Can an owner check if a service bulletin is applicable?

Old Geek

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Old Geek
I got a service bulletin on my Rotax 912 engine requiring a specific inspection if it is in a range of serial numbers. Mine isn't. Am I authorized to make an entry in the aircraft logbook indicating that the service bulletin is not applicable to my engine and aircraft. This is a special light sport airplane if it makes any difference.
 
A service bulletin complaiance is not required under part 91. No one needs to make a notation.
 
I got a service bulletin on my Rotax 912 engine requiring a specific inspection if it is in a range of serial numbers. Mine isn't. Am I authorized to make an entry in the aircraft logbook indicating that the service bulletin is not applicable to my engine and aircraft. This is a special light sport airplane if it makes any difference.

No obligation, but it always a good idea to make an entry in the log that you checked.
 
Even though service bulletins are not required for Part 91 operations, all manufacturers service bulletins are required to be complied with for S-LSA aircraft. Although you say that this one isn't applicable to your engine due to serial number, it can never hurt to put a note in the logbook notating that for future reference.
 
They are your records, write anything you like in them.
Not real good advice. Boggle up your aircraft records with inappropriate or improper entries, and you create questions in the mind of any prospective purchaser. In any event, there's no need to make an entry in aircraft maintenance records about an SB not being applicable. Of course, a neat SB list (like the AD list your IA creates at annual) showing all SB's on your aircraft and whether or not they are applicable/complied with would be a nice thing to have, but not essential.
 
I would put a note in the logs ,saves time so the mechanic doesn't have to do the same checking.
 
I would put a note in the logs ,saves time so the mechanic doesn't have to do the same checking.
...other than having to page through the logbook looking for something that for all s/he knows might not even be there. OTOH, you could create a nice, neat SB list with all SB's for your aircraft on it, put it in with the AD list, and make life easy for anyone who ever wants to know.
 
...other than having to page through the logbook looking for something that for all s/he knows might not even be there. OTOH, you could create a nice, neat SB list with all SB's for your aircraft on it, put it in with the AD list, and make life easy for anyone who ever wants to know.

A list as you suggest could take up a whole log book, It's possible that every component in the aircraft would have several SB, And many of which will require maintenance the owner is not authorized to do, just to see if the SB was completed or not.

The general concept of recording what maintenance was completed and returned to service IAW FAR 43, is what is expected in a maintenance record, but there is no guidance as what else can be placed there. After all they are the owners property, and they can write anything they desire in them.

As to what is seen as bad or good is simply a matter of the eye of the beholder.
 
A list as you suggest could take up a whole log book, It's possible that every component in the aircraft would have several SB,
Oh, hooey. It's going to be at most marginally bigger than the AD lists we get every annual from good IA's, and those are hardly enough to "take up a whole log book".
And many of which will require maintenance the owner is not authorized to do, just to see if the SB was completed or not.
Please give me an example of how an owner would have to do something beyond preventive maintenance to determine whether a SB is applicable to his/her aircraft. Sure, if an owner doesn't know how to review aircraft maintenance records for legal airworthiness, that might be a problem, but if the owner is a licensed pilot above Student, s/he's been trained, tested, and certified on how to do this.
 
Oh, hooey. It's going to be at most marginally bigger than the AD lists we get every annual from good IA's, and those are hardly enough to "take up a whole log book".
When you compile a list for a light twin such as an Aztec you are dealing with 2 engines, 2 props, a south wind heater, and ever accessory in stalled each engine, plus every radio, instrument and the airframe.
Please give me an example of how an owner would have to do something beyond preventive maintenance to determine whether a SB is applicable to his/her aircraft. Sure, if an owner doesn't know how to review aircraft maintenance records for legal airworthiness, that might be a problem, but if the owner is a licensed pilot above Student, s/he's been trained, tested, and certified on how to do this.

Try the Lycoming oil pump service bulletin, the accessory case had to be removed and the pump disassembled to inspect the material the gears were made from.
That finally became an AD as did many others.
Such as the Bendix coil and the Slick 500 hour inspection.

Plus the fact that SBs are not required for airworthiness most do not get complied with during any inspection, so to actually get all the SBs for any aircraft/engine you must have a subscription to the manufacturers to get every SB for every item on the equipment list. unless you want to spend days trying to find them on line.
 
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"Plus the fact that SBs are not required for airworthiness most do not get complied with during any inspection, ................"



I think you guys are misinterpreting this. For S-LSA aircraft, SB's ARE REQUIRED for airworthiness. For standard category aircraft, they are not required.
 
Most A&Ps (and owners will be well advised) to keep a running list of ADs (and SBs) and their applicability (logging serial numbers or whatever) and compliance. This isn't in the "logs" per se, but the regs don't say squat about "logs" just maintenance records.

I see no reason for an AD that if it says it only applies to a certain serial number an owner pilot can't verify for himself that it doesn't apply to his aircraft. I certainly did on an old fuel pump AD on my gopher engine. Once I got upside down with a mirror in the engine compartment to grab the serial number (now I'd have just stuck my iPhone in there and snapped a picture of it), you can be darn sure I wrote down the serial number in case the question ever came up again.

If you're going to write anything in the maintenance records it behooves you to follow the rules in part 43 for doing so.
 
Most A&Ps (and owners will be well advised) to keep a running list of ADs (and SBs) and their applicability (logging serial numbers or whatever) and compliance. This isn't in the "logs" per se, but the regs don't say squat about "logs" just maintenance records.

I see no reason for an AD that if it says it only applies to a certain serial number an owner pilot can't verify for himself that it doesn't apply to his aircraft. I certainly did on an old fuel pump AD on my gopher engine. Once I got upside down with a mirror in the engine compartment to grab the serial number (now I'd have just stuck my iPhone in there and snapped a picture of it), you can be darn sure I wrote down the serial number in case the question ever came up again.

If you're going to write anything in the maintenance records it behooves you to follow the rules in part 43 for doing so.


+1

Now when it comes to required items I would recommend having an A&P make an entry about it not applying. It takes almost no time if done concurrent with other maintenance and will really streamline future checks. It is just too easy to have ADXXXX-XX-XX DNA by S/N (or what ever reason) stuck into an entry to skip IMO
 
"Plus the fact that SBs are not required for airworthiness most do not get complied with during any inspection, ................"



I think you guys are misinterpreting this. For S-LSA aircraft, SB's ARE REQUIRED for airworthiness. For standard category aircraft, they are not required.

Cite please.
 
Here is the text from AOPA's website explaining this.

"Will airworthiness directives (ADs) be issued for light sport aircraft?

ADs will not be issued for LSA. However, mandatory service bulletins (SBs) will be issued for light sport aircraft. For SLSA, compliance with these bulletins is required. For ELSA, compliance is only recommended."

I have never actually found this in the FAR's, but have seen it listed in S-LSA aircraft operating limitations that are attached to the Certificate of Airworthiness.
 
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Here is the text from AOPA's website explaining this.

"Will airworthiness directives (ADs) be issued for light sport aircraft?

ADs will not be issued for LSA. However, mandatory service bulletins (SBs) will be issued for light sport aircraft. For SLSA, compliance with these bulletins is required. For ELSA, compliance is only recommended."

I have never actually found this in the FAR's, but have seen it listed in S-LSA aircraft operating limitations that are attached to the Certificate of Airworthiness.

That's what I thought. The latest info that I have is that only what's specifically defined in the FAR's is legally required. The chain of command does not extend to the manufacturer's documentation. Not that I'm advocating ignoring a service bulletin. I don't.
 
So if an aircraft's operating limitations say that compliance with mandatory service bulletins is required, you are saying it is ok to ignore them because there is not a specific FAR pertaining to this?

Just asking for clarification.
 
That's what I thought. The latest info that I have is that only what's specifically defined in the FAR's is legally required. The chain of command does not extend to the manufacturer's documentation. Not that I'm advocating ignoring a service bulletin. I don't.
Actually, it is defined in the FAR's -- see 14 CFR 21.190(c)(5), which says "...the manufacturer will monitor and correct safety-of-flight issues through the issuance of safety directives and a continued airworthiness system that meets the identified consensus standard;..." The root of this is that S-LSA's are not certified to FAA standards, but rather to industry consensus standards, and that means the manufacturer takes the place of the FAA in some regards -- and this is one of them. Since the industry rather than the FAA sets the certification standards for S-LSA's, the industry (i.e., the manufacturer) decides when it is essential to airworthiness that a alteration or inspection be made, and the FAA backs their play.
 
Actually, it is defined in the FAR's -- see 14 CFR 21.190(c)(5), which says "...the manufacturer will monitor and correct safety-of-flight issues through the issuance of safety directives and a continued airworthiness system that meets the identified consensus standard;..." The root of this is that S-LSA's are not certified to FAA standards, but rather to industry consensus standards, and that means the manufacturer takes the place of the FAA in some regards -- and this is one of them. Since the industry rather than the FAA sets the certification standards for S-LSA's, the industry (i.e., the manufacturer) decides when it is essential to airworthiness that a alteration or inspection be made, and the FAA backs their play.

Um, no. A&P was violated for servicing an S-LSA without manufacturer's required training, violation was voided by general counsel because the training was not required by CFR. No time to look up citation. Has been debated ad nauseam in the light sport forums.
 
Um, no. A&P was violated for servicing an S-LSA without manufacturer's required training, violation was voided by general counsel because the training was not required by CFR. No time to look up citation. Has been debated ad nauseam in the light sport forums.
I agree -- nothing in the regulations requires taking training the manufacturer says is necessary. But that's not the issue here, which is a requirement to perform alterations or inspections which the manufacturer says is necessary, and that is covered in 21.190.
 
I agree -- nothing in the regulations requires taking training the manufacturer says is necessary. But that's not the issue here, which is a requirement to perform alterations or inspections which the manufacturer says is necessary, and that is covered in 21.190.

We were talking about service bulletins, not safety bulletins.
 
+1

Now when it comes to required items I would recommend having an A&P make an entry about it not applying. It takes almost no time if done concurrent with other maintenance and will really streamline future checks. It is just too easy to have ADXXXX-XX-XX DNA by S/N (or what ever reason) stuck into an entry to skip IMO

Depends on how the AD is written. if it just says it only applies to PartsCo Model 214 Widgets SN 1000-1200 and you know you don't have one of those in your plane, you can just throw the AD notice in the trash. It doesn't apply to you. If the AD specifically requires you to check to see if your PartsCo Widget is in the affected range I *might* agree with you.
 
We were talking about service bulletins, not safety bulletins.
The overarching term the FAA uses in the regs is actually "safety directive" (not "safety bulletin"), but there are three categories of safety directive, including Safety Alert, Service Bulletin, and Notification (see AC 65-32A for details), so a Service Bulletin from an S-LSA manufacturer is in fact a "safety directive" in this context. If it comes from the S-LSA manufacturer stamped "Mandatory Service Bulletin" and contains direction to take action, it's a safety directive under the meaning of 21.190, and compliance is mandatory. See also 14 CFR 91.327: "The owner or operator complies with each safety directive applicable to the aircraft that corrects an existing unsafe condition."
 
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The overarching term the FAA uses in the regs is actually "safety directive" (not "safety bulletin"), but there are three categories of safety directive, including Safety Alert, Service Bulletin, and Notification (see AC 65-32A for details), so a Service Bulletin from an S-LSA manufacturer is in fact a "safety directive" in this context. If it comes from the S-LSA manufacturer stamped "Mandatory Service Bulletin" and contains direction to take action, it's a safety directive under the meaning of 21.190, and compliance is mandatory. See also 14 CFR 91.327: "The owner or operator complies with each safety directive applicable to the aircraft that corrects an existing unsafe condition."

Your cite of AC 65-32A is crystal clear on the subject. "Safety Directives" are the ASTM-required format for manditory maintenance issues. "Service Bulletins" are for recommended maintenance issues. Nothing in AC 65-32 or the ASTM standards called or addresses a "mandatory service bulletin".
 
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Your cite of AC 65-32A is crystal clear on the subject. "Safety Bulletins" are the ASTM-required format for manditory maintenance issues. "Service Bulletins" are for recommended maintenance issues. Nothing in AC 65-32 or the ASTM standards called a "mandatory service bulletin".
Thank you for agreeing.
 
Then we agree that there is no FAR compliance requirement behind a service bulletin?
No, I agreed with what you last said about "safety bulletins", which seems to be your word for Service Bulletins. Otherwise, I disagree. The reg says all safety directives must be complied with, and a Service Bulletin is a safety directive. Of course, fi the Service Bulletin says the action is only "recommended," then it would not be mandatory, but if the Service Bulletin says "mandatory" on it, there's no choice.
 
No, I agreed with what you last said about "safety bulletins", which seems to be your word for Service Bulletins. Otherwise, I disagree. The reg says all safety directives must be complied with, and a Service Bulletin is a safety directive. Of course, fi the Service Bulletin says the action is only "recommended," then it would not be mandatory, but if the Service Bulletin says "mandatory" on it, there's no choice.

Your interpretation. Fair enough. I'll go by the FAR's and the ASTM.
 
For S-LSA aircraft, SB's ARE REQUIRED for airworthiness. For standard category aircraft, they are not required.

Because the Type Certificate has that statement.
 
No, I agreed with what you last said about "safety bulletins", which seems to be your word for Service Bulletins. Otherwise, I disagree. The reg says all safety directives must be complied with, and a Service Bulletin is a safety directive. Of course, fi the Service Bulletin says the action is only "recommended," then it would not be mandatory, but if the Service Bulletin says "mandatory" on it, there's no choice.

Is that a play on words or a simple spin the topic?

Service bulletins are not required in part 91 unless the aircraft type certificate requires them, as in light sport.

you can call it mandatory, to no avail it still does not apply.
 
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Ron did his home work on this one.

Do I have to comply with an FAA Airworthiness Directive (AD) on SLSA?
While the FAA does not preclude the possibility of issuing an AD specifically for SLSA, an AD may be issued on a TC product (e.g. engines and propellers) incorporated into an SLSA and if necessary on products having other forms of FAA approval. 14 CFR § 91.327(b)(3) requires compliance with all applicable ADs.
• You may want to consider the components installed on an SLSA prior to purchase in regard to the impact of this requirement.
Do I have to comply with the manufacturer’s Safety Directive on SLSA?
SLSA manufacturers will issue Safety Directives to correct unsafe conditions on their aircraft. To keep the SLSA airworthiness certificate valid, owners/operators must comply with all Safety Directives applicable to their aircraft as required by 14 CFR § 91.327(b)(4).
Light-Sport Aircraft Airworthiness Certification Issued on July 8, 2013 Page 3 of 9 AIR-230

Let's keep the nomenclature correct. Safety bulletins, Safety Directives, Service bulletins, Service instructions, all have a meaning and used in different regulations and other FAA writings.
 
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Is that a play on words or a simple spin the topic?

Service bulletins are not required in part 91 unless the aircraft type certificate requires them, as in light sport.

you can call it mandatory, to no avail it still does not apply.



I was under the impression that since SLSA aircraft are certified through ATSM standards, and not FAR's, they do not have a type certificate.

Am I incorrect?
 
I was under the impression that since SLSA aircraft are certified through ATSM standards, and not FAR's, they do not have a type certificate.

Am I incorrect?

No,

Special Category Light-Sport Aircraft (SLSA)
A special airworthiness certificate in the light-sport category is issued to an aircraft that meets the definition of light-sport aircraft (LSA), is manufactured to the applicable consensus standards, and is one of the following five classes of the LSA category: airplanes, gliders, powered parachutes, weight-shift-control aircraft (commonly called trikes), and lighter-than-air aircraft (balloons and airships). When the aircraft meets all the eligibility requirements of Title 14 Code of Federal Regulations (14 CFR) §§ 1.1 and 21.190, it may be issued an airworthiness certificate in the LSA category.
 
No,

Special Category Light-Sport Aircraft (SLSA)
A special airworthiness certificate in the light-sport category is issued to an aircraft that meets the definition of light-sport aircraft (LSA), is manufactured to the applicable consensus standards, and is one of the following five classes of the LSA category: airplanes, gliders, powered parachutes, weight-shift-control aircraft (commonly called trikes), and lighter-than-air aircraft (balloons and airships). When the aircraft meets all the eligibility requirements of Title 14 Code of Federal Regulations (14 CFR) §§ 1.1 and 21.190, it may be issued an airworthiness certificate in the LSA category.

Obviously they are issued Special Airworthiness certificates, both my planes have them, but you said in an earlier post they have type certificates. That is what I was inquiring about.
 
Obviously they are issued Special Airworthiness certificates, both my planes have them, but you said in an earlier post they have type certificates. That is what I was inquiring about.
That post was directed at Ron's remark about service bulletins being mandatory.

service bulletins = part 23 certified aircraft
safety directives = light sport.
 
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