Anonymous

Let me first state that I have 30 years as an A&P working in Factory Service Centers, FBO’s, U.S. Military and Corporate aviation in capacities from line mechanic to DOM, so I have been around the block. From the perspective of an Active A&P if an AD is issued and it pertains to specific “parts” with specific “part numbers” then it is my responsibility to determine if those “specific” parts are currently installed on the aircraft I am maintaining. If I determine that those “specific” parts are not on this aircraft at this time then I need to state in the log book as the AD being “non-applicable” to my aircraft, sign it off and take responsibility for this action. It is not my responsibility to make engineering determinations as to the applicability of the already installed “serviceable part” which has been installed and has corresponding documentation stating the “serviceability” of this part that was obtained from an FAA certified vendor and/or manufacturer. My suggestion in regards to FAA-2010-1167 is for the legal team (WG; ADARC) to actually go into the field and observe what goes on in the field, or more plainly state “in the real world” of aviation. You cannot actually know what happens out here unless you have experienced it, and sitting in an office reading proposals/drafts/briefs is definitely no substitute. It would also be a substantial improvement to the FAA if they got their internal house in order (having leadership would be a good start!), such as all FISDO’s working from the same play book and not as “little fiefdoms”, experienced and qualified field personnel and less time spent in trying to place responsibility on those of us who already have plenty. As I read the supplementary information I believe that what I am reading is once again the FAA’s intent to relieve themselves of their responsibility to ensure the safety of aircraft and place it on a part of the industry that has little or no control over the areas that are in question., in