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By Sarah MacLeod SARAH MACLEOD is executive director of the Aeronautical Repair Station Association (ARSA), an orga- nization she helped found more than 25 years ago. For more information visit www.arsa.org. A R S A O U T L O O K www.AviationPros.com | www.AMTSociety.org 21 M a i ntena nce prov iders t hat suppor t custom- ers on the road are par- ticularly v ulnerable to an owner's desire to fix the aircraft "right now." The ability to provide mobile maintenance services either through a repair station work- ing away from its fixed location or as an independent part 65 mechanic is def initely not limitless. The prov i- sions of parts 43, 65, and 145 all prevent work from being performed improperly. Maintenance providers must always ensure they have the proper housing, facilities, tools, equipment, technical data, and knowledge to accomplish the work in such a manner as to return the item to at least its original condition. If a discrepancy cannot be fixed, the aircraft must be ferried. Safe for operation W hether fixed or ferried, the certificat - ed person (either the repair station or mechanic) must deem the aircraft safe for operation. To deem an aircraft safe to operate, a careful inspection must be accomplished to delineate those items that create unair worthy conditions from those issues that can be resolved at a later date. The Federal Aviation Administration (FA A) has issued several legal interpre- tations stating that not every discrep- ancy renders an aircraft unairworthy — the best summar y of the agency's position can be found in its letter to Christopher Witkowski dated March 26, 2008 found here*. Unfortunately, the determination of what does and does not create an unair worthy con- dition depends upon the knowledge, expertise and mental acuity of a mainte- nance provider. The individual making determinations of whether an aircraft has to be fixed or can f ly as is will have to justify the decision based upon what a "court" would think. Nevertheless, the language used by judges and law yers using 20/20 hind- sight is important to understand. The National Transportation Safety Board (and subsequently, the FA A's legal opinion) stated that not "… ever y scratch, dent, 'pinhole' of corrosion, missing screw, or other defect, no mat- ter how minor, or where located on the aircraft …" creates unairworthiness. Rather, the defect must be such that it has an "adverse impact on the level of safety that an aircraft's conformity with Always Responsible It is a maintenance provider's responsibility to determine airworthiness; those decisions have to be made in the hangar or shop and on the road its type [design] is intended to insure." The maintenance provider's knowledge must encompass the aircraft's "original condition" which includes its certifica- tion basis. Without understanding the product's (aircraft, aircraft engine or propeller) certification standard, it is hard to make and hold to determina- tions of whether a defect has an adverse impact on the ability of the design to uphold its safety requirements. Understand what can and cannot be fxed W hen working on the road with lim- ited housing, facilities, equipment, tools and other necessities, the maintenance provider must not only understand the basic airworthiness standards but what can and cannot be fixed with the tools and information at hand, deferred or determined to have no impact on the aircraft's required level of safety. Those facts must be balanced against the pilot (or owner's) desire to get home or to accomplish the next leg. The individuals tasked with servicing customers on the road must enhance their technical skills right along with t hei r com mu n icat ion capabi l it ies. W hether the decision is to fix, defer, or ferry, it must be clearly documented against the facts and regulations so an owner's expectations can be tempered with genuine safety considerations. It is a maintenance provider's responsibility to determine airworthiness; those deci- sions have to be made in the hangar or shop and on the road. This 74-foot tractor-trailer serves as a mobile service center and contains special tools, a generator, air compressor, satellite dish, Wi-Fi connectivity, and the top 10 parts most often needed. GULFSTREAM AEROSPACE CORPORATION *http://www.faa.gov/about/office_org/ headquarters_offices/agc/pol_adjudication/ agc200/interpretations/data/interps/2008/ witkowski-assocflightattendants - (2008) legal interpretation.pdf AMT_21_ARSA Outlook.indd 21 4/17/14 4:13 PM