Narrative:

I renewed our apprentice/mentor relationship so that I could get my a&P rating finished. I performed all sorts and manner of aircraft repairs under the provisions of far 43.3D. I would make note of all work and would not release an aircraft for return to service until mr X came to town to check my work. Based on mr Y's assertions. I believed this out-of-town oversight of my work with all questionable or complex operations personally inspected/supervised by mr Y was completely legal under far part 43. All maintenance logbook entries were left to mr Y. No entries were made by myself on any aircraft except my own. In dec/xx/94 mr Y severed our relationship by writing the FAA. Informing them he was no longer supervising my work. Mr Y failed to inform me of this until approximately feb/xx/95. In the interim he worked on 3 or more different aircraft with me. On jan/xx/95 I regained my private pilot license. Fortunately for me some of my work then once again fell under appendix a of far 43. On feb/xx/94, I received a call from FSDO 13 in columbia, sc. The local FBO had filed a complaint against me for performing work on aircraft in violation of far 43, ie, unsupervised. Much to my shock I learned that the local FSDO viewed my actions as a violation of the spirit if not the letter of the far's.' they further interpreted far 43.3D to mean the supervisor of the work must be on the premises where and when an apprentice performs any maintenance. I fully acknowledged all of my past actions and cooperated fully in the FSDO investigation. On the afternoon of feb/xx/95. I was once again invited to the local FSDO, whereupon they found me to be in violation of several sections of part 43. They informed me that they were going to issue a letter of correction for these infractions. The point to be made is always perform any apprenticeship maintenance in the physical presence of an appropriately rated individual. And appendix a of part 43 does not allow you unlimited power to perform maintenance on any number of aircraft. I submit this report in hopes of educating someone else before they have to go through what I have. As I work for the FAA I'm told it could have gone much worse for me. I guess this is 1 of those rare instances where cooperating fully with the FAA paid off.

Google
 

Original NASA ASRS Text

Title: APPRENTICE MECHANIC PERFORMED MAINT ON ACFT EITHER SUPERVISED OR WORK CHKED. COMPLAINT FILED BY LCL FBO FOR PERFORMING MAINT ON ACFT IN VIOLATION OF FAR 43.

Narrative: I RENEWED OUR APPRENTICE/MENTOR RELATIONSHIP SO THAT I COULD GET MY A&P RATING FINISHED. I PERFORMED ALL SORTS AND MANNER OF ACFT REPAIRS UNDER THE PROVISIONS OF FAR 43.3D. I WOULD MAKE NOTE OF ALL WORK AND WOULD NOT RELEASE AN ACFT FOR RETURN TO SVC UNTIL MR X CAME TO TOWN TO CHK MY WORK. BASED ON MR Y'S ASSERTIONS. I BELIEVED THIS OUT-OF-TOWN OVERSIGHT OF MY WORK WITH ALL QUESTIONABLE OR COMPLEX OPS PERSONALLY INSPECTED/SUPERVISED BY MR Y WAS COMPLETELY LEGAL UNDER FAR PART 43. ALL MAINT LOGBOOK ENTRIES WERE LEFT TO MR Y. NO ENTRIES WERE MADE BY MYSELF ON ANY ACFT EXCEPT MY OWN. IN DEC/XX/94 MR Y SEVERED OUR RELATIONSHIP BY WRITING THE FAA. INFORMING THEM HE WAS NO LONGER SUPERVISING MY WORK. MR Y FAILED TO INFORM ME OF THIS UNTIL APPROX FEB/XX/95. IN THE INTERIM HE WORKED ON 3 OR MORE DIFFERENT ACFT WITH ME. ON JAN/XX/95 I REGAINED MY PVT PLT LICENSE. FORTUNATELY FOR ME SOME OF MY WORK THEN ONCE AGAIN FELL UNDER APPENDIX A OF FAR 43. ON FEB/XX/94, I RECEIVED A CALL FROM FSDO 13 IN COLUMBIA, SC. THE LCL FBO HAD FILED A COMPLAINT AGAINST ME FOR PERFORMING WORK ON ACFT IN VIOLATION OF FAR 43, IE, UNSUPERVISED. MUCH TO MY SHOCK I LEARNED THAT THE LCL FSDO VIEWED MY ACTIONS AS A VIOLATION OF THE SPIRIT IF NOT THE LETTER OF THE FAR'S.' THEY FURTHER INTERPRETED FAR 43.3D TO MEAN THE SUPVR OF THE WORK MUST BE ON THE PREMISES WHERE AND WHEN AN APPRENTICE PERFORMS ANY MAINT. I FULLY ACKNOWLEDGED ALL OF MY PAST ACTIONS AND COOPERATED FULLY IN THE FSDO INVESTIGATION. ON THE AFTERNOON OF FEB/XX/95. I WAS ONCE AGAIN INVITED TO THE LCL FSDO, WHEREUPON THEY FOUND ME TO BE IN VIOLATION OF SEVERAL SECTIONS OF PART 43. THEY INFORMED ME THAT THEY WERE GOING TO ISSUE A LETTER OF CORRECTION FOR THESE INFRACTIONS. THE POINT TO BE MADE IS ALWAYS PERFORM ANY APPRENTICESHIP MAINT IN THE PHYSICAL PRESENCE OF AN APPROPRIATELY RATED INDIVIDUAL. AND APPENDIX A OF PART 43 DOES NOT ALLOW YOU UNLIMITED PWR TO PERFORM MAINT ON ANY NUMBER OF ACFT. I SUBMIT THIS RPT IN HOPES OF EDUCATING SOMEONE ELSE BEFORE THEY HAVE TO GO THROUGH WHAT I HAVE. AS I WORK FOR THE FAA I'M TOLD IT COULD HAVE GONE MUCH WORSE FOR ME. I GUESS THIS IS 1 OF THOSE RARE INSTANCES WHERE COOPERATING FULLY WITH THE FAA PAID OFF.

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.