Can an IA perform a 100-hour inspection?

Discussion in 'Maintenance Bay' started by schmookeeg, Nov 20, 2019.

  1. schmookeeg

    schmookeeg Cleared for Takeoff

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    Bear with my logic here. :D

    I'm flipping through my logbooks, and discovered the following entry styles:

    Airframe: Annual Inspection completed 1/2019 by IA.
    Engines: 100hr Inspection completed 1/2019 by IA.
    Props: 100hr Inspection completed 1/2019 by IA.

    My question:

    I believe the scope and criteria of a 100-hour inspection is identical to that of an Annual inspection. (neh?)

    As such, if a person conducts THAT inspection, and holds an IA, isn't he signing an Annual, not a 100-hour? (Or, isn't he signing both, identical inspections?)

    If he writes "100-hour inspection" and signs as an IA, is it equivalent to an Annual? Isn't he being churlish by signing it as a 100-hour? Thus, can an IA ever sign as "only" a 100-hour, when it's the same inspection, criteria, and qualifications as an Annual? What would be the difference between the two entries?

    #showerthoughts
     
  2. RussR

    RussR Cleared for Takeoff

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    I had a similar situation with a new mechanic and asked about it. His explanation, if I remember it correctly, went like this:

    There is a requirement that the aircraft have an annual inspection. (91.409)
    There is no requirement that the engine and propeller have their own annual inspection. (91.409 uses the word "aircraft").
    Signing off an annual just in the airframe logbook would be perfectly acceptable.
    However, owners want something in the engine and prop log for obvious reasons.
    Since there is no requirement for an engine and propeller annual inspection, there also isn't such a thing as an engine and propeller "annual".
    However, there is such a thing as a 100-hour for the engine and prop, so to put something in the logbooks, it is signed off as a 100-hr inspection.

    Some/many mechanics don't make this distinction and sign all of them off as annuals. Some/many do and sign it off like yours (and mine).

    To me, it seems a bit pedantic, but then again, I didn't go to A&P school.

    I also could have this wrong and could be remembering the conversation wrong.
     
    Last edited: Nov 20, 2019
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  3. Bell206

    Bell206 Pattern Altitude

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    No. All aviation mechanics have an A&P. Some A&Ps have an Inspection Authorization (IA). Only an A&P with a IA can sign-off an Annual inspection, but he can also sign off a 100 HR inspection. Annual and 100HR are two different inspection requirements even though they are performed to the same standard.

    The Annual inspection is technically only against the aircraft. However, as some owners have separate logbooks they request a separate sign-off in each logbook. There is no separate "annual" inspection requirement for a propeller or engine. So the sign-offs you reference in your post are good.
     
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  4. Clip4

    Clip4 Final Approach

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    Some claim a 100 hour and an annual are the same inspection in every aircraft. If a 100 hour inspection, which may be performed by any AP, is the same for every aircraft, why does an AP with an IA have to sign off an annual?
     
  5. tom28z

    tom28z Filing Flight Plan

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    You sign off the annual as a whole, the engine airframe and prop. You can write 100 hr on the engine and prop for the records. I’ve seen it done both ways. Annual on engine and prop or 100 hr. Annual on the airframe.


    Sent from my iPhone using Tapatalk
     
  6. Bell206

    Bell206 Pattern Altitude

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    It has nothing to do with the content of the inspection. It is the specific regulatory difference between the inspections by name. In general terms, all aircraft require an Annual which basically "revalidates" the AWC and requires the additional authorization. Whereas only aircraft "for hire" require a 100hr. If there was no regulatory difference then all aircraft inspections would require an IA.

    Years ago when only the CAA/FAA perfomed Annual inspections they would issue a new AWC each year. After GA took off in the 40s the feds could no longer keep up and they implemented the Authorized Inspector program which then morphed into the present day Inspection Authorization with no yearly AWC replacement. Some older mechanics still refer to annual time as to "re-license the aircraft" as back in the day that's what actually happened.
     
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  7. Clip4

    Clip4 Final Approach

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    That still doesn’t answer the question.
     
  8. Bell206

    Bell206 Pattern Altitude

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    Here, let me simplify it a little more for you. In order for a mechanic to use the word "Annual" in a logbook sign off per 43.11, he is required to possess a valid Inspection Authorization as shown in 65.95. As I said it has zero to do with the content of the inspection.
     
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  9. Clip4

    Clip4 Final Approach

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    But if an annual inspection and a 100 hour inspection are identical inspections, as some claim, you fail to answer why the FAA requires IA just to write the word annual. Functionally someone is missing something.
     
  10. unsafervguy

    unsafervguy Pattern Altitude

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    If the IA performs everything he/she needs to do for an annual there is nothing stopping them from signing it off as an annual every 100hrs as long as they fullfill all the requirements of the annual. Or they can just call it an 100hr it’s up to them.
     
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  11. Clip4

    Clip4 Final Approach

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    Which is the difference. An IA with more experience and training is required to inspect the entire aircraft vs an AP inspecting the airframe and another inspecting the engine, ect. In that regard, the inspections are not the same as the IAs inspection is expected to be more comprehensive.
     
  12. Bell206

    Bell206 Pattern Altitude

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    You're failing to functionally understand the difference between the regulatory requirements of the Annual and the 100hr, regardless if they have the same criteria. It also partly appears you believe every write up an IA makes must be signed as an Annual. As to one inspection being more comprehensive then the other, they're not. If you as owner request an Annual inspection required per 91.405 then the mechanic must have an IA in order to perform and sign off the Annual inspection. If you as owner request a 100hr inspection then a mechanic with or without an IA can perform and sign off the 100hr inspection. Can you as owner request every 100hr inspection to be performed and signed off as an Annual inspection? Sure, provided the mechanic has an IA. Entiendes ahora?
     
  13. Clip4

    Clip4 Final Approach

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    no, an IA can certainly perform a inspection and enter it as a 100 or an annual. Some sign them off as both a 100 and annual.
     
  14. schmookeeg

    schmookeeg Cleared for Takeoff

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    There seems to be some doubt whether a 100hr inspection is identical to an Annual, in form -- I thought that it was. Was I mistaken? I see that the scope in FAR 43 Appendix D is shared for both. I interpreted this to mean the only difference is the person doing the inspecting, and whether they are A&P or A&P IA
     
  15. Witmo

    Witmo Pattern Altitude

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    This is inaccurate. An airplane mechanic may have A&P but he/she may have only a A or only a P or none at all. Depending on the type of operation and what is being returned to service and under what regulation the work is being done, determines the certification required of the mechanic. A mechanic with the inspection authorization required to do an annual inspection will always have both airframe and powerplant certificates.
     
  16. Witmo

    Witmo Pattern Altitude

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    You are correct.
     
  17. schmookeeg

    schmookeeg Cleared for Takeoff

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    Okay, that confirmed, if an IA chose to inspect but only signed it off as a 100-hour, is he being a jerk? :D Could one then argue that he indeed performed an Annual inspection, despite his "downgraded" log entry?

    None of this is about my plane or mechanic, it's just rumination on my part. :D
     
  18. Bell206

    Bell206 Pattern Altitude

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    FYI: In the context of this discussion the latter form was my intent as we were not discussing other types of mx ops since you can't get an IA without the A&P.;)
     
  19. Skip Miller

    Skip Miller Final Approach

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    I was told that an Annual Inspection included, among other things, a search of relevant AD’s and logbook evidence of compliance for the applicable ones, whereas a 100 hour inspection did not require the AD search. True? If true, the two inspections are different.

    -Skip
     
  20. Bell206

    Bell206 Pattern Altitude

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    And the reason the inspection is performed. Some operators sign all their inspections as Annuals as it is beneficial to their need. For most GA aircraft it is not a benefit to sign off everything as an Annual.
    No. It would depend on what the owner requested and wanted. It's not down graded as the Annual inspection requirement was signed off in the airframe logbook which covers the prop and engine also. There's no requirement for the other 2 entries.
     
  21. Bell206

    Bell206 Pattern Altitude

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    No. Performing Annuals and 100hr inspections follow the same Part 43 performance rules.
     
  22. Skip Miller

    Skip Miller Final Approach

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    OK, another myth busted! Thanks.
     
  23. Shuswap BC

    Shuswap BC Pre-takeoff checklist

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    I get an annual done once a year, although not necessarily right at 365 days apart. But certainly not three a year, which is what it would be if done every 100 hours. Usually do my best to be pro-active about buying the parts required ahead of time as well. I get them all in my garage ahead of the 100 hour or annual, and depending on what it is I put them in the back of the plane if feasible, or in the case of my next annual it will be going down in my pickup before the plane, because it's a new engine, prop, tires, accessories etc this time.
     
  24. Witmo

    Witmo Pattern Altitude

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    I understand that many equate an annual inspection with doing required maintenance to keep an airplane "airworthy" but in fact, an annual inspection is only an inspection. Replacing filters and fixing things or complying with ADs and service bulletins are separate from the inspection itself and it is only because of the "convenience" of addressing these required/recommended maintenance items during the course of the inspection that they are done by the inspecting IA or shop. It would be perfectly all right for an IA to do the inspection and merely list all the things to make the aircraft safe/legal to fly and hand the list to the owner. The airplane annual is complete. It is then up to the owner to accomplish the list and have each item complied with and the aircraft returned to service by an appropriately certificated person whether that be the owner/operator (PP or above) in the case of preventive maintenance or a mechanic (A, P, or AP, depending on the maintenance required). The owner/operator is responsible for the airworthiness of his/her aircraft and the annual or 100 inspection is only a tool he/she uses to guide them. If the owner/operator chooses to ignore an item or the entire list, then that's their choice. The airplane will be "in annual" but unairworthy due to the owner/operator's negligence. Most IAs would do well to keep a copy of any list they provide to an owner in case an owner decides to blow off a listed discrepancy and gets into an accident to prove the IA provided notice to the owner/operator of the discrepancy.
     
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  25. Salty

    Salty En-Route PoA Supporter

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    Huh? How is an IA going to state "the aircraft was deemed to be in airworthy condition" if he just provides a list of issues? This sounds wrong.
     
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  26. Witmo

    Witmo Pattern Altitude

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    He's not. He'll state he completed an annual inspection and provided the owner with a list of unairworthy discrepancies. The aircraft does not need a declaration of airworthiness provided any airworthiness discrepancies are rectified and the aircraft is returned to service by an appropriately certificated person.
     
  27. Shuswap BC

    Shuswap BC Pre-takeoff checklist

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    I can only guess here, but think what he is saying is that the owner of said plane could take it since it is theirs, and fly it, with the annual inspection done, but failed, and no certificate of air worthiness in place. Meaning it did have an annual inspection, but failed, and the guy/gal said screw it and flew it anyway. I'm sure somewhere is a village, who's idiot has done just that.
     
  28. Doc Holliday

    Doc Holliday Line Up and Wait

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    And your guess is totally wrong.

    Witmo gave the correct response.
     
  29. Bell206

    Bell206 Pattern Altitude

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    He doesn't. Reference 43.11(a)(5) and (b). Perfectly legit process as Witmo explained.
     
  30. Bell206

    Bell206 Pattern Altitude

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    FYI: They could provided the owner got a Special Flight Permit to do so. But short of that no, legally. Have signed off on a few ferry permits to do just that.
     
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  31. weirdjim

    weirdjim En-Route

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    Having done owner-assisted annuals for some thirty years now, perhaps I can shed some light on this ... in accordance with the Lincoln story that follows.

    This poor fellow back in the 1840s had a wheel break on his wagon going home in the middle of a HORRENDOUS thunderstorm. He could only walk a few hundred yards before a lightning flash would illuminate his path, and then a few seconds later a tremendous thunder would drive him to his knees. After a few miles of this, he prayed to the Lord, "Oh Lord, a little less noise and a little more light if you please."

    My owners are taught how to inspect an airplane in accordance with the best A&P principles. The first year I watch them like a hawk. The second year, not so much. And so on. They all have check lists that I have taught them how to perform on their specific aircraft. I look at their checklists and then perform my own inspection. The more often they do a perfect checklist, the more confidence I have in it and the less often I find unairworthy items in my inspection. They know their airplane inside out, and they know that I'll find things that they try to slide by. Double cost for the annual if I find anything OBVIOUS that wasn't caught.

    So, for all intents and purposes, my owners perform a 100 hour inspection without the authority to sign it off, but to every standard that the A&P regulations require. If they had the A&P, they could have signed it off, and when I come by and do the SAME EXACT inspection, I can legally sign their annual inspection.

    Did that do ANYTHING to clarify this mess?

    \
     
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  32. Silvaire

    Silvaire En-Route

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    Jeeze, I had to look that one up. I’m an old man and honestly I’ve never met anyone who has used the word “churlish” before.

    But to answer your question I think that “rude” or “mean spirited” might be a bit of an overreaction to this. Not to say your mechanic couldn’t actually be those things but I wouldn’t draw such a conclusion based simply on him being an IA and signing the inspection off as a 100 hr. It might not have even occurred to him since the inspection was being performed to comply with the need for a 100 hr. Probably if you asked nice he’d say “Yea sure, we can sign it as an annual” So long as he doesn’t find this thread first.
     
  33. schmookeeg

    schmookeeg Cleared for Takeoff

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    I agree, 'niggardly' covers the case better, but that word gets me in trouble a lot, so I don't use it much :D

    Luckily it was just a hypothetical thought, part of the afterburn from A&P training, so no IAs will be annoyed with me for asking the question. :cheerswine:
     
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  34. bluerooster

    bluerooster Pattern Altitude

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    Churlish, and niggardly are two different words, with two different meanings. One being "mean", the other being "tightwad", or could be used to mean "overly conservative".
     
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  35. Checkout_my_Six

    Checkout_my_Six Final Approach

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    nice to see the word police in action....:D
     
  36. schmookeeg

    schmookeeg Cleared for Takeoff

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    I suspect only the Germans have a word that accurately captures "I have the authority to approve an inspection one way, but for reasons known only to me, I have approved a lesser inspection"
     
  37. MauleSkinner

    MauleSkinner Final Approach

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    Yup...they take that full sentence and take the spaces out of it to make one word.
     
  38. MauleSkinner

    MauleSkinner Final Approach

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    Yup...they take that full sentence and take the spaces out of it to make one word.
     
  39. weirdjim

    weirdjim En-Route

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    Mrs. Noah Webster (of dictionary fame) came home unexpectedly and found Noah and the downstairs maid in a compromising situation. She said, "Mr. Webster, I'm SURPRISED!!"

    Noah said, "No, no, my dear. You were AMAZED. **WE** were surprised."

    :cheerswine:

    Jim
     
  40. Dan Thomas

    Dan Thomas Final Approach

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    Yup.