Why aren’t A&Ps trained as well as pilots are?
I never really wanted to become an A&P. All I really wanted was to be able to maintain my own airplane without adult supervision.
Heck, I’d been doing virtually all the maintenance of my 1979 Cessna Turbo 310 myself for about 10 years. The various A&Ps who had agreed to supervise me all agreed that I now knew more about the maintenance aspects of my than any of them did. It seemed like high time for me to take full responsibility for my work and be able to sign it off.
All I really wanted was something like the Limited Repairman Certificate that the FAA grants to the builder of an Experimental Amateur-Built (E-AB) aircraft that permits them to maintain their own machine. I had absolutely no desire to swing wrenches on any aircraft other than my own. Sadly, the FAA offers nothing comparable for the owner of a certificated aircraft who wants to do his own maintenance (although I certainly wish they did).
My only option was to earn an A&P mechanic certificate. It was an all-or-nothing proposition.
The FAA sure doesn’t make it easy to earn an A&P certificate. They set the bar quite high. Before you’re even eligible to take the tests, you must be able to document 30 months of full-time or 4,800 hours of part-time experience swinging wrenches on aircraft.
To put this in perspective, it takes 40 hours of total flight experience to take the Private Pilot exam, 250 hours for the Commercial exam, and 1,500 hours for the ATP. The 4,800-hour requirement to take the A&P test is a very high hurdle. As a part-time mechanic with a serious non-aviation day job, it took me 10 years of doing 100% of the maintenance on a complex turbocharged piston twin to accumulate enough documented wrench-swinging time to meet the requirement.
Then there are the exams. There are four of them: three multiple-choice knowledge tests followed by an oral/practical exam with a Designated Mechanic Examiner (DME). My oral/practical exam took an entire day and was significantly more difficult than any pilot checkride I’d ever taken (and as a multiengine commercial instrument pilot and flight instructor, I’ve taken quite a few).
Earning the A&P was a major accomplishment, and one that I’m very proud of. But as a longtime pilot and aircraft owner but fledgling A&P, I found certain aspects of my newly-earned A&P status quite surprising.
Privileges and limitations
To maintain my pilot privileges, I must undergo regular recurrent training and regular evaluations. The FAA requires me to submit to a Flight Review with a CFI every two years (even though I’m a CFI myself), and to undergo an Instrument Proficiency Check every six months. My insurance company requires me to undergo annual simulator training in order to keep my airplane insured. Doing all this costs me a lot of time and money, but I think it’s essential and actually look forward to each of these events. They keep me sharp and proficient.
By contrast, I was shocked to discover that once I earned my A&P certificate, the FARs include absolutely no requirement for me to get any sort of recurrent training as a mechanic, and no requirement that my mechanic knowledge or skills ever be re-evaluated by anyone. The FAA treats the mechanic certificate as a license for life. There is a requirement (FAR 65.83) that I exercise the privileges of my mechanic certificate for at least six out of the past 24 months—a requirement that is almost never enforced—but no requirement that my work be scrutinized by anyone else and no requirement that my knowledge ever be re-tested or kept up to date.
That seems so very wrong. Why the double standard?
Here’s something else I found troubling: As a pilot, my privileges are strictly limited by the pilot certificates and ratings I hold. If I want to fly IFR, I’m required to earn an instrument rating. If I want to fly a twin or a helicopter or a glider, I’m required to earn the appropriate category class ratings to do so. If I want to fly a turbojet or a large airplane over 12,500 pounds, I’m required to earn a specific “type rating” for each such make and model that I want to fly. All that is as it should be, I think.
By contrast, as an A&P the scope of my maintenance authority is virtually boundless. The FAA permits me to swing wrenches on anything from a J-3 Cub to a Boeing 747 to a Blackhawk helicopter to the Goodyear Blimp (although in the latter case Goodyear might not be amused). Regardless of whether it’s powered by turbine or recip, constructed of wood and fabric, welded steel tube, monocoque riveted aluminum, or carbon fiber composite, with airfoils that are fixed or rotating, I’m allowed to work on it.
In fact, as an A&P mechanic, there are only two things I’m not allowed to do: major repairs and alterations to propellers (those must be performed by a certified propeller repair station), and any repairs and alterations to instruments (those must be performed by a certified instrument repair station). Literally anything else is fair game for any A&P to perform and approve.
Am I the only one who thinks this makes no sense? Why the double standard?
Call me crazy, but I have long thought that mechanics ought to have to earn “type ratings” in order to work on various types of airframes and engines, just as pilots are required to do to fly them. I also think that mechanics should be required to take regular recurrent training and undergo regular re-evaluation of their knowledge and skills, just as pilots are required to do.
Can the Titanic be turned?
The FAA established an industry advisory group known as the Aviation Rulemaking Advisory Committee (ARAC) to provide information, advice, and recommendations to the FAA Administrator on aviation-related issues that could result in rulemaking. ARAC comprises various working groups that focus on various regulatory issues. One of them is the Airman Certification Standards Working Group (ACS-WG) that has been responsible for creating the new Airman Certification Standards that recently replaced the old Flight Test Standards (FTS) for the Private, Commercial, and ATP certificates and the Instrument rating.
In early 2016, the FAA asked the ARAC ACS-WG to take on the additional task of developing a new ACS for the Aviation Maintenance Technicians (a.k.a. A&Ps). The FAA invited me to serve on the new ACS-WG subgroup tasked with developing a new ACS that would re-define how mechanics were trained and tested. I jumped at the chance to participate in this important effort, because I felt quite passionately that the existing way mechanics are trained and tested was Jurassic and in very serious need of a major overhaul.
Over the next 18 months, I made a half-dozen trips to Washington DC to participate in multi-day meetings of the subgroup, participated in biweekly conference calls with the group between face-to-face meetings, and churned out hundreds of pages of white papers and draft ACS language that I hoped would have a real impact on the subgroup’s final recommendations to the FAA.
Early on, it was made clear to me by the FAA that things like recurrent training and re-evaluation of mechanics was beyond the scope of the subgroup’s charter. So I focused my efforts in three areas:
- Scrapping the old “Airframe” and “Powerplant” ratings in favor of a new system of meaningful type ratings—things like Recip, Turbine, Small Airplane, Large Airplane, Helicopter, Avionics, and possibly Wood Structures, Metal Structures, and Composite Structures.
- Adding a major area to mechanic training/testing on Principles of Troubleshooting—this is the area that existing A&Ps are weakest in based on my experience.
- Adding another major area to mechanic training/testing on Reliability-Centered Maintenance and Avoiding Maintenance-Induced Failures—this is an all-important area that has been totally absent from mechanic training.
After a year and a half of intense effort, I concluded my efforts with the AMT subgroup had accomplished nothing. My ideas met with intense resistance within the subgroup. The FAA participants felt they were way too radical. So did the industry participants who represented the big aviation schools (who had a lot of money invested in their current sillibi and seemed anxious not to make any major changes) and the airlines (who seemed to feel that there wasn’t anything seriously wrong with the existing system of mechanic training and testing).
Very discouraged after 18 months of seeing how FAA sausage is made, I sadly resigned from the subgroup. One can only take so much banging of head against concrete, and I’d reached my limit.
A surgical approach
I just returned from my annual pilgrimage to the national convention of the Flying Physicians Association (FPA), where each year I speak to the group on aviation topics and sit through roughly 16 hours of Continuing Medical Education sessions. I’m not a doc, but I find this stuff fascinating, and in 2011 FPA made me an honorary member. This year, the convention was in Fort Worth, Texas.
One of the presentations I attended was by Tyler G. Hughes MD, professor of surgery at the University of Kansas School of Medicine and a board member of the American Board of Surgery (and a Bonanza owner). His talk was titled “The Surgical Biennial Flight Review,” and dealt with a program that has recently been instituted by the American Board of Surgeons to provide regular recurrent training and re-evaluation of Board-certified surgeons.
My ears immediately pricked up, because I immediately realized this might be relevant to the problem of aircraft mechanic training and re-evaluation. Mechanics, after all, are the surgeons of aviation.
Dr. Hughes explained the American Board of Surgery was founded in 1937 to differentiate formally trained surgeons from doctors in general practice, and to protect the public and ensure professionalism within the surgical specialty of medicine. For a doctor to become a Board-certified surgeon, he had to pass a rigorous series of knowledge and practical tests administered by the Board. (This was over and above the medical licensing requirements of state government entities.)
At first, once a physician passed these tests, he became a Board-certified surgeon for life. But in 1976, the American Board of Surgery became one of the first boards to introduce the notion of recertification by requiring that surgeons undergo retesting every 10 years (a policy that elicited howls of protests from many surgeons at the time, but ultimately became well-accepted practice by most such boards).
This “decennial flight review” continued for the next 40 years. However, the accelerating rate of change in surgical knowledge and practice made the members of the Board increasingly uncomfortable that re-evaluation of surgeons every 10 years was simply not often enough. At the same time, the universal availability of broadband Internet, smartphones, and other knowledge-projecting technologies made it possible to provide both recurrent training and recurrent testing in ways that were vastly more convenient and less disruptive to surgeons’ busy work schedules.
So, in 2016 the American Board of Surgery started replacing the old decennial recertification requirement with a new “continuous certification” protocol that called for Board-certified surgeons to (1) obtain recurrent training consisting of at least 150 CME credits over the past five years (most of which could be obtained online), and (2) undergo recurrent re-evaluation every two years by taking an online “self-assessment” that involves answering 40 questions and scoring at least 80% (i.e., 32 correct answers).
The self-assessment is “open book” but the 40 questions are designed to be quite difficult and challenging. Each doc is giving a maximum of two weeks to complete the self-assessment. If he doesn’t score at least 80%, he gets another chance the following year. If he flunks again, he loses is board certification and must start from scratch to earn it again.
Why couldn’t we do this?
What if various aviation industry players got together and created an American Board of AMTs? What if they offered Board-certification of mechanics that was over and above and independent of what the government (FAA) requires to earn a mechanic certificate? This new Board could define a set of subspecialties (a.k.a. type ratings) and could Board-certify mechanics in each of the subspecialties in which the mechanic wished to practice.
What if mechanics then listed their Board-certification credentials proudly after their names and “A&P” license designation, just as board-certified physicians now do—for example, “Dirk D. Doctor, MD FACS” where the “MD” denotes the government license (Medical Doctor) and the “FACS” denotes the board certification (Fellow, American College of Surgeons). Perhaps savvy aircraft owners would then look for these credentials when choosing their mechanics just as savvy patients now do when choosing their surgeons and other medical specialists.
Now, what if the AMT Board instituted a “continuous certification” program of recurrent training and recurrent re-examination, along the same lines as what the American Board of Surgeons recently did? Would that be insanely great, or what?
You bought a plane to fly it, not stress over maintenance.
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