Narrative:

After speaking with our lead mechanic on the phone about a wire that needed to be replaced from the solenoid to the bandix starter motor, the owner/operator told me to put the wire on the plane. I was at first flight airport (ffa) which is about 15 mi from our maintenance base (dare county airport, mqi). The mechanic said he would be there in a little while to check the maintenance work. As I was replacing the wire exactly as I saw the old one, 2 FAA inspectors arrived at the airplane and asked me what I was doing and I told them, as previously mentioned in this statement. They asked me for my a and P license and I told them I was not an a and P. They then asked me for my pilots license, which I let them see. They wrote down my name, address (local) and certificate number. They then asked me if I was familiar with the FAA preventive maintenance program. I said, 'yes, a little'. The FAA inspector asked where the a and P mechanic was and I told him he was at the maintenance base at mqi (dare county airport). He said it was not proper procedure to perform any maintenance unless I was under the direct supervision of the a and P mechanic in the immediate physical vicinity of the airplane. I told the inspector that I did not realize I was doing anything wrong and I would stop immediately what I was doing at the time. He then asked when the mechanic was supposed to be at ffa and I said, 'about xa O'clock (local). The a and P arrived about xa O'clock to check the work and of course was met by the 2 FAA inspectors. Just to mention, the FAA inspectors were very cordial. In summation, I did not realize that the a and P had to be physically present and in the immediate vicinity in order for me to perform any type of repairs or preventive maintenance on an airplane. I thought it was submissible to perform the work and then have the a and P inspect the work before anything else could be done to or with the airplane even though he was not in the immediate vicinity at the time of repair. After reading far 43.3, although there seems to be a grey area in the interpretation as most FARS are left purposefully open in regards to interpretation. I now will be much more cautious and prudent in making sure that if I perform any maintenance on an aircraft that a certified a and P mechanic will be physically present in the work area so no questions will or can be asked as to the meaning of far 43.3.

Google
 

Original NASA ASRS Text

Title: AGENCY AND OTHER MGMNT POLICY CHALLENGE TO FACILITY MAINT POLICY PROC WHEN ATX PLT IS OBSERVED PERFORMING MAINT ON COMPANY ACFT WITHOUT PROPER ACFT AND PWR PLANT LICENSE.

Narrative: AFTER SPEAKING WITH OUR LEAD MECH ON THE PHONE ABOUT A WIRE THAT NEEDED TO BE REPLACED FROM THE SOLENOID TO THE BANDIX STARTER MOTOR, THE OWNER/OPERATOR TOLD ME TO PUT THE WIRE ON THE PLANE. I WAS AT FIRST FLT ARPT (FFA) WHICH IS ABOUT 15 MI FROM OUR MAINT BASE (DARE COUNTY ARPT, MQI). THE MECH SAID HE WOULD BE THERE IN A LITTLE WHILE TO CHK THE MAINT WORK. AS I WAS REPLACING THE WIRE EXACTLY AS I SAW THE OLD ONE, 2 FAA INSPECTORS ARRIVED AT THE AIRPLANE AND ASKED ME WHAT I WAS DOING AND I TOLD THEM, AS PREVIOUSLY MENTIONED IN THIS STATEMENT. THEY ASKED ME FOR MY A AND P LICENSE AND I TOLD THEM I WAS NOT AN A AND P. THEY THEN ASKED ME FOR MY PLTS LICENSE, WHICH I LET THEM SEE. THEY WROTE DOWN MY NAME, ADDRESS (LCL) AND CERTIFICATE NUMBER. THEY THEN ASKED ME IF I WAS FAMILIAR WITH THE FAA PREVENTIVE MAINT PROGRAM. I SAID, 'YES, A LITTLE'. THE FAA INSPECTOR ASKED WHERE THE A AND P MECH WAS AND I TOLD HIM HE WAS AT THE MAINT BASE AT MQI (DARE COUNTY ARPT). HE SAID IT WAS NOT PROPER PROC TO PERFORM ANY MAINT UNLESS I WAS UNDER THE DIRECT SUPERVISION OF THE A AND P MECH IN THE IMMEDIATE PHYSICAL VICINITY OF THE AIRPLANE. I TOLD THE INSPECTOR THAT I DID NOT REALIZE I WAS DOING ANYTHING WRONG AND I WOULD STOP IMMEDIATELY WHAT I WAS DOING AT THE TIME. HE THEN ASKED WHEN THE MECH WAS SUPPOSED TO BE AT FFA AND I SAID, 'ABOUT XA O'CLOCK (LCL). THE A AND P ARRIVED ABOUT XA O'CLOCK TO CHK THE WORK AND OF COURSE WAS MET BY THE 2 FAA INSPECTORS. JUST TO MENTION, THE FAA INSPECTORS WERE VERY CORDIAL. IN SUMMATION, I DID NOT REALIZE THAT THE A AND P HAD TO BE PHYSICALLY PRESENT AND IN THE IMMEDIATE VICINITY IN ORDER FOR ME TO PERFORM ANY TYPE OF REPAIRS OR PREVENTIVE MAINT ON AN AIRPLANE. I THOUGHT IT WAS SUBMISSIBLE TO PERFORM THE WORK AND THEN HAVE THE A AND P INSPECT THE WORK BEFORE ANYTHING ELSE COULD BE DONE TO OR WITH THE AIRPLANE EVEN THOUGH HE WAS NOT IN THE IMMEDIATE VICINITY AT THE TIME OF REPAIR. AFTER READING FAR 43.3, ALTHOUGH THERE SEEMS TO BE A GREY AREA IN THE INTERPRETATION AS MOST FARS ARE LEFT PURPOSEFULLY OPEN IN REGARDS TO INTERPRETATION. I NOW WILL BE MUCH MORE CAUTIOUS AND PRUDENT IN MAKING SURE THAT IF I PERFORM ANY MAINT ON AN ACFT THAT A CERTIFIED A AND P MECH WILL BE PHYSICALLY PRESENT IN THE WORK AREA SO NO QUESTIONS WILL OR CAN BE ASKED AS TO THE MEANING OF FAR 43.3.

Data retrieved from NASA's ASRS site as of July 2007 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.