Avionics News December 2020 - 24

THE VIEW FROM WASHINGTON
Continued from page 17

Administrative Procedure Act, is still in place today
and is fundamental in all our rulemaking activities, and
why we object to " rulemaking by policy. " For 75 years,
the departments and independent agencies within the
executive branch of the U.S. government have been
" regulated " on when, where, and how they regulate the
public by the Administrative Procedure Act.
Let us jump back to 1938 and the civil air regulations:
title 14 of the Code of Federal Regulations. While the
words of the regulations are familiar, the organization
was different. Today's Part 43 was yesterday's Part 18;
Part 145 was Part 52; and Part 65 was Part 24. And
for the record, yes, the classification of repairs and
alterations as " major and minor " dates back to 1938!
You have to appreciate the simplicity of the
regulations in 1938. While there were specific equipment
requirements for each of the 12 classes of repair stations,
the general requirements were pretty basic:
52.400 General. Every certificated aircraft repair
station shall show the following facilities and
equipment:
52.4000 (a) A stock room properly set up to insure
the proper segregation of materials.
52.4001 (b) A proper system of keeping records of
all work.
52.4002 (c) Facilities and equipment for making
small drawings. 52.4003 (d) Suitable housing
facilities adequately heated and lighted.
52.4004 (e) Adequate certificated personnel
qualified to perform or supervise the type of work
involved.
The requirement for " adequate certificated personnel "
took us to Part 24, which stated that " no person shall
engage as a mechanic in the navigation of aircraft while
under way or be directly in charge of the inspection,
maintenance, overhaul, or repair of aircraft, aircraft
engines, propellers, or appliances (except parachutes),
unless said person is possessed of a valid airman
certificate certifying his competency to serve in such
capacity. "
The original mechanic certificate was limited to an
aircraft mechanic rating and an aircraft engine mechanic
rating. In 1944, there was a proposal to revise the
mechanic ratings to nine category ratings and two class
ratings (first and second class). The nine category ratings
included:
a.	 Maintenance and service - light aircraft.
b.	 Repair and overhaul - light airframes.
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c.	 Repair and overhaul - light engines.
d.	 Maintenance and service - heavy aircraft.
e.	 Repair and overhaul - heavy airframes.
f.	 Repair and overhaul - heavy engines.
g.	 Propellers.
h.	 Instruments.
i.	 Radio.
That proposal failed.
Recognizing the limitations of a mechanic certificate,
the CAA added a limited mechanic certificate with
a propeller or aircraft appliance rating in June 1945.
According to the Federal Register notice, " A mechanic
certificate with a propeller or aircraft appliance rating
may be issued by the administrator of Civil Aeronautics
to an individual who is employed and designated by
either a manufacturer holding a currently effective
propeller or aircraft appliance production certificate or
by an applicant for a repair station certificate with a
propeller or aircraft appliance rating. The individual must
be in direct charge of the inspection, overhaul, or repair
of propellers or aircraft appliances and his experience and
employment record must indicate that he is competent
to engage in such activity. The individual to whom a
certificate is issued shall exercise the privileges of his
certificate only with respect to the work performed for
such manufacturer or repair station and through the use of
facilities provided by the manufacturer or repair station. "
The limited mechanic certificate was continued until
1952 when the CAB established the requirements for
the issuance of mechanic and repairman certificates and
ratings, delineated the privileges of each certificate, and
established the basic operating rules for the holders of the
certificate.
Subpart B of Part 24 contained the certification rules
for the issuance of a repairman certificate. As stated in
section 24.100:
§ 24.100 Classification. There is hereby established
a classification of airman, known as a " repairman, "
who (a) possesses special qualifications to perform
inspection, maintenance, overhaul, or repair of
aircraft, aircraft engines, propellers, or appliances,
(b) is employed by a certificated repair station
or an appropriately certificated air carrier for a
particular job requiring such special qualifications,
and (c) is recommended for certification by such
employer to the administrator or his authorized
representative.
Clearly, the 19th century French writer, Jean-Baptiste
Alphonse Karr, captured our findings: " The more things
change, the more they remain the same. " Or, better yet, to
quote Berra, " It's déjà vu all over again. " q
Avionics News December 2020

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