McCauley Propeller service bulletins

[Tom-D]

Almost all the old SBs are now in the overhaul manual.

click the bottom link.

http://www.mccauley.textron.com/service_bulletins.html

All the maintenance we could, do is now limited to a CRS.

 

[denverpilot]

Definition: CRS? Please. Thanks Tom.

 

[Norman]

Can't remember s***

Oh. Wait. I think he means Certificated Repair Station.

 

[denverpilot]

Ahh got it. And the CRS here has stopped doing IRANs and will only do a full overhaul anymore. (Rocky Mtn Propeller)

 

[wsuffa]

Hartzell has made their certain documents as part of the Type Certificate data for some of their props. There result is that overhaul times are now mandatory - time-in-service or calendar time, whichever comes first.

 

[Norman]

Hartzell has made their certain documents as part of the Type Certificate data for some of their props. There result is that overhaul times are now mandatory - time-in-service or calendar time, whichever comes first.

Under Part 91? Something sounds wrong there. If they could do that, aircraft manufacturers could do the same. Then you'd be stuck overhauling your airframe on a schedule.

 

[wsuffa]

Under Part 91? Something sounds wrong there. If they could do that, aircraft manufacturers could do the same. Then you'd be stuck overhauling your airframe on a schedule.

Yes, under Part 91. If the OH time gets specified in the TC or ICA, the it becomes mandatory. For everyone. Including Part 91.

 

[RotorAndWing]

Yes, under Part 91. If the OH time gets specified in the TC or ICA, the it becomes mandatory. For everyone. Including Part 91.

Hartzell has made their certain documents as part of the Type Certificate data for some of their props. There result is that overhaul times are now mandatory - time-in-service or calendar time, whichever comes first.

Legal-Interpretation-of-Current-as-it-Applies-to-Maintenance-Manuals

Applicability and Enforcement of Manufacturer’s Data

 

[FORANE]

Overhaul required even on experimentals? If I had a Hartzell prop on an experimental it would be required to be overhauled at a maximum every 5 years (as read on page 13 here:http://hartzellprop.com//wp-content/uploads/2012/12/SL061Y-R03-W.pdf )?

 

[Norman]

Legal-Interpretation-of-Current-as-it-Applies-to-Maintenance-Manuals

Applicability and Enforcement of Manufacturer’s Data

And the phrase "other techniques, methods, and practices acceptable to the administrator gets you off the hook under Part 91. Does not apply to Part 135 or 121.

 

[Tom-D]

Hartzell has made their certain documents as part of the Type Certificate data for some of their props. There result is that overhaul times are now mandatory - time-in-service or calendar time, whichever comes first.

Show me.

 

[Tom-D]

Definition: CRS? Please. Thanks Tom.

Certified repair station

 

[Tom-D]

Yes, under Part 91. If the OH time gets specified in the TC or ICA, the it becomes mandatory. For everyone. Including Part 91.

The type certificate can limit the life on any part. I do not see any thing like that in the Propeller Type certificates.

The ICAs for propellers are the owners manual for the propeller, and includes only minor maintenance while in service.

Certified Propeller repair stations must comply with the repair manuals when the prop is sent in for overhaul.

BUT

the option is still available to repair as required and allow the time between overhauls to continue.

when the TBO is written into the repair manuals It becomes the same as when Continental and Lycoming says all service bulletins must be complied with at overhaul in their overhaul manuals, it does not include TBO. as we both know is a SB. It just isn't done in part 91.

 

[bnt83]

All of you need to visit FAA order 8620.2A that even says notes sections of TCDS may not be mandatory.

Service bulletins in MM doesn't mean much.

Further, although § 43.13(a) does not specifically address SB’s or SL’s, an OEM may legitimately incorporate an SB or SL into one of its maintenance manuals by reference. If it does so, the data specified, and the method, technique, or practice contained therein, may be acceptable to the Administrator. However, unless any method, technique, or practice prescribed by an OEM in any of its documents is specifically mandated by a regulatory document, such as Airworthiness Directive (AD), or specific regulatory language such as that in § 43.15(b); those methods, techniques, or practices are not mandatory.

 

[wsuffa]

The type certificate can limit the life on any part. I do not see any thing like that in the Propeller Type certificates.

The ICAs for propellers are the owners manual for the propeller, and includes only minor maintenance while in service.

Certified Propeller repair stations must comply with the repair manuals when the prop is sent in for overhaul.

BUT

the option is still available to repair as required and allow the time between overhauls to continue.

when the TBO is written into the repair manuals It becomes the same as when Continental and Lycoming says all service bulletins must be complied with at overhaul in their overhaul manuals, it does not include TBO. as we both know is a SB. It just isn't done in part 91.

Type certificate P9EA specifies that life limits, mandatory inspections, and airworthiness limitations are specified in Hatrzell Manuals 113(), 115N or 117(). The manuals refer to mandatory OH times. At least one FAA FSDO reads that to mean that OH is required as specified in those manuals, including use in Part 91.

 

[Tom-D]

All of you need to visit FAA order 8620.2A that even says notes sections of TCDS may not be mandatory.

Service bulletins in MM doesn't mean much.

Further, although § 43.13(a) does not specifically address SB’s or SL’s, an OEM may legitimately incorporate an SB or SL into one of its maintenance manuals by reference. If it does so, the data specified, and the method, technique, or practice contained therein, may be acceptable to the Administrator. However, unless any method, technique, or practice prescribed by an OEM in any of its documents is specifically mandated by a regulatory document, such as Airworthiness Directive (AD), or specific regulatory language such as that in § 43.15(b); those methods, techniques, or practices are not mandatory.

This note pretty much says it all.

9. Life Limits and Placarding. Adherence to component life limit retirement times listed on a TCDS is required by 43.16 or 91.409(e), and a requirement to follow placard instructions is required by 91.9(a).
10. Summary. Consistent with 14 CFR, a TCDS is part of a product’s TC. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable.

Used as a sole source says that we have other documents that apply to airworthiness such as a STC and Field approvals they are saying that you need to research all the documents. not just the TCDS.

 

[RotorAndWing]

Type certificate P9EA specifies that life limits, mandatory inspections, and airworthiness limitations are specified in Hatrzell Manuals 113(), 115N or 117(). The manuals refer to mandatory OH times. At least one FAA FSDO reads that to mean that OH is required as specified in those manuals, including use in Part 91.

From Order 8620.2A


6.
Applicability.
a.
Section 43.13(a) states, in part, “Each person performing maintenance, alteration, or
preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods,
techniques, and practices prescribed in:
1)
The current manufacturer’s maintenance manual or;
2)
Instructions for Continued Airworthiness prepared by its manufacturer, or;
3)
Other methods, techniques, and practices acceptable to the Administrator.”
b.
The language of § 43.13(a) clearly provides a person with three permissible options when
performing maintenance, alterations, or preventive maintenance on a product. Section 43.13(a) does not provide an order of precedence for these three options. Further, although § 43.13(a) does not specifically address SB’s or SL’s, an OEM may legitimately incorporate an SB or SL into one of its maintenance manuals by reference. If it does so, the data specified, and the method, technique, or practice contained therein, may be acceptable to the Administrator.
However, unless any method, technique, or practice prescribed by an OEM in any of its
documents is specifically mandated by a regulatory document, such as Airworthiness Directive (AD), or specific regulatory language such as
that in § 43.15(b); those methods, techniques, or practices are not mandatory.

7.
TCDS.
Consistent with 14 CFR, a TCDS is part of a product’s type certificate (TC). A
TCDS is a summary of the product’s type design.
It is used primarily by authorized persons during initial or recurrent issuan
ce of a Standard Airworthiness Certificate. It is neither a
regulation, a maintenance requirements document, or a flight manual document. As such, for
aircraft holding a valid and current airworthiness certificate, a TCDS
should not be used as a sole source to determine what maintenance is required
or what the flight operations requirements are.
Any language on a TCDS, by itself, is not regulatory and is simply not enforceable. There must be a corresponding rule to make any language on
the TCDS mandatory. For example, there is a mention of “operating limitations” on most
TCDS. The corresponding rule for “operating limitations” is 14 CFR § 91.9(a) which states, “Except as provided in paragraph (d) of this section, no person may operate a civil aircraft
without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the countryof registry.” Without § 91.9, the TCDS requirement to comply with operating limitations would not be enforceable.

8.
TCDS Notes.
TCDS notes are intended primarily to provide information on the various
requirements for issuing an airworthiness certificate as well as the type and location of various
technical documents used to operate and maintain the product. Some OEM’s have placed
mandatory language such as “shall,” “must,” and “will” on their TCDS that imply that
compliance with TCDS notes is mandatory. However, in the absence of regulatory language, or an AD that makes such TCDS notes mandatory, compliance with such notes is not mandatory. It would mean that FAA regulations effectively authorize OEMs to issue “substantive rules,” i.e., it would enable an OEM to impose legal requirements on the public that differ from the 14 CFR requirements. This would be objectionable for
two reasons. First, the FAA does not have the authority to delegate its rulemaking authority
to an OEM. Second, “substantive rules” can be adopted only in accordance with the notice and comment procedures of the Administrative Procedures Act (APA), which
does not apply to an OEM.

9.
Life Limits and Placarding.
Adherence to component life limit retirement times listed on a TCDS is required by §§ 43.16 or 91.409(e), and a requirement to follow placard instructions is required by § 91.9(a).

10.
Summary.
Consistent with 14 CFR, a TCDS is part of a product’s TC. As such, for aircraft
holding a valid and current airworthiness certificate, a TCDS should
not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable.

 

[bnt83]

What this says to me is:

1. On the latest revision of the TCDS P9EA for Hartzell props, is that the "life limits and mandatory inspections" are NOT mandatory, unless implemented via AD, as they were slipped in there in the notes section after initial certification.






8.TCDS Notes.
TCDS notes are intended primarily to provide information on the various
requirements for issuing an airworthiness certificate as well as the type and location of various technical documents used to operate and maintain the product. Some OEM’s have placed mandatory language such as “shall,” “must,” and “will” on their TCDS that imply that compliance with TCDS notes is mandatory. However, in the absence of regulatory language, or an AD that makes such TCDS notes mandatory, compliance with such notes is not mandatory. It would mean that FAA regulations effectively authorize OEMs to issue “substantive rules,” i.e., it would enable an OEM to impose legal requirements on the public that differ from the 14 CFR requirements. This would be objectionable for two reasons. First, the FAA does not have the authority to delegate its rulemaking authority to an OEM. Second, “substantive rules” can be adopted only in accordance with the notice and comment procedures of the Administrative Procedures Act (APA), which does not apply to an OEM.




Then there are OEM's who have revised the MM to include an FAA approved Airworthiness Limitations section that did not exist previously. With the legal interpretation of "current" from the FAA, I don't see how those new Airworthiness Limitations sections can be considered mandatory without an AD making it so.

 

[wsuffa]

What this says to me is:

1. On the latest revision of the TCDS P9EA for Hartzell props, is that the "life limits and mandatory inspections" are NOT mandatory, unless implemented via AD, as they were slipped in there in the notes section after initial certification.






8.TCDS Notes.
TCDS notes are intended primarily to provide information on the various
requirements for issuing an airworthiness certificate as well as the type and location of various technical documents used to operate and maintain the product. Some OEM’s have placed mandatory language such as “shall,” “must,” and “will” on their TCDS that imply that compliance with TCDS notes is mandatory. However, in the absence of regulatory language, or an AD that makes such TCDS notes mandatory, compliance with such notes is not mandatory. It would mean that FAA regulations effectively authorize OEMs to issue “substantive rules,” i.e., it would enable an OEM to impose legal requirements on the public that differ from the 14 CFR requirements. This would be objectionable for two reasons. First, the FAA does not have the authority to delegate its rulemaking authority to an OEM. Second, “substantive rules” can be adopted only in accordance with the notice and comment procedures of the Administrative Procedures Act (APA), which does not apply to an OEM.




Then there are OEM's who have revised the MM to include an FAA approved Airworthiness Limitations section that did not exist previously. With the legal interpretation of "current" from the FAA, I don't see how those new Airworthiness Limitations sections can be considered mandatory without an AD making it so.

At least one FSDO is of the opinion that the addition of that language makes it mandatory. Yours may not.

 

[RotorAndWing]

What this says to me is:

1. On the latest revision of the TCDS P9EA for Hartzell props, is that the "life limits and mandatory inspections" are NOT mandatory, unless implemented via AD, as they were slipped in there in the notes section after initial certification.






8.TCDS Notes.
TCDS notes are intended primarily to provide information on the various
requirements for issuing an airworthiness certificate as well as the type and location of various technical documents used to operate and maintain the product. Some OEM’s have placed mandatory language such as “shall,” “must,” and “will” on their TCDS that imply that compliance with TCDS notes is mandatory. However, in the absence of regulatory language, or an AD that makes such TCDS notes mandatory, compliance with such notes is not mandatory. It would mean that FAA regulations effectively authorize OEMs to issue “substantive rules,” i.e., it would enable an OEM to impose legal requirements on the public that differ from the 14 CFR requirements. This would be objectionable for two reasons. First, the FAA does not have the authority to delegate its rulemaking authority to an OEM. Second, “substantive rules” can be adopted only in accordance with the notice and comment procedures of the Administrative Procedures Act (APA), which does not apply to an OEM.




Then there are OEM's who have revised the MM to include an FAA approved Airworthiness Limitations section that did not exist previously. With the legal interpretation of "current" from the FAA, I don't see how those new Airworthiness Limitations sections can be considered mandatory without an AD making it so.

You are correct.