are you this obtuse on purpose?

It is fairly obvious that the OP understood what the regulations currently ARE (which is all that you've restated) - everyone else understood this. What he was asking was whether it would be possible to CHANGE the E/AB regulations so that they more closely resembled the ELSA regulations, which he also stated. That is what the rest of us have been discussing - the notion of changing the E/AB regs to be similar to the ELSA regs, and whether that's a good idea or not.

For someone who claims that he doesn't argue, Tony is sure doing a bang-up imitation of it. That's three posts he's made on this thread, containing essentially the same statement (e.g., one cannot receive a repairman certificate for an EAB he didn't build) while completely ignoring the original poster's actual question....

Ron Wanttaja

[Greeneyes2141]

For someone who claims that he doesn't argue, Tony is sure doing a bang-up imitation of it. That's three posts he's made on this thread, containing essentially the same statement (e.g., one cannot receive a repairman certificate for an EAB he didn't build) while completely ignoring the original poster's actual question....

Ron Wanttaja

If all those A&Ps out their would be more willing to take on someone's home-built, EAB that he or she didn't build it would be so nice, thanks, jw.

[Mike M]

If all those A&Ps out their would be more willing to take on someone's home-built, EAB that he or she didn't build it would be so nice, thanks, jw.

Very true. Consider. They may be willing to take on the aircraft but not the owner.

First. Aircraft. Not all E-AB are engineered professionally and competently. Not all are built exactly to the engineer's design. Not all have been maintained to that design through the years and subsequent owners. My limited experience indicates there are basket cases out there with years, perhaps decades of pencil whipped inspections, and some of them are E-AB. When an A&P agrees to perform a condition inspection and finds one of them, we arrive at...

Second, the owner. Operator, sure. Not all of us are maintainers. Operators know it flew into the inspection. They know what they've done to it to keep it going. It should fly out. But. What about the stuff found wrong? The ops limits contains the magic phrase for a successful inspection, but nothing about signing off a "NOT in condition" result. So. Will the owner pay for the inspection alone, up front? Does the owner want the A&P to fix until it passes? Or tie up A&P's shop space until owner gets parts and time to do it? Finish inspection, no signoff, watch owner button up and angrily fly away in an unsafe aircraft (ok, maybe ferry permit, but really?) then race to the bank before the check is voided?

Pretty sure there are more reasons to refuse some people's request to perform a CI. Personality alone, perhaps.

A qualifying path for a make&model or airframe-specific E-AB Repairman certificate is a logical outgrowth of that LSA provision. Yep. Oughta be on the to-do list after abolishing the 3rd class medical?

[1600vw]

I laugh at the thought of trying to change this. It will be like what is happening with the third class medical. It will get ignored on someones desk until its forgotten. If its not forgotten it will just be denied. It takes an A&P IA to do an Annual on a GA airplane. It takes an A&P to do a condition inspection on an EAB aircraft. Jusy why does the FAA believe it only takes a repairman's certificate to do a Condition Inspection on an LSA that was factory built. The repairman's certificate is only issued to one builder but now it can be issued to any owner of an LSA. Sounds like a double standard to me. I am amazed the FAA does not say one needs an IA for this inspection on a LSA being its factory built. Why not a Repairman's certificate to do an Annual on a GA. That is what I would be yelling about. If an LSA owner can do this inspection with a repairman's certificate, why not a GA airplane owner. Both are factory built.

This was the point I was trying to make. But I guess I needed to spell it out. Not arguing but discussing. I argue you discuss. I see how it is.

Tony

[WLIU]

"They may be willing to take on the aircraft but not the owner."

I see a lot of this. As described above we are seeing second owners of E-AB's with unrealistic expectations.

As for the experience aspect of a Repairman Certificate, your mechanic fresh out of A&P school does not match the ideal characterization of the inspector we want that multiple posts above speak to. Everyone has to start somewhere. And while a segment of the owner popualation seem to take the low road on maintenance, most know that they are going to be the first ones to the scene of an accident. So your average owner, like your average A&P, is motivated to look for issues and take care of them. So please do not take the worst case and use it as the standard for comparison. If we did that for other aviation tasks we would never get in the airplane and fly.

The most important part of the training is knowing when a task is beyond your current skill level and how to ask for help. Holders of Repairman Certificates are not prevented from asking for advice and further instruction from more experienced individuals.

We see certificated A&P's who are awful, and A&P's who are genius craftsmen (persons?). I expect that we see the same in the current builder Repairman population and would see the same in any future Repairman population if there becomes the opportunity for non-builder owners to obtain a Repairman Certificate. Its neither magic nor rocket science. We all start with zero experience. Its what you do next that counts. And any training will provide guidance about that.

Best of luck,

Wes
N78PS