A question for the CFIa amoung us
- Thread starter Tom-D
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Tom-D
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Tom-D
You work the op side of the FAA, what guidance do you give the DPEs in your FSDO?This will be the 23rd CR,but who's counting?
Tom-D
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Your great fantasy is placed in service, I'm standing on a dock in south east, with my SES trying to return it to service, and have no cell connection, So would I wait until AT&T builds a cell tower? or violate the FAR 43 regs?
EdFred
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Sound like the same situation as if I don't have my logbooks with me.
denverpilot
Tied Down
Already covered that. Paper is an acceptable substitute until appropriate Net connection can be found to update the online records. And online system can be printed if folks want paper "backup".
Heck, it's no worse than getting the sticker today. Or even WINGS...
Get sticker for MX today, enter data later, request is sent to A&P for confirmation. Even better than signing book next to sticker.
This isn't that difficult.
Anyone still getting cancelled checks from their bank? (Not many do... they're going away.) Still sending paper mail to their stock broker and waiting a month to get stock certificates?
The paper logbook system is outdated. It works, but it could be a whole lot better.
I'm no giant fan of government in general, Tom... but you yourself have said folks need jobs. This could create some if everyone weren't so afraid of trying something new/different. Scared of our own shadows... nobody with enough guts to stand up and say, "It's time to modernize this."
But we'll keep hearing about how 1990's unencrypted, unauthenticated, low-speed data based off of infinitely jammable GPS (ADS-B) is "the future" and moving forward on that one...
Seems like centralized automated maintenance record-keeping is a lot lower hanging fruit than ripping out a working ATC system. But, I know... I'm crazy.
Most 121 carriers already have computerized MX record-keeping, they just don't have a published interexchange format to send it to FAA, right? Start there... work down to the shade-tree...
jesse
Touchdown! Greaser!
Have you used IACRA or any other FAA website? *shudder* The last thing I want is to *HAVE* to use their website for maintenance logs.
What I would prefer is a system in the private sector that is built in a manner acceptable to the Administrator. Honestly, I really can't see any reason it couldn't be done now.
denverpilot
Tied Down
Nope, haven't had the uh... pleasure... yet.
Yup. Well, except for the whole willpower thing (you know, the OSI model goes to Layers 8 and 9... Religion and Politics)... we'll have to wait for more folks who didn't grow up with computers to die off to get that part accomplished.
bgdriveway
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Ah.... but there are always exceptions to the rule, among other things, a progressive can be done. I worked on a 172 that was on a progressive for a little while. Part 91. And also if you read 91.409 close enough turbine rotorcraft can be on a 100 hr inspection. No annual needed. No progressive, just 100 hr inspection. (And all the life limited parts....)
As to the centralized mx database, call me paranoid, (but just because I am paranoid doesn't mean that they are NOT out to get me) but I don't want anyone in the FAA to be able to look at all my log entries just whenever they want. Just like I don't want anyone to be able to track me where ever I go. (The whole big brother deal. I don't want a national medical records database either.) I'm not trying to hide anything, but we are human. We make mistakes on occasion, for one thing. I don't want my licenses pulled because of an honest mistake. And I know of a particular case where that has happened. FAA inspector with a grudge against someone.... (Note to owners, double check times and such. Copy and paste is nice, but sometimes we forget to change times or dates. Is it our fault, yep, but it happens.)
It's actually scary how much info someone can find out about you if they know how to look for the info. (I know how to look...) Consolidated info is not always better. I'm not anti-technology at all. I have used computerized maintenance systems, from excel spread sheets, to online systems like the air carriers use. For tracking items due, they work great (As long as someone puts the times into the system.) For log entries, they are a pain in the hindquarters. Typically you have to fill out a separate entry for each job you do instead of listing 10 or 15 things you did on one form. Could that be changed, sure, but that's not how the systems are or likely to happen. They usually are like job cards that the airlines have. Again, a real pain.
I happen to also be an EMT. When the various agencies I have worked/work/volunteer for, switched from paper to computer, it more than doubled the amount of time to complete the paperwork. Bad designed programs for the paperwork, sure, but everyone says "Oh, we have a computer program, we can make them do all this extra stuff." Which ends up in a lot of duplication on the same form.
Computers are good, I like them for tracking times/ components, AD's etc. but for log entries, No thanks.
Oh, and I grew up with computers, the one everyone comes to when they have a computer problem. Not a true IT guy or understand all that, but I am quite familiar with computers in general.
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Ghery
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Yes, in the past week or so. And, no, I wouldn't want to deal with it on a routine basis.
RotorAndWing
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Better reread that. A turbine helicopter can be on a 100 hour inspection but an Annual is also required.
Doggtyred
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And the annual can serve as a 100 hr. And if you want, any 100 hr performed and documented as meeting annual requirements can restart the calendar for the next annual.
bgdriveway
Pre-takeoff checklist
There are all sorts of exceptions for turbine powered aircraft in 91.409. Including turbine rotor craft. Also turbine multi-engine fixed wing don't have to have a complete progressive done every year if the manufacturer has that written into the program. (I worked on a king air that maybe flew 100 hrs a year. We did Phase 1 and 2 one year, 3 and 4 the next.) They can have it extended to 24 calendar months.
I am going to quote portions of 91.409 here
a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had......... [an annual inspection]
(c) Paragraphs (a) and (b) of this section do not apply to--
(3) An aircraft subject to the requirements of paragraph (d) [D is related to progressives] or (e) of this section; or
(4) Turbine-powered rotorcraft when the operator elects to inspect that rotorcraft in accordance with paragraph (e) of this section.
(e) Large airplanes (to which part 125 is not applicable), turbojet multiengine airplanes, turbopropeller-powered multiengine airplanes, and turbine-powered rotorcraft. No person may operate a large airplane, turbojet multiengine airplane, turbopropeller-powered multiengine airplane, or turbine-powered rotorcraft unless the replacement times for life-limited parts specified in the aircraft specifications, type data sheets, or other documents approved by the Administrator are complied with and the airplane or turbine-powered rotorcraft, including the airframe, engines, propellers, rotors, appliances, survival equipment, and emergency equipment, is inspected in accordance with an inspection program selected under the provisions of paragraph (f) of this section, except that, the owner or operator of a turbine-powered rotorcraft may elect to use the inspection provisions of Sec. 91.409(a), (b), (c), or (d) in lieu of an inspection option of Sec. 91.409(f).
(f) Selection of inspection program under paragraph (e) of this section. The registered owner or operator of each airplane or turbine-powered rotorcraft described in paragraph (e) of this section must select, identify in the aircraft maintenance records, and use one of the following programs for the inspection of the aircraft:
(3) A current inspection program recommended by the manufacturer.
(4) Any other inspection program established by the registered owner or operator of that airplane or turbine-powered rotorcraft and approved by the Administrator under paragraph (g) of this section. However, the Administrator may require revision of this inspection program in accordance with the provisions of Sec. 91.415.
Lets take a Jet Ranger, on which I work for a 135 operator. (We do annuals, but that's besides the point. We are 135, not 91.)
You could do an inspection series on a Bell 206 as per Bell, and not do an "annual". There are 12 month inspection requirements, but what is required for those 12 month items do not even come close to a annual inspection.
Or you could talk to your FSDO and get any sort of inspection that is reasonable to the FAA dude signing it off without actually doing annuals.
RotorAndWing
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I am fully aware of the Inspection requirements. I was commenting on your quote:
You insinuated that a turbine powered rotorcraft could only be inspected via 100 hour inspection if the operator so chose.
In reality one must use a) annual inspection or b) progressive inspection or c) Approved Manufacturer Inspection (which is a progressive system).
You left out an important section:
No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records.
That's a "progressive inspection" and must be followed through it's entirety which if done correctly is as comprehensive as an Annual. That inspection is based upon a) time flown and b) calender time. While the entire inspection is not done at one event the entire cycle of the inspection is comprehensive. An operator cannot jump back and forth between progressive and annual requirements, it's either one or the other.
An Airworthiness Inspector will usually defer to the manufacturers progressive program for that particular airframe. If the inspection the operator is proposing is any less than that it will not get approved.
Once again, it's going to be an a) Annual Inspection or b) Progressive Inspection.
bgdriveway
Pre-takeoff checklist
Well then why are there multiple paragraphs if they are all the same? para. (d) which is about progressives, and (e) which is other means of compliance in the 91.409? Unless you are broadly classifying every inspection as either an annual or a progressive. I would then wonder about a "progressive 100hr"?
Secondly, even if a progressive insp. was done, it would not be "performed under paragraph (b) of this section". It would be under para. c. or other. Anything performed under para. b is an annual.
Thirdly, I know of a case where the FAA was after a guy. Something about a grudge maybe. I don't know the whole background. Anyway, the records for the one particular heli were gone through in detail. The guy is an A&P only. (Which you cannot even supervise a progressive unless you are an IA. I'm sure you know this, but I am including it for all the others that will be reading.) The FAA did not bust him on not having an annual inspection. They got him for something else. Maybe oversight, but I don't think so.
And even if a ASI usually goes with the manufacturer's recomendation, that doesn't mean they have to, or always will. Just means that most of the time they do.
The real point is that they want the whole aircraft inspected on a regular basis, that they want it to be safe, and they realize that one size doesn't fit all. Turbine powered aircraft are one of the areas that you have more latitude in how you get your inspections done.
Secondly, even if a progressive insp. was done, it would not be "performed under paragraph (b) of this section". It would be under para. c. or other. Anything performed under para. b is an annual.
Thirdly, I know of a case where the FAA was after a guy. Something about a grudge maybe. I don't know the whole background. Anyway, the records for the one particular heli were gone through in detail. The guy is an A&P only. (Which you cannot even supervise a progressive unless you are an IA. I'm sure you know this, but I am including it for all the others that will be reading.) The FAA did not bust him on not having an annual inspection. They got him for something else. Maybe oversight, but I don't think so.
And even if a ASI usually goes with the manufacturer's recomendation, that doesn't mean they have to, or always will. Just means that most of the time they do.
The real point is that they want the whole aircraft inspected on a regular basis, that they want it to be safe, and they realize that one size doesn't fit all. Turbine powered aircraft are one of the areas that you have more latitude in how you get your inspections done.
Tom-D
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If you are due a 100 hour, you can complete an annual and reset the clock.
They are the same Scope and Detail,(43-D) but it is a matter of who can sign the annual off and where the signature goes.
AC43-9C para 10, (d) last sentence
RotorAndWing
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Not true. If the manufacturer has a program then that will be followed unless the operator can show an alternate means of compliance, but then that does not allow the operator to do any less of an inspection.
Your previous claim that an A&P can just perform 100 hours on a turbine powered helicopter in lieu of annual/progressive inspections is simply not true.