Robinson OH major repair?

Pilot4him · May 22, 2013

Hello everyone!

I have a newb question in the realm of mechanics...

I'm in a&p school now. I just got my A and should have my p by the end of August.

I've also signed up for the Robinson factory maintenance course in September.

I would like some light on the 2200/4400 overhauls and 12 year inspections.

I know as a new a&p I can't perform major repairs or alterations.

I also know that I can't do anything that I haven't done at least once before.

My questions are as follows:

Does a 12 year inspection require your IA? Also,

Does the 2200 OH also need IA privileges?

Looking at 14 cfr 43 appendix a, I saw that splitting the case on the engine is a major, but as far as the rest of the oh, could it theoretically be done by just an a&p?

Appendix A doesn't seem very helpful in regards to defining helicopter work...

Forgive my ignorance, but any references or suggestions for references are appreciated!

I guess what I'm really wondering is could I, as a new A&P fresh out of Robinson maintenance find a ship that needs a 2200 hr or 12 yr and return it to service (perhaps with an engine swap) if it didn't require any additional repairs as outlined in 43 appendix A?

Thanks in advance!!

iChris · May 23, 2013

Appendix A doesn't seem very helpful in regards to defining helicopter work...
Forgive my ignorance, but any references or suggestions for references are appreciated!
I guess what I'm really wondering is could I, as a new A&P fresh out of Robinson maintenance find a ship that needs a 2200 hr or 12 yr and return it to service (perhaps with an engine swap) if it didn't require any additional repairs as outlined in 43 appendix A?

Research the following § as a start:

43.3 [a] &

43.7 [a] &

65.81

65.85

65.87

65.95

REF LINK:

Office Of The Chief Counsel Interpretation

Edited May 23, 2013 by iChris

apiaguy · May 23, 2013

ugg... it's obvious Chris that in a whole year of airframe school they didn't teach him any understanding of those parts so having him research them will draw a blank face...

1) Pilot 4 him.... going down your post the first thing I find a problem with is "I also know that I can't do anything I haven't done at least once before"

REALLY? This is rediclious and I can't believe you're hearing this from school. Do you also have a mechanic logbook that shows each thing you have learned to do? Run. Run very fast.

2) Nothing in the 2200 or 12 year requires an Inspection authorization Except the Annual inspection for return to service.

3) Splitting the case is not a major repair

iChris · May 23, 2013

I also know that I can't do anything that I haven't done at least once before.

Don’t take that to far out of context. In a 1992 legal interpretation it stated, if the recent graduate of a FAA-certified maintenance school performed a particular task satisfactorily during his or her training they met the requirements of 65.81[a]. However, in all other cases only work performed satisfactorily, at an earlier date, as a certificated mechanic will satisfy the requirement of 61.85[a].

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.

Edited May 24, 2013 by iChris

May 24, 2013

Pilot4him, you have asked alot more questions than you think ! You as a new A&P can not do anything is a fairly grey statement, any task you have performed in school, A&P or factory can be counted as you have done that task and are "good to go" on that one. (but say you changed a tire on a cessna 150, can you now change a tire on a 747?) You can do major repairs and alterations, you just cannot approve them--take a look at a 337 form. You can split the case of an engine-as long as you have done B4, remember===a major overhaul of an engine is a minor repair ! ( yes there is a reg somewhere about a supercharged engine , as i remember- so those cases are off limits to you)

Legally? doing a 12 year inspection/overhaul of an r22, you would have to have done every task prior, but? the reg does not say that just because you now have a helicopter engine to be replaced, does not say that the Cessna engine you replaced last week under a mechanics supervision could not be counted,

My best advice would be to get job with Robinson dealer, go through at least one complete inspection/rebuild & then think of venturing off on your own.

And also i failed to advise you of the obvious, these are all good questions for your A&P school instructors !

Edited May 25, 2013 by pokey

May 25, 2013

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.

the keyword here is 'or'. Why they try to 'hide' the obvious in the regs is beyond me.

as far as a mechanic log book? No it is not required, but i have talked to quite a few FAA inspectors that say it is a good idea, and i know of a few mechanics that do it. I personally do not, but since the 'computer age' i do keep copies of every log book entry that i have made.

and the other key word is "certificated" mechanic... B4 you take and pass your test? you have no certificate..............and the plot thickens

and suppose the "he" is a she? OH MY ! !

Edited May 25, 2013 by pokey

ridethisbike · May 25, 2013

and suppose the "he" is a she? OH MY ! !

Pilot4him · May 27, 2013

Thanks everyone for the info...

Pilot4him · May 27, 2013

@ iChris: thanks for those references. I actually am familiar with them, except for the letter from the Office of the Chief Counsel of Interpretation regarding 100hr and Annuals. It was very informative and interesting. Thanks!

@Apia guy:

I guess I gave a terrible paraphrase, but the reference I was referring too was 65. 81. General privileges and limitations. "A certificated mechanic...May not supervise the maintenance, preventative 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 perform the work concerned at an earlier date."

I guess I should ask instead:

After going through A&P school and the Robinson course, would it be safe to say that I should have done enough work to meet the requirements of 65. 81(a) and perform the OH?

Obviously that would also be somewhat subjective as well, since all A&P courses are different!

Also, in regards to splitting the case being a major repair, I was referring to 43. Appendix A((2)(ii) which says:

"Separation or disassembly of a crankcase or crankshaft of a reciprocating engine equipped with other than spur type-propeller reduction gearing." is a major repair.

Pilot4him · May 27, 2013

@pokey. Thanks for the advice! I agree that the interpretation can be a little fuzzy! I'm also aware that I can do work I haven't performed before under supervision, and that I can perform major repairs and alterations, but just can't approve and return to service.

I also asked one of my instructors, and was under the impression that work performed satisfactorily in school before I was certificated counted toward the requirements of 65.81.