Avionics News February 2020 - 17

FREQUENTLY ASKED
QUESTIONS
United States

Appropriately rated
technician
The following information is from the Federal Aviation
Regulations and Federal Register 77 FR 30070.

Question:

Does a technician need a repairman's certificate
in order to return to service a transponder (§
91.413) or altimeter check (§ 91.411)?

Answer:

No.
If all they are doing is "check and inspect,"
then yes, a mechanic is appropriately rated.
But if there is any adjustment to the altimeter
(considered a repair), then yes, they would need
an instrument repairman rating since instrument
repair is excluded from a mechanic's privilege.
As an explanation:
14 CFR 145.157 Personnel authorized to
approve an article for return to service.
(a) A certificated repair station located
inside the United States must ensure each
person authorized to approve an article for
return to service under the repair station
certificate and operations specifications is
appropriately certificated as a mechanic
or repairman under Part 65.
The language of paragraph 145.153(b)(1) was
revised Aug. 12, 2014 (79 FR 46971). Prior to
2014, the regulations simply required supervisors
and RTS inspectors to "be certificated under
Part 65". The August 2014 rulemaking added
the "be appropriately certificated as a mechanic
or repairman under Part 65" language. As part
of the NPRM, the FAA explained that "The

appropriateness of the certificate is based in the
privilege of the mechanic or repairman certificate
issued under Part 65 subpart D or E (77 FR
30070)."
By looking at 14 CFR 65.81, which includes
the general privileges and limitations of a
certificated mechanic, we see that a certificated
mechanic may perform or supervise maintenance
on an aircraft for which they are rated but
excluding major repairs to, and major alterations
of, propellers, and any repair to, or alteration of,
instruments.
As such, a mechanic is not appropriately
certificated for "major repairs to, and major
alterations of, propellers, and any repair to, or
alteration of, instruments."
So back to the original question: Does a
technician need a repairman's certificate in order
to return to service a transponder (§ 91.413) or
altimeter check (§ 91.411)?
First, both § 91.411 and § 91.413 require
tests and inspections. Test and inspect is not
part of the definition of repair or alteration;
therefore, the prohibition to repair or alteration
of instruments contained within 14 CFR 65.81
would not be applicable and a certificated
mechanic working for a properly rated repair
station would be "appropriately rated" to test
and inspect either the altimetry system or the
transponder system.
Second, regarding § 91.413 ATC transponder
tests and inspections. The transponder is a radio.
As such, a mechanic would be "appropriately
rated" to not only perform the test and inspection
but could also repair the transponder system.
Finally, regarding § 91.411 Altimeter system
and altitude reporting equipment tests and
inspections. The altimeter is an instrument. As
such, a mechanic would be appropriately rated
to test and inspect the system to determine pass
or failure. Should a discrepancy exist that would
require a repair to an instrument (including
an adjustment), the mechanic would not be
appropriately rated. q

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Avionics News February 2020

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