A question for the FAR Gods

Tom playing "stump the chump" reminds me of Lucy, Charlie Brown, and the football.

Why do you keep playing the game?
 
Tom-D said:
Your LOI refers to who can return to service after an annual inspection. When did that become the question?
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It never was in question. That LOI was for Fast Eddie. The extra credit Tom question was the post before it.
 
kyleb said:
Tom playing "stump the chump" reminds me of Lucy, Charlie Brown, and the football.

Why do you keep playing the game?
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Apparently the stump has been chumped.
 
kyleb said:
Tom playing "stump the chump" reminds me of Lucy, Charlie Brown, and the football.

Why do you keep playing the game?
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Why is it, when others make their opinions known to a question I present, you believe that I'm playing stump the chump?
I often ask questions, why should you take offense to that?
 
Wow, guys. You make this too hard. An annual inspection is just that. An inspection. Any actual maintenance done can be done by anyone as long as it is properly supervised and signed off.

As to Tom’s original question, why not just log the work done as maintenance throughout the month? I assume you would have inspected it in order to return it to service. All an annual really is is a series of mini inspections. Personally, I would have no problem with Tom’s scenario because I believe it fulfills the intent of the regulation.
 
Tom....using your logic one could start the inspection 7 -8 month’s ago and sign it off when done. o_O
 
Tom-D said:
That really depends upon how far the IA is willing is to stretch it.
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I'd go over a couple of week ends.....but the plane is grounded.

I'm thinking you're gonna have issues with your thought process.....especially if you drag out the inspection over weeks...and then they turn into months.
 
Greg Bockelman said:
Wow, guys. You make this too hard. An annual inspection is just that. An inspection. Any actual maintenance done can be done by anyone as long as it is properly supervised and signed off.

As to Tom’s original question, why not just log the work done as maintenance throughout the month? I assume you would have inspected it in order to return it to service. All an annual really is is a series of mini inspections. Personally, I would have no problem with Tom’s scenario because I believe it fulfills the intent of the regulation.
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A long restoration period usually ends with an annual sign off with out going back and opening every thing up again.
 
To me, the FAA only is concerned with 1 thing, when was it completed, and the 12 month clock zeroed.

I've never been asked "when did you start this annual"?
 
kyleb said:
Tom playing "stump the chump" reminds me of Lucy, Charlie Brown, and the football.

Why do you keep playing the game?
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To most who participate it isn't a game.
 
Tom-D said:
To me, the FAA only is concerned with 1 thing, when was it completed, and the 12 month clock zeroed.

I've never been asked "when did you start this annual"?
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how is what you are describing different than a progressive inspection?
 
Checkout_my_Six said:
how is what you are describing different than a progressive inspection?
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Progressives are signed off in segments, phase 1, phase 2, etc. and are required to be completed once per year.
Annuals as I described are completed once per year and signed off once.

we really have no guidance on how long one should take, nor do we want any.
There are occasions when annual and it's associated repairs may take a year.
 
Checkout_my_Six said:
how is what you are describing different than a progressive inspection?
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Well for one... a progressive inspection requires a written request to the local FSDO and approval. It also requires references well outside of 43 Appendix D and terminating the inspection program requires immediate FAA notification.
 
Bell206 said:
Well for one... a progressive inspection requires a written request to the local FSDO and approval. It also requires references well outside of 43 Appendix D and terminating the inspection program requires immediate FAA notification.
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Progressive inspections were designed for aircraft used for commercial service where being laid up for a period of time would impact their earning ability.
When making the flight schedule is a prime concern progressives make sense, helping an owner use their aircraft better can be simple.
 
I'm sorry, but Tom is correct. The FAR is silent on the matter, so it is left to the discretion of the IA as to what is within the limits of their limits.

I do an annual in December of 2016. It is good until the end of December 2017. I inspect the motor in January 2017. I inspect the airframe in July 2017. I inspect the appliances (carb filters, brakes, and the like) in November 20I7. I put the last cowl screw in on New Year's Day 2018 and sign the annual. And the airplane has flown a couple of hundred hours that year between annuals.

Somebody tell me with chapter and verse of the FARS where I cannot do that. Don't give me the bushwa that I'm doing a progressive without a progressive approval because I ain't . Give me CHAPTER AND VERSE of the FAR where I cannot do that. Would I do that? Not a chance in hell. But COULD I do that is the question.

Will the FSDO ask me what the hell I think I'm doing? Probably. But I'll ask them to quote them same chapter and verse.

Jim
 
weirdjim said:
Somebody tell me with chapter and verse of the FARS where I cannot do that. Jim
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When I started this thread, I thought there was one,, but couldn't find it. seems like there ain't one.
had a conversation with an ASI and they agree there isn't any guidance on the subject.
They simply do not want to limit the IA's judgment on how long it should take, because there is no one rule that would fit all.
 
Tom-D said:
A long restoration period usually ends with an annual sign off with out going back and opening every thing up again.
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A major rebuild will not be flying, accumulating wear and tear and time either.

Say the rebuild has been solely on the left wing. It was opened up for repairs and the IA (who is also the mechanic doing the work) personally saw everything and can attest that all the items included in an annual have been inspected. The right wing and the engine and the prop and the airframe, etc will still have to be inspected before the AIRCRAFT can be certified as having had an annual inspection.

The AIRCRAFT is what is inspected, not the individual pieces.

Can you legally perform an annual on an aircraft with no prop installed? As Tom said:

Tom-D said:
That really depends upon how far the IA is willing is to stretch it.
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You can do whatever you can get away with.
And since the FAA is reactionary, and has burden of proof that an FAR was/is violated, odds are nothing will happen by doing it Jim's way.
 
Bell206 said:
Now a carry on question of my own:
When you sign off your annual inspections as airworthy, which version of airworthy are you implying to, the regulatory definition or the statute definition?
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What is the difference between legal vs statutory definitions?
 
JAWS said:
Actually, you cannot legally perform an annual on an aircraft that has had it's prop removed. It is explained in the link below that was previously mentioned.

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2015/stanley - (2015) legal interpretation.pdf
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Review the definition of airworthiness.

You can complete the inspection and declare it un-airworthy, give the owner/operator a list of unairworthy discrepancies.
1. Prop missing,
then any authorized person can return the aircraft to airworthy condition by repairing that discrepancy.
Notice this falls far short of requiring the entry in the equipment maintenance records.
quote from the reference.

Thus, if an owner or operator maintains multiple logbooks for the aircraft, it would be good practice for the holder of an inspection authorization to document the completion of an annual inspection in each of the respective logbooks. If the holder of an inspection authorization chooses to document the completion of an annual inspection in a maintenance logbook for equipment other than an aircraft, he or she should make the record entry specific to the product. For example, ifthe holder of an inspection authorization chooses to document the completion of the annual inspection in the maintenance logbook for the propeller, he or she should document the following or a similarly worded statement-"! certify that this propeller has been inspected in accordance with an annual inspection and was determined to be in an airwmihy condition." However, for the reasons explained above, the rules require the holder of an inspection authorization to document only that the aircraft has received an annual inspection. Also as noted above, an annual inspection of an aircraft includes inspecting the engine and propeller.

Leave this solely up to the IA.
Personally, I ask the owner which they prefer, I have no heart ache doing it either way. They are your records. they should contain what you want.
 
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Checkout_my_Six said:
I'd go over a couple of week ends.....but the plane is grounded.
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In actuality when the inspection finds discrepancies, ISn't the aircraft unairworthy until they are corrected?
But if the discrepancies are corrected and returned to service, isn't the aircraft airworthy and safe to fly.?
why would the annual inspection need to be signed off at that time?
 
I am not so sure. The annual would still need to be performed on the found prop after the fact. How would that work? Plus, there would be other items that could not be performed as part of the annual, such as the engine runs and ops checks, with no prop installed. As noted above:

Tom-D said:
the rules require the holder of an inspection authorization to document only that the aircraft has received an annual inspection. Also as noted above, an annual inspection of an aircraft includes inspecting the engine and propeller.
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The aircraft is the sum of all of it's parts - engine, prop, left wing, pilot seat, right elevator, nose wheel, etc, etc. The annual is supposed to be a "snapshot" in time that attests that it was airworthy on this date. An aircraft can't be airworthy if it is missing a prop (other than a jet :)) or the right elevator or some other part that is legally required in order to make the aircraft whole (meet it's type design).

What if the prop is attached, but is found to have a few nicks in the leading edge? Would that change anything? :eek:

As far as performing maintenance over a period of time and using that as a reason to justify signing off on an annual at a later date, to appease an owner ... sorry, not this guy. I am not saying that I don't bend a bit here and there, but I feel it is a slippery slope and once you start going down that path, it can become difficult to stop. My licence and livelihood are intertwined, but I also need to sleep at night.

I find it funny how an owner who flys maybe 10 hours a year will need his aircraft right at the moment it is due for an inspection, like somehow it came out of no where! And of course the "mission" is life and death! :rolleyes:
 
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Jim, do you just do the annual on your own aircraft that way, or do you do friends, or customer's aircraft that way, too? Or was that just hypothetical? Portions of your annual are being accomplished at different TAT, if you are only recording one TAT for the completion of annual I can see how it could be considered falsification, and an illegal progressive inspection.
 
JAWS said:
What is the difference between legal vs statutory definitions?
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The regulatory definition conforms the aircraft to its type design and the statutory (law based) version conforms the aircraft to its type certificate.
 
Tom-D said:
Annual inspections.
I didn't want to hijack Jeff K's thread
I start an annual on the first of the month. I do the engine group of required items of FAR 43-D.
This aircraft's annual does not expire until the end of the month.
Can I release this aircraft return to flight status?
then after the flight do more items of the required items of FAR 43-D. then allow the aircraft to go fly again.
wash rinse, repeat until all the items of the required items are done, then sign off the annual on the first of the next month.

Is this legal?
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Not where I went to mechanic school.

Say the valves are burned during the release to service. Then you finish with the airframe and sign off the aircraft as airworthy. The reference is your signature.

§43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”​

dtuuri
 
That's what I said way back earlier. It may not be inked in a FARs anywhere but common sense dictates that if you inspect an engine, allow it to be flown for a few months and a few dozen hours, and sign off the annual a few months later stating that the aircraft/engine is airworthy on that date, then you are committing fraud (or perjury, or whatever the legal term would be in this case) because you don't know what might have happened to that engine in the interim.
 
timwinters said:
That's what I said way back earlier. It may not be inked in a FARs anywhere but common sense dictates that if you inspect an engine, allow it to be flown for a few months and a few dozen hours, and sign off the annual a few months later stating that the aircraft/engine is airworthy on that date, then you are committing fraud (or perjury, or whatever the legal term would be in this case) because you don't know what might have happened to that engine in the interim.
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If you find burned valves, would you sign it off as airworthy prior to them being fixed?
The idea wasn't a few months? I suggested maybe a month. Your light civil shouldn't take over a couple nights to do anyway.
what harm does it do to allow the aircraft to be flown during the annual?
 
dtuuri said:
Not where I went to mechanic school.

Say the valves are burned during the release to service. Then you finish with the airframe and sign off the aircraft as airworthy. The reference is your signature.

§43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”​

dtuuri
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dtuuri said:
Say the valves are burned during the release to service. dtuuri
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Valves don't burn over night, had the inspection started a month prior to the drop dead date of the annual, I don't believe you'd find burned valves in a month of services.
When you start an annual, then find a big repair, and the aircraft sets in the corner of the Hangar for 6 months while it is repaired, are you going back and reinspect every thing that had already been done?
 
Tom-D said:
what harm does it do to allow the aircraft to be flown during the annual?
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Because once it's flown, you no longer know the condition of that engine.

It's not rocket surgery, Tom.

But, more importantly, you should bring your signature tag line from Red over here.
 
timwinters said:
Because once it's flown, you no longer know the condition of that engine.

It's not rocket surgery, Tom.
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When you do the whole engine inspection, clean plugs, change oil/filter, would you expect it to fly 3 hours, an still be airworthy?
When you service wheel bearings and brakes would you expect them to make 2 landings and still be airworthy?
It certainly isn't rocket science to realize that when aircraft are in perfect condition they will continue to operate normally.
I worry more about aircraft that get 5-10 hours per year than I do ones that fly most every day.
 
JAWS said:
I am not so sure. The annual would still need to be performed on the found prop after the fact. How would that work? Plus, there would be other items that could not be performed as part of the annual, such as the engine runs and ops checks, with no prop installed. As noted above:



The aircraft is the sum of all of it's parts - engine, prop, left wing, pilot seat, right elevator, nose wheel, etc, etc. The annual is supposed to be a "snapshot" in time that attests that it was airworthy on this date. An aircraft can't be airworthy if it is missing a prop (other than a jet :)) or the right elevator or some other part that is legally required in order to make the aircraft whole (meet it's type design).

What if the prop is attached, but is found to have a few nicks in the leading edge? Would that change anything? :eek:

As far as performing maintenance over a period of time and using that as a reason to justify signing off on an annual at a later date, to appease an owner ... sorry, not this guy. I am not saying that I don't bend a bit here and there, but I feel it is a slippery slope and once you start going down that path, it can become difficult to stop. My licence and livelihood are intertwined, but I also need to sleep at night.

I find it funny how an owner who flys maybe 10 hours a year will need his aircraft right at the moment it is due for an inspection, like somehow it came out of no where! And of course the "mission" is life and death! :rolleyes:
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The problem with your theory is, annual inspections do not have to be signed off as airworthy.
to be airworthy it must be in a condition for safe operation. "Not fully assembled, is not airworthy"

with your prop situation, you'd make a decision is it airworthy? or not?

All maintenance takes time, (that is what we bill). it is just a matter if we allow the aircraft to be used during the inspection.

I have always tried to help my customers to use their aircraft the best way possible, I don't mind doing their maintenance when they want. Isn't that what they pay us for?
engine run ups and any other required items must be done prior to sign off, there is no getting around that, plus was never insinuated that any step be omitted.
I always see the engine run up numbers prior to signing it off, it does not matter that the owner is going to fly it away right after that.
 
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