Welding

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lowej42_1
lowej42_1's picture
Welding

In general how does the FAA feel about welded repairs, who effects the repair, and are there specific regulations covering welding?   I've seen repair stations certified for welding, how do you get your repair station certified? 

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n14ky
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Read AC 43.13-1b Chapter 4. An A&P can weld pretty much anything he has the equipment for and the specs for and is weldable. Over time, I've done welded repairs on steel tube fuselages, exhaust systems, landing gear, fairings, seats, and on and on. Welded repairs are Major Repairs for the most part and will need a 337 and an IA to inspect it, and be done in accordance with Approved Data.

For a repair station, it kind of depends on what you repair station is rated for along with what equipment you have and the training of your employees.

For all welded repairs, the Approved Data is the key, without approved data it's a non-starter. With approved data, proper equipment and the necessary skill set, have at it. A&P license and an IA to inspect is all you need to return the item to service

Even A&P mechanics have limitation when it comes to welding under part 43.13. You have to have the tools, equipment, proper training (welding rating in some cases) and follow the manufacture manuals.

This is where the limitations comes in for mechanics if the manual indicates you hold a welding rating for a certain metal then as an A&P you cannot perform the welding task. Under part 145 repair station welding is a specialized service and requires the repair station he meet part 43.13 requirements and have their welder certified by the American Welding Society for the type of metals they will be welding i.e. aluminums, steel, stainless steel and etc.

As stated; “For all welded repairs, the Approved Data is the key, without approved data it's a non-starter”. This is a very true statement and welding is a major repair that requires a form 337 according to part 43 Appendix A (b) for primary structure.

Bottom line here is read the maintenance manual to see what is required, does it allow welding for the part, if so is there any limitations on who can perform the task, and do you have the tools, training, and equipment.

whitefaced
whitefaced's picture

Welding is a maintenance task, no different from riveting, parts replacement, or any other maintenance task. Where an A&P rated mechanic is concerned, the rules that govern whether or not he/she can legally perform this task are contained in 14 CFR part 65. An FAA accepted maintenance manual cannot impose additional limitations on mechanic privileges and limitations. I would argue, that even the FAA approved portions (ie ch. 4, or TCD) cannot stipulate WHO is allowed to perform welding operations. An airworthiness directive however would have the authority to do this.
Once an A&P meets the part 65 requirements, then part 43 requirements stipulate HOW the welding task must be performed.

In some respects I agree a mechanic can perform a welding tasks as long as they meet part 65.81 as stated below where it talks about “for which he is rated unless he has satisfactorily performed the work concerned at an earlier date.”

§ 65.81 General privileges and limitations.
(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§ 65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

This takes us to part § 65.85 Airframe rating; additional privileges.
(a) Except as provided in paragraph (b) of this section, a certificated mechanic with an airframe rating may approve and return to service an airframe, or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations).

I think a mechanic can weld as long as it is not a major repair or major alteration as the rule indicates. However, this still takes us back to part 43.13.

§ 43.13Performance rules (general).
(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator.
(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

The current manufacturer’s maintenance manual by regulation is the first manual to use in maintenance to know what procedure to use. If no procedure is provided then AC 43.13 may be used if the aircraft meets the requirements explained on the title page. This is the same for welding, riveting, corrosion removal, minor propeller repairs and etc. The key here is part 43.13(b) where it says will be at least equal to its original or properly altered condition. If you make it better than (stronger) or less than (weaker) it is unacceptable. So my concern is welding does effect metal depending on what you are welding and one must use caution in this area not to make it better than or less than CYA.

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