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The Unknowable

I wish to pose some counterpoints to your article (see AM, July, p. 4, ‘Unknowable: The Number of Licensed Mechanics’). The article is centered around the issue of aviation maintenance safety, with regards to the “work” being performed on type certificated product and components being done by those persons authorized under 14 CFR Part 43.3.

To say that the work is being handed off to “contract repair stations, where uncertificated mechanics make up a greater percentage of the workforce” equates to sub- standard maintenance or inspection is disingenuous! 14 CFR 145 Facilities, FAA DAS, and FAA SFAR 36 Facilities must all meet the same performance rules as the “certificated mechanics” 14 CFR Part 43.13a, 43.13b or 43.13c, plus the applicable sections of 14 CFR Part 91, and the design data rules of 14 CFR part 21 for which the product was certificated under. I readily admit that “certificated mechanics” have gone through a more rigorous training curriculum than the more narrowly certificated repairmen, but that does not preclude the work being done to the same regulatory standards.

I have not included 14 CFR Part 43.17 [Canadian AMT], or like organizations, nor have I included JAA, and EASA 145 equivalent certificated persons, who because of bilateral [agreements] can return to service under a form 1 [equivalent to a form 8130-3] product, appliances, and parts determined to meet the type certificate holders instructions for continued airworthiness. So is the FAA also responsible to know the available “certificated personnel” worldwide? A daunting task indeed!

I would not worry so much about levels of “certificated mechanics” but, rather, the availability of well-qualified maintenance organizations and training institutions. I see the decline of the one type of “certificated” individual [i.e., mechanics] because these skill sets are being diversified through “repairmen,” or these “mechanics” are moving up the skill set to other aviation responsibilities i.e. management, additional delegations, IA DMIR’s, DAR-T/F, etc. Therefore I see the migration toward other “certificated” venues, rather than an extinction or skill loss, or lower airworthiness.

Dominick DaCosta
FAA Licensed Mechanic
FAA DER-T & DAR-F

Surge Damage
I would like to disagree with the surge damage article (AM, August, p. 26, ‘Surge Damage’).
It has been my experience, working on mostly Boeing and Lockheed aircraft with RR, P&W, and GE engines, that the maintenance manuals of these manufacturers are very clear on what to do in the case of an engine surge/stall event.

Although this inspection is not called out in ATA chapter 05, ATA chapters 71 and/or 72 have specific detailed instructions of what must be done in order to return the aircraft engine to revenue service. I’m not sure which aircraft or engine manufacturers that Mr. Tasseron is referring to, but I see no reason to remove each engine from service that has had a surge/stall event and tear it down for a detailed inspection.

This type of action has rarely been necessary in events with which I have been involved. After correcting the cause of the surge/stall and performing the inspections called out, most engines have gone on to live a long and healthy life. If a surge/stall has caused detrimental damage to an engine, it has always been evident during inlet/exhaust or borescope inspections and/or engine ground run up. I do not see where an industry wide change is needed.

Jeff Armstrong
Fleet Controller, ATA Airlines