Stop drilled cracks

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tewels

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How many stop drilled cracks are allowed in an aileron or flap? Where would I find that info.....for a Cessna.....
..thanks.
 
1958 C-182. I went to chapter 19 but couldn't find anything on it.
 
Rotor&Wing said:
If you can't find anything in the MM then I suggest you refer to AC43.13.
Click to expand...

I tried that today, and believe I concluded that AC43-13 says to follow manufacturer's directives.
 
SCCutler said:
I tried that today, and believe I concluded that AC43-13 says to follow manufacturer's directives.
Click to expand...

To a degree. If the manufacturer doesn't have maintenance instructions then you can go to AC43.13 for guidance. If AC43.13 doesn't offer any guidance then you can go to a DER (Designated Engineering Rep) and seek approval.

I don't have the MM in front of me nor have I looked in the AC43.13 but I would say if it's not there or tells you to seek manufacturer direction then it is not repairable without engineering data. At that point it's cheaper to find another control surface or have the present one reskined.

There's a shop in Central Florida that rebuilds Cessna flight controls using new corrugated skins and they do excellent work. http://www.rjdauhnaircraft.com/
 
This is from the c150 SM 1969-1976
You should find the SM that applies to your Cessna.

In it, the sections on wing flap and aileron negligible damage says refer to this section on wing skin negligible damage.

"Stop drilling is considered a temporary repair and a permanent repair must be made as soon as practicable."
 

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The manual for our R182 calls for no more than six cracks per skin, and refers to cracks through or emanating from the rivets.

The skins are too thin and flex too much, and Cessna's trailing edge bulb extrusion has parallel sides that stresses the skin when the rivets are bucked. MacFarlane makes a bulb with the right taper to it.

Dan
 
Rotor&Wing said:
Usually the Maintenance Manual. Which model Cessna?
Click to expand...


For some body that claims to be an FAA ASI you sure don't know where to get the proper information.

It's in the Structural repair manual.

the AC 43 Can not be used on any Cessna, they are all supported by Cessna either by manuals or blue prints, and customer support.
 
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Tom-D said:
For some body that claims to be an FAA ASI you sure don't know where to get the proper information.

It's in the general shop practices of the cessna maintenance manual.
Click to expand...

Please reread my post before flame baiting.

Rotor&Wing said:
To a degree. If the manufacturer doesn't have maintenance instructions then you can go to AC43.13 for guidance. If AC43.13 doesn't offer any guidance then you can go to a DER (Designated Engineering Rep) and seek approval.

I don't have the MM in front of me nor have I looked in the AC43.13 but I would say if it's not there or tells you to seek manufacturer direction then it is not repairable without engineering data. At that point it's cheaper to find another control surface or have the present one reskined.

There's a shop in Central Florida that rebuilds Cessna flight controls using new corrugated skins and they do excellent work. http://www.rjdauhnaircraft.com/
Click to expand...
 
In the MM for my year 182 (1958) there is no mention. However there is reference in the 1969 MM about stop drilling cracks.
 
Let'sgoflying! said:
This is from the c150 SM 1969-1976
You should find the SM that applies to your Cessna.

In it, the sections on wing flap and aileron negligible damage says refer to this section on wing skin negligible damage.

"Stop drilling is considered a temporary repair and a permanent repair must be made as soon as practicable."
Click to expand...

We have a winner....... the AC43, can not be used on any Cessna built after 1946, simply because Cessna's are supported by maintenance manuals and structural repair manuals.
 
tewels said:
In the MM for my year 182 (1958) there is no mention. However there is reference in the 1969 MM about stop drilling cracks.
Click to expand...

see the structural repair manual for the repairs, stop drilling is not considered by Cessna to be a repair. and on most of their aircraft no mention will be made about it in any of the maintenance manuals.
 
Rotor&Wing said:
Please reread my post before flame baiting.
Click to expand...

How can you possibly mention the AC 43 when the aircraft is supported by its manufacturer? You should have known from thought one, that Cessna supports their aircraft. and told the OP to see the structural repair manual for his answer.

You have on several occasions sent me PMs saying you are a ASI at FSDO,:yikes::yikes: yet you do not demonstrate the basic knowledge to be one.:rolleyes:
 
Tom-D said:
see the structural repair manual for the repairs, stop drilling is not considered by Cessna to be a repair. and on most of their aircraft no mention will be made about it in any of the maintenance manuals.
Click to expand...

Tom-D said:
the AC 43 Can not be used on any Cessna, they are all supported by Cessna either by manuals or blue prints, and customer support.
Click to expand...

Tom-D said:
How can you possibly mention the AC 43 when the aircraft is supported by its manufacturer? You should have known from thought one, that Cessna supports their aircraft. and told the OP to see the structural repair manual for his answer.
Click to expand...


AC 43.13-1B

PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the
Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no
manufacturer repair or maintenance instructions. This data generally pertains to minor repairs. The repairs
identified in this AC may only be used as a basis for FAA approval for major repairs. The repair data may
also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA form 337
when:
a. the user has determined that it is appropriate to the product being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer’s data.

You are incorrectly interpreting that AC 43.13 cannot be used. The intent of the paragraph above is "only when there are no
manufacturer repair or maintenance instructions" means if the item is not listed in the repair or maintenance manual, then AC 43.13 can be used. Also, since the data within AC43.13 is "acceptable" to the Administrator it can also be used in conjunction with Maintenance Manuals and ICA's.

Here is the legal interpretation from the General Counsel.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/Inter%20AC%2043-13-1B.pdf

Date: JAN 1 2 2010
To: ~e.r, Flight S~s Division, AEA-200
From: ~fltifrt~tctu6~10r Regul~ons, AGC-200
Prepared by: Edmund Averman, AGC-21 0
Subject: Legal Interpretation of PURPOSE Paragraph of
Advisory Circular AC 43-13-1B
This is in response to your May 4,2009, request for a legal interpretation on the text in the
PURPOSE paragraph of Advisory Circular AC 43.13-1B. That paragraph presently states:
PURPOSE. This advisory circular (AC) contains methods, techniques, and
practices acceptable to the Administrator for the inspection and repair of
non-pressurized areas of civil aircraft, only when there are no manufacturer
repair or maintenance instructions. This data generally pertains to minor
repairs. The repairs identified in this AC may only be used as a basis for
FAA approval for major repairs. The repair data may also be used as
approved data, and the AC chapter, page, and paragraph listed in block 8
of FAA form 337 when:
a. the user has determined that it is appropriate to the product
being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer's data.

You asked for "legal advice concerning the authority of the AC to restrict the use of data that has
been found to be acceptable to the Administrator, if the manufacturer has also provided
acceptable instructions for continued airworthiness (lCA)." Your concern takes issue with the
first sentence of the PURPOSE paragraph, which states that the information in the AC is
acceptable "only when there are no manufacturer ... instructions." (Emphasis added.) This
implies that if manufacturer repair or maintenance instructions exist, the information in the AC
would not be acceptable. Your concern is well-founded because, taken literally, the statement is
not correct, as a matter of law. 1
As you know, 14 C.F.R. § 43. 13(a) provides that a person performing maintenance shall use the
current manufacturer's maintenance manual or Instructions for Continued Airworthiness [ICA],
"or other methods, techniques, and practices acceptable to the Administrator .... " (Emphasis
added.) Thus, if a person performs aircraft maintenance and uses a method, technique, or
practice that differs from those specified in the applicable manufacturer's maintenance manual or
Instructions for Continued Airworthiness, the FAA would have to show that the maintenance
done, even though different from the steps outlined in the manual, was not acceptable in order to
prove a violation of the regulation.
It is our understanding that the repair methods and data in the AC are generally acceptable to the
FAA for use in minor repairs on non-pressurized areas of civil aircraft, unless the manufacturer
of the aircraft at issue specifically recommends against the method, technique, or practice. In
any such case, whether the repair method, technique, or practice chosen by the maintenance
provider would nevertheless be acceptable to the FAA would require a fact-specific
determination.
The word "only" in the third sentence of the PURPOSE paragraph renders the sentence
confusing at best, as it could be read to mean that the repair information in the AC could not be
used for any purpose other than as a basis for FAA approval for major repairs, whereas in fact
the information may be used in performing minor repairs.2 We recommend deleting "only"
from the text and, because the regulations require that major repairs be done in accordance with
FAA-approved data, we also recommend that the sentence refer to the repair data in the AC
being used as a basis for FAA approval of data for major repairs.
Finally, we recommend that the last sentence in the PURPOSE paragraph be revised for clarity.
We recommend the paragraph be replaced with the following:
1. PURPOSE. This advisory circular (AC) contains methods, techniques,
and practices acceptable to the FAA for performing inspections and minor
repairs of non-pressurized areas of civil aircraft unless the repair at issue is
recommended against in the applicable manufacturer's maintenance or repair
instructions. The repair data described in this AC may be used as a basis for
FAA-approved data for major repairs. The repair data may be used as FAAapproved
data for repairs of non-pressurized areas of civil aircraft provided the
AC chapter, page, and paragraph are listed in Block 8 of FAA Form 337, and
the data are:
I Our recollection is that the reference to "only" in the fIrst sentence expressed the thought that, if the maintenance
provider had applicable manufacturer repair or maintenance instructions, there would be no reason to consult the
AC.
2 Our recollection is that the reference to "only" in the third sentence expressed the thought that the repairs in the
AC are not, per se, approved data, with the exception being as stated in the fourth sentence.
3
a. appropriate to the product being repaired;
b. directly applicable to the repair being made; and
c. not contrary to the manufacturer's data.

This response was prepared by Edmund Averman, an Attorney in the Regulations Division in the
Office of the Chief Counsel and coordinated with the Aircraft Maintenance Division (AFS-300)
in the Office of Flight Standards If you have additional questions regarding this matter, please
contact us at your convenience at (202) 267-3073.

Rebecca B. MacPherson
 
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Rotor&Wing said:
AC 43.13-1B

PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the
Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no
manufacturer repair or maintenance instructions. This data generally pertains to minor repairs.
Click to expand...


But there are approved repair instruction given in Cessna Structural repair manuals.
 
Rotor&Wing said:
AC 43.13-1B

PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the
Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no
manufacturer repair or maintenance instructions. This data generally pertains to minor repairs. The repairs
identified in this AC may only be used as a basis for FAA approval for major repairs. The repair data may
also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA form 337
when:
a. the user has determined that it is appropriate to the product being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer’s data.

You are incorrectly interpreting that AC 43.13 cannot be used. The intent of the paragraph above is "only when there are no
manufacturer repair or maintenance instructions" means if the item is not listed in the repair or maintenance manual, then AC 43.13 can be used. Also, since the data within AC43.13 is "acceptable" to the Administrator it can also be used in conjunction with Maintenance Manuals and ICA's.

Here is the legal interpretation from the General Counsel.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/Inter%20AC%2043-13-1B.pdf

Date: JAN 1 2 2010
To: ~e.r, Flight S~s Division, AEA-200
From: ~fltifrt~tctu6~10r Regul~ons, AGC-200
Prepared by: Edmund Averman, AGC-21 0
Subject: Legal Interpretation of PURPOSE Paragraph of
Advisory Circular AC 43-13-1B
This is in response to your May 4,2009, request for a legal interpretation on the text in the
PURPOSE paragraph of Advisory Circular AC 43.13-1B. That paragraph presently states:
PURPOSE. This advisory circular (AC) contains methods, techniques, and
practices acceptable to the Administrator for the inspection and repair of
non-pressurized areas of civil aircraft, only when there are no manufacturer
repair or maintenance instructions. This data generally pertains to minor
repairs. The repairs identified in this AC may only be used as a basis for
FAA approval for major repairs. The repair data may also be used as
approved data, and the AC chapter, page, and paragraph listed in block 8
of FAA form 337 when:
a. the user has determined that it is appropriate to the product
being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer's data.


In this case repair by stop drilling is contrary to Cessna's instructions.
You asked for "legal advice concerning the authority of the AC to restrict the use of data that has
been found to be acceptable to the Administrator, if the manufacturer has also provided
acceptable instructions for continued airworthiness (lCA)." Your concern takes issue with the
first sentence of the PURPOSE paragraph, which states that the information in the AC is
acceptable "only when there are no manufacturer ... instructions." (Emphasis added.) This
implies that if manufacturer repair or maintenance instructions exist, the information in the AC
would not be acceptable. Your concern is well-founded because, taken literally, the statement is
not correct, as a matter of law. 1
As you know, 14 C.F.R. § 43. 13(a) provides that a person performing maintenance shall use the
current manufacturer's maintenance manual or Instructions for Continued Airworthiness [ICA],
"or other methods, techniques, and practices acceptable to the Administrator .... " (Emphasis
added.) Thus, if a person performs aircraft maintenance and uses a method, technique, or
practice that differs from those specified in the applicable manufacturer's maintenance manual or
Instructions for Continued Airworthiness, the FAA would have to show that the maintenance
done, even though different from the steps outlined in the manual, was not acceptable in order to
prove a violation of the regulation.
It is our understanding that the repair methods and data in the AC are generally acceptable to the
FAA for use in minor repairs on non-pressurized areas of civil aircraft, unless the manufacturer
of the aircraft at issue specifically recommends against the method, technique, or practice. In
any such case, whether the repair method, technique, or practice chosen by the maintenance
provider would nevertheless be acceptable to the FAA would require a fact-specific
determination.
The word "only" in the third sentence of the PURPOSE paragraph renders the sentence
confusing at best, as it could be read to mean that the repair information in the AC could not be
used for any purpose other than as a basis for FAA approval for major repairs, whereas in fact
the information may be used in performing minor repairs.2 We recommend deleting "only"
from the text and, because the regulations require that major repairs be done in accordance with
FAA-approved data, we also recommend that the sentence refer to the repair data in the AC
being used as a basis for FAA approval of data for major repairs.
Finally, we recommend that the last sentence in the PURPOSE paragraph be revised for clarity.
We recommend the paragraph be replaced with the following:

1. PURPOSE. This advisory circular (AC) contains methods, techniques,
and practices acceptable to the FAA for performing inspections and minor
repairs of non-pressurized areas of civil aircraft unless the repair at issue is
recommended against in the applicable manufacturer's maintenance or repair
instructions. The repair data described in this AC may be used as a basis for
FAA-approved data for major repairs. The repair data may be used as FAAapproved
data for repairs of non-pressurized areas of civil aircraft provided the
AC chapter, page, and paragraph are listed in Block 8 of FAA Form 337, and
the data are:

That paragraph was never incorporated in the AC.

I Our recollection is that the reference to "only" in the fIrst sentence expressed the thought that, if the maintenance
provider had applicable manufacturer repair or maintenance instructions, there would be no reason to consult the
AC.
2 Our recollection is that the reference to "only" in the third sentence expressed the thought that the repairs in the
AC are not, per se, approved data, with the exception being as stated in the fourth sentence.
3
a. appropriate to the product being repaired;
b. directly applicable to the repair being made; and
c. not contrary to the manufacturer's data.

This response was prepared by Edmund Averman, an Attorney in the Regulations Division in the
Office of the Chief Counsel and coordinated with the Aircraft Maintenance Division (AFS-300)
in the Office of Flight Standards If you have additional questions regarding this matter, please
contact us at your convenience at (202) 267-3073.

Rebecca B. MacPherson
Click to expand...

Read the AC published on the FAA web site, it was never changed from its original wording.

The Lawyer may have recommended the change but it never happened.

Cessna aircraft have structural repair manuals and blue prints available which ARE APPROVED DATA for repairing their aircraft, and they do not recommend stop drilling as a permanent repair.

secondly, the repair of any flight control is a major repair IAW FAR 43-A, and should be dealt with accordingly.

a) Major alterations —(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:

(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.


If you really are a ASI, you need a refresher training, on major repair documentation.
 
Tom,

Your comprehension skills are lacking at best. You obviously don't understand what a legal opinion rendered by the Office of the Chief Counsel means.

Argue with them if you don't like their ruling.
 
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Copied directly from the AC om the FAA web site.

1.
PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the Administrator for the inspection and alteration on non-pressurized areas of civil aircraft of 12,500 lbs gross weight or less. This AC is for use by mechanics, repair stations, and other certificated entities. This data generally pertains to minor alterations; however, the alteration data herein may be used as approved data for major alterations when the AC chapter, page, and paragraph are listed in block 8 of FAA Form 337 when the user has determined that it is:
a.
Appropriate to the product being altered,
b.
Directly applicable to the alteration being made, and
c.
Not contrary to manufacturer’s data.
end quote

IOWs any data contained in this AC must be approved by FSDO on a 337 prior to its being approved data for any repair.

so using it in the return to service entry for a flap repair (temporary or not) may get your certificate revoked or suspended. unless you have a preapproved 337 to back it up.

you might better leave the crack alone, or have it repaired IAW the Cessna structural repair manual and documented on a major repair form called a 337.

wrinkle skins are available by part number from Cessna or several after market sources. and may be replaced by any A&P or authorized persons.
 
As Tom-D seems to suggest, is it a legal certainty that a 337 is necessary to repair a cracked flap via stop drilling, if there is no particular mention of stop drilling procedures in the manufacturer maintenance manual?
I had my Cirrus cracked flap (which is made in Aluminum) repaired via stop drilling during the last Annual/100Hrs and no 337 was filed by the maintenance shop: was that an "illegal" repair?
 
SCCutler said:
I tried that today, and believe I concluded that AC43-13 says to follow manufacturer's directives.
Click to expand...

You are right, Cessna aircraft after 1968 have a maintenance manual, thus the 43-13 does not apply.

Generally the stop drilled hole will relieve the stress that is causing the crack, but when it does not many A&Ps will drill it again hoping for the best.
For the best advice on this call Cessna technical support because their manuals do not give a number on this.
 
This is hilarious on some levels and sad on others.

Tom, every FAA approved structural or electrical drawing I’ve seen my entire career, to alter aircraft from Cessna 206 all the way to Gulfstream V, lists AC43.13 on it somewhere on the first page.
 
That 'ignore function'....can we use it to make two other people ignore each other? :D
 
bnt83 said:
This is hilarious on some levels and sad on others.

Tom, every FAA approved structural or electrical drawing I’ve seen my entire career, to alter aircraft from Cessna 206 all the way to Gulfstream V, lists AC43.13 on it somewhere on the first page.
Click to expand...

Minor repairs are not considered an alteration. (stop drilling)

If the Cessna is later than a 68 it has guidance in the Cessna manuals.

If it is an earlier Cessna with out guidance, Stop drilling will be a minor repair, only needing a log book entry. You can uses the later M/M for guidance it will be accepted as approved data for the log book entry.

Any repairs completed must comply with FAR 43-A and be documented accordingly, and must have been approved on a major repair form. That can be approved by the local FSDO when they stamp block 4. See AC 210 E. on how to gain their approval.
 
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Its also not unheard of to see FAA approved installations that are contrary to manufacturer's data. There are so many different suppliers and opinions of the equipment installed its gonna happen. An example is antenna spacing. There may be some sort of antenna spacing issues on an airplane that violates at least one of the manufacturer's data, but through appropriate ground testing, compliance with the regulations can be shown.

Then there is manufacturer's data, that when installed in the airplane, renders the airplane unairworthy. An example is a cabin chair vendor that issues a service bulletin to allow extended seat tracking limits. The extended seat tracking limits must still be FAA approved to ensure they don't violate isle and e-exit clearance limits as installed in the airplane.

These are alterations, but in reality repairs and alterations must meet the same regulations at the end of the day.
 
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To answer the OP, if you have more than three or four on a flight surface, I'd get it fixed.

To the old dudes, please stop being so cranky. Get some Metamucil and back off of the coffee.
 
0luke1 said:
To the old dudes, please stop being so cranky. Get some Metamucil and back off of the coffee.
Click to expand...


But it is so fun to watch the battles :yes: between CapNRon, Rotor, and Tom...I believe we could have the newest Jerry Springer Show. For the record, they are cranky old buzzards but hold a wealth of knowledge.
 
Flymeariver said:
But it is so fun to watch the battles :yes: between CapNRon, Rotor, and Tom...I believe we could have the newest Jerry Springer Show. For the record, they are cranky old buzzards but hold a wealth of knowledge.
Click to expand...

When you watch these discussions do you learn any thing ?
 
Tom-D said:
When you watch these discussions do you learn any thing ?
Click to expand...

Every time. Hence the wealth of knowledge :). When I finally purchase I know you are the go to on mx, Rotor for FAA stuff, Ron for any and all regs, etc :). Ive learned each day and appreciate the discussions :yes:
 
Tom-D said:
You have on several occasions sent me PMs saying you are a ASI at FSDO,:yikes::yikes: yet you do not demonstrate the basic knowledge to be one.:rolleyes:
Click to expand...

Unfortunately, Tom, he does. Both you and I have met our fair share of ASIs with this level of expertise.

Jim
 
Closing thread per MC.
 
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