AD Compliance - Fuel Injection Lines

NealRomeoGolf

NealRomeoGolf

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Does an AD have to explicitly say in the compliance section that a private pilot can perform the AD, or if it involves an inspection that falls within preventive maintenance then the private pilot can perform it?

Specifically asking about AD 2015-19-07 which requires an inspection of the fuel injection lines for Lycoming engines. Part 43 says a private pilot can replace pre-fabricated fuel lines, which to me sounds like I can inspect and replace lines as needed under this AD. Or am I overreaching here?

https://rgl.faa.gov/Regulatory_and_...acb0f30786257ecf005d80c7/$FILE/2015-19-07.pdf

https://www.lycoming.com/sites/defa...Support Clamp Inspection and Installation.pdf
 
NealRomeoGolf said:
Does an AD have to explicitly say in the compliance section that a private pilot can perform the AD,
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Yes. You can still perform the work but under supervision of your mechanic as he'll need to sign it.
 
Good catch!

Might be a good idea to post a pic.

Typically I see a gap of about .030 in the silver solder joint.


It seems some of these just go forever.

Other times when one fails another one does likewise in 100 -200 hrs.

Can it be a QC is
 
The AD was issued because those lines are so critical to safety. If one breaks or starts leaking in flight, you have a stream of gasoline spraying all over the hot engine and exhaust. Because there's an alternator and a couple of magnetos that are not sealed (usually) and are sparking internally, and an exhaust system that is often red-hot at high power settings, a fire is pretty much a given, and a fire like that is often unsurviveable.

Those lines are often just bent up out of the way by mechanics doing injector or cylinder work. That fatigues the stainless tubing and can cause cracking that leads to a failure. If the rubber cushion in a clamp fails due to age and heat and vibration, the aluminum clamp strap eats into the tubing, weakening it. Long unsupported sections of line will resonate with engine vibration, work-hardening and cracking the tubing.

Proper inspection and correction of defects is paramount, therefore, and the average owner just doesn't have the basic awareness of the hazards here to just go replacing prefabricated fuel lines. Might be legal, might also be lethal. Knowledge and wisdom are two very different things.

Owners also typically overtorque hardware, and overtorquing the tubing fittings is another way to introduce incipent failure. You can swell or crack those nuts, and you can start shearing the threads on the injectors and manifold fittings. If not careful you can get dirt or grit or paint flakes into the line or injector. This AD is not one of those done-by-owner things.
 
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It seems Dan nailed it.

New Lines are not bent per removed and there is a bend radius concern.


However; finding the defect at oil change, researching and ordering parts along

with cowling R & R provides lot of possible owner involvement.
 
There is no need to analyze this, the actual answer is much simpler. If the inspection can be performed and signed off as completed by the pilot it will state that in the AD. If it doesn't it can't.
 
Dan Thomas said:
Those lines are often just bent up out of the way by mechanics doing injector or cylinder work.
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FYI: Lycoming has been shifting to Part 33 certification standards on some of their new model variants. The newer standards require variant specific MMs that now include Airworthiness Limitations Sections with mandatory inspections. In the case of the new "IO" type variants it now lists a mandatory 100hr or after maintenance inspection of the fuel injector lines which would require a sign-off each time. The ALS also includes the 500 mag inspection, and 1000hr exh valve guide inspection where applicable. Will be interesting if this trend continues with other OEMs. I ran across this change while researching a new helicopter trainer with a new Lyc 390 variant. Definitely could catch an unsuspecting mechanic off guard having an ALS for your average recip engine.
 
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This is a general CYA trend that has been ongoing. Cessna came out with SID's which is mandatory in Australia (not sure about Canada) and on the first page of the SID's document is a statement saying that ALL applicable Service Bulletins are to be complied with. That right there tosses a big monkey wrench in the working status of a large number of privately owned aircraft in the U.S. if it were to become mandatory here.
 
Silvaire said:
That right there tosses a big monkey wrench in the working status of a large number of privately owned aircraft in the U.S. if it were to become mandatory here.
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Cessna did try that here when they came out with a new Airworthiness Limitations Section for the 210. And it did cause quite the riot. The ALS contained the SIDs and a few other things that Cessna contended were applicable per 91.403/43.16 to all 210s regardless of manufacture date. So for about six months there was a lot back and forth over this but in the end it was confirmed by the FAA that the new 210 ALS was only applicable to 210s manufactured new after the date of the ALS revision.

Unfortunately it did have some consequences for several 135 operators until that got corrected as well. And lucky for Cessna they stopped making the 210 prior to that date.:rolleyes:

However, its mine and others opinion that this was a test run by Cessna to see what they could get by with. Thankfully some of the bigger shops caught it right away and fought back. There are a number of articles on this but here what the FAA had to say.
https://www.faa.gov/about/office_or...ft services - (2015) legal interpretation.pdf
 
Isn’t the FI Lines AD mandatory via AD @ 100 hrs or when disconnected?

That would require a signature .

Any difference with ALS?


So if I sign an Annual with 50 hrs till mag 500 hr and 50 hrs till Exhaust Valve Guide

Insp and Part 91 Operator overflies by 70 hrs they fall into a trap?

These are “hard “ Inspection Times?
 
So it looks like a “ALS Status Report” similar to the current “AD Status Report”

will be required.

And possibly ignored till the next inspection.
 
Magman said:
So it looks like a “ALS Status Report” similar to the current “AD Status Report” will be required.
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That's one way to do it. Most turbine operators or helicopter operators use the Status Sheet method.
Magman said:
And possibly ignored till the next inspection.
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Only at your or their peril.;)
 
Far too common is finding ADs that came due since the last inspection.

I’ve considered putting reminders in the cockpit but that could be

counterproductive in a Ramp Check.
 
No, the AD does not authorize an owner operator to perform the AD.
 
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