Eddie O. Cunningham

Comments for proposed rule making FAA-2010-0224 notice number 10-5 This is a great opportunity to correct a long standing problem. We missed this issue when it came to EWIS but hopefully we can correct it now. Currently Items classified as precision tools required for returning an aircraft to service such as, Wire crimpers and torque wrenches have no clear regulatory requirement to be calibrated. All repair stations and most Air Carriers’ consider the importance of these tools and include them in their calibrated tool program; however, there are many that don’t. The reasoning behind this is, it is only a manufacturer’s recommendation and there is no regulatory requirement that says they must include certain tools in their calibrated tools program. It only requires them to have one. I have spoken to many manufactures that will not change their suggested practice to a requirement simply because they sell these tools to many clients that have no connection to aviation. Since we have the opportunity I believe that now is a great time to mandate the calibration of precision tools that are used to return an aircraft to service due to the importance of ensuring that a positive crimp, torque or connection is made.