Does anyone have a copy of the “one-paragraph letter” mentioned in the original post and the short-form article? I’d like to see what it says (and who it was sent to).
The borescope example is spot on. Viewing an item via bore scope (especially one with a screen) is not “in person”. The persons eyeball is several inches, if not feet away from the object being viewed.
Further, I have a bore scope that connects to my phone via Bluetooth. I can be in the hangar next door viewing a head. I am certainly not “in person” making the visual inspection. Now, extrapolate that and make the visual hundreds of miles away. 1 foot or 100 miles, the results are the same.
Further still, depending on the gripe, that borescope inspection could be the stand alone inspection that makes an airworthiness determination.
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You must not wear glasses. There are many details I can detect using the camera on my phone that I can’t detect without it.
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Indeed. As an active owner & type club member, I became quite knowledgeable about my particular bird. My IA had another one of the same type that he serviced, and he would ask me questions about it.
Yes, here’s the link to the “Moss Interpretation” letter from the FAA as published on the FAA’s web-site:
https://www.faa.gov/media/84326
PS - and here’s a link to the Blakey v. Sugen, National Transportation Safety Board (NTSB) Order No. EA-5128 cited as an example that a mechanic “…must be able to physically intervene at every step of the process.”
What the Moss Interpretation does is align the responsible party, the one(s) returning the aircraft to service, to the obligation in the maintenance task rather than rely on outside consultation as a means to “share” the obligation out of inexperience or ignorance.
Mike Busch’s organization has access to a large number of very experienced technicians who, for a price, will advise and provide instructions in how to perform a maintenance task. What they cannot do is sign off the logbook. That on site person is using this outside “authority” to subrogate his obligation. The Moss Interpretation reinforces the intent of the original rule which was never intended to allow a shared obligation in determining airworthiness. What also does, and could lead to, is more definitive regulation on the topic when none is really needed.
I find it amazing/interesting how this interpretation is creating so much concern. When the interpretation letter from the FAA legal department came out on time and duty rest rules for pt 135, there are still FSDO’s that ignore that interpretation and allow on demand pt 135 ops to continue in violation of that newer interpretation. Rather than worrying about new interpretations maybe the way to go is to get the FAA house in order so that rule interpretations are the same nationwide. And that would mean getting an administrator to actually enforce those legal rulings. I get the feeling that individual FSDO’s will interpret this item on maintenance just like they do on everything else, however the current FDSO manager wants to.
Robert, Your response challenging the premise that the use of a borescope can be described as “not in-person” and is not used as standalone tool for the determination of airworthiness or serviceability is absolutely spot on. Anyone making the argument otherwise is not contributing an informed rational point.
Whats Next….banning mirrors?
Thanks, but I’ve seen the original Moss Interpretation already. I’m looking for the “one paragraph letter” that was referenced in the AvWeb article.
You can write all the rules you want. The FAA cannot be in every shop enforcing them. It comes down to integrity and common sense 99% of the time. Over twenty years I have brought a good number of oversights to the attention of even good shops.
Here’s a copy of the letter from the FAA. It simply says the interpretation is on hold.
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