AOPA Pilot Magazine - December 2024 - 90

RUDDER & WRENCH
TOP OFF
YOUR PLANE &
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The FAA seems to be saying it is no longer
sufficient for the supervisor to ensure
that the work has been done properly and
that any mistakes are corrected before the
aircraft is approved for return to service.
Now, apparently, the supervisor is required
to be continually present to watch the
work like a hawk and intervene if necessary
to make sure no mistakes are made.
I cannot believe this is what the origi2%
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nal authors of 43.3(d) intended when they
wrote the rule 60 years ago. The rule they
wrote has always been understood to grant
the supervisor discretion to provide supervision
" to the extent necessary to ensure
that it is being done properly, " and that
almost never necessitates continuous surveillance-much
less continuous physical
presence-of the work from start to finish.
Consider the task of changing a cylin*
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der on a reciprocating aircraft engine. This
is one of the most critical and invasive tasks
that mechanics are called upon to do, the
A&P equivalent of open-heart surgery. Yet
even a task as risky as this doesn't warrant
full-time surveillance. If I were supervising
a cylinder change, I might want to be physically
present at four points in the process:
(1) removal of the piston pin, since they can
be pretty stubborn; (2) installation of the
rings on the piston, to ensure that the stack
up is correct and the compression ring end
gaps are within specs; (3) tightening of the
through bolts and hold-down studs, where
proper torque, thread lubrication, and various
other factors are absolutely critical;
and (4) final inspection after all the work
is done, to ensure that the cooling baffles
are correctly installed, the spark plug leads
are properly secured and protected from
chafing, and so on. If the cylinder replacement
requires four hours of work, the
critical phases that require close supervision
might total 30 minutes, tops.
Now, if this same apprentice mechanic
had performed cylinder replacement
under my supervision a dozen times before
and I were convinced he knew what he
was doing, the amount of on-site supervision
needed to ensure the work was being
done properly would be significantly less.
Yet the Moss Interpretation seems to say
I'd need to be watching the apprentice
mechanic's work for the entire four hours.
That's absurd.
90
AOPA PILOT / December 2024
Consequences
Interestingly, not everyone I've spoken
with disagrees with the Moss
Interpretation. I've heard from some
aircraft owners who say, " I don't want
anyone but licensed A&Ps swinging
wrenches on my airplane. " I've also
heard from some FSDO inspectors who
seemingly can't wait to bring enforcement
actions against mechanics who fail
to conform with this new notion of what
supervision means. But I'm convinced
that if the Moss Interpretation stands,
the consequences will be devastating to
aircraft owners and maintainers alike.
Here's why.
Most aircraft maintenance facilities-whether
GA or airline-employ
uncertificated mechanic-apprentices
who work under supervision to fulfill
the 30-month practical experience
requirement to qualify for the A&P certificate.
If the Moss Interpretation is
permitted to stand, then each such
mechanic-apprentice would require fulltime
supervision by an A&P who would
be required to continuously watch every
phase of the trainee's work and be prepared
to intervene at any moment. The
supervisor would be precluded from
using any electronic means to perform
this surveillance, so would literally have
to be physically looking over the apprentice's
shoulder. This kind of continuous
in-person surveillance would be economically
unsustainable. Thus, the Moss
Interpretation would make it infeasible
for shops to employ mechanic-apprentices
seeking to become eligible to earn
an A&P mechanic certificate.
Similarly, GA shops could no longer
supervise owner-assisted annuals or
other owner-performed maintenance,
because the full-time on-site surveillance
required by the Moss Interpretation
would effectively preclude the supervisor
from doing anything else while supervising
the aircraft owner. There could
be no more " call me when you're done
so I can inspect your work. " The Moss
Interpretation would make owner-performed
maintenance under supervision
a thing of the past.
Given the present acute shortage
of A&Ps throughout the industry but
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AOPA Pilot Magazine - December 2024

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