Avionics News September 2019 - 18

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INTERNATIONAL NEWS
Continued from page 17

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SOUTH PACIFIC

News & Regulatory Updates

Surrender of Austasia Aviation Centre Pty. Ltd. Part
147 certificate.
Numerous amendments to course information
and additional course approvals (including course
deletions) at various locations throughout the
document.

New Zealand
Australia
The Civil Aviation Safety Authority of Australia
published version 6.0 of Advisory Circular 147-02:
Approved Part 147 training organizations.
The changes contained in the July 2019 revision include:
*	 Removal of the Aircraft Maintenance and Training
School B.V (AM&TS).
*	 Addition of courses not previously provided by an
approved MTO at various locations throughout the
document.

FREQUENTLY ASKED
QUESTIONS
United States

Overhaul
The following information is from a Federal
Aviation Administration legal interpretation
dated Aug. 28, 2015.

Question:

Can an aircraft component part be recorded as
overhauled if it is not subjected to disassembly,
repair, assembly or testing?

Answer:

Yes, provided a mechanic follows the entirety of the
overhaul process and that, during the overhaul, does
not discover that additional repairs are necessary.
In an Aug. 28, 2015, legal interpretation, the FAA
reiterated a previous 1991 legal interpretation on this
subject. The following is extracted from the 2015
interpretation:
Section 43.2(a)(1) & (2) sets out the requirements
for describing a part as "overhauled." Under §
43.2(a)(l), a part may be described as overhauled
when, "using the methods, techniques, and
practices acceptable to the administrator, (the

18

avionics news

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september

2019

The Civil Aviation Authority of New Zealand published
Revision 5 of AC 43-14: Standard Design Changes -
Acceptable Technical Data.
This revision amends the title of the advisory circular
and incorporates the following appendices.
*	 Appendix 2: Installation of FAA TSO-C126
( ) ELTs.
*	 Appendix 13: Installation of stand-alone ADS-B
systems.
*	 Appendix 14: Temporary mounting of lightweight
cameras. q

part is) disassembled, cleaned, inspected, repaired
as necessary, and reassembled ..." Section
43.2(a)(2) further requires a part to be "tested
in accordance with approved standards and
technical data, or in accordance with technical
data acceptable to the administrator ..."
You ask whether § 43.2 requires disassembly or
repairs if the design approval holder's overhaul
instructions or other data acceptable to the
administrator expressly requires only cleaning
and inspection.
The answer is that, just as a mechanic is
not required by the term "disassembly" in
§ 43.2(a) to destroy an aircraft part, neither
is a mechanic required by the phrases
"disassembly," "reassembly," etc., to take
maintenance action beyond what is provided
in the overhaul instructions. Of course, this
interpretation assumes that a mechanic follows
the entirety of the overhaul process and that,
during the overhaul, does not discover that
additional repairs are necessary. In all cases,
a mechanic may not label a part as overhauled
if that mechanic performs less than the entirety
of the maintenance process acceptable to the
administrator.
It is important to note that while the regulation
(section 43.2) does not reference an overhaul manual,
this legal interpretation does highlight that the work
was done following "overhaul instructions" that have
been deemed acceptable to the administrator. q
Avionics News September 2019

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