Bell Helicopter 407
Maintenance Airframe; Maintenance Powerplant
Maintenance Technician 12
Confusion; Training / Qualification
Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Published Material / Policy
General None Reported / Taken
Chart Or Publication; Human Factors; Procedure
I may have inadvertently violated CFR 14 65.81 by supervising the installation of a First Surface Vinyl wrap on the exterior of a Bell 407 helicopter. While I have applied many First Surface Vinyl decals and 'N' number registration numbers in the exact same way; this is sort of a gray area. During a routine conformity check; a member from the Certificate Management Team (CMT) inquired as to how we obtained information for the installation of this vinyl wrap and did not seem satisfied with the descriptive sign off and reference of the CFR 14 part 43 appendix A paragraph(C) item 9. The CMT member questioned my abilities to install a large sticker on the exterior portion of the aircraft that did not require removal or disassembly of any primary structure or operating system. In hindsight; I could have used CFR 14 part 43 app A paragraph (c) item 10 instead since there is no published data saying that the first surface vinyl is not permitted on those areas or considered contrary to good practice.I believe the major issue; as is with most CFR's; is the opinion of the administrator and the intent of the CFR. Ask 5 different [inspectors] their interpretation of a CFR and you'll end up with 5 different opinions.
Maintenance Technician reported during an FAA routine conformity check; there was ambiguity in the translation of FARs regarding the instillation of vinyl decal on the exterior surface.