Progressive Event Inspection Sign Offs

There has been a lot of confusion about Progressive Inspections and who can sign off the individual event inspections. I have researched the Code of Federal Regulations (CFRs) and have concluded only FAA Inspection Authorization (IA) holder can sign off the individual events on progressive inspections. I have been giving a lot of thought to what has to be in the Progressive Manual and have reviewed several manufacture progressive inspection manuals from Piper, Cirrus, and Cessna that I have. Not even the manufacture manuals cover all the requirements Part 91 Section 91.409(d) where it talks about an IA responsibility and how they must perform and/or supervise or who is responsible when it comes to repair stations or the aircraft manufacturer. This got me thinking about what the CFRs says about mechanic limitations so I went back to Part 65 and looked at the limitations for mechanics and IA again. It is clear in Section 65.85 and 65.87 that an A&P cannot perform a Progressive Inspection. In Section 65.95 IA limitations, only an IA can perform the Progressive Inspection and sign it off. So just based on Part 65 limitations it would make sense to me that only an IA is allowed to sign off the individual events showing compliance that the inspection was accomplished. However, I believe under supervision the A&Ps can perform the individual tasks in each event, but sign off the individual event inspection. This reasoning would meet the requirement of Section 91.409(d)(1) where it says and IA, repair station or aircraft manufacture can perform the Progressive Inspection. The responsible person as I read section 91.409(d)(1) is the IA, repair station or aircraft manufacture. The IA cannot delegate that responsibility to an A&P mechanic for the individual event sign off in my opinion. Part 43 Section 43.15(d) talks about the progressive inspection and if away from home base another IA can perform the inspections NOT and A&P again supporting only the IA can sign off the individual event. A progressive inspection is a complete inspection on one identified aircraft that completes a cycle each 12 calendar months. To show compliance that the IA completed a progressive inspection it would make sense for the IA to sign off each event to show compliance. The holder of an IA must personally perform the inspection or supervise the Progressive Inspection in accordance with the rules. The regulations do not provide for delegation of this responsibility. The inspection itself is essentially a visual evaluation of the condition of the aircraft and its components and certain operational checks. When the holder of an IA approves an aircraft for return to service, he or she will be held responsible for the condition of the aircraft as of the time of approval. The regulatory scheme recognizes that the mechanic with inspection authorization (IA) is required to progress a higher degree of skill and experience than is the person who may only repair and maintain aircraft, without the ability to conduct the required inspections. The holder of an IA and other maintenance personnel or agencies are required to record maintenance, inspections, or alterations performed or approved in accordance with the requirements of 14 CFR part 43, §§ 43.9 and 43.11. The owner or operator is required by 14 CFR part 91, § 91.417 to keep maintenance records. The holder of an IA is also required to indicate the total aircraft time in service when a required inspection is done. Responsibility for maintenance work performed rests with the person whose signature and certificate number is entered on the appropriate maintenance record and/or forms. The responsibility for annual and progressive inspections and approval for return to service after major repairs or major alterations is assumed by the holder of an IA whose signature and certificate number appears on the appropriate maintenance records. The owner should be made aware that the annual or progressive inspection does not include correction of discrepancies or unairworthy items and that such maintenance will be additional to the inspection. Maintenance and repairs may be accomplished simultaneously with the inspection by a person authorized to perform maintenance if the owner and the IA holder agree. This method would result in an aircraft that is approved for return to service upon completion of the inspection. (Reference FAA-G-8082-19)

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