Rotax 100hr Maintenance Question

[Doug G.]

I not only enter things in my logbook, but I keep a file that holds detailed info on my annuals.

[Doug Hereford]

To all,

There is only ONE legally required inspection for SLSA aircraft.......... "Condition Inspection". 

The terms "Annual Inspection", and "100 hr. Inspection" DO NOT apply to SLSA aircraft....... period. These inspections have legal definitions that pertain to standard airworthiness aircraft (not special airworthiness).

If the SLSA is not flown for hire, then "Condition Inspections" are due every 12 calendar months.

If the SLSA aircraft is flown for hire, then "Condition inspections" are due at each 100 hrs. TIS, or 12 calendar months (which ever comes sooner). Whether done on an annual interval, or 100 hr. interval, the scope and detail of the inspection is the SAME, and the sign-off is the SAME.

To me, it is helpful to look at SLSA inspection requirements this way. People interchange the terms Annual, 100 hr, and condition inspection all of the time, but they are technically not interchangeable.

If you are one of those owners who want to have other mfg. recommended inspections done, ie Rotax 100 hr. items, etc....... then my advice is to specifically request that your maintenance provider comply with these items, and you provide them with the checklist. Otherwise you have no right to ask them to include those additional inspection procedures into a "Condition inspection" sign-off.

Also, the 10 hr. "grace" period for 100 hr. inspections DOES NOT apply to aircraft with light sport certificates.

 

Doug Hereford

[S3flyer]

Doug - excellent points as to what is required as per the regulations.

 

However, one may want to adhere to the manufacturers recommendations, though, so the Rotax +/-10 hr leeway would apply in this case. Whether that is material after the engine is out of warranty is up to the owner and Rotax.

[Anticept]

Looked up 91.327 ( c ) and ( c )( 1 ), and compared the wording to 91.409 ( b ), and additionally reading 91.409 ( c ) and ( c )( 1 ), supports doug's claims.

 

However, part of the phrasing says "inspection procedures developed by the aircraft manufacturer or a person acceptable to the FAA" in 91.327. The grammar in that paragraph is very weird. I am going to call up AFS 610 tomorrow and ask about this.

[Doug Hereford]

Anticept,

The phrase "Inspection procedures" refers to the accepted methods, techniques, and practices that must be employed when performing maintenance. Key word being "perform". Procedures are not used to convey requirements of "WHEN" inspections are to be performed. A practical example of what I am talking about is this:

 

MFG's condition inspection procedure contains a checklist with all of the required inspections listed on it. Off on the R/H side of this list are columns that specify intervals of "WHEN" these inspection items are due to be done. This information on the check list is NOT regulatory, and could actually cause the inspector to perform an incomplete inspection of the aircraft. If he/she only performs the "100 hr. items", and these items do not cause the entire aircraft to be inspected, he/she cannot actually certify that the aircraft is in a condition for safe operation, as the regulations require.

 

As I said before, there is only one required inspection in the SLSA world. "Condition inspections" are WHOLE aircraft inspections performed to determine whether the aircraft (entire aircraft) is or is not in a condition for safe operation.

 

My reply speaks only to regulatory requirements as that is what I thought the original question pertained to, however, I can't imagine Rotax denying an otherwise legitimate warranty claim if someone did not comply with all of their whimsical inspection stuff. I also can't believe anybody would continue to buy their product if they did do this.

 

Doug Hereford

[Doug G.]

So does that mean the wings have to be pulled every inspection?

[Anticept]

Doug H, the part of interest is who is a person acceptable to the FAA?

 

Also, define condition inspection. I point that out because I do not see where in 91.327 that it says you must perform a condition inspection every 100 hours when used in flight instruction. It only says to use procedures developed by the manufacturer (or this mystical person). I quote below:

 

© No person may operate an aircraft issued a special airworthiness certificate in the light-sport category to tow a glider or unpowered ultralight vehicle for compensation or hire or conduct flight training for compensation or hire in an aircraft which that persons provides unless within the preceding 100 hours of time in service the aircraft has—

 

(1) Been inspected by a certificated repairman with a light-sport aircraft maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station in accordance with inspection procedures developed by the aircraft manufacturer or a person acceptable to the FAA and been approved for return to service in accordance with part 43 of this chapter; or

Also, condition inspections have been held for a long time with experimental aircraft to at least include the items in 43 app D. If it wasn't so late, I would do some more digging to see what the FAA wants done on S-LSAs but I need to get up early in the morning.

 

The LSA regulations are poorly written. That came from AFS 610 themselves. The regulations always refer to the "Administrator" for example, but if the FAA ever changed their name, anything referring to the FAA (like in the light sport regs) instead of the "Administrator" would be in limbo.

[FastEddieB]

So does that mean the wings have to be pulled every inspection?

Interestingly, on my Sky Arrow pulling the wings is not on the inspection checklist.

 

But if you read the chapter in the AMM on the wings, it does state they should be removed and inspected annually.

 

Tough call, since removing/replacing the wings always entails some small risk of maintenance induced failures.

[FlyingMonkey]

 

Tough call, since removing/replacing the wings always entails some small risk of maintenance induced failures.

 

 

In a fairly important structure, since wings help the airplane, you know...fly.  

[Doug Hereford]

Anticept,

I agree with your concerns. I have asked the same question about who is "acceptable". No good answer. I also agree that the lack of specific defined "Condition Inspection" scope and detail leaves all of us in the field at great liability. My recommendation to owners is to maintain copies of the aircraft manufacturer's provided checklist/procedures, and make those available to you mechanic/inspector. The two people need to agree up front on EXACTLY what inspection items will be performed. Inspectors, however have the final say on scope and detail. This is because it the inspector that will ultimately certify the entire aircraft (not the owner, manufacturer, or FAA). While FAR 43 app. D is not applicable to SLSA, it is a great place to start with regard to necessary scope and detail on SLSA condition inspections.

 

A practical example of the safety implications: CT Condition Inspection check list does not even mention the BRS. (I have not researched this lately, but as of about a year ago, this was the case). This is illegal, and an immediate safe-of-flight issue that should have been addressed by Safety Directive long ago. (All that is my opinion).

 

Fast Eddy: We used to work on a couple of Sky Arrows (2000 hrs TIS combined). We would always pull the wings and horizontal on Condition Inspections. In my opinion, the attachment features for these parts requires detailed inspection every time. We also lubed the horizontal attach fitting which is impossible to do completely with the stabilizer in place. Another place to watch closely in the main gear carry through shelf. Very poor design and prone to delamination. (I would be glad to give more detail on a different thread).

 

Doug Hereford

[FastEddieB]

Doug,

 

I'll start another thread about Sky Arrow annual issues later to avoid hijacking this thread.

 

I'm very interested in your experiences.

[Roger Lee]

CT wing inspection is only do every 2 years or 600 hours which ever comes first per the written documentation from FD. Nothing to debate. trying to always meet the letter of the law verses the spirit can be counter productive.

 

I do everything on the Rotax list and fuselage list every inspection. Why spend time nit picking an inspection list. I always do the 100 hr. and annual condition together and document them as so. The difference is only a couple of items. Why be mediocre and take short cuts. It doesn't take that much longer, is a more complete job and it covers the mechanic and owner for any legal issues so you won't need to spends hours and months trying to figure out if it was really necessary and should make the inspection far better towards flight safety. Doing things this way also keeps the re-sale value up by $5k-$10K. I did the research years ago. If you want top dollar work then seek out someone who is not happy with mediocre and isn't looking to save a hours worth of time. When you strive to find loop holes then you strive to be incomplete in both spirit and work thoroughness. 

Look how much time in society people work on how to get out of things instead of striving to be better.

 

I never understand why someone always looks for loop holes to do less work, when striving to be better and more complete serves all and many times takes less time when you commit.

 

Mediocre is always happy with itself and excellence never is because it always strives to be better. Mediocrity always will defend itself and have an excuse.

 

“Mediocrity always sets goals it knows it can achieve.
Excellence stretches itself.
And although it may not always achieve its goals…
it always outperforms mediocrity.”
~ Deborah Cole Micek

 

 

Bottom line: Why not just do both inspections and completely and be done with it?

[Doug G.]

Roger, I was questioning the, "do everything" on the list regardless of the hours accumulated, or how many years, as suggested by Doug H. The lists are specific from the manufacturers and I follow them, and file them.

The question about the wings was only to say that there are things that are not done every inspection as indicated by the manufacturer.

[Roger Lee]

Hi Doug G.,

 

I agree. The only thing I tend to let go full time is the wing inspection. I have tried to get that to 3 years with FD, but have had no luck. To my knowledge FDUSA supports that, but not FD Geramany. Since I always include the 100 with the annual I personally include everything on both list (except wings).

[Doug Hereford]

Doug G,

Regarding the CT wing, the thing about it that would concern me the most are the front and back wing root pins. It seems to me that the pins, and the area around them would warrant a detailed visual / coin tap check at each Condition inspection. Like somebody said, they let the airplane.................... fly. Labor is minor, and the chance for induced problems is low as well.

 

In general, I would consider myself an absolute minimalist with regard to aircraft maintenance. That being said, I do not promote, nor would I tolerate the use of "loop-holes", "short cuts", or mediocrity" in aviation.

I do promote knowing and following the letter (and spirit) of the rules.

 

Doug Hereford

[Anticept]

Hi Everybody!

 

So I called AFS 610. That was a very enlightening conversation. As the regs say, App D doesn't apply, it's the manufacturer's inspection procedures that do. Additionally, keep in mind, this is INSPECTION, not maintenance. Even if you find something timed out, you are not required to replace it unless there is a limitation that applies to MECHANICS (not pilots! different regs!), such as an FAA APPROVED Airworthiness Limitations section of a manual, or a regulation in part 43 or 65. Keep in mind, an APPROVED section will have an FAA Approval Signature and Date.

 

Next, airworthiness certificates are very important to read. There's a limitations section that MUST be followed. In White certificates (standard aircraft), they will have a definition of "Airworthiness", which states that the aircraft is airworthy when it meets it's type design or properly altered condition. As a side note, that's where experimental aircraft have the limitation requiring them to do a condition inspection following 43 App D, since there's no reg for it. In PINK slip aircraft such as S-LSA, there's a long list of limitations on the certificate. All of these limitations, plus any applicable regulations for maintenance, must be met for the aircraft to be considered "in a condition for safe flight", in addition to judgement calls made by the mechanic for any problems they encounter. With that said, you do not have to remove the wings until the time that the manufacturer says you do. So yes, it does somewhat leave the mechanic who signs the logbook out on the chopping block, but since there is no type design for experimental and light sport aircraft, there's no manual or standard to meet except for what the manufacturer provides.

 

Doug H: You don't have to remove the wings and do the tap testing each inspection (as stated above). The material and buildup around the wing pins and sockets has the strength of several thousand pounds each anyways. If problems occur, it will be very easy to see just by using a light or a borescope and looking down into it. I had first hand experience, 6FD had some cracking around the two rear sockets and required FD Germany engineering to get involved, which amounted to sanding out some of the damaged area and applying layups over it to reinforce. Despite the cracking, it still had a phenomenal amount of strength, well beyond what was required.

[Doug Hereford]

Anticept,

With all do respect, what that means to me is, inspect the wing pins every time. It is easy, and necessary. I don't care how many pounds of strength strength FD unofficially says the pins are. Put it in a condition inspection  check list, and then I might listen.

Also, inspections are maintenance, legally speaking.

AFS 610 does bring up a good point, Airworthiness  Limitations are a very important consideration. Most professed SLSA gurus don" even know what airworthiness limitations are. Thanks for mentioning them. Very important!!!!!!!! 

 

Doug Hereford

[Anticept]

By 14 CFR 1.1, maintenance encompasses everything as a definition (minus preventative maintenance), but from a part 43 point of view, which is what matters for exercising your privileges, they are different. Additionally, AFS 610 stated that an LSA aircraft is no different than a standard aircraft in regards to maintenance, except that the manufacturer is the authority for major repairs and major alterations. In that regard, a person can perform an inspection per the manufacturer's instructions, but you are not required to comply with the maintenance instructions that may be attached to said inspection instructions if you deem it safe for flight. This means things like TBO may be ignored, but it does leave the mechanic open for lawsuit if someone is injured.

 

As for the wing pins, what I'm saying is that taking the wings off for a coin tap test every 100 hours isn't necessary; a visual inspection qualifies as an inspection. If delamination or problems occur, they will show up very clearly as cracking and peeling of the paint. Flight Design discourages continued removal and installation of the wings as the aircraft is not designed for it. I'm trying to find the source of where I had read it, I remember it was referring to trailering the aircraft.

 

If you look at page 4.1.1 - Wing Structure, it gives you an inspection procedure that does not involve removing the wing.

 

 

Move the wing tips slightly forward and backward, there should be no play and noise. If there is play or

noise, pull the wings about 20 cm out (see p. 4.1.2) and check if the root rib, especially at the pin area

has no cracks or damages.

If there is not damage but some play between fuselage and wing root rib, washers can be used to

compensate.

[Roger Lee]

Right out of the 100 hr/annual check list.

 

"Wing Attachment Area. Inspect wing spar and main bolt bushings

for cracks and debonding. Check visible attaching hardware for loss

of torque. Inspect aileron bellcranks for cracks and corrosion. Check

root rib pins for debonding and cracks, and the forward one for fuel

leak. Check each 600 hrs or at the next 100 hrs inspection after

2 years, whichever occurs first."

 

I have confirmed this with FD twice.  Since most of us don't fly 600 hrs. in two years as a private owner this one is aimed more at schools and the 2 year mark is the farthest out you can go regardless of hours for the wing inspection. I have tried to get this to 3 years, but have not been successful. Not an FD USA issue, but a Germany one.

Just to put your mind at rest no one has ever had any wing spar or pin issues.

[Doug G.]

Does this require actual complete removal of the wings, or can they be partially removed and still inspected?

[Anticept]

Just pop the wings out a little, you don't have to take them all the way off.

[Doug Hereford]

Anticept,

I was not intending to say that anyone must remove the wings at each condition inspection, only that I would have to. I do agree that full removal is not necessary, just apart enough to access the pin areas. 

 

I realize that I will be strongly disagreed with here, but the fact is that the wing removal inspection is technically/legally never required. If FD wants to make it a legal requirement, then they need to issue a Safety Directive to that effect. That being said, for me to sign a Condition Inspection on a CT, the wings would have to come off enough for me to inspect those pins thoroughly. Just my personal position, and not law. 

 

Ask yourself this: Why does FD want the wing removal inspection done at all? What is magic about 2 yrs. or 600 hrs.?

How has the plane been flown? or moored? or ground handled? How many hours does the aircraft have on it? 100, or 10,000. There is currently no legally enforceable life limit on these airframes. Could anything have happened to put undo stress on the attachment areas? Because the wing attachment is so critical, and because these questions may or may not be answerable, the wings come off (or loose) each time (my opinion only).

 

Inspections are absolutely a type of maintenance task whether referenced to part 1, part  43, part 65, part 91, or any other part of the rules. If one is performing an inspection, then they are performing maintenance.

 

Doug Hereford

[Doug G.]

I honestly don't know the answer to this - who determines what is done for an annual (or 100 hr.) on a standard certificated plane?

[FlyingMonkey]

I honestly don't know the answer to this - who determines what is done for an annual (or 100 hr.) on a standard certificated plane?

 

The manufacturer issues a list of list items that must be performed in accordance with the type certificate, and the A&P or IA is responsible for compliance, I believe.  Though a mechanic cannot force you to do any particular work, they can just refuse to sign off on the work or annual.

[Tom Baker]

I honestly don't know the answer to this - who determines what is done for an annual (or 100 hr.) on a standard certificated plane?

It must include at least the scope and detail of CFR 43 appendix D.

 

Andy, the proper way for a annual if there are problems is to sign it off as un airworthy and provide a list of discrepancies to the owner.