Avionics News November 2014 - 62

legislative

B Y
J A S O N
D I C K S T E I N
AEA GENERAL COUNSEL

Using the right tools,
equipment and test apparatus

n aircraft maintenance, we need to use the right tools. But
case, a mechanic used a pressure tester recommended by the
what does this really mean?
airframe manufacturer's field representative. The airframe
The general rule for maintenance tooling is found in
manufacturer's manual specified a different pressure tester.
section 43.13 of the regulations:
Because a different tester was specified, there were no caliEach person performing maintenance, alteration or prebration standards for the tester that was actually used. The
ventive maintenance ... shall use the tools, equipment and
administrative law judge (and the appellate board) held that
test apparatus necessary to assure completion of the work in
the mechanic had performed maintenance in an unacceptaccordance with accepted industry practices. If special equipable manner because the mechanic had not calibrated the
ment or test apparatus is recommended
by the manufacturer involved, he must
As always, if you think you might be doing something
use that equipment or apparatus or its
equivalent acceptable to the administrathe wrong way, then stop and look carefully at what
tor." 14 CFR § 43.13(a) (maintenance
performance rules).
you are doing to make sure that you've identified the
Most mechanics in the industry are
familiar with the notion that the methods,
right way to accomplish the task.
techniques and practices used must be
acceptable to the administrator, but a different standard applies to the "tools, equipment and test appapressure tester according to the calibration standards that
ratus." The tools, equipment and test apparatus must conform
applied to the (different) pressure tester recommended in the
to accepted industry practice.
manual. Thus, varying from the maintenance manual recomThe regulations do not specify where the equipment/appamendations - even when the variance is based on a manuratus recommendation might be found. The most obvious
facturer's recommendation - can set the stage for a potential
place for equipment/apparatus recommendations would be in
violation.
the manufacturer's maintenance manual (instructions for continued airworthiness).
Tooling distinguished from equipment
A recommendation issued by the manufacturer in some
One interesting distinction in this rule is that tooling is
other form, such as a special tooling manual or a service
distinguished from special equipment and test apparatus. All
bulletin, could be considered to be controlling to the same
three must be chosen in accordance with accepted industry
extent as a recommendation published in the maintenance
practices, but the manufacturer's recommendation trumps
manual, but it may depend on the form in which it was
accepted industry practices for equipment or apparatus but not
issued. For example, in one Federal Aviation Administration
for tooling.
62

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Avionics News November 2014

Table of Contents for the Digital Edition of Avionics News November 2014