Maybe. Are you signing a 100 hr off in the book? If so, what will the write up state? I used to do something similar but I signed off a complete 100hr via Appendix D and I also checked the ADs due to the reference i posted above. Splitting hairs with "91 required inspection" could leave you open in the future as there is no regulatory path to separate a complete 100 vs a 90% 100 insp unless stated in your sign off.
Regulation regarding AD review?
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alfadog
Final Approach
I put "approved for return-to-service pending an annual inspection" in my write-up. And I am comfortable with the condition of the a/c and of the AD's. But, it is a lesson learned and I will be even more careful in the future.
Silvaire
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Silvaire
No, “airworthy IAW an annual inspection” has nothing to do with the AD’s. There could be an AD that specifies “within 10 hrs TIS” since issuance and maybe the airplane only has 8 hrs so two hours after the annual is signed off it’s unairworthy. But the annual inspection is done and is good for a year.
Granted, we don’t usually go about it this way but sometimes, due to circumstances, you do and there’s nothing wrong with it.
A quick FYI: your A&P signature constitutes an approval for return to service so no need to be spelled out and I would also leave out "pending an annual." Signing off an aircraft "pending" something else is a bit out of place and can appear to mean "after" the annual is completed. If the aircraft is airworthy... it's airworthy, period.
Eh? As pointed out airworthiness is always an "instant" thing. It could be unairworthy tomorrow.
If you do a 100 hour prior to the annual being done, you can certainly add "Annual due 11/2018" or whatever. Similarly if with an annual or 100Hr with an AD coming up, you can say AD 2016-99-99 due before x/xx as a heads up, but certainly not required. There should be a list of the existing ADs and their status somewhere in the aircraft records.
ANYBODY authorized to perform maintenance can return an aircraft to service after an annual. If the IA signs off my plane "Annual performed, tires not airworthy, need replacing." As the owner-pilot I can replace them and return the plane to service on my signature in the log.
If you do a 100 hour prior to the annual being done, you can certainly add "Annual due 11/2018" or whatever. Similarly if with an annual or 100Hr with an AD coming up, you can say AD 2016-99-99 due before x/xx as a heads up, but certainly not required. There should be a list of the existing ADs and their status somewhere in the aircraft records.
ANYBODY authorized to perform maintenance can return an aircraft to service after an annual. If the IA signs off my plane "Annual performed, tires not airworthy, need replacing." As the owner-pilot I can replace them and return the plane to service on my signature in the log.
Checkout_my_Six
Touchdown! Greaser!
those are not recommended sign-offs....however, a sign off with discrepancies is the correct method.
Tarheelpilot
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Tarheelpilot
Umm no
The person signing the inspection has to actually inspect the aircraft, no proxies.
They can likely get away with delegating a few things (opening inspection plates, washing the engine, etc...) called out for, but not for putting their eyes on the plane and paperwork both.
They can likely get away with delegating a few things (opening inspection plates, washing the engine, etc...) called out for, but not for putting their eyes on the plane and paperwork both.
N3368K
Cleared for Takeoff
Duly noted and publicly responded as such, but your taking notice and taking even more time to post such a detailed response really makes all the difference. I really was on the fence until your well constructed...grunt. Now, if only Ravioli would chastise me, my day would be complete.
Everyone will now be returned to their previous program, still in progress.
In all seriousness, I admit I was wrong. I know that is infrequent on an aviation board.
Skip Miller
Final Approach
“Inspection of Nxxxx performed at xxxx hours. (Insert list of items inspected.) No discrepancies found. Next annual inspection due in (month/year).” This last is based on the date of the last annual inspection not the most recent 100 hr.
Not an A&P nor an IA. Just spitballing here.
Tarheelpilot
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In all seriousness, I admit I was wrong. I know that is infrequent on an aviation board.
You’re not alone. I do too.
alfadog
Final Approach
In actual fact, there is no need to say that you inspected anything if it is not a required inspection. That is my takeaway here. I can inspect the airplane all I like, I can use the 100-hr/annual inspection checklist as a guide, but I only make maintenance entries for those things I actually do, not inspect, and then my signature is an RTS for work performed.
SkyDog58
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Canis Non Grata
Here are a couple FAA Chief Counsel opinions that might be worthwhile reading for those who remain uncertain as to the requirements in regards to Airworthiness Directives and Annual Inspections.
Opinion 1.
Opinion 2.
Opinion 1.
Opinion 2.
alfadog
Final Approach
Interesting. Thanks!
Part 43.11 provides the basic guidance. I normally follow this and add more details as needed.
“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”
FWIW, you're digging yourself a hole with that logic path. Keep it simple. If you use Appendix D state it. The first question that came to mind when I read your post was what are you trying to hide. If you try to split hairs on 43.9 and 43.11 while following your thought process you slide close to 43.12 which is not a fun place for an A&P to be. Forget the "required" adjective.
alfadog
Final Approach
If an owner comes to me and says "Look, I have an IA that will do the annual but he is an old guy and does not want to do anything beyond the actual inspection. I want you to go over the a/c and get it in shape for an annual". If that is the case, why would I mention "inspection" at all in my logbook entry? Why would I not just list the actual work I performed? That is what I am saying there.
Why wouldn't you? Isn't that what you are doing?
Let's cut to the chase. If I understand you correctly, you are going to "look over the aircraft" to ensure the old IA won't run into any issues? If so, post here the write up you will enter/entered in the logbook for the work you perform. And we'll see where it takes us.
Checkout_my_Six
Touchdown! Greaser!
Why?....an A&P does not have the authority to perform "inspection" for the annual. He can perform "maintenance"....but, not "inspection".
If you want to do a pre-buy and fix stuff....then do so and sign that off. But, if you claim "inspection" that's an open door for trouble. IMHO.
If you want to do a pre-buy and fix stuff....then do so and sign that off. But, if you claim "inspection" that's an open door for trouble. IMHO.
alfadog
Final Approach
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Okay. Now you lost me. Aside from the "pending Annual inspection" bit, you have signed off a 100 hour inspection in both write ups. So what was the issue again? Even without the "I certify" part of 43.11 you still own it as an inspection and have a greater chance of getting gigged for not including "I certify." Good write ups by the way.
And a further FYI: if you state you followed that Gruman checklist be sure you followed every step. If not make sure you note which ones you didn't. And while I don't speak Gruman a majority of OEM checklists I'm familar with usually contain a line to check ADs which I think was your original post?. It's a trap many people have gotten caught in.
Also, does the Gruman checklist provide engine requirements? Usually the airframe docs refer to engine docs which should be used for sign off reference.
alfadog
Final Approach
My original question in the opening post had to do with where the requirement to look at ADs on an annual came from and did it also apply to 100-hr. That was answered. Then I figured that I could avoid the whole issue by simply not mentioning 100-hr at all in my logbook entries and simply write up the work performed as below. I still like that option. Note that this a/c is out-of-annual by about a year.
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An A&P can perform any inspection. It falls to an IA to perform the inspection he will sign off. In years past, I would assist owner in disassembly, perfom 100hr per Appendix D, IA would then come by with acft open and perform annual per Appendix D, owner would close up. In the end, there would by a 100hr sign off, annual sign off, and owner sign off unless I inc!uded owner name in my sign off. Same inspection, two sign offs.
Without the 100hr referenence, how did you find these disc? Did you disassemble the aircraft like needed for an annual and those were the items you found and corrected? If so, then you would need to indicate that disassembly/reassembly in your non 100 hr write ups. It's all mx that must be documented. A reference like a 100hr guide or Appendix D cuts all the small stuff out.
And just a tip, popular issues found on annuals for aircraft that sat for extended times revolve around AD compliance and bird nests in vertical fins. You're on the right track though.
Silvaire
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Silvaire
Depending on what you’re working on you want to be cautious as to how you make your entry. For instance citing a maintenance manual for an annual inspection could draw you into SID’s which in turn is saying that every service letter and bulletin has been complied with. Stating only that it has been done in accordance with an annual inspection specifically implies appendix D because nowhere else in the FAR’s is there an alternate definition of “annual inspection”. Having done this for decades I’d say that a majority of maintenance entries are unnecessarily wordy. Nothing wrong with that, it’s your logbook, but it can make it tedious for an A&P looking for the important stuff.
SkyDog58
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Canis Non Grata
But the annual inspection must include the scope and detail of appendix D but is not limited to it. The actual checklist can come from a variety of sources and can include more items as determined by the IA or the manufacturer or whoever designed the checklist. Appendix D is the minimum standard.
43.15 (c) Annual and 100-hour inspections.
(1) Each person performing an annual or 100-hour inspection shall use a checklist while performing the inspection. The checklist may be of the person’s own design, one provided by the manufacturer of the equipment being inspected or one obtained from another source. This checklist must include the scope and detail of the items contained in Appendix D to this part and paragraph (b) of this section.
Correct. But if you state a specific checklist like the Gruman above and don't follow every step for the inspection then you leave yourself open to some major issues. One option is to state which steps you did not follow, but that just causes more writing. In other words you can't cherry pick a stated reference to meet the minimums of Appendix D. But as silvaire stated sign off "annual inspection" with no stated reference you are legal and can cherry pick between as many checklist lists as you want. But just be sure you can replicate that checklist if asked by your local blue badge.
Checkout_my_Six
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sounds like a gummint operation....
alfadog
Final Approach
So would you think that my best bet in this instance, would be to say "inspected aircraft in accordance with a 100-hour inspection." It is not a required inspection so I would not need to say anything regarding airworthiness.
You seem to be stuck on "required inspection." Required means nothing to a mechanic in this instance as the term is tied to operational reqirements from Part 91. Part 43 is a performance based regulation that covers what we do. In other words, perform the task, use an appropriate reference, and sign your name. Everything you perform deals with airworthiness. If you perform a 100 inspection, whether required or not, you physically perfomed the inspection and you should state that. The best practice is to do what you say and write up what you do in as few a words as possible.
Maybe an example. If I were tasked with this job, I would have used Appendix D as a guide, performed a 100hr, and signed as follows:
I certify that this aircraft was inspected in accordance with a 100hr inspection per Part 43 Appendix D and a list of discrepancies dated xx/xx/xxxx was provided to the owner.
Depending on what the owner wanted i could have corrected the disc on the fly and signed off aircraft airworthy per 43.11. Or, in an ideal situation disassemble aircraft for the 100, corrected disc on separate write up(s), and have the IA insp/sign annual. This would prevent a second aircraft disassemble for the annual.
alfadog
Final Approach
That is because of my concern over reviewing the ADs. That was my original question in this thread. If the owner does not want to pay me to review the ADs because the IA is going to do it, that is only okay if it is not a required inspection. So the required issue does play a part.
Checkout_my_Six
Touchdown! Greaser!
IMHO....the A&P can do all the required maintenance to "pass" the annual inspection. That's it. Those prior 100hr sign-offs are meaningless. The IA is responsible for signing-off an airworthy aircraft. He has to perform the inspection. The inspection can not be supervised or delegated, he has to perform the inspection. The IA is also responsible for determining that all ADs are complied with. If the A&P wants to perform them, that's OK, but the IA signs that off.
ALL other prior sign-offs are meaningless.....Once the Annual inspection is performed prior sign-offs are historical and moot. The IA bears the responsibility for an airworthy aircraft ....at the instance of the sign-off.
ALL other prior sign-offs are meaningless.....Once the Annual inspection is performed prior sign-offs are historical and moot. The IA bears the responsibility for an airworthy aircraft ....at the instance of the sign-off.
Well, I've taken this topic as far as I can. Considering I've done this type work for many years what I exp!ained above is based on that experience and how I was taught. If your intent is to prep the aircraft for an annual, it's best to follow the same path. Just trying to save you a learning experience. Good luck.
Only from the viewpoint of annual inspections. But the OP was signing off worked performed prior to the annual. Not the same thing. Sometimes the owner wanted me to perform the 100 a month prior to the annual due date. For that last month my sign off had meaning in order to continue flight. For those times when the IA performed the annual concurrently with my 100, that sign off had meaning, not toward annual requirement but it covered the work I performed on the aircraft regardless if the annual was due or not. It all has to be documented. A 100 hr provides a simple and easy sign off covering that work.
alfadog
Final Approach
I do very much appreciate your help. Thanks.
bluesideup
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bluesideup
Hi everyone.
I do not understand why many mechanics and CFIs do not follow thw required by FAA wording when they sigh someone off.
In the case of IAs..., if the wording
I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”
and or additional lists / guides used, is that acft airworthy, and should the owners accept that?
Is there any difference between Normal and SLSA?
I do not understand why many mechanics and CFIs do not follow thw required by FAA wording when they sigh someone off.
In the case of IAs..., if the wording
I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”
and or additional lists / guides used, is that acft airworthy, and should the owners accept that?
Is there any difference between Normal and SLSA?
alfadog
Final Approach
Well, I would not know if the a/c is airworthy, that is determined by the pilot at the moment he climbs in it (I'm picking nits, of course) but that statement certainly seems acceptable to me.
Don't know about CFIs, but on the mx side it's not "required" to enter that wording verbatum as just prior to that statement in 43.11 it states: a similarly worded statement—. The important info is listed in 43.11(a)(1-3). Is it more advantageous to use the exact I certify statement? In my opinion yes, but not required.
Yes it's airworthy and legal. A mechanic's signature constitutes approval for return to service which includes airworthiness.
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You need to look in the operating limitations of the LSA to see how it is to be inspected. There will also be exact wording for the logbook entry you are to use. LSAs are not TCd airplanes and have their own rules.