Avionics News July 2017 - 13

of employees subject to drug and alcohol
testing.
In its answer, the FAA stated:
Sections 120.105 and 120.215 list
the employees who must be tested.
Among those listed are employees who
perform "aircraft maintenance and
preventative maintenance duties." To
better understand which employees
are performing maintenance and
preventative maintenance duties
requires reading the definition of
both of these terms under 14 CFR §
1.1. Section 1.1 defines maintenance
as "inspection, overhaul, repair,
preservation, and the replacement
of parts, but excludes preventative
maintenance." Preventative
maintenance is defined as "simple or
minor preservation operations and
the replacement of small standard
parts not involving complex assembly
operations."
Also, 14 CFR Part 43 applies to
the performance of maintenance
and preventative maintenance.
Sections 43.9 and 43.11 establish
recordkeeping requirements for tasks
associated with maintenance and
preventative maintenance. These
recordkeeping requirements have
never been applied to tasks associated
with receiving articles for stock.
Individuals who perform receiving
tasks ensure that there is no visible
damage to the packaging or the
enclosed items, and that the articles
were obtained from an approved
or acceptable source. Persons
performing these tasks compare part
numbers, serial numbers, quantity, etc.
with the purchase order and confirm
that the items match the purchase
order and that they are not damaged.
These tasks are not maintenance or
preventative maintenance activities.
Therefore, employees receiving items
for stock are not safety-sensitive
employees under Part 120 and
should not be included in the pool of
employees subject to drug and alcohol
testing.

FREQUENTLY ASKED QUESTIONS:
ADS-B

Dual ADS-B Out installations
The following information is from the Federal Aviation
Administration Advisory Circular AC 20-165B: Airworthiness
Approval of ADS-B Out Systems.

QUESTION:

I have a customer who wants to keep their installed
Mode A/C transponder and install an ADS-B
transponder as a dual transponder with a selectable
switch. Is this acceptable?

ANSWER:

Yes. There is no prohibition against this.
The FAA recognizes redundant ADS-B Out installations that
may benefit dispatch capabilities. However, there are specific
installation criteria to the system that must be addressed during installation.
AC 20-165B 3.2.2.4 Multiple ADS-B Out Systems, states:
"If the aircraft has the ability to operate a 1090ES and a
UAT ADS-B Out system at the same time, the systems must
have a single point of entry for the emergency code, IDENT,
and Mode 3/A code. Neither system may use the anonymity
(random address) feature. If dual ADS-B Out systems of the
same link are installed (for example, to increase dispatch
reliability), the installation must preclude operation of both
systems simultaneously. Also, dual systems must be the same
version level; that is, if the 1090ES system meets the requirements of RTCA/DO-260B (version 2), the UAT system must
meet the requirements of RTCA/DO-282B (version 2)."
However, after Jan. 1, 2020, any domestic airspace that the
customer's installed Mode A/C transponder would be needed
should require ADS-B Out capability. While there is no prohibition against this, it may not provide the redundancy the
customer thinks it will.

Continued on following page
avionics news

july

2017

Table of Contents for the Digital Edition of Avionics News July 2017