Does an A&P Really Have to Attend Robinson Factory Training?

By David Botich

Robinson Helicopter Company states in its R22, R44, and R66 maintenance manuals that only appropriately certificated mechanics who have completed the applicable Robinson factory-sponsored maintenance course—or who are working under the direct supervision of such a mechanic—may perform maintenance, repairs, or inspections on the helicopter.

At first glance, that sounds straightforward: no Robinson factory training, no maintenance.

But there is an important question behind that statement:

Is Robinson factory training actually an FAA regulatory requirement for an A&P mechanic, or is it a Robinson requirement that the company has placed in its maintenance documentation?

The distinction matters.

What Robinson says

Robinson's current maintenance manuals contain a section titled "Maintenance Authorization." The language is quite direct. For the R22 and R44, the manuals state that only appropriately certificated mechanics who have successfully completed the applicable Robinson factory-sponsored maintenance course—or who are under the direct supervision of such a mechanic—may perform maintenance, repairs, or inspections.

The R66 manual uses substantially similar language.

So there is no question about Robinson's position. Robinson intends factory training to be a prerequisite for maintenance on its helicopters.

But the existence of the requirement in a manufacturer's manual does not necessarily make it an FAA requirement.

What does the FAA say?

Interestingly, the FAA has addressed this exact issue with other manufacturers.

In a 2012 FAA Office of Chief Counsel legal interpretation concerning Rotax engines, the FAA was asked about manufacturer-required factory and recurrent training. The FAA concluded that Part 43 does not require a certificated mechanic or repairman to complete manufacturer training before performing maintenance.

More importantly, the FAA stated that manufacturers may not impose additional requirements on mechanics or repairmen that are not contained in the regulations.

The FAA went further, explaining that manufacturer maintenance manuals are not themselves FAA regulations and that, without a regulatory basis, manufacturer-imposed training provisions are not enforceable as FAA requirements.

FAA Carpenter Legal Interpretation — Rotax training requirements

The Cirrus case is even more interesting

A 2014 FAA legal interpretation involving the Cirrus SR22 provides an even stronger comparison. Cirrus had language in its FAA-approved Airworthiness Limitations concerning maintenance of its CAPS parachute system. The language stated that the system had to be serviced by Cirrus-trained and authorized technicians and specifically indicated that an A&P certificate alone was not sufficient.

The FAA nevertheless drew a distinction between requiring maintenance to be performed and determining who is legally qualified to perform it.

The FAA concluded that the manufacturer's attempt to restrict the work exclusively to Cirrus-trained technicians was not enforceable from an FAA regulatory perspective.

FAA Hereford Legal Interpretation — Cirrus maintenance personnel requirements

That is significant because the Cirrus requirement was found in the Airworthiness Limitations section—an area that actually carries special FAA-approved status.

In other words, the FAA's position was essentially:

FAA-approved maintenance requirements do not automatically give a manufacturer the authority to create its own mechanic-licensing system.

What about Robinson's maintenance manual?

This is where some terminology becomes important.

Robinson's Maintenance Manuals are part of the aircraft's Instructions for Continued Airworthiness (ICA). Mechanics are required to use applicable maintenance data when performing maintenance. But the FAA distinguishes between FAA-approved data and FAA-accepted ICA. FAA Order 8110.121 explains that maintenance manuals are generally considered ICA that are accepted rather than approved, while certain portions—most notably Airworthiness Limitations—have a different approval status.

FAA Order 8110.121 — Type Certification and Continued Airworthiness

That distinction is important because it means we should not simply say:

"It's in the Robinson maintenance manual, therefore the FAA requires it."

That's not how the FAA's regulatory system works.

So does an A&P need Robinson training?

Based on the FAA material examined here, the most defensible answer appears to be:

Robinson requires it as a condition of its own stated maintenance authorization, but that does not necessarily make Robinson factory training an FAA qualification requirement for an appropriately certificated A&P.

There is no FAR that says an A&P must complete Robinson's factory course before exercising his or her Part 43 privileges on an R22, R44, or R66.

Nor have I found an FAA Airworthiness Directive or other FAA rule that creates such a requirement.

That is an important distinction from saying the Robinson course is unnecessary. Robinson training may be highly valuable, and there can be legitimate reasons for an owner, operator, repair station, insurance company, or Robinson Service Center to require it.

But those are different questions from:

"Does the FAA prohibit an otherwise qualified A&P from performing the work?"

So far, the FAA's own legal interpretations suggest that the answer is no, not solely because the mechanic hasn't attended the manufacturer's training course.

The larger issue

There is a fundamental principle at work here.

The FAA regulates mechanic certification under Part 65 and maintenance under Part 43. Manufacturers are responsible for developing maintenance instructions and Instructions for Continued Airworthiness for their products.

Those two authorities overlap—but they aren't the same thing.

A manufacturer can specify how a component must be inspected, what torque must be used, when a component must be replaced, and what procedures must be followed.

The more difficult question is whether the manufacturer can independently establish who is legally permitted to perform that work by requiring a privately administered training course that is not required by the FAA.

The FAA's Rotax and Cirrus interpretations suggest that there is a significant difference between those two things.

If the manufacturer were allowed to create policy that overrides FAR 65, then that would mean that our FAA issued mechanics certificate would require something like a type certificate for each different manufacturers make and model.

The question I'd like to see answered is if Robinson's factory-training requirement is truly an FAA qualification requirement, there should be a straightforward answer to a straightforward question:

What FAA regulation, Airworthiness Directive, or other FAA-approved requirement makes completion of Robinson's factory course a prerequisite for an appropriately certificated A&P to perform maintenance on an R22, R44, or R66?

Until that question is answered, it appears that Robinson's "Maintenance Authorization" requirement and the FAA's legal qualification requirements for mechanics should not automatically be treated as the same thing.

And that distinction could have implications well beyond Robinson.

Disclaimer: This is an analysis of FAA regulations and FAA Chief Counsel legal interpretations, not legal advice. A mechanic facing an actual FAA enforcement action or disputed return-to-service issue should obtain advice from an aviation attorney and/or the appropriate FAA office.