Jim Posted August 30, 2012 Report Share Posted August 30, 2012 I believe this has already been covered by a safety bulletin, but it's worth noting that it's now an AD as well. http://www.flyingmag.com/news/faa-issues-rotax-912-fuel-system-ad?cmpid=enews083012&spPodID=030&spMailingID=7249513&spUserID=MzYzMTcwNjIxMTgS1&spJobID=204471266&spReportId=MjA0NDcxMjY2S0 Link to comment Share on other sites More sharing options...
Jim Meade Posted August 31, 2012 Report Share Posted August 31, 2012 You made an engine log book entry with the SB? You make another for the AD? Link to comment Share on other sites More sharing options...
CT4ME Posted September 1, 2012 Report Share Posted September 1, 2012 Interesting "political" action here... This warning, essentially from "the government", comes several months after the LSA/ASTM/Manufacturers had already issued their own. The LSA world demonstrating that self-regulation CAN work... Tim Link to comment Share on other sites More sharing options...
chanik Posted September 1, 2012 Report Share Posted September 1, 2012 The larger issue, if you read up on aviation law articles covering LSA and the FAA, is actually a bit worrisome for the LSA industry. Recently the FAA has 'grabbed the wheel' several times preempting this whole self-regulation ethos. They have ruled against Rotax and LSA on 100hr requirements, against requiring Rotax training for A&Ps, and now affirming the applicabilty of ADs to LSA. Before this, the understanding was that an LSA OEMs would interpret and issue guidance on their own WRT ADs on TSOd components. The FAA made it clear that ADs are required to be followed even if the OEM is silent on them and that the FAA can issue ADs on non-TSOd things as it likes, as with the current one on Rotax hoses. It confuses the issue of where to find required maintenance issues since used to be a mechanic could just read the official manuals and SDs and be good to go. Now, if you have a TSOd radio (usually) or a transponder or ELT (always TSOd) the mechanic has to know to hunt down those parts for possible ADs outside the OEM documentation. The worry is that if the FAA keeps getting upset for instance about OEMs playing games and pencil whipping the Statements of Compliance (required documents from the OEMs to affirm they are following ASTM standards) then they could end up essentially gutting the whole self-regulation approach. Link to comment Share on other sites More sharing options...
Doug Hereford Posted September 2, 2012 Report Share Posted September 2, 2012 CT4ME, The time lapse you noted is very common with the Airworthiness Directive system. This is due in large part, to the fact that an Airworthiness Directive is itself, a law, and as such, is subject to the rule making process. This means that it must be published in the federal register as a notice of proposed rule making (NPRM), and the interested (or even uninterested) general public is given a chance to comment on it before it is formally adopted. This can take up to 90 days sometimes. The system does have provision for immediate addoption of an AD that the FAA deems to be of an critial safety concern. In this case, a Priority Letter is issued with out the normal comment period. This can be done is much less time. Then, normally this PL, which is still an AD, is followed up on with the standard process, to include public comment. The majority of AD's being issued today make reference to relevent manufacturer's service info. I believe that this is due mainly to the fact that the FAA recoginzes that the mfg. is the most knowledgeable on the product, and it reduces duplication of effort. However, it is also not uncommon, that an AD will have important differences from mfg. service info. (SB SI, ASB, etc......) such as due times, recurring action, etc. The AD will normally make reference to these differences, and state that AD requirements supercede the requirements of the service info. whenever these difference exist. The FAA issues AD's against products produced under their (FAA) approval only. This includes things like TSO, PMA, Type certificated and standard parts (MS, AN, NAS parts). Because these "approved" parts/products may be found on ASTM cert. basis aircraft, ADs must be considered for SLSA even though popular opinion seems to state otherwise. This has been the case since day one (July 2004) for SLSA. The AD in question is AD 2012-16-13. It is an engine AD and applies to certificated (Type Certificated) engines only. The service bulletin(s) that it references have two parts, one for certificated engines (back to the AD) and one (ASB-912-061R1 ULS) for non-certificated engines. To me the interesting thing here is that an unsafe condition exists. FAA issues an AD, fine. I have to assume that the same unsafe condition may exist on SLSA (non-certificated engines), as demonstrated by ASB912-061R1 ULS. If this is true, any aircraft manufacturer that uses, or has used one of these 912ULS engines on its product, should be issuing a Safety Directive to the SLSA world. I am willing to bet that this is not being done. Remember that Safety Directives are not the same thing as ASB's or SB's or SI's etc... Safety Directives have the same legal force and effect as AD's in the standard world. The other service info. does not. Doug Hereford Link to comment Share on other sites More sharing options...
Adam Posted September 2, 2012 Report Share Posted September 2, 2012 I think Jim's (Meade) original question still stands. What action should an owner take with respect to the AD? 1.) Should we make note in the logs that this AD has been complied with? 2.) Is no action required at all bacause the AD applies to certificated versions of the 912 and ours are non certificated? and finally 3.) if action IS required, Is it required that a mechanic make the notation or can the owner? All Flight Design Owners have of course complied with the Safety Alert issued by FD since we were required to do so and we all have made notations to our logs per the FD Safety Alert issued for our specific model of plane. Doug, good explanation. I for one forgot all about the fact that there are many "certified" versions of the Rotax 912/914 series engines out there. One that immediately comes to mind is the new part 23 certified Tecnam twin that of course has 2 certified engines. The fact that certified engines exist means its completely logical for the FAA to issue the AD. I am assuming the answer is 2.) No action required, the AD applies to certificated engines only. Link to comment Share on other sites More sharing options...
Roger Lee Posted September 2, 2012 Report Share Posted September 2, 2012 A responsible owner or mechanic will log any AD, SB,, SA, SI, or SD and log it complied with and any action taken or log it and note no action required and the reason. I.e. not applicable due to serial number, ect... Link to comment Share on other sites More sharing options...
Doug G. Posted September 2, 2012 Report Share Posted September 2, 2012 This is what the AD requires, "This AD requires replacing the pressure side fuel hose on certain fuel pumps and inspecting the carburetors connected to those fuel pumps for contamination within 5 flight hours after the effective date of the AD". As I read that, if I don't have that fuel pump, there is no requirement, and there is no AD against my engine or fuel pump. Logic says that an AD, SB, etc. against something that is not a part of your plane does not have to be noted, doesn't it? Since I have a CTLS, don't have to log SBs that have to do with CTSWs. Since I don't have that fuel pump, I don't have to log a non-hose change on my non-ADed fuel pump, do I? I think there is a difference between regulatory requirement and good practice. It is useful information to have the notation that it was checked - it may be helpful to a future owner - but I don't see that it is required. Roger? Link to comment Share on other sites More sharing options...
Jim Meade Posted September 2, 2012 Report Share Posted September 2, 2012 A responsible owner or mechanic will log any AD, SB,, SA, SI, or SD and log it complied with and any action taken or log it and note no action required and the reason. I.e. not applicable due to serial number, ect... You're not answering the question. What do you mean by "responsible"? That is an emotionally laden term. What do you mean, "any" AD, etc.? That is exactly the question I asked. Answer this yes or no. I have a CTSW. The FAA issues an AD on a CTLS. Do I log it in any way at all? Yes or no: Rotax issues an SD and the FAA issues an AD on a Rotax 912A. I have a 912ULS. Do you log this and why? There is no way it can apply to me. I have a FD CTSW. Do I log ADs on a Cessna 170? Link to comment Share on other sites More sharing options...
Tom Baker Posted September 2, 2012 Report Share Posted September 2, 2012 I've seen and made lots of AD list over the years. It's nice when you are doing a search to have the list of AD's show the ones that don't apply, but could have. In the case of this AD it does not apply, and no action is required. the next time someone new looks up AD's on this airplane it sure is nice to already have an entry saying that it does not apply rather than having to verify again that it does not apply. I do have an other issue with how some people do AD's. I've seen several times when a mechanic has repetedly signed of an AD that does not even apply. The AD may have once applied, but the repetitive part has been cancelled by some action yet they keep signing it off year after year. It's like they don't even bother to read what the AD's say. Link to comment Share on other sites More sharing options...
Jim Meade Posted September 2, 2012 Report Share Posted September 2, 2012 Tom, If you look at an unsigned list of AD's in the back of some book, you have nothing but a list of ADs, right? An unsigned list is meaningless. Any concerned mechanic would ignore it beyond perhaps taking it under consideration in his AD search. (SD, etc. included in above, of course). The other part of the question is, where do you draw the line? Do you do 912ULS that don't apply? Do you do 912A that don't even have the same model number? Link to comment Share on other sites More sharing options...
Tom Baker Posted September 3, 2012 Report Share Posted September 3, 2012 Tom, If you look at an unsigned list of AD's in the back of some book, you have nothing but a list of ADs, right? An unsigned list is meaningless. Any concerned mechanic would ignore it beyond perhaps taking it under consideration in his AD search. (SD, etc. included in above, of course). The other part of the question is, where do you draw the line? Do you do 912ULS that don't apply? Do you do 912A that don't even have the same model number? First off if I make an entry saying it doesn't apply I say why and then I sign it. It's not just an unsigned list in the back of the logbook it's part of the aircraft records. I would do the Rotax 912 series, just like I would do the Lycoming 0-320 series, just like I would do the CTSW or CTLS series which ever applied. Link to comment Share on other sites More sharing options...
Runtoeat Posted September 3, 2012 Report Share Posted September 3, 2012 The FD Safety Alert SA-ASTM-CTSW-05 requires the owner to "Inspect for applicability to Rotax ASB-912-UL-R1". Before all of this conversation came up, I had already inspected my aircraft and noted this in both my Airframe and Engine logs. I just don't consider this much of a reach to do since the bulletin instructed me to examine my plane and note whether or not I was affected if my plane had the engine that the bulletin refers to installed in it. There was the distinct possibility that I might have been affected by this. Same goes for any SA or SB which specifically deals with either a CTSW or the Rotax 912ULS. If the bulletin specifically states that an accounting must be made, I log into the appropriate airframe, propellor, avionics or engine logs. If the bulletin doesn't require an accounting, I have a running bulletin log where I enter all bulletins that pertain to the equipment or systems my plane contains and note whether these bulletins are "N.A. due to S/N" or give a date when I complied with them "C/W 9/2/12". All this seems pretty cut and dried to me. I do not intend to make a log entry for the FAA's AD since I consider the actions already taken have fullfilled the current LSA rules. Link to comment Share on other sites More sharing options...
Roger Lee Posted September 3, 2012 Report Share Posted September 3, 2012 I'm with Tom. Link to comment Share on other sites More sharing options...
Jim Meade Posted September 3, 2012 Report Share Posted September 3, 2012 I have an Experimental.and don't think I am REQUIRED to do anything about any of this. If you go back to the beginning of this thread, what we have is some speculation over what the SD and AD requires (some of) us to do and then we have a bunch of proposed 'best practices" or "recommended practice" for logging that are very useful to know but do not have the weight of regulation. It's not as if we're citing an AC to justify how we do the work, it's that we're proposing certain ways of listing the AD's etc. The discussion about what goes on this list is interesting. One could include all Rotax engines, all Rotax 4 cylinder 4 cycle opposed engines, all 912/914, all 912, all uncertified 912, etc. Each of us apparently establishes our own criteria. The next mechanic who sees the airplane will start all over. If he's researching the Rotax data base and includes all the above, he'll charge you for the research. If he searches only on 912ULS, then one assumes that is all he'll lilt if he makes a list at all. It seems to me it's up to how the mechanic searches? I bet 10 mechanics will give 11 different solutions. Link to comment Share on other sites More sharing options...
Tom Baker Posted September 3, 2012 Report Share Posted September 3, 2012 I have an Experimental.and don't think I am REQUIRED to do anything about any of this. If you go back to the beginning of this thread, what we have is some speculation over what the SD and AD requires (some of) us to do and then we have a bunch of proposed 'best practices" or "recommended practice" for logging that are very useful to know but do not have the weight of regulation. It's not as if we're citing an AC to justify how we do the work, it's that we're proposing certain ways of listing the AD's etc. The discussion about what goes on this list is interesting. One could include all Rotax engines, all Rotax 4 cylinder 4 cycle opposed engines, all 912/914, all 912, all uncertified 912, etc. Each of us apparently establishes our own criteria. The next mechanic who sees the airplane will start all over. If he's researching the Rotax data base and includes all the above, he'll charge you for the research. If he searches only on 912ULS, then one assumes that is all he'll lilt if he makes a list at all. It seems to me it's up to how the mechanic searches? I bet 10 mechanics will give 11 different solutions. Jim, I'm not going to argue about if they apply or don't for your experimental. If you look at 91.417(a),(2),(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. This is part of the aircraft records. The regulation only requires the applicable ones to be included on the list, but if I don't include the ones that are not applicable on the list then I will have to check them for applicability next year when I do my search. By making an entry on the list like AD2012-16-13 does not apply by model number keeps me from looking at the text of the AD next year to see what models it applies to. If you don't go as broad as the whole 912 series and just go to the 912 ULS you still have some that don't apply by serial number. If I don't log those I would have to check them again next year because I can't keep track of every airplane and SD in my head. Link to comment Share on other sites More sharing options...
Jim Meade Posted September 4, 2012 Report Share Posted September 4, 2012 Tom, Your point is well taken and I appreciate what you are saying. I like to be clear on these kinds of questions on what is required by regulation, what is common practice and what is preferred or best practices. You've done a nice job of clarifying that. Thank you. Link to comment Share on other sites More sharing options...
Doug G. Posted September 4, 2012 Report Share Posted September 4, 2012 So, SB requires inspection, and notation. This AD requires nothing legally if you don't have the fuel pump (you would need to know if you have it or not.) Good practice says make a note so you don't have to check again. I am in Oshkosh with the Rainbow folks. I'll try ask the question here. Doug Link to comment Share on other sites More sharing options...
Jim Meade Posted September 4, 2012 Report Share Posted September 4, 2012 So, SB requires inspection, and notation. This AD requires nothing legally if you don't have the fuel pump (you would need to know if you have it or not.) Good practice says make a note so you don't have to check again. I am in Oshkosh with the Rainbow folks. I'll try ask the question here. Doug And if it's Experimental? I am sure you'll have a very good experience at OSH with Rainbow. Carol and Brian and their staff are excellent. If you are going to the LEAF Line Maintenance Class 15-16 Sep, I'll see you there. I missed it last year and am delighted to be able to get it now. Link to comment Share on other sites More sharing options...
Doug G. Posted September 4, 2012 Report Share Posted September 4, 2012 No idea on experimental, but it will probably come up. I thought very seriously about the LEAF course, but I think I will wait for another time. I think I'll need the weekend to process all the info in this one. Link to comment Share on other sites More sharing options...
Doug G. Posted September 4, 2012 Report Share Posted September 4, 2012 Sorry I'll miss meeting you though, Jim. Link to comment Share on other sites More sharing options...
Jim Meade Posted September 4, 2012 Report Share Posted September 4, 2012 No idea on experimental, but it will probably come up. I thought very seriously about the LEAF course, but I think I will wait for another time. I think I'll need the weekend to process all the info in this one. LEAF only offers that course once a year in conjunction with Rainbow. I felt like you did and then regretted not taking it. Don't put your decision off, as I decided late in n the coures to take it and it was too late. There are not as many slots at LEAF as there are Rainbow students. Link to comment Share on other sites More sharing options...
chanik Posted September 4, 2012 Report Share Posted September 4, 2012 Experimentals have to follow ADs for any TSOd equipment they have installed. Everything else is optional but, of course, highly recommended. BTW, SBs do not require notation even for S-LSA. Link to comment Share on other sites More sharing options...
Roger Lee Posted September 4, 2012 Report Share Posted September 4, 2012 Many things aren't really required I agree, but there is doing things right. You can be in the bottom 10% and just get by the law or requirement, then there is the 50%'ers that are better, then there are the 90%-100%'ers that go the extra mile to do things right, required or not. When you pick a doctor to do surgery which do you want, if you pick an accountant which do you want, a dentist and then your flight safety keep your butt safe mechanic. I want the people who graduated in the top 10% not the bottom 10% and or who I know will go the distance for me. If mechanics or people skimp by in one place where else do they skimp by? Link to comment Share on other sites More sharing options...
chanik Posted September 4, 2012 Report Share Posted September 4, 2012 I wouldn't buy an E-LSA that did not have at least notations for all the SDs and SBs corresponding to its S-LSA cousins. But it is legal to have none of them Link to comment Share on other sites More sharing options...
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