POH / AFM

Ron Levy said:
No, it is not. I publicly offer to indemnify the legal expenses of anyone who gets in trouble with the FAA while following my advice on this point.
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Meaningless.

Ron Levy said:
How's that for a guarantee? Can you make the same guarantee for someone choosing to do otherwise? And if you cannot, then kindly bugger off and find someone else to annoy while I try to give people sound advice on how to operate legally.
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Your "advice" here is worth exactly what's being paid for it. And many times your "interpretations" are, at best, looney.


Ron Levy said:
And I do not hold a "Flight Instructor rating" -- those went away many decades ago, as you should know if you were an FAA ASI (Ops). I hold a Flight Instructor certificate. So please try to be more accurate in your posts.
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Nice twist to deflect the subject. I will give you credit on that, whenever you get called out on something you are very clever on twisting the argument away to something else.

Bottom line Ron, if you want to make claims such as your AFS-800 one, put up or shut up little man.
 
Thanks for the spirited debate, gents. This has been pretty insightful.

Let's assume that I do choose to follow the limitations in the TCDS, and that we are talking about a FAR23 aircraft.

Would anyone disagree with the following:

  • The only changes you are required to make to the manufacturer-suplied, serial-number-specific POH/AFM/RFM, besides supplements, are changes provided by the manufacturer and marked specifically for that serial number.
  • The only changes you can legally make to the manufacturer-suplied, serial-number-specific POH/AFM/RFM, besides supplements, are changes provided by the manufacturer and marked specifically for that serial number.
The above has been my understanding for some time now. I've been trying to keep this very generic, so the thread is of use to other people, but I'll explain why I'm asking for verification.

Robinson Helicopter Company (RHC) releases POH updates in a few different ways. One is via a PDF on their webpage. Anyone can download and print the most current revision of their POH from their website. I want to make sure I'm correct in saying that these printed out pages, many of which require FAA approval, can NOT be used to update the POH that shipped with the aircraft and have older approval dates.

Another way RHC release updates is via a subscription service. This service isn't necessarily tied to a particular airframe (although the order form allows you to specify your serial number). These are (or can be) generic updates that, essentially, save you from having to print out the pages as described above. Similarly, I want to make sure I'm correct in saying that an owner/operate is not required to subscribe to do this and keep the POH updated with these pages.

I assume—but don't know because I'm not an owner/operator—that if a POH update is required for a POH tied to an aircraft, RHC would send out the update specifically for that serial number (not via the subscription, or online PDF mentioned above).
 
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I've never seen a company put out a "serial number" specific update. What they'll typically do is issue a Service Bulletin with the range of serial numbers that update applies to. Sometimes these SB's get elevated to the level of an AD.

Just as with anything else, if you have a "required" POH, the only thing that can "require" a change for most of us non-commercial operators is an AD. Even MANDATORY service bulletins aren't.
 
bqmassey said:
Let's assume that I do choose to follow the limitations in the TCDS, and that we are talking about a FAR23 aircraft.

Would anyone disagree with the following:

  • The only changes you are required to make to the manufacturer-suplied, serial-number-specific POH/AFM/RFM, besides supplements, are changes provided by the manufacturer and marked specifically for that serial number.
  • The only changes you can legally make to the manufacturer-suplied, serial-number-specific POH/AFM/RFM, besides supplements, are changes provided by the manufacturer and marked specifically for that serial number.
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The only changes you are required to make to your AFM/POH are those directed by the FAA by Airworthiness Directive, and that AD will specify which aircraft are affected. You are also permitted to make any changes which are official revisions to the AFM/POH by the type certificate holder. Further, you are required to add any AFM supplements required by any approved alterations, e.g., adding a GNS430 AFMS to your AFM/POH if you have an aftermarket 430 installed.

Note that if you have a pre-1978 aircraft with no AFM, and you add something that requires an AFMS (like a 430), you may have to carry the applicable AFM supplement even though you have no AFM to supplement.
 
Yep, right before I went for my instrument checkride I decided to tidy up my aircraft paperwork in case the examiner was a stickler for such things. I have a loose leaf binder with the limitations book and the equipment list in it plus all the flight manual supplements. I stuck all the pilot guides that are required (autopilot, GNS480, MX20, JPI) in the seat pocket. I did a little nicer W&B pictograph by hand on a sheet of paper. (There's actually no loading graph in my "official" paperwork. It just describes the envelope in the form of a few arms and weights and "straight line intropolation between then."

Garmin came out with a MANDATORY SB (now rescinded after the next software update) that required the 480 to lose it's GPS sole means navigation. I conveniently neglected to file that one.
 
Ron Levy said:
The only changes you are required to make to your AFM/POH are those directed by the FAA by Airworthiness Directive, and that AD will specify which aircraft are affected.
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Ron Levy said:
Further, you are required to add any AFM supplements required by any approved alterations, e.g., adding a GNS430 AFMS to your AFM/POH if you have an aftermarket 430 installed.
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Awesome, that was my understanding. Thanks for the summary!

Ron Levy said:
You are also permitted to make any changes which are official revisions to the AFM/POH by the type certificate holder.
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When you say "official" revisions, are you referring only to the updates that are sent out specifically to the owners of the relevant models?

Or, could someone update their aircraft's POH/AFM/RFM via alternative methods, using pages

  • Xerox'd from a more up to date POH
  • printed from digital form of the latest version (like the scanned PDF's available on Robinson's website)
  • from an subscription intended to keep non-serialized, home-study POH's up to date?
 
bqmassey said:
Awesome, that was my understanding. Thanks for the summary!



When you say "official" revisions, are you referring only to the updates that are sent out specifically to the owners of the relevant models?

Or, could someone update their aircraft's POH/AFM/RFM via alternative methods, using pages

  • Xerox'd from a more up to date POH
  • printed from digital form of the latest version (like the scanned PDF's available on Robinson's website)
  • from an subscription intended to keep non-serialized, home-study POH's up to date?
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The key is whether the update is specific to your aircraft. While that might not mean something as specific as tail number, it will mean serial number.

You might be surprised at how limited a group that might be. Although not an official example, this might be illustrative: Some years ago a Comanche (definitely not a POH aircraft!) aficionado decided to create a modern POH out of AFM material. The one for the model I flew was identified as applicable to the 1950-1960 model years but only for "Serial Numbers 24-103 through 24-2298 except 24-2003"
 
bqmassey said:
When you say "official" revisions, are you referring only to the updates that are sent out specifically to the owners of the relevant models?
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Doesn't matter how you got it as long as it is applicable to your aircraft and you have the relevant revision change page to get you through it and the updated page with the list of effective pages. The only page which really must come from the manufacturer is the original cover page with the s/n and signature.

Or, could someone update their aircraft's POH/AFM/RFM via alternative methods, using pages

  • Xerox'd from a more up to date POH
  • printed from digital form of the latest version (like the scanned PDF's available on Robinson's website)
  • from an subscription intended to keep non-serialized, home-study POH's up to date?
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Other than the title page, I don't think the FAA will care one way or the other as long as the end result is complete in accordance with the effective pages list. and matches up with what they have on file the Aircraft Certification Office.
 
midlifeflyer said:
The key is whether the update is specific to your aircraft. While that might not mean something as specific as tail number, it will mean serial number.

You might be surprised at how limited a group that might be. Although not an official example, this might be illustrative: Some years ago a Comanche (definitely not a POH aircraft!) aficionado decided to create a modern POH out of AFM material. The one for the model I flew was identified as applicable to the 1950-1960 model years but only for "Serial Numbers 24-103 through 24-2298 except 24-2003"
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I would point out that those early Comanches have a required AFM of a dozen pages or so (nothing like the very comprehensive post-78 AFM's with which most of us are familiar). While you are certainly free to create any document you like to carry along with the official FAA-approved AFM, you must still have that FAA-approved AFM aboard unless you get the FAA to approve your homemade AFM as a replacement. I've seen such an approved replacement comprehensive POH/AFM for a pre-78 Turbo Twin Comanche. I have no idea whether the PA-24 POH to which Mark refers is or is not so approved, but I'll bet the ICS has all the details on the options for both single and Twin Comanches.
 
Ron Levy said:
The only changes you are required to make to your AFM/POH are those directed by the FAA by Airworthiness Directive, and that AD will specify which aircraft are affected. You are also permitted to make any changes which are official revisions to the AFM/POH by the type certificate holder.
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Not true at all.

You MUST keep your AFM/POH current with the manufacturers revisions.

There is no "cherry picking" what revisions to which you may want to adhere.

A good example is this revision to certain King Air AFM/POHs....


""""For the E90 and H90 fuselage pressure vessel structural life limit, refer to the latest revision of the airplane flight manual for mandatory retirement time.
For the Model C90A and C90GT, the retirement limit is 13,500 hours time in service. However, the Fuselage
Life may be unlimited if the airplane is maintained and inspected at the required intervals in Chapter 5 (or
Chapter 4 or Airworthiness Limitations Section, as appropriate) of the Airplane’s Maintenance Manual """""""


You are NOT allowed to ignore that AFM revision and willy/nilly fly beyond retirement limit.
 
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kgruber said:
Not true at all.

You MUST keep your AFM/POH current with the manufacturers revisions.

There is no "cherry picking" what revisions to which you may want to adhere.

A good example is this revision to certain King Air AFM/POHs....


""""For the E90 and H90 fuselage pressure vessel structural life limit, refer to the latest revision of the airplane flight manual for mandatory retirement time.
For the Model C90A and C90GT, the retirement limit is 13,500 hours time in service. However, the Fuselage
Life may be unlimited if the airplane is maintained and inspected at the required intervals in Chapter 5 (or
Chapter 4 or Airworthiness Limitations Section, as appropriate) of the Airplane’s Maintenance Manual """""""


You are NOT allowed to ignore that AFM revision and willy/nilly fly beyond retirement limit.
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You can point to the FAA regulation saying that AFM revisions after the C of A was issued but not called for in an AD must be complied with?
 
Ron Levy said:
You can point to the FAA regulation saying that AFM revisions after the C of A was issued but not called for in an AD must be complied with?
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A similar yet different event going on recently.

Cantilever Cessna 210 Service Manuals was just revised to include an FAA approved Airworthiness Limitations section covering eddy current of wing spars, and no one at the FAA has given an interpretation if its required, not even the inspector who signed the thing. All have passed the buck to get legal involved. If required, the FAA has found a work around to avoid the NPRM/AD process. This could happen to any airplane flying.

None of these old cantilever 210's had such a thing in the Service Manual. There is no Airworthiness Limitations on the Type Certificates (except P210 windows).
 
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bnt83 said:
A similar yet different event going on recently.

Cantilever Cessna 210 Service Manuals was just revised to include an FAA approved Airworthiness Limitations section covering eddy current of wing spars, and no one at the FAA has given an interperation if its required, all have passed the buck to get legal involved. If required, the FAA has found a work around to avoid the NPRM/AD process. This could happen to any airplane flying.

None of these old cantilever 210's had such a thing in the Service Manual. There is no Airworthiness Limitations on the Type Certificates (except P210 windows).
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The Chief Counsel has taken Flight Standards to task before for trying to bypass the rulemaking process, and the Administrator has backed the Chief Counsel in those confrontations Note that since AD's are regulatory, they are indeed subject to the rulemaking process.
 
The text kgruber quotes comes out of the the notes on the King Air type certificate and tells you where you can find the pressure vessel service life information. It doesn't say squat about having to have any edition of POH in the plane.

In fact, the TC spells out the which part number to use for the AFM by model and serial number. To deviate from that would take compliance with some piece of approved data (AD, SB). For most of us, service bulletins even when characterized as MANDATORY aren't mandatory.
 
Ron Levy said:
I guess the answer is you don't have an answer. A life limit revision will come out as an AD, not just an AFM revision.
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You don't have a clue. Another MAJOR revision to most Beech AFMs was the REMOVAL of the short field takeoff procedures. This happened to all Beech's I am familiar with, from All the King Airs to the Bonanzas.

So with your logic, just ignore the AFM revision and keep on flying the previously published SFP.

Starting to sound ignorant here again, Ron.:no:
 
kgruber said:
You don't have a clue. Another MAJOR revision to most Beech AFMs was the REMOVAL of the short field takeoff procedures. This happened to all Beech's I am familiar with, from All the King Airs to the Bonanzas.

So with your logic, just ignore the AFM revision and keep on flying the previously published SFP.

Starting to sound ignorant here again, Ron.:no:
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Again, please show me the regulation which says this. A manufacturer cannot arbitrarily change the certification requirements for plane already issued a C of A. It must go through the FAA approval/certification process at the cognizant FAA Aircraft Certification Office and an AD must be issued directing the change to previously certified aircraft.
 
You're sounding like a broken record, Ron.

With your logic Beech owners can still use the short field.....W/flap....takeoff procedures, in disregard to the AFM/POH revisions.

Typical of your kind of asinine kind of argument. How about you show me the FAA reg that says owners can ignore AFM/POH revisions.
 
kgruber said:
You're sounding like a broken record, Ron.

With your logic Beech owners can still use the short field.....W/flap....takeoff procedures, in disregard to the AFM/POH revisions.

Typical of your kind of asinine kind of argument. How about you show me the FAA reg that says owners can ignore AFM/POH revisions.
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You still don't get it -- it takes an AD to make such a revision binding on the operator of an aircraft already issued a C of A. A manufacturer cannot make changes to an FAA-approved AFM without approval of the ACO, and if approved, an AD must be issued to effect the change. This is exactly what R&W's oft-cited FAA Order 8620.2A addresses. Once that AD is issued and sent to all registered owners of the affected aircraft, they will have some specified time within which to bring their aircraft into compliance, but the AD process must be followed to effect such a change or it is legally unenforceable.
 
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Wrong.

You are that type of person who likes to sound authoritative, and can usually get away with it even if you are clueless.

I am calling B.S. I can assure you that if my King Air 65-A90 were FAA inspected and I showed the inspector where I didn't update the AFM/POH, there would be a violation.

BTW, a TCDS revision requires the AFM/POH to be revised for the time life limitation on the King Air airframe.


Notice they are on Revision 65.
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/0/8c3d574efe5ea4a58625733a006a4a8b/$FILE/3a20.pdf

The AFM/POH must be current. You say it needn't. Show me!
 
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And I will back up C'Ron here. You're talking out you ass. There's not only NOT any requirement for people to update the manual, it takes a specific authorization to make changes from the type certificate.

If you are operating part 135 the RULES are different. Mandatory service bulletins are indeed mandatory. I've certainly seen POH changes, etc... distributed in that fashion. However for the non-commercial operator, service bulletins, like TBOs (in most cases) are just suggestions by the manufacturer and not binding.

And you show me WHERE in the current 3A20 that it says anything of the sort. What it says is that the life limit information can be found in the latest AFM version. That's maintenance information. It doesn't say squat about having that information in the aircraft.
 
Great. If you have a Bonanza or an old King Air.....go back and see if you can find the pages that got ripped out in 1978. Then you can just use flaps for takeoff.

You clearly know nothing and can add nothing substantive.
 
Thanks all for the continued discussion. I find it quite interesting.

Here is a Letter of Interpretation that you guys might find noteworthy:

Elmy 2011
 
kgruber said:
Great. If you have a Bonanza or an old King Air.....go back and see if you can find the pages that got ripped out in 1978. Then you can just use flaps for takeoff.
.
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I'm not sure I understand this analysis.

Are you talking about a manufacturer simple removing the procedure or are you talking about the manufacturer creating a new limitation?

If simply removing those pages without issuing a prohibition, it's probably an irrelevant discussion. It just means there is no manufacturer-approved short takeoff procedure. If the manufacturer not covering something in a POH created a limitation against the procedure, I violated operating limitations for 20 years in Colorado when I took off at density altitudes not covered by the POH performance specs. So sure, find an older manual and under controlled conditions see if the old procedure works.

If you are talking about actually creating a new limitation, let's clarify what you mean: Pilot A buys a 1973 Bonanza in 1980. Pilot B buys it in 1974. A manual revision takes place in 1978 that imposes a new "limitation" - no takeoff with approach flaps. But it wasn't imposed by AD.

Am I correct you see no difference between:
(1) a manufacturer (non-AD) revision that existed when I bought it ; and
(2) a manufacturer (non-AD) revision that did not exist when I bought the airplane
?
 
midlifeflyer said:
I'm not sure I understand this analysis.

Are you talking about a manufacturer simple removing the procedure or are you talking about the manufacturer creating a new limitation?
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The King Air 65-A90 had a short field takeoff procedure in the POH, when issued in 1967.

In about 1978, beech mailed out a POH revision that removed that page. There was no change to the "limitations." I believe this happened across the board to most Beech airframes.

Under the Elmy interpretation, I needn't have done that.

Also, now at Flight Safety, where they hand out the latest AFM/POH to thousands of students.........along with a pile of revisions. They can just say............""you may throw away the revisions, that don't have associated ADs""..........if you don't personally like them.

And all Beech owners can rifle through their garbage and reinstall their short field procedures. Which, would be a good thing.
 
kgruber said:
TAlso, now at Flight Safety, where they hand out the latest AFM/POH to thousands of students.........along with a pile of revisions. They can just say............""you may throw away the revisions, that don't have associated ADs""..........if you don't personally like them.
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But the material they hand out at FlightSafety is for reference only. It is obviously not tied to any particular airplane because, as you said, it's handed out to thousands of students. You can do whatever you want with this material, leave it behind, recycle it...
 
kgruber said:
In about 1978, beech mailed out a POH revision that removed that page. There was no change to the "limitations." I believe this happened across the board to most Beech airframes.

Under the Elmy interpretation, I needn't have done that.
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Technically no. And besides, the removal of the pages in that context really only means "there is no longer a manufacturer-approved flap takeoff procedure for this aircraft," nor "takeoff with flaps prohibited." It doesn't even mean "takeoff with flaps is unsafe." I would expect that to be a limitation or at least a required cautionary placard (like the famous non-limitation slips with flaps placard in the Cessna 172) if that were the case

BTW, I am looking at a 2002 edition A36 PIM right now. No, there is no "short field takeoff" procedure in the Normal checklists. But the Before Takeoff Section includes "Flaps - Set for Takeoff" and Performance section includes takeoff performance numbers with flaps at 12°.

How does that affect your analysis?

Also, now at Flight Safety, where they hand out the latest AFM/POH to thousands of students.........along with a pile of revisions. They can just say............""you may throw away the revisions, that don't have associated ADs""..........if you don't personally like them.
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As Mari said, those are not official in any way, just informational stuff.

And all Beech owners can rifle through their garbage and reinstall their short field procedures. Which, would be a good thing.
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I don't know if I would "re-install" them after removing them. But I would sure like to have a reference for how to best accomplish the flap takeoff shown in the POH performance pages instead of using a generic procedure.
 
On the topic of 23.1581 and the AFM/POH...

I recently rented a 162. When I pointed out that the POH was not in the aircraft, I was told that the manufacturer-provided checklist was sufficient and that the POH was not required. How can this be?

As it turns out, the 162 POH itself states that while the "POH [is] recommended to be accessible to pilot in flight", the "162 pilot's checklist [is] required to be accessible to pilot in flight".
 
You were told wrong. The 162 flight manual is required to be on board. It can be stored someplace not accessible in flight (though it is recommended that it is).

It is an additional requirement that the checklist MUST be accessible. That doesn't SUPPLANT the requirement the AFM be onboard.
 
GeorgeC said:
On the topic of 23.1581 and the AFM/POH...

I recently rented a 162. When I pointed out that the POH was not in the aircraft, I was told that the manufacturer-provided checklist was sufficient and that the POH was not required. How can this be?
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Since the C-162 is a Light Sport Aircraft, the normal AFM requirements of Part 21 (specifically, 14 CFR 21.5) do not apply. This is shown in the Equipment List in the POH which shows the POH as Standard, but not Required. So, while flying without the POH aboard might not be the best/smartest idea, it's not illegal.
 
Thanks, Ron. Is 91.327 (d) the pertinent reg?
 
GeorgeC said:
Thanks, Ron. Is 91.327 (d) the pertinent reg?
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Yes, it is, since the Equipment List provided by Cessna specifically lists the POH as "Standard" rather than "Required".
(d) Each person operating an aircraft issued a special airworthiness certificate in the light-sport category must operate the aircraft in accordance with the aircraft's operating instructions, including any provisions for necessary operating equipment specified in the aircraft's equipment list.
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Nice research work, by the way. :yes:
 
I had to bump this thread because I recently (in an effort to clean up my airplanes paperwork) got into this.

I have a 1956 Cessna 172 that only came with an "owners manual". Nothing in it about being approved by the FAA. It does however contain lengthy chapters on weight and balance as well as operating limitations.

I dug and dug and eventually came up with the TCDS for my make/model and read through it.

Long story short, for my serial number an approved my flight manual or POH is not required.

What is required, however, is the installation of a stall warning indicator (already done), modification of any weight and balance calculation to include 30lbs of unusable fuel (at time of manufacture, unusable fuel wasnt included I guess), and a host of placards.

I have ordered the missing placards, but that takes care of the O (in AROW) for me. It only took asking for some guidance and reading through 50+ years of maintenance documentation, and then reading through FAA docs.
 
gitmo234 said:
I had to bump this thread because I recently (in an effort to clean up my airplanes paperwork) got into this.

I have a 1956 Cessna 172 that only came with an "owners manual". Nothing in it about being approved by the FAA. It does however contain lengthy chapters on weight and balance as well as operating limitations.

I dug and dug and eventually came up with the TCDS for my make/model and read through it.

Long story short, for my serial number an approved my flight manual or POH is not required.

What is required, however, is the installation of a stall warning indicator (already done), modification of any weight and balance calculation to include 30lbs of unusable fuel (at time of manufacture, unusable fuel wasnt included I guess), and a host of placards.

I have ordered the missing placards, but that takes care of the O (in AROW) for me. It only took asking for some guidance and reading through 50+ years of maintenance documentation, and then reading through FAA docs.
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Nice research work. Well done.
 
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