Narrative:

I may have inadvertently violated crash fire rescue equipment 14 65.81 by supervising the installation of a first surface vinyl wrap on the exterior of a bell 407 helicopter. While I have applied many first surface vinyl decals and 'north' number registration numbers in the exact same way; this is sort of a gray area. During a routine conformity check; a member from the certificate management team (cmt) inquired as to how we obtained information for the installation of this vinyl wrap and did not seem satisfied with the descriptive sign off and reference of the crash fire rescue equipment 14 part 43 appendix a paragraph(C) item 9. The cmt member questioned my abilities to install a large sticker on the exterior portion of the aircraft that did not require removal or disassembly of any primary structure or operating system. In hindsight; I could have used crash fire rescue equipment 14 part 43 app a paragraph (c) item 10 instead since there is no published data saying that the first surface vinyl is not permitted on those areas or considered contrary to good practice.I believe the major issue; as is with most crash fire rescue equipment's; is the opinion of the administrator and the intent of the crash fire rescue equipment. Ask 5 different [inspectors] their interpretation of a crash fire rescue equipment and you'll end up with 5 different opinions.

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Original NASA ASRS Text

Title: Maintenance Technician reported during an FAA routine conformity check; there was ambiguity in the translation of FARs regarding the instillation of vinyl decal on the exterior surface.

Narrative: I may have inadvertently violated CFR 14 65.81 by supervising the installation of a First Surface Vinyl wrap on the exterior of a Bell 407 helicopter. While I have applied many First Surface Vinyl decals and 'N' number registration numbers in the exact same way; this is sort of a gray area. During a routine conformity check; a member from the Certificate Management Team (CMT) inquired as to how we obtained information for the installation of this vinyl wrap and did not seem satisfied with the descriptive sign off and reference of the CFR 14 part 43 appendix A paragraph(C) item 9. The CMT member questioned my abilities to install a large sticker on the exterior portion of the aircraft that did not require removal or disassembly of any primary structure or operating system. In hindsight; I could have used CFR 14 part 43 app A paragraph (c) item 10 instead since there is no published data saying that the first surface vinyl is not permitted on those areas or considered contrary to good practice.I believe the major issue; as is with most CFR's; is the opinion of the administrator and the intent of the CFR. Ask 5 different [inspectors] their interpretation of a CFR and you'll end up with 5 different opinions.

Data retrieved from NASA's ASRS site and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.