Annuals Vs engine change

Tom-D said:
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Biography
Comercial, Instrument, CFII, SEL, MEL, SES, Helicopter, Glider, Hot air Balloon, A&P / IA, GROL with Radar endorsement .
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Are you saying you hold those ratings Tom?
 
RotorAndWing said:
:dunno:

Can you please show some sort of reference for that??? :rolleyes:

Do you apply the same "logic" to magnetos? Alternator? Starter? :dunno:
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It's not in 91.409. It's in 91.417, and other chapters, by backwards reference from FAA enforcement actions upheld by the NTSB.

91.417,a,1 requires records for the maintenance, alterations, and, 100 hour, progressive or annual inspections for each aircraft, engine, propeller, rotor, and appliance of an aircraft.

Explain to me how the maintenance records required here can be complete, WITHOUT an annual inspection on the engine you just installed?

This rule applies to owners, not to mechanics directly, but you would be remiss to release an AIRCRAFT back to the owner, with a different engine WITHOUT an annual inspection on that different engine. It would be impossible for him to comply with 91.417.a.1, and since the records require the signature of the person performing the work, this is how the mechanic gets violated for not accomplishing the annual on the installed engine before approval for return to service. Since the mechanic's signature constitutes the approval for return to service, anything he signs for must be in compliance with the applicable regulations, and in the case of an engine swap of an engine that does not have a current annual, he is liable to perform that annual, and make the required logbook entry.

And for the nitpickers, remember that the reg says APPLIANCES too, so yes, you have to be certain that all appliances have a current annual.
 
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philiplane said:
It's not in 91.409. It's in 91.417, and other chapters, by backwards reference from FAA enforcement actions upheld by the NTSB.

91.417,a,1 requires records for the maintenance, alterations, and, 100 hour, progressive or annual inspections for each aircraft, engine, propeller, rotor, and appliance of an aircraft.

Explain to me how the maintenance records required here can be complete, WITHOUT an annual inspection on the engine you just installed?

This rule applies to owners, not to mechanics directly, but you would be remiss to release an AIRCRAFT back to the owner, with a different engine WITHOUT an annual inspection on that different engine. It would be impossible for him to comply with 91.417.a.1, and since the records require the signature of the person performing the work, this is how the mechanic gets violated for not accomplishing the annual on the installed engine before approval for return to service. Since the mechanic's signature constitutes the approval for return to service, anything he signs for must be in compliance with the applicable regulations, and in the case of an engine swap of an engine that does not have a current annual, he is liable to perform that annual, and make the required logbook entry.

And for the nitpickers, remember that the reg says APPLIANCES too, so yes, you have to be certain that all appliances have a current annual.
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I'm not buying it. :no:
 
If you have a plane in annual, and with entries made in accordance with 91,417,a,1,for all the components listed "each engine, propeller, rotor, and appliance" are in annual, and then you remove one of them, and replace it with another, (that DOES NOT have an annual inspection entry in it's own logbook), how can the records now be complete?

Simple answer, they aren't, and you have to perform and log an annual inspection for the part in question, so the records can once again be complete.

Small Part 135 guys get busted on this more often than anyone else since they tend to have fleets and rotate engines and propellers among the fleet. That is why the smart ones are in the habit of keeping logs for engines and props, with their own annual sign-offs. They can then swap components and not run afoul of this rule.
 
philiplane said:
It's not in 91.409. It's in 91.417, and other chapters, by backwards reference from FAA enforcement actions upheld by the NTSB.

91.417,a,1 requires records for the maintenance, alterations, and, 100 hour, progressive or annual inspections for each aircraft, engine, propeller, rotor, and appliance of an aircraft.

Explain to me how the maintenance records required here can be complete, WITHOUT an annual inspection on the engine you just installed?

This rule applies to owners, not to mechanics directly, but you would be remiss to release an AIRCRAFT back to the owner, with a different engine WITHOUT an annual inspection on that different engine. It would be impossible for him to comply with 91.417.a.1, and since the records require the signature of the person performing the work, this is how the mechanic gets violated for not accomplishing the annual on the installed engine before approval for return to service. Since the mechanic's signature constitutes the approval for return to service, anything he signs for must be in compliance with the applicable regulations, and in the case of an engine swap of an engine that does not have a current annual, he is liable to perform that annual, and make the required logbook entry.

And for the nitpickers, remember that the reg says APPLIANCES too, so yes, you have to be certain that all appliances have a current annual.
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Simple, the installation and signature putting the engine into service serve as the primary statement of affect. When you sign it into service, you are declaring it correct and legal. That starts the "Annual Inspection" cycle for that component. No further action is required until the end of that component's inspection cycle, however due to matters of practicality, at the next Aircraft Annual Inspection cycle, we go ahead and incorporate that component and do the inspection protocol ahead of time to coordinate all the clocks.

The component does not require an annual inspection signature until the year after it was put into service.
 
philiplane said:
If you have a plane in annual, and with entries made in accordance with 91,417,a,1,for all the components listed "each engine, propeller, rotor, and appliance" are in annual, and then you remove one of them, and replace it with another, (that DOES NOT have an annual inspection entry in it's own logbook), how can the records now be complete?

Simple answer, they aren't, and you have to perform and log an annual inspection for the part in question, so the records can once again be complete.
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Sorry, you are reading more into this than is actually there. And I'm still not buying it. :nonod:

philiplane said:
Small Part 135 guys get busted on this more often than anyone else since they tend to have fleets and rotate engines and propellers among the fleet. That is why the smart ones are in the habit of keeping logs for engines and props, with their own annual sign-offs. They can then swap components and not run afoul of this rule.
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I'm not buying this either.

And just for fun I called a couple of my old friends that are AW Inspectors, ran this scenario by them and they just laughed. As I suspected.

So, if you change a set of magnetos on a plane after it had an annual, you actual sign off that the magnetos have an "annual inspection"? Really? :rolleyes:
 
Mechanics can't declare a 20 year old, out of annual engine, removed from a junk airplane, airworthy without an inspection of some type. So install said engine on an airplane, and what do you have? An unairworthy engine, because it is out of annual, the airframe logbook does not cover it, and you don't have records to comply with 91.417.a.1.

Mechanics don't declare things "correct and legal", they make entries in accordance with approved technical data, to fulfill obligations imposed under applicable rules.

If the engine in question does not have a current annual, it needs one before approval for return to service. Not to comply with 91.409 directly, but to comply with the records required under 91.417, of the inspections performed under 91.409.

Read it again, I'm not making this up:

91.417.a.1: "records of the maintenance (100 hour and annuals) for each aircraft, AND, each engine, propeller, rotor, and appliance OF AN AIRCRAFT"

This has come up in dozens of Part 135 inspections, in many different FSDO's and it seems to be something they look for. Records are the easiest thing to check, they do have a Job Task card that calls these things out, making violations easy to find.

So if the engine in question has not had an annual inspection in the preceding 12 months, it needs one upon installation. If it is the same engine from the same airplane, and still with a current annual but just overhauled, it does not need another annual.
 
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philiplane said:
Mechanics can't declare a 20 year old, out of annual engine, removed from a junk airplane, airworthy without an inspection of some type. So install said engine on an airplane, and what do you have? An unairworthy engine, because it is out of annual, the airframe logbook does not cover it, and you don't have records to comply with 91.417.a.1.

Mechanics don't declare things "correct and legal", they make entries in accordance with approved technical data, to fulfill obligations imposed under applicable rules.

If the engine in question does not have a current annual, it needs one before approval for return to service. Not to comply with 91.409 directly, but to comply with the records required under 91.417, of the inspections performed under 91.409.

Read it again, I'm not making this up:

91.417.a.1: "records of the maintenance (100 hour and annuals) for each aircraft, AND, each engine, propeller, rotor, and appliance OF AN AIRCRAFT"

This has come up in dozens of Part 135 inspections, in many different FSDO's and it seems to be something they look for. Records are the easiest thing to check, they do have a Job Task card that calls these things out, making violations easy to find.

So if the engine in question has not had an annual inspection in the preceding 12 months, it needs one upon installation. If it is the same engine from the same airplane, and still with a current annual but just overhauled, it does not need another annual.
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Whatever. :rolleyes2:
 
philiplane said:
Mechanics can't declare a 20 year old, out of annual engine, removed from a junk airplane, airworthy without an inspection of some type. So install said engine on an airplane, and what do you have? An unairworthy engine, because it is out of annual, the airframe logbook does not cover it, and you don't have records to comply with 91.417.a.1.

Mechanics don't declare things "correct and legal", they make entries in accordance with approved technical data, to fulfill obligations imposed under applicable rules.

If the engine in question does not have a current annual, it needs one before approval for return to service. Not to comply with 91.409 directly, but to comply with the records required under 91.417, of the inspections performed under 91.409.

Read it again, I'm not making this up:

91.417.a.1: "records of the maintenance (100 hour and annuals) for each aircraft, AND, each engine, propeller, rotor, and appliance OF AN AIRCRAFT"

This has come up in dozens of Part 135 inspections, in many different FSDO's and it seems to be something they look for. Records are the easiest thing to check, they do have a Job Task card that calls these things out, making violations easy to find.

So if the engine in question has not had an annual inspection in the preceding 12 months, it needs one upon installation. If it is the same engine from the same airplane, and still with a current annual but just overhauled, it does not need another annual.
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The mechanic cannot install it without it being airworthy at the time of installation. It is a fact of that signature that enters that aircraft repair into service. Mechanics determine airworthiness every day, it's part of the job.
 
Henning said:
The mechanic cannot install it without it being airworthy at the time of installation. It is a fact of that signature that enters that aircraft repair into service. Mechanics determine airworthiness every day, it's part of the job.
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I can install any engine I like on any aircraft I like. and make a record of doing that. There is nothing saying I must declare it airworthy.
 
Tom-D said:
I can install any engine I like on any aircraft I like. and make a record of doing that. There is nothing saying I must declare it airworthy.
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Can you install an engine that is not airworthy, and return the plane to service?
 
philiplane said:
Mechanics can't declare a 20 year old, out of annual engine, removed from a junk airplane, airworthy without an inspection of some type. So install said engine on an airplane, and what do you have? An unairworthy engine, because it is out of annual, the airframe logbook does not cover it, and you don't have records to comply with 91.417.a.1.

Mechanics don't declare things "correct and legal", they make entries in accordance with approved technical data, to fulfill obligations imposed under applicable rules.

If the engine in question does not have a current annual, it needs one before approval for return to service. Not to comply with 91.409 directly, but to comply with the records required under 91.417, of the inspections performed under 91.409.

Read it again, I'm not making this up:

91.417.a.1: "records of the maintenance (100 hour and annuals) for each aircraft, AND, each engine, propeller, rotor, and appliance OF AN AIRCRAFT"

This has come up in dozens of Part 135 inspections, in many different FSDO's and it seems to be something they look for. Records are the easiest thing to check, they do have a Job Task card that calls these things out, making violations easy to find.

So if the engine in question has not had an annual inspection in the preceding 12 months, it needs one upon installation. If it is the same engine from the same airplane, and still with a current annual but just overhauled, it does not need another annual.
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91.117 is about record keeping not what inspections must be made. It is our guide when making entries thus telling what the entry shall contain.

That is all it does for us. It does not dictate that each item it refers to must have an annual inspection.
 
Henning said:
Can you install any engine that is not airworthy, on any aircraft I like and return the plane to service?
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NO !.. read the whole post not what you think you saw.
 
philiplane said:
So if the engine in question has not had an annual inspection in the preceding 12 months, it needs one upon installation. If it is the same engine from the same airplane, and still with a current annual but just overhauled, it does not need another annual.
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It certainly does not need an annual. the act of installing it, and returning it to service is simply maintenance keeping the aircraft in an airworthy condition.

When I sign off your annual as unairworthy due to the engine being removed, allows any properly rated mechanic to install the engine and return the aircraft to service as airworthy. The annual was complete when I signed it off and good for 12 cal. months. Any maintenance completed during the 12 months stands on its own merit.
 
Tom-D said:
I can install any engine I like on any aircraft I like. and make a record of doing that. There is nothing saying I must declare it airworthy.
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So do you often install unairworthy components and sign the return to service? What would the maintenance record entry look like for installing something on a standard category aircraft which you are not "declaring airworthy"?
 
James331 said:
Are you saying you hold those ratings Tom?
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:rolleyes2: Are you new to the internet or what? were we not talking about Brian's ratings when I posted that?

If you are going to eves drop, pay attention.
 
philiplane said:
And for the nitpickers, remember that the reg says APPLIANCES too, so yes, you have to be certain that all appliances have a current annual.
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I think I'm doing it all wrong......:yikes:

I've never logged my appliances with an annual inspection.....:no:
 
Checkout_my_Six said:
so....what's in a signature?:dunno:
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43.9-a
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

And if it hasn't been preformed properly ? What then.?

If I am asked to replace an engine for the simple reason the aircraft can't be moved with out it, am I required to declare it airworthy? Or do I have the option of simply making the entry saying I just bolted it back on to comply with 91.117?
 
Checkout_my_Six said:
I think I'm doing it all wrong......:yikes:

I've never logged my appliances with an annual inspection.....:no:
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This is where it becomes confusing for owners who can't tell the difference between maintenance and the annual inspection. It all gets signed off with one entry, SO, it must be part of the inspection that costs $10,000.
 
Tom-D said:
43.9-a
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.

And if it hasn't been preformed properly ? What then.?

If I am asked to replace an engine for the simple reason the aircraft can't be moved with out it, am I required to declare it airworthy? Or do I have the option of simply making the entry saying I just bolted it back on to comply with 91.117?
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Can you make an entry noting the installation stating that the aircraft is not returned to service?
 
Henning said:
Can you make an entry noting the installation stating that the aircraft is not returned to service?
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Yes..

If you requested me to remove an engine for overhaul, and you were having some other A&P install it after the overhaul What would I say in the entry?
 
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Checkout_my_Six said:
that sounds ugly.....:yikes:
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Why?

You simply make an entry in the Aircraft log book saying " engine Serial number ______, was removed at Aircraft TT _____.

You simply make an entry in the Engine log book saying " engine Serial number ______, was removed from A/C ____ at Engine TT _____.
 
Tom-D said:
Yes..

If you requested me to remove an engine for overhaul, and you were having some other A&P install it after the overhaul What would I say in the entry?
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:confused: "This signature shall not be used to establish a return to service."?:dunno:

I don't know, I'm trying to establish exactly what all aspects the signature represents in the standard form. Does signing off the work provide a de facto return to service without the entry specifying a "return to service"?
 
Tom-D said:
Why?

You simply make an entry in the Aircraft log book saying " engine Serial number ______, was removed at Aircraft TT _____.

You simply make an entry in the Engine log book saying " engine Serial number ______, was removed from A/C ____ at Engine TT _____.
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why?.....just have the installer do the log book entries.

Heck, the owner could have done the removal....:D
 
Checkout_my_Six said:
why?.....just have the installer do the log book entries.

Heck, the owner could have done the removal....:D
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Or just don't do them. let some A&P figure it out 20 years from now, and back fit all the entries.

Just been there with that.

I'd venture a guess that 50% of the owners/pilots in GA don't know what is supposed to be written in their logs.
 
Henning said:
:confused: "This signature shall not be used to establish a return to service."?:dunno:

I don't know, I'm trying to establish exactly what all aspects the signature represents in the standard form. Does signing off the work provide a de facto return to service without the entry specifying a "return to service"?
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When you make an entry to comply with 91.417 be careful read what it says. Many A&P's simply will not make an entry if the aircraft is not safe to return to service.

BUT

the rules say if you do maintenance, it will be logged.
 
Tom-D said:
When you make an entry to comply with 91.417 be careful read what it says. Many A&P's simply will not make an entry if the aircraft is not safe to return to service.

BUT

the rules say if you do maintenance, it will be logged.
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Ok, then you confirm my interpretation of what that signature means.

If you sign it, that is a de facto return to service. Since you cannot return to service a component you believe to be not airworthy, you are declaring the component you installed and signed off as airworthy. In order to do so you established not only the physical condition of the part is in order, but also the paperwork is in order. As an A&P you are authorized to do that and place the component as an airworthy repair in compliance with the same set of rules the IA inspects from. This makes the repair for all intents and purposes compliant with the rules. The IA is only required once a year to determine the validity of the data at that point in time in the cycle. Outside of that, it is the A&P (also owner operator) duty to maintain the continued airworthiness between those inspection periods.

Besides, if an IA was required to put a replacement engine into service, the FARs would spell that out specifically, and no where in the FARs I have ever seen is this even hinted at. It would negate the entire reason behind having two certificates. Anything an IA or higher is not specifically designated required for is in the purvue of an A&P. Since an Annual Inspection signature is not in the purvue of an A&P alone, while the repair/replacement/& return to service of any component, including an engine, it gives proof of no annual entry required mid period.

Therefore the condition that an engine replacement requires an Annual Inspection sign off defies all logic.
 
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Henning said:
Ok, then you confirm my interpretation of what that signature means.

If you sign it, that is a de facto return to service. Since you cannot return to service a component you believe to be not airworthy, you are declaring the component you installed and signed off as airworthy. In order to do so you established not only the physical condition of the part is in order, but also the paperwork is in order. As an A&P you are authorized to do that and place the component as an airworthy repair in compliance with the same set of rules the IA inspects from. This makes the repair for all intents and purposes compliant with the rules. The IA is only required once a year to determine the validity of the data at that point in time in the cycle. Outside of that, it is the A&P (also owner operator) duty to maintain the continued airworthiness between those inspection periods.

Besides, if an IA was required to put a replacement engine into service, the FARs would spell that out specifically, and no where in the FARs I have ever seen is this even hinted at. It would negate the entire reason behind having two certificates. Anything an IA or higher is not specifically designated required for is in the purvue of an A&P. Since an Annual Inspection signature is not in the purvue of an A&P alone, while the repair/replacement/& return to service of any component, including an engine, it gives proof of no annual entry required mid period.

Therefore the condition that an engine replacement requires an Annual Inspection sign off defies all logic.
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read it again, the signature only certifies what the description of the work completed, says it does.

When you say "Engine removed for overhaul", that's all you certifying. there is no airworthiness in involved. you are stating only what you did.
 
Tom-D said:
read it again, the signature only certifies what the discerption of the work completed, says it does.

When you say "Engine removed for overhaul", that's all you certifying. there is no airworthiness in involved. you are stating only what you did.
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would you also do a log entry for removing the wings?:D
 
The entry in the airframe log says

Installed engine S/N _____ on Aircraft N______ in accordance with the aircraft maintenance manual, servicing and testing not completed.


Am I returning this aircraft to service?

No. I've had this happen twice, owner simply ran out of money, I didn't know If I would finish the installation or not. What else was I supposed to do, except tell any who reads the log what was completed. by who.
 
Checkout_my_Six said:
would you also do a log entry for removing the wings?:D
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yes. specially if I didn't know If I was putting them back.

If I knew I was doing the whole job, I would simply say Removed and replaced the wings, yada yada.
 
Tom-D said:
read it again, the signature only certifies what the description of the work completed, says it does.

When you say "Engine removed for overhaul", that's all you certifying. there is no airworthiness in involved. you are stating only what you did.
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:confused: Ok, we're back into stupid territory again. Where does that entry place the aircraft into service? I'm not Charlie Brown, I'm not chasing the football.

The plane needs an annual once an annual cycle regardless what happens in between, end of subject for me.
 
Henning said:
:confused: Ok, we're back into stupid territory again. Where does that entry place the aircraft into service? I'm not Charlie Brown, I'm not chasing the football.
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Every entry in a maintenance record doesn't return the aircraft to service. Many simply say what was done, and by who.
 
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