The Federal Aviation Administration has published InFO 15009 providing clarification concerning the scope of the authorization to operators holding a repair station rating, limited to altimeter and system test and inspection, for compliance with Title 14 of the Code of Federal Regulations (14 CFR) Part 43 Appendix E.
From FAA InFO 15009:
14 CFR Part 43 Appendix E contains the criteria for test and inspection of an altimeter and altimeter system as required by 14 CFR Part 91, § 91.411. Airframe and equipment manufacturers provide recommended procedures for the performance of these tests in their instructions for continued airworthiness. In some cases, these instructions include repair procedures as well as test and inspection procedures.
Altimeter and altimeter system test and inspection procedures may include instructions to perform a calibration procedure when an observed value is outside of tolerance limits. The calibration of a component is a repair action requiring separate authorization beyond the scope of a limited instrument rating limited to 14 CFR Part 43 Appendix E tests and inspections, as is clearly stated on the authorizing Operations Specification (OpSpec), A003, Ratings and Limitations, issued by the FAA.
Unless specifically stated, a repair station holding a limited repair station rating, limited to altimeter and system test and inspection for compliance with Part 43 Appendix E, is not authorized to perform repairs and/or adjustments to an altimeter.
The FAA recommends repair stations review the procedures they follow when performing § 91.411 tests and inspection to ensure the work they intend to perform is within the scope of their authority.
The Aircraft Electronics Association encourages its member companies to review the Operations Specification (OpSpec), specifically A003, Ratings and Limitations. If the limitation does not include ALL aspects of the maintenance performed, contact your FAA CHDO (PMI/PAI) and request a revision to your Operations Specification BEFORE you perform additional work.
FOR MORE INFORMATION:
Contact Ric Peri, vice president of government & industry affairs for AEA, by email at email@example.com or by phone at 202-589-1144.