Doug Hereford Posted October 9, 2012 Report Share Posted October 9, 2012 Roger, You put much more faith in the feds. than I do. My opinion is that each of us should put ourselves in a position to know as much or more about the rules than the FAA does. Link to comment Share on other sites More sharing options...
Tom Baker Posted October 9, 2012 Report Share Posted October 9, 2012 Nobody can supervise inspections. Not even an A&P or IA. An A&P can suupervise maintenance if he has done it before. A LSRM does not have this privilege, but he can inspect maintencance and approve it for return to service. This means you can't watch them do the work, but you can inspect it and approve it afterwords. Link to comment Share on other sites More sharing options...
Doug Hereford Posted October 9, 2012 Report Share Posted October 9, 2012 Tom, You are correct that no one can supervise inspections. That is what I have posted from the beginning of this discussion. I will ask for the same thing from you that I have asked of Roger, and not received: Please give relevant regulatory citation to confirm the statement: "An A&P can supervise maintenance if he has done it before. A LSRM does not have this privilege,". Roger, I never asked you to go to the FAA or other sources. You did that on your own, so that burden is not my responsibility. I still wait for those regulatory references. Doug Hereford Link to comment Share on other sites More sharing options...
Tom Baker Posted October 9, 2012 Report Share Posted October 9, 2012 Tom, You are correct that no one can supervise inspections. That is what I have posted from the beginning of this discussion. I will ask for the same thing from you that I have asked of Roger, and not received: Please give relevant regulatory citation to confirm the statement: "An A&P can supervise maintenance if he has done it before. A LSRM does not have this privilege,". Roger, I never asked you to go to the FAA or other sources. You did that on your own, so that burden is not my responsibility. I still wait for those regulatory references. Doug Hereford 65.81 a covers what the A&P can do, ans specifically says he may supervise. § 65.81 General privileges and limitations. (a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§ 65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned. Nowhere in 65.107 does it give him the prililege to supervise. The words are not in there. Link to comment Share on other sites More sharing options...
Doug Hereford Posted October 10, 2012 Report Share Posted October 10, 2012 Tom, The 65.107 rule does absoultely exclude expressed premission to supervise that the 65.81, and 65.103 rules include. I have also had a chance to review the preamble to the 2004 light sport rule making, and it is clearly the intention of the lawmakers to exclude the light sport repairman from having supervision privileges. While I don't personnaly agree with this position, I do have to formally retract my posted opinions related to any Light sport repairmans authority to supervise maintenance. I am not a Light sport repairman my self, so practicly speaking, this limitation does not effect me. However, I believe that LSRM have just as much authority, and responsibility as A&P's and repair stations when performing their duties, and would have absolutely no issues being supervised by one when they have the requsite knowledge that I do not. I also have to believe that certain schools employ LSRM as instructors. While they may not be supervising students in the legal maintenance sense, in a practial sense, they are doing just that. To all, As I stated, I do formally retract my previous position. Doug Hereford Link to comment Share on other sites More sharing options...
Tom Baker Posted October 10, 2012 Report Share Posted October 10, 2012 You know the funny thing is while a LSRM can not supervise (watch them do the work), but he can approve for return to service work done by someone else after inspection. from 65.107 © The holder of a repairman certificate (light-sport aircraft) with a maintenance rating may— (1) Approve and return to service an aircraft that has been issued a special airworthiness certificate in the light-sport category under § 21.190 of this chapter, or any part thereof, after performing or inspecting maintenance (to include the annual condition inspection and the 100-hour inspection required by § 91.327 of this chapter), preventive maintenance, or an alteration (excluding a major repair or a major alteration on a product produced under an FAA approval); Link to comment Share on other sites More sharing options...
Runtoeat Posted October 10, 2012 Report Share Posted October 10, 2012 Some may be interested on attending this EAA Webinar? https://www2.gotomeeting.com/register/656593890 Link to comment Share on other sites More sharing options...
Doug Hereford Posted October 10, 2012 Report Share Posted October 10, 2012 Tom, I agree , and the particular part of 65.107 that you highlighted is exactly the point I have been standing on, (and unofficially, still do). I have to officially back-up on my previous posts though because the last thing I want to do is send anyone down the wrong road (myself excluded). The other funny thing to me is that if one just looks at the relevant rules on this topic (43.3, and 65.107) and does not consider the wording differences in 65.81 and 65.103, it is easy to argue that LSRM can supervise. I don't think that prohibiting LSRM from supervising maintenance enhances safety at all, and may actually be limiting to the light sport movement. I would really like to know what the rule makers thoughts were on why they didn't want LSRM supervising. I also recognize that many may have been following this discussion, and think of it as trivial, or simply argumentative. That has certainly not been my intention. It is my opinion that many of the best aspects of aviation in this country have come from people hammering out the little details to reach the best outcome. Doug Hereford Link to comment Share on other sites More sharing options...
Doug G. Posted October 10, 2012 Report Share Posted October 10, 2012 I agree - the discussion has been good, and got me looking into the rules and regs. Wandered a bit away from the original topic, but that's how these things go. Thanks all. Doug G. Link to comment Share on other sites More sharing options...
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