You are performing an inspection on an aircraft and you remove a component part. You then clean, inspect and reinstall the part. You don’t disassemble or assemble the part. You don’t perform any testing or repair of the part. Rather, you simply follow each of the steps and requirements in the applicable overhaul manual, or other approved data you are using in connection with the work on the component part.
In order to understand the FAA’s position, we need to first review 14 C.F.R. § 43.2 governing records of overhaul and rebuilding. Section 43.2(a) tells us that a component part is not “overhauled” unless that part was (1) disassembled, cleaned, inspected, repaired as necessary, and reassembled using methods, techniques, and practices acceptable to the FAA; and (2) tested in accordance with approved standards and technical data, or in accordance with current standards and technical data acceptable to the FAA. This makes sense if you can actually remove the component part and actually take it apart, clean it, and then put it back together, using FAA approved techniques, standards, data etc., of course.
But what about a component part that can’t be disassembled? For example, an aircraft engine can be disassembled, but some of the engine’s component parts are incapable of nondestructive disassembly. Can a component part that cannot be disassembled ever be considered “overhauled”?
According to the FAA, “a part, component, or subassembly of [a] larger assembly or product should … be deemed overhauled if it can be shown to be airworthy by inspection, examination, or tests that do not require disassembly beyond [the part’s] normal state.”
That is, if it would be illogical or impossible to disassemble the component part (e.g. because disassembly would destroy the part) but the mechanic can still both perform the required maintenance and confirm the adequacy of that maintenance (e.g. confirm that the part is in a condition consistent with manufacturer specifications) then that component part would not need to be disassembled in order for it to be considered “overhauled.” Thus, the term “disassembly” as used in Section 43.2(a) does not require destruction of a component part.
Additionally, Section 43.2(a)’s references to “disassembly,” “reassembly,” etc., do not mean that a mechanic has to take any maintenance action beyond what is provided in the design approval holder’s overhaul instructions. Remember, the manufacturer’s overhaul instructions, or any other method used by the mechanic, must be acceptable to the FAA.
As a result, the mechanic must follow all of those instructions or methods for overhauling the component part. And, if during the course of following those instructions the mechanic determines that additional repairs are necessary, he or she must then perform those repairs in accordance with FAA-approved methods and data. Once the mechanic has performed all of the acceptable maintenance processes with respect to the component part, only then may the component part be considered “overhauled.”
How does this apply to our scenario? Well, the important point to remember is that the work on the component part must be performed in accordance with the design approval holder’s overhaul instructions or other methods acceptable to the FAA.
If the overhaul instructions or other methods acceptable to the FAA expressly require only cleaning and inspection of the component part, then Section 43.2 would not require disassembly of the component part in order for that part to be considered and identified as an “overhauled” part. And as a result, the component part in our scenario could appropriately be identified as “overhauled.”
Greg has more than two decades of experience working with airlines, charter companies, fixed base operators, airports, repair stations, pilots, mechanics, and other aviation businesses in aircraft purchase and sale transactions, regulatory compliance including hazmat and drug and alcohol testing, contract negotiation, airport grant assurances, airport leasing, aircraft related agreements, wet leasing, dry leasing, FAA certificate and civil penalty actions and general aviation and business law matters.
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