ARAC Recommendation For Updates to Mechanic ACS

On July 19, the FAA Aviation Rulemaking Advisory Committee (ARAC) delivered the final report of its Repairman Certificate Portability Working Group to the FAA. The report responds to a March 2021 tasking to provide advice and recommendations on the most effective ways to allow a repairman certificate to be transferrable between employers.

Currently, 14 CFR part 65 ties repairman certification to a specific job at a specific employer. As a result, a repairman must surrender their certificate when changing employers.

 The working group asserts that since the individual’s qualifications have already been established once the repairman certificate is issued, the certificate should remain valid until revoked or suspended. This approach aligns with the standard practice for other airman certificates.

The report further recommends that part 65 recognize repairman certificates as “limited mechanic certificates.” According to the working group, “the FAA issues the certificate based on the misunderstanding that the repairman is a lesser certificate than a mechanic certificate. Rather, the repairman certificate is a limited mechanic certificate that needs to be held to the same technical standard as today’s mechanic’s certificate with respect to the task, function, or specialty performed.”

 If adopted, the limited mechanic ratings would be identical to those of the employer air agency certificate holder and also align with the FAA mechanic ACS elements, as proposed in the report’s draft guidance material. This alignment would clearly and consistently define what the FAA will require a limited mechanic to know, say, and do, based on the employer’s capabilities.

For example, a repair station with a “Powerplant – Reciprocating engines” rating would certify that its employee limited mechanic applicant possesses the knowledge, risk management, and skill set outlined in the ACS general subject areas and all powerplant subject areas, excluding those not directly associated with reciprocating engines (e.g., Section B Turbine Engines, Section K Turbine Engine Air Systems).

Given that part 147 programs are already mandated to align their curriculum with the Mechanic ACS, the proposed link of limited mechanic qualifications to the ACS places schools in a prime position to support training for air carrier or repair station employees seeking limited mechanic certification. If the FAA adopts and implements the recommendation, opportunistic part 147 programs could modularize existing curriculum and offer ACS-aligned training resources to employer partners that are specific to a limited mechanic standardized rating. This approach would ensure that all associated knowledge, risk management, and skill requirements are comprehensively met by the applicant.

To read the full recommendation, visit https://www.faa.gov/regulationspolicies/rulemaking/committees/documents/repairman-certificate-portability-working-group