Need help with really bad AD

[RotaryWingBob]

The FAA has issued an AD (see attached) which sets a very bad precedent: it describes a preflight procedure and then says that each time the preflight procedure is performed (every flight) that a logbook entry must be made.

Now, you may ask, "Why do I give a crap about a helicopter AD"?

Because if the FAA gets away with this one, maybe the next one will call for inspection of aileron hinges on PA28's and then require a logbook entry be made before every flight!

If you agree, please post a comment to this AD at http://www.regulations.gov

and search for 2007-26-12 which will retrieve the Robinson AD (as well as a Cessna AD).


The text of the comment I posted was:

The requirement:

(c) Thereafter, if the rotor blade has been found airworthy by the inspections in paragraph (a), before each flight, visually check for any exposed (bare metal) skin-to-spar bonded area on the lower surface of each blade within the outboard 24 inches paying particular attention to the last 10 inches
before the tip. An owner/operator (pilot) holding at least a private pilot certificate may perform this visual check and must enter compliance into the aircraft maintenance records in accordance with 14
CFR 43.11 and 91.417(a)(2)(V).

to log each preflight inspection is unduly burdensome. It also implies that the aircraft logbooks must be carried in the helicopter. This may be unsafe because they would need to be stowed under one of the seats which might interfere with the ability of the seat to provide a crush zone in the event of a crash.

 

[ScottM]

I agree overly burdensome. I uploaded my comment before I even posted this response.

If this does get into the final AD I guess you can always refuse to do preflights thus absolving you of having to do the log book entry

 

[Don Jones]

Insane rule, comment posted

 

[tdager]

Comments submitted. This is ridiculous and excessive. No way should a logbook entry have to be made for each pre-flight.

 

[Tom-D]

I think you can save your ink, this is a done deal.

Read the paragraph called comments invited. unless you have real data to submit save your ink.

 

[gprellwitz]

I think you can save your ink, this is a done deal.

Read the paragraph called comments invited. unless you have real data to submit save your ink.

Why do you say that?

This AD is a final rule that involves requirements that affect flight safety and was not preceded
by notice and an opportunity for public comment; however, we invite you to submit any written data,
views, or arguments regarding this AD. Send your comments to an address listed under
ADDRESSES. Include ''Docket No. FAA-2007-0378; Directorate Identifier 2007-SW-04-AD'' at the
beginning of your comments. We specifically invite comments on the overall regulatory, economic,
environmental, and energy aspects of the AD. We will consider all comments received by the closing
date and may amend the AD in light of those comments.

{emphasis mine}

 

[wsuffa]

But they're protecting the public. Just like the TSA.

 

[L10MAN]

This is not the first time the FAA has issued an AD requiring an inspection and a sign off prior to flight. When the United 747 on T/O out of Honolulu lost the forward cargo door and a bunch of skin above it, the AD required the door lock idicators be visuall checked prior to each departure. The only difference was, at least in TWA's case, a work sheet had to be signed instead of the log, but same idea, the check had to be documented. That AD did have terminating action, yours, so far, does not. There in lies the rub, if the helicopter is flown frequently you could fill up several log books in a hurry. I don't think anyone is going to talk the FAA out of documenting the check ( this a big time CYA AD) but you might get them to change the way it is documented. Maybe a "work sheet" stating the rotor blade inspection per AD 2700-26-12 was accomplished prior to flight with the date accomplished and pilots name and number. That sheet to remain with the helicopter at all times. What the hey it's worth a shot. In any case good luck.
Ron

 

[Tom-D]

Why do you say that?

{emphasis mine}

This AD is a final rule that involves requirements that affect flight safety and was not preceded
by notice and an opportunity for public comment; however, we invite you to submit any written data,
views, or arguments regarding this AD. Send your comments to an address listed under
ADDRESSES. Include ''Docket No. FAA-2007-0378; Directorate Identifier 2007-SW-04-AD'' at the
beginning of your comments. We specifically invite comments on the overall regulatory, economic,
environmental, and energy aspects of the AD. We will consider all comments received by the closing
date and may amend the AD in light of those comments.

 

[gprellwitz]

This AD is a final rule that involves requirements that affect flight safety and was not preceded
by notice and an opportunity for public comment; however, we invite you to submit any written data,
views, or arguments regarding this AD. Send your comments to an address listed under
ADDRESSES. Include ''Docket No. FAA-2007-0378; Directorate Identifier 2007-SW-04-AD'' at the
beginning of your comments. We specifically invite comments on the overall regulatory, economic,
environmental, and energy aspects of the AD. We will consider all comments received by the closing
date and may amend the AD in light of those comments.

Hmmm....
You concentrate on the "final rule" and I concentrate on the "may amend the AD". Methinks we're both right! I'm just saying that the efforts aren't worthless, not that they may immediately affect you!

 

[Tom-D]

Hmmm....
You concentrate on the "final rule" and I concentrate on the "may amend the AD". Methinks we're both right! I'm just saying that the efforts aren't worthless, not that they may immediately affect you!

I wish the FAA would get reversed on some of these ADs.

I know nothing about helo blades or the necessity of the blade inspection.

But I have seen these emergency ADs before, and to get one reversed in near impossible, You be required to show the AD in not going to be effective in reducing the accident rate.

OR

You must show that the blade failures do not constitute a safety hazzard to the public..

tough road

 

[Henning]

The FAA has issued an AD (see attached) which sets a very bad precedent: it describes a preflight procedure and then says that each time the preflight procedure is performed (every flight) that a logbook entry must be made.

Now, you may ask, "Why do I give a crap about a helicopter AD"?

Because if the FAA gets away with this one, maybe the next one will call for inspection of aileron hinges on PA28's and then require a logbook entry be made before every flight!

If you agree, please post a comment to this AD at http://www.regulations.gov

and search for 2007-26-12 which will retrieve the Robinson AD (as well as a Cessna AD).


The text of the comment I posted was:

The requirement:

(c) Thereafter, if the rotor blade has been found airworthy by the inspections in paragraph (a), before each flight, visually check for any exposed (bare metal) skin-to-spar bonded area on the lower surface of each blade within the outboard 24 inches paying particular attention to the last 10 inches
before the tip. An owner/operator (pilot) holding at least a private pilot certificate may perform this visual check and must enter compliance into the aircraft maintenance records in accordance with 14
CFR 43.11 and 91.417(a)(2)(V).

to log each preflight inspection is unduly burdensome. It also implies that the aircraft logbooks must be carried in the helicopter. This may be unsafe because they would need to be stowed under one of the seats which might interfere with the ability of the seat to provide a crush zone in the event of a crash.

No big deal. I believe you can keep a seperate log for this with the proper entry noted, and on completion of inspection you sign and date, nothing onerous in my view, besides, this isn't a first, there is precedent on these types of ADs. Be glad you don't have to maintain a radio log as well.

 

[tdager]

How many of you keep your log books in your plane? I do not.

So I guess now some guy is going to have to buy a seperate "propeller" logbook to do this. Oh and you all KNOW it will be filled in after the fact, I doubt everyone will actually write this every time they pre-flight.

 

[EdFred]

I would just print off about 200 stickers, put them all in their own special logbook, and just sign em as I need to.

 

[RMCN172RG]

Could it not be interpeted that you need a written record, like for the VOR radio test every 30 days. That record does not mean a logbook entry.

 

[Ted]

Comments made.

 

[RotaryWingBob]

Thanks guys. 43.11 makes it pretty clear what must be in the entry, but I guess that doesn't preclude using a separate logbook. The really dumb thing (to me anyway) is that I don't know any pilots who don't do a visual inspection of both main and tail rotor blades. Even on a refueling stop, I always look at the blades and engine oil level...