If the ‘Moss Interpretation’ ever gets enforced there is going to be a massive re-write of the FARs, Advisory Circulars (A.C.) and Airworthiness Directives (A.D.). Quite often the Operator of the aircraft is required per A.D. to perform a maintenance task (like inspections). The FAA has declared these items as “Maintenance”: Checking and airing Tires, opening/closing access panels/covers/cowling, landing gear securing pins, replenishing fluids, inspections and the list goes on.
(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.
If the FAA really wants to get silly? Then the FAA Inspector needs to stand behind the Operator who is standing behind the A&P who is standing behind the lonely Apprentice while they add brake fluid behind the rudder pedals of the Cessna. I don’t know if a Cessna 150 is big enough for everyone watching over everyone.
For over 100 years the Aviation Industry has based everything on “TRUST”. The house of cards all collapses without “Trust”.
So my experience in 12 years of working for the USAF as an civilian engineer is that there are three main types of government employees (this doesn’t cover everyone but it does the majority) There are the majority of employees that show up follow the rules and turn the crank of government. they really don’t try to fix any problems they know they are unlikely to get anywhere. There are the bureaucrats that are mainly concerned with climbing the ladder and don’t want to rock the boat and then there are the reformers that get rather upset with the inefficiencies and waste and try to fix things. The reformers have a real tendency to burn out beating there head against the wall not getting anywhere. The ones that run things are mainly the bureaucrats they make the major decisions and, in my experience, so far are mainly concerned with not rocking the boat. There seems to be a real bad tendency right now in the USAF to blame the messenger.
There are some libertarians that are close to the anarchy types but not all. My view is that government like any other large organizations primary purpose is self-preservation, government is not your friend, It is the responsibility of the people to carefully keep an eye on everything being done by the government and slap them down whenever they get out of line. Unfortunately, I see far too much tendency to want to hand everything over to the government to be taken care of and only pay any attention right before an election. That does not work very well and as far as the “people be good” idea I actually have the exact opposite opinion as far as I can tell outside of the constraints of religion, society and government people are actually pretty much selfish and self-serving. Unfortunately government is run by people as well which means it tends to be selfish and self-serving and as such needs to be the last resort in regard to ensuring a polite society not the first.
Ok my two cents worth. I know a lot of folks who have built or maintained their own planes and done a stellar job. I also know quite a few who were idiots and did some unairworthy maintenance. As an A&P, IA, for many years, I’ve seen it all. I worked for an Airline, did a 5 year apprenticeship as an Aircraft Engineer, worked in the US in GA and crorporate etc etc.
The bottom line is that anyone who works on a plane, who can’t sign off their own work, needs to have it inspected, to the depth required for such a task, That’s what the regs state. Zoom and other methods? I’m sorry, but that’s about equivalent to using binoculars or a drone to inspect the tail of a Boeing 727 from the ground. It won’t wash, and it’s not legal, and it’s not safe. Period. How can you inspect a weld on a steel fuselage if the zoom camera doesn’t get around to the backside of the weld? How can you verify in detail whether rivet tails are cracked because they weren’t heat treated and or stored in an ice box before driving? Too many IA’s are willing to let someone do the work, while they sign it off with a cursory glance. That’s putting a huge noose around their own necks.
I don’t see that the Moss will have much effect on persons or companies who are doing things correctly. A pilot of owner can do their own preventative matinernance per FAR 43, and there is a detailed list of what they can perform and sign off using their pilots’ license.
Surely larger, more important things need to be approved but a properly rated indiividual who has taken a proper look at the work done and satisfied themselves that it was done correctly? I support the Moaa interpretation, both from a certification side and a safety side. As KlausM states, Avaiation industry has based everything on trust. However we live in a litigious society too. I’d go with trust but verify. And I think that’s what Moss is trying to accomplish.
I would also suggest that the FAA follow this same interpretation. Ever since COVID it has been difficult to work with the FAA, and in person is nearly impossible.
I’m not sure what the actual percentage off FAA personal at the FSDO level even come to their offices anymore.
IA renewals are virtual with no face to face supervision", and nearly every facet of the FAA’s in person work is conducted by a designee.
I hate to call the kettle black, but seriously, it sure seems like the entire FAA responsibility, at least in the maintenance sector is remote/virtual/passed off to a designee.
I see the Moss interpretation as “distrust and verify”. And what I’ve found is that when you don’t give anyone trust (or through regulation aren’t allowed to give anyone trust), they have no reason to earn your trust and behave appropriately poorly.
You know, I rather think I’d enjoy a beer with you over this conversation. So we’re completely off topic and I would not blather on more, but to say this; I understand what you say from from your experience, mine will be different, but I an not in disagreement as much as seeing through a different lens. Over that mythical beer I’d try to show you where I come from.
there was one thing you misunderstood from my post and back when I wrote it I thought I should have stated it better.
“people be good”
I should have put a /s for sarcasm after that or “people be good…not” to go modern. I believe in an ideal that there is good in all of us, but it is something we need to work on daily and it can be hard. Being bad is easy and sadly I feel We are getting lazy more theses days and yes, that carries into the government. I am an optimist so I’ll end with this, to paraphrase Franklin, 'government is not the best, but the alternative is even worse".
Were you wanting to continue to conversation feel free to message offline otherwise, fly safe.
I held an IA with my A&P for 20 years prior to retirement. I worked for a major helicopter manufacturing co. and was an instructor, seeing the young people coming into the company had zero experience. Some never handle tools. I don’t see how we are going to successfully maintain or build aircraft in the future. Very unskilled help coming in. Very scary to me.
I have to agree that FAA’s positions on multiple issues have been disasters. I understand the sentiment in many of the posts against Moss. However, I also see that FAA is broken, and has no clue about aviation in its most basic forms. For example the Boeing debacles. No need to go into that any further. As a person who held an A&P and IA for Allmost 50 years, I’ve done my share of annuals, major alts and repairs etc. Now, I can’t do anything. The reason; changes to FAA regs. I can no longer renew my IA because the change in the part 65 regs will not let me hold my A&P as valid anymore, because I don’t have a plane to work on. The last plane I looked after, we sold last year. A Cessna 190. Now I have no basis to work on planes, so my A&P is in effect at rest until I comply with certain rules. So I also had to let my IA go, because you can’t hold an IA without a valid A&P.
I do understand the predicament and feelings of those who don’t support Moss. I’ve done a lot of owner assisted annuals. However, being the one who signs it off, I had alswyas basically let the owners upen and close, and do some of th engine work, supervised. Why? Bedause it was my neck and livelihood that was on the line. Do I trust an owner to change out spark plugs, or inspect them.? Yes and no. Did they torque them to the required specs when they reinstalled them? Did they inspect them per part 43, and clean them, or just whip them out, no reinstall. That’s why I say I always trust, but verify. When working on a plane that was going to depart say, early in the morning, and I discovered and repaired a defect on it, but nobody was around to double check my work, I always had a pilot look at it. Why? Because the PIC is responsible for the airworthiness of the plane. Yes, I can repair it, and I can sign it off without a second set of eyes, but shouldn’t I give the pilot the information about what I did so they can satisfy themselves it was done correctly, even if they don’t really know what they are doing? It’s called common courtesy, as well as allowing the pilot to understand what was done and make his determination off whether the aircraft is airworthy or not. I’ve done this all my career. I was a director off Maintenance for well over 28 years, and a Director of Aviation for a corporate flight department for several years. I still worked on our planes from time to time, nad I still had someone else inspect my work, as all of us Techs did. It’s the smart thing to do. Just saying that trust but verify, works for everyone. BTW, I’d love to discuss over a virtual beer Bucc5062. You can email me offline at jetdoc2@me.com.
Let’s reframe the question and see if it answers itself:
How many times do you have to supervise the same person using a torque wrench before you can trust them to do it on their own?
The key words in the original regulation say “…to the extent necessary…”.
The first time you are going to watch their every move and tell them how to do it.
But after the tenth time without error? The hundredth?
Before this interpretation that was up to the IA. Now, the FAA has tied the IA’s hands. Effectively, any task that requires an IA can only be done by an IA. After all, why would you hire someone else to do the work if you are stuck watching their every move?
The FAA talks about the ability to “physically intervene”. I don’t take that to mean that somebody has to be within arm’s reach to knock a wrench out of your hand at a moment’s notice. I read “Physically intervene” as the ability to walk over and say “It looks like you’re using the wrong thing here.”. It just means someone has to be around to guide you and stop you (me) from doing something silly. Clarification around what constitutes the ability to physically intervene would be helpful to reduce confusion and consternation. Clarification around what the consider a “step of the process” when they paraphrase the NTSB would also be helpful. Is a turn of every single screw a step? Or is a step a general concept? Is a step the removal or addition of a part?
Owner assisted maintenance isn’t a bad thing. Guidance around what constitutes supervision of that owner assised maintenance isn’t a bad thing either. My point is we should get clarification before we all lose our collective minds. Hopefully AOPA and the EAA are on this. As is I’m not sure I see that much of a change from what we have all been doing for years.
I don’t see a policy change. I am not sure how anyone can misinterpret “in person”. If you don’t like FAR 43.3(d) then petition to change the FAR. I have run a shop for almost 30 years and employ mechanics apprentices and if they are working on an airplane myself or another A&P are present.
Mike Busch sells subscriptions to pilots. He continually undermines A&P mechanics with his chicken little stories. When did he last write a story that showed a mechanic other than himself in a good light? His goal here is so his pilots can work on their airplanes and then pay an A&P to sign it off. That gains him more followers in the pilot community, more money and an even bigger ego.
I work with owners that want to help and learn but I have also fired some because of the things they do when I am not around that are not legal or safe. My livelihood and reputation is on the line and I will protect them both.
Steve I agree with you 100% you are right on concerning Mike. He definitely has a vested interest in being able to do remote. Of course they do all kinds of recommendations but they don’t put their name on anything. (As far as I know). I’m glad the FAA came out with a stronger interpretation because I do worry that the airlines would take advantage of that when it comes to required inspection items as we call them RII. While I am certainly not against using technology there are just too many things in our aviation world that need to have a second set of eyes . I have professional pilot friends that went out and got their mechanics ratings just so they could work on their own airplane. I guarantee you and I would not have them work on our own aircraft. Yet the FAA has no problem letting just about anyone get a mechanic’s license. We don’t advertise it as a avocation and love of aviation anymore it’s a job that’s the way the FAA is fostering our career. With the new hires I have worked around and supervised there is a big difference between people who actually like airplanes and those who are looking for a job with benefits. Those people walk around with their phone in their hand all day long. Carl
I am an owner working on getting my A&P / IA simply because my old mechanics retired and anyone I find now wants to do annuals on time and material cost basis, I don’t think so, I’m not giving someone thousands of dollars just for an inspection. Once I get that IA I don’t care who trusts me I’m going flying.
There’s not a lot of discussion here about labor costs but that’s what all this boils down to, I’m not going to harm my family because you want to run up some sky high bill.
We are pretty much already Europe and the only people who will be left in GA are owners with their own A&P / IA or multi millionaires.
All the ga airports around me are really quiet, many many planes tied down that haven’t moved in MANY years.
In addition to not seeing that much of a change right now, I’d also like to point out something else: Raising barriers doesn’t stop poor maintenance, it just drives it into the shadows. Many of us can remember (multiple) airplanes we’ve come across with auto parts installed and undocumented repairs. Keeping owner-assisted work easy reduces the incentive for folks to just bolt on an auto-part and blast. If we make it harder to maintain planes, more planes are going to be flying around with all kinds of weird and undocumented stuff hidden within.
Again, I don’t see that much of a change with the Moss interpretation. I just wanted to come back and address whether restrictive policies actually have the desired effect.
So all us mechanic/shop owners just want to run up the bill? If it was easy everyone would do it. Good luck with your A&P and 2 years later your IA and gaining the knowledge and the skills. I have been doing it for 30 plus years, still learning and still enjoying it.
People who make a career of maintaining airplanes understand that the FAA can interpret whatever they want however they want to fit the particular circumstance or agenda. It is what we’ve had to accept since the beginning. Consequently, one learns what’s important and what can get them in trouble, categorized by make and model with a bias and nod to the level of experience shop personnel have to offer.
Mechanic certification, or lack thereof, does little to determine oversight responsibilities and expectations. New A&Ps are just as risky as the kid who washes airplanes after an annual. Everybody needs supervision all the time. It’s a shop-wide effort to ensure a safe and reliable product is rolled out the door while elevating the overall level of experience and expertise of its personnel.
The Moss Interpretation and 43.3(d) needs no further clarification. We’ve worked with its vague attributes for decades. Grass roots efforts by well meaning “experts” will only lead to more restrictive rules.
Just to clarify, I did not give up my A&P. it’s just in stasis until I do what’s required by the new FAR to become practicing again. So, if my A&P is not technically valid, my IA can’t be exercised. Here are the references: FAR 65.83, recent experience requirements. Then there is FAR 65.91 which deals with the IA requirements. I renewed my IA using the online training for many years after I retired, but the new experience requirements forced upon us by FAA and the fact that as of this year, I no longer have an aircraft to look after, means that keeping up per the reg as current when retired is about impossible.