Reoccurring AD removal question.

OkieAviator

OkieAviator

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OkieAviator
I meet with my A&P Sunday to finalize my interior refurbishment and walk through all the things I did and hope I didn't do anything that he won't sign off on.

I didn't reinstall the post Map light and switch on the 172. There's a reoccuring AD on this (AD 01-23-03) that gets checked every annual/100 hour. If I removed it, I would think that means this AD wouldn't be valid anymore.

Would the log entry just say something like "Removed original map light and switch. AD 01-23-03 no longer applicable."?

Forgot to add I'm working up the log entry on the changes because it contains so many part numbers and other information.
 
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OkieAviator said:
I meet with my A&P Sunday to finalize my interior refurbishment and walk through all the things I did and hope I didn't do anything that he won't sign off on.

I didn't reinstall the post Map light and switch on the 172. There's a reoccuring AD on this (AD 01-23-03) that gets checked every annual/100 hour. If I removed it, I would think that means this AD wouldn't be valid anymore.

Would the log entry just say something like "Removed original map light and switch. AD 01-23-03 no longer applicable."?

Forgot to add I'm working up the log entry on the changes because it contains so many part numbers and other information.
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Pretty much.
 
That AD is actually "2001-23-03" -- using the full title makes it easier to find, and here it is. In there, you will find the following:
(e) Can I comply with this AD in any other way?

This AD applies to each airplane identified in paragraph (a) of this AD, regardless of whether it has been modified, altered, or repaired in the area subject to the requirements of this AD. For airplanes that have been modified, altered, or repaired so that the performance of the requirements of this AD is affected, the owner/operator must request approval for an alternative method of compliance in accordance with paragraph (e) of this AD. The request should include an assessment of the effect of the modification, alteration, or repair on the unsafe condition addressed by this AD; and, if you have not eliminated the unsafe condition, specific actions you propose to address it.
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Therefore, you and your A&P need to do what it says in paragraph (e) of that AD.
(1) You may use an alternative method of compliance or adjust the compliance time if:

(i) Your alternative method of compliance provides an equivalent level of safety; and

(ii) The Manager, Wichita Aircraft Certification Office (ACO), approves your alternative. Submit your request through an FAA Principal Maintenance Inspector, who may add comments and then send it to the Manager, Wichita ACO.

(2) Alternative methods of compliance approved in accordance with AD 80-04-08, which is superseded by this AD, are not approved as alternative methods of compliance with this AD.
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So, you're going to have to send a request for AMOC approval though your mechanic's PMI at the FSDO. Until then, you're going to have to have that area inspected and a log entry made by an A&P every 12 months even if there's nothing to inspect. Note that the removal of that light and switch is an alteration, and should be logged and signed by your A&P. I suppose you could submit that alteration to the FSDO on a 337 including instructions for continued airworthiness on the back saying that there is no further need for recurring inspection per the AD due to the removal of the switch.
 
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Ron Levy said:
That AD is actually "2001-23-03" -- using the full title makes it easier to find, and here it is. In there, you will find the following:
Therefore, you and your A&P need to do what it says in paragraph (e) of that AD.
So, you're going to have to send a request for AMOC approval though your mechanic's PMI at the FSDO. Until then, you're going to have to have that area inspected and a log entry made by an A&P every 100 hours even if there's nothing to inspect. Note that the removal of that light and switch is an alteration, and should be logged and signed by your A&P. I suppose you could submit that alteration to the FSDO on a 337 including instructions for continued airworthiness on the back saying that there is no further need for recurring inspection per the AD due to the removal of the switch.
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It just occurred to me that AD numbers are possibly the date they come out? I was going off my AD sheet from the annual and for whatever reason it's in there without the '20'.

I read through that a few times and if I'm understanding it correctly, next annual he'll still look at the post, see the switch and light aren't there and then call it compliant? Otherwise a ton of paperwork has to get shuffled around to make the AD N/A?
 
OkieAviator said:
It just occurred to me that AD numbers are possibly the date they come out? I was going off my AD sheet from the annual and for whatever reason it's in there without the '20'.

I read through that a few times and if I'm understanding it correctly, next annual he'll still look at the post, see the switch and light aren't there and then call it compliant? Otherwise a ton of paperwork has to get shuffled around to make the AD N/A?
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I must have caught the flu to have missed paragraph (e).

If I were you, I send a simple email to your local FSDO via http://www.faa.gov/about/office_org/field_offices/fsdo/okc/contact/

or:
Issued in Kansas City, Missouri, on November 5, 2001.
Michael Gallagher,
Manager, Small Airplane Directorate,
Aircraft Certification Service.
[FR Doc. 01-28332 Filed 11-14-01; 8:45 am]
BILLING CODE 4910-13-P

and see if amoc already exists which he will forward to you via email.

Just ask them what AMOCs exist for 2001-23-03

"Hello, I'm looking at a 172X and was wondering what AMOCs exists for AD 2001-23-03. I'm interested in removal of the switch and light for terminating action"
 
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OkieAviator said:
It just occurred to me that AD numbers are possibly the date they come out? I was going off my AD sheet from the annual and for whatever reason it's in there without the '20'.
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That's partly true. The first block is year, but the other two blocks are in some sort of sequence. They used to have just the last two digits of the year, but here in the 21st century they changed it to have all four.
I read through that a few times and if I'm understanding it correctly, next annual he'll still look at the post, see the switch and light aren't there and then call it compliant? Otherwise a ton of paperwork has to get shuffled around to make the AD N/A?
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Not sure it's a "ton" of paperwork, but otherwise, you've got the picture (silly as it may seem).
 
Yes, until there is a documented terminating action like the AMOC. The AD must be listed and checked and signed off at every annual.
 
OkieAviator said:
...Would the log entry just say something like "Removed original map light and switch. AD 01-23-03 no longer applicable."?...
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Your mechanic could simply sign off the AD each annual as having been complied with since he knows there is no longer a switch installed and no need for inspection. He cannot however sign it off as NLA because, for one thing, there is no technical document allowing him to remove the map light in the first place. I'm not saying it's a big deal to have done that, I'm just saying that due to the AD there is no way to cleanly document it.

If you were to have a different mechanic perform your annual it's most likely he will have to do the inspection regardless of the fact that the switch is no longer installed, at least once anyway.

Attempting to get an approved AMOC through deletion of the map light would most likely be an exercise in frustration and honestly, it's probably better not to draw unnecessary attention. You probably shouldn't even have made this post ;)
 
Na....I'd log removing the light, then log that AD xxxxxx is no longer applicable. From there on out anyone doing AD research will see that it no longer applies.

I doubt that light is required equipment....:rolleyes:

But....since removing the light is not preventative maintenance an entry is required by an A&P.
 
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The statement " or it's properly altered condition" in the airworthiness definition means that the aircraft can be properly altered, by a Field approval, STC, etc,

I would suggest you have your A&P prepare a 337 requesting an alteration of the light wiring skit, when that is approved the aircraft will be properly altered to not include the AD.

Be certain the block 8 of the 337 makes that statement.
 
Tom-D said:
The statement " or it's properly altered condition" in the airworthiness definition means that the aircraft can be properly altered, by a Field approval, STC, etc,

I would suggest you have your A&P prepare a 337 requesting an alteration of the light wiring skit, when that is approved the aircraft will be properly altered to not include the AD.

Be certain the block 8 of the 337 makes that statement.
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Is this a major alteration?
 
Checkout_my_Six said:
Is this a major alteration?
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Maybe, Maybe not, it is a method of making the AD go away.

In general, if you change the operating instructions for the aircraft it should be documented and approved by 337 or a STC.

This not a written rule, but an acceptable practice, and usually a paper work drill at FSDO.
 
Ron Levy said:
T
So, you're going to have to send a request for AMOC approval though your mechanic's PMI at the FSDO. Until then, you're going to have to have that area inspected and a log entry made by an A&P every 12 months even if there's nothing to inspect. Note that the removal of that light and switch is an alteration, and should be logged and signed by your A&P. I suppose you could submit that alteration to the FSDO on a 337 including instructions for continued airworthiness on the back saying that there is no further need for recurring inspection per the AD due to the removal of the switch.
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You forget,, the aircraft is already modified.. When that is documented properly the AD will go away.

There will be no need for AMOC
 
The type society got a blanket AMOC for one of the Navion ADs. We've got a "courtesy letter" that we send to people that the ACO gave us.
 
flyingron said:
The type society got a blanket AMOC for one of the Navion ADs. We've got a "courtesy letter" that we send to people that the ACO gave us.
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Did that AMOC tell you how to inspect a part no longer in the aircraft.?
 
OBTW folks, any one read the AD? It was a one time inspection, it should have been signed off way back in 1980. If it was signed off, what is the problem now ?

the newest version has just the cover involved,

All that is required now is the documentation of the wiring change on how you control the light. and how the cover was removed.
 
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I'm surprised there isn't already an AMOC or removal of the switch isn't an option in the AD because I disagree with the FAA - removing that A pillar trim piece every year, it's eventually gonna get busted. amhik :nonod:
 
Tom-D said:
OBTW folks, any one read the AD? It is a one time inspection, it should have been signed off way back in 1980. If it was signed off, what is the problem now ?...
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(d)(1) Compliance - Repetitively inspect thereafter at intervals not to exceed 12 calendar months
 
Tom-D said:
You forget,, the aircraft is already modified.. When that is documented properly the AD will go away.

There will be no need for AMOC
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First, if you read the OP, you'll see the alteration is in progress, not completed. Second, if you read the AD paragraph b2 (particularly the part I highlighted when I quoted it), you'll see the 12-month requirement for the AD inspection signoff does not go away no matter how the aircrft is modified unless an AMOC is requested and approved IAW paragraph e.
 
Tom-D said:
OBTW folks, any one read the AD? It was a one time inspection, it should have been signed off way back in 1980. If it was signed off, what is the problem now ?
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Yes -- apparently everyone else who replied except you.
 
Silvaire said:
I'm surprised there isn't already an AMOC or removal of the switch isn't an option in the AD because I disagree with the FAA - removing that A pillar trim piece every year, it's eventually gonna get busted. amhik :nonod:
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Things that make ya go; Hmmm, kick back? Mabe not but food for thought.
 
Ron Levy said:
First, if you read the OP, you'll see the alteration is in progress, not completed.
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All he was saying is he was going to talk to his A&P to complete the paper work. that is why it ain't done.


Ron Levy said:
Second, if you read the AD paragraph b2 (particularly the part I highlighted when I quoted it), you'll see the 12-month requirement for the AD inspection signoff does not go away no matter how the aircrft is modified unless an AMOC is requested and approved IAW paragraph e.
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IOWs you do not understand what in a properly altered conditions is. Properly altered and approved the AD goes away.
 
Ron Levy said:
AD inspection signoff does not go away no matter how the aircrft is modified unless an AMOC is requested and approved IAW paragraph e.
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That's totally wrong, when the aircraft modification is properly documented and approved there is no need for a AMOC.


other wise there would be a AMOC required for every AD that was deleted by a PN upgrade or any part removed from service that had a AD issued.
 
Tom-D said:
Did that AMOC tell you how to inspect a part no longer in the aircraft.?
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I don't know what this question is about, but if an AMOC is to remove the part (ours actually is to replace it with a different one) and the AMOC says that terminates the AD, complying with the AMOC terminates the AD. Just as if the original AD said that you could terminate the AD by removing the part.


This one is particulary goofy as the AD applies to every Navion fuel system no matter what valve was in it. The compliance is a repetitive inspection or to buy the replacement valve from the owner of the TC paperwork who thought this would be a great cash flow idea for him. The Chicago ACO just couldn't fight the fact that you had the "aircraft manufacturer" jumping up and down claiming that the airplanes were unsafe even in the light of the facts otherwise. However, they were very liberal with AMOCs. The type society PMA'd our own valve (both the "manufacturer" valve and ours were based on the Andair fuel valve. The "manufacturer" one was a hack job, it doesn't sit recessed into the floor like the original, uses goofy banjo fittings rather than the original A/N ones, and lacks the safety feature to prevent you from turning the valve the wrong way and shutting off the fuel in flight. Ours fixes those problems). The ACO also approved JLO's valve (which I had anyhow) if it had proper ICA paperwork (essentially the only difference between my old valve and the new one is the new one has a SN stamped in it and a seperate ICA paper from the tip tank system it's part of). Some individuals managed to even get their own non-PMA'd Andair (spruce sells them for homebuilts) approved.

Yeah, I might have been through the AD and AMOC procedure a bit Tom. My name even appears in the FR preamble for the AD itself.
 
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Tom-D said:
That's totally wrong, when the aircraft modification is properly documented and approved there is no need for a AMOC.
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As I said, you really should read that AD carefully, especially this part:
Note 2: This AD applies to each airplane identified in paragraph (a) of this AD, regardless of whether it has been modified, altered, or repaired in the area subject to the requirements of this AD. For airplanes that have been modified, altered, or repaired so that the performance of the requirements of this AD is affected, the owner/operator must request approval for an alternative method of compliance in accordance with paragraph (e) of this AD. The request should include an assessment of the effect of the modification, alteration, or repair on the unsafe condition addressed by this AD; and, if you have not eliminated the unsafe condition, specific actions you propose to address it.
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Tom-D said:
other wise there would be a AMOC required for every AD that was deleted by a PN upgrade or any part removed from service that had a AD issued.
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Not every AD has the language quoted above. Most have language which says it is applicable only if the part is installed. This one is, if you read it completely, quite different.
 
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Tom-D said:
Cheap shot Ron. You know I went back and corrected it.
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You may have altered it, but it's still not "corrected". Your post still says it's only a one-time inspection, and it's not -- 12-month recurring inspection is still required after the initial inspection. Here's the link to the actual AD on the FAA's web site. Please take the time to read it carefully before responding, including the part on Compliance:
Initially inspect within the next 100 hours time-in-service (TIS) after December 27, 2001 (the effective date of this AD), or within the next 12 calendar months after December 27, 2001 (the effective date of this AD), whichever occurs first. Repetitively inspect thereafter at intervals not to exceed 12 calendar months.
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.
 
Ron Levy said:
Not every AD has the language quoted above. Most have language which says it is applicable only if the part is installed. This one is, if you read it completely, quite different.
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Almost every AD written with in the last decade has that statement.

In your method of thinking, the properly altered condition of the aircraft means nothing.

and that simply isn't true.
 
Tom-D said:
Almost every AD written with in the last decade has that statement.
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Really? Please give us some examples.

In your method of thinking, the properly altered condition of the aircraft means nothing. and that simply isn't true.
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What part of "This AD applies to each airplane identified in paragraph (a) of this AD, regardless of whether it has been modified, altered, or repaired in the area subject to the requirements of this AD" don't you understand?
 
To clear the field... I decided to just mention in the log that removal of lamp and switch 'affects' the AD and I'm bolding the AD incase someone ever looks in the log for when it got removed. I'm assuming the A&P will just check it every year, sign the AD because the part isn't there and move on.
 
OkieAviator said:
To clear the field... I decided to just mention in the log that removal of lamp and switch 'affects' the AD and I'm bolding the AD incase someone ever looks in the log for when it got removed. I'm assuming the A&P will just check it every year, sign the AD because the part isn't there and move on.
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In that case, your A&P would be playing by the rules. The only other choice would be requesting an AMOC as discussed in the AD to eliminate the recurring inspection requirement based on the switch having been removed.
 
Ron Levy said:
Really? Please give us some examples.

What part of "This AD applies to each airplane identified in paragraph (a) of this AD, regardless of whether it has been modified, altered, or repaired in the area subject to the requirements of this AD" don't you understand?
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When you figure out which has precedence you will understand why you are wrong.
 
OkieAviator said:
To clear the field... I decided to just mention in the log that removal of lamp and switch 'affects' the AD and I'm bolding the AD incase someone ever looks in the log for when it got removed. I'm assuming the A&P will just check it every year, sign the AD because the part isn't there and move on.
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That is what 99% of the IAs will do.

but in this case the IA can not comply with the AD as written, with the part missing.
 
OkieAviator said:
To clear the field... I decided to just mention in the log that removal of lamp and switch 'affects' the AD and I'm bolding the AD incase someone ever looks in the log for when it got removed. I'm assuming the A&P will just check it every year, sign the AD because the part isn't there and move on.
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Did you, or did you not, modify the aircraft.

If so, how did you document that alteration?

When you properly engineer and document the Field approval and it is approved by FSDO, that becomes your means of compliance with the AD. Then the AD can be properly signed off as it no longer applies to this aircraft.

Your A&P's PMI will do the research to insure that your field approval meets any and all AMOC currently in use.

It makes absolutely no sense for you to apply for a AMOC for all 172s that this AD covers. and that is what the AMOC requests does.
 
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