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Roger Lee

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If a mechanic performs a procedure or maybe 2-3 procedures he is not allowed to do then signs the logbook label off as being in a safe condition for operation for that annual inspection is the logbook label void since he wasn't allowed to do certain procedures and is now in violation of 65.81?

 

What do you guys think?

 

I don't know the real answer and will need to call the FAA.

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If a mechanic performs a procedure or maybe 2-3 procedures he is not allowed to do then signs the logbook label off as being in a safe condition for operation for that annual inspection is the logbook label void since he wasn't allowed to do certain procedures and is now in violation of 65.81?

 

What do you guys think?

 

I don't know the real answer and will need to call the FAA.

Things like this normally have ripple effects. If the FAA determined that he indeed did sign off some items and he had not met the requirements of 65.81 it would create problems. Most likely they would require the aircraft the he had signed off to be re-inspected.

Something like this happened not to long ago on the pilot side of things. A DPE was not following the rules and the FAA shut him down. They required some of the applicants that he had tested for their ratings to be retested.

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Roger,

The simple answer is yes the entry is void. Here is why. The aircraft must be approved for return to service by someone listed in 14 CFR part 43.7. In this case, 43.7 sends us to part 65 for mechanics. Since this mechanic has not successfully completed this work before, they are not in compliance with 65.81, and therefore not authorized to approve the aircraft for return to service.  The violation would likely be sited to the 43.7 rule.

 

Doug Hereford

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Boy what a can of worms that would open people up for, both owners and mechanics. I know this happens because I have seen it, but because no one gets caught it just goes on to the next annual.

I think this is where it would behoove owners to question their mechanic's before an inspection to determine their qualifications. Even though some mechanics may have started out this (no experience with a particular job) way a few years back they may now have that experience because they did it anyway.

 

Interesting quandary. 

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Roger,

This stuff has been around for a long time. It is of course not unique to mechanics. A very similar requirement exists for repairmen 14 CFR part 65.107. Like I tried to point out in a previous thread, A&P school is very comprehensive with regard to performance of maintenance tasks. I cannot speak for all schools, but most that I am aware of will require students to perform numerous tasks like wing removal and replacement, aircraft control system rigging, etc. I actually remember overhauling a J69 turbojet engine in my power plant course.

 

Obviously, no schooling or OJT can address every situation. In talking with FAA attorneys in the past, they seem to indicate that violations down this path are pretty rare.

I don't see how you could have "seen this" for yourself though unless someone just outright admits that they have not performed something before, and then goes and does it. I do agree that the owner has responsibility to utilize qualified maintenance personnel. I can't imagine any owner not wanting to do this anyway. In the end, only the person performing the work can know for sure whether or not they meet the requirements of 65.81 or 65.107. It is usually a tough one for the FAA to prove.

 

Doug,

In talking with the same FAA attorney, and numerous ASIs, the interpretation is pretty liberal. Obviously one could contort it to the point that no one could legally do anything. The fact that you approached the wing removal the way that you did gives me the feeling that you have a good grasp on how the process works with regard to previous successful completion of work.

 

 

Doug Hereford

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Here's my thought on 65.81, and why I think it's a flawed regulation and extremely difficult to follow.

 

1) The FAA is eerily silent on what qualifies as "work". If I have worked with one model gascolator, and a customer brings in a plane with a slightly different one, am I no longer qualified to work on it? Or, what if I've welded plenty of times before on a steel bracket, but now I need to weld a steel tube? Or here's a good one: what about ELECTRICAL systems? Rarely, even between airplanes 1 serial apart, are the systems exactly the same. There's a lot of interpretations, but nothing concrete.

 

2) Burden of proof is on the mechanic, but it's almost impossible to prove, period. Unless you want to document EVERYTHING you have EVER done.

 

3) In effect, one could say nobody is qualified to do anything if you were extremely strict in interpretating this regulation.

 

I'm also going to SPECULATE for a moment. 65.81 is a very very very very very old regulation. I believe that the original intention of that regulation was not meant for specific tasks on an airplane, but rather applicable for METHODS AND PRACTICES (generalized, like AC 43.13 methods and practices). Never welded before? Then you can't weld until you demonstrate that you've done it correctly. Never worked with wood? You can't go gluing that wood spar on. Haven't done work on electrical systems? Then you can't go splicing wires. This is what I think that regulation was meant to address.

 

I don't think it is meant for "have you ever taken wings off and put them back on before?" Rather, lets examine a little deeper: what is taking off a wing? If we break it down into it's constituent components, it's removing and re-installing bolts, routing of cabling or pushrods, jacking an aircraft, inspecting for damage, etc. If you've done those constituent components, then you're fine for taking off the wing. I would still STRONGLY recommend that someone who HAS done that before be there with you to help of course, but I don't think 65.81 would have, in it's original writing, intended to stop you from doing it.

 

So, here's what I'm going to say. 65.81 leaves for a lot of judgement on the mechanic performing the work to determine if they are actually allowed to do it. With that said, if you perform it satisfactorily, then you won't have an issue. I'm not saying it's a blanket "do whatever you want", what I am saying is, really ask yourself, "Have I done anything like this in the past, and am I CONFIDENT I can do this correctly?"

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Anticept,

From what I see on the GPO website, the original issue of 65.81 was published in 1962 and has been amended twice since. The last amendment was in 2004 . I am sure that was language to address the LSA rule.

65.107 has nearly identical language on this topic. It was published in 2004, and has not been revised.

 

To me, the main thing that these rules accomplish, is that they allow the FAA to say to the general public: We require people who work on aircraft to personally know what they are doing. Furthermore, our system does not permit anyone to approve an aircraft for flying after maintenance unless they have prior experience with that maintenance.

Both of these rules go on to require that the person actually "understands" what the manufacturer's procedure is. Even though in the case of Standard Airworthiness, one does not necessarily have to employ those specific procedures. Again, this lets the FAA be in a position to say: We require maintenance providers to always consider what the manufacturer says before they employ an alternate procedure.

 

I can just imagine a plaintiff's attorney asking the FAA: You mean to tell me that your system allows people to do things that they have never done before, and authorize the plane to fly? FAA: No we don't, we have a specific rule in place to prevent that.

 

Doug Hereford

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I just spent  over an hour with two FAA people and went went through several rules.

 

First I have to concede to Doug about the term accept and approve. Anyone that wants to teach an LSA 120 repairman course must submit a DVD with the entire course powerpoint, class materials and procedures to Edsel Ford. It is then reviewed and then accepted or denied or sent back for changes. Here is the example he gave me between approved and accepted.

 

Accepted means if after the course is accepted you find a word in your presentation that is misspelled or wrong it can be changed. You have a limited number of items that can be changed as spelled out by the FAA without another acceptance.

Approved means even if you want to change one word or correct spelling you are not allowed to alter anything. You would need then to get approval from the FAA to make that one word change or whatever you need the change to be, even spelling.

So approval according to the FAA is a step higher than accepted.

 

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Funny thing there was just another legal ruling that hit the FAA desk the other day. Who knew and what timing. 

 

The FAA just released a new legal interpretation called Schober 2015. Filed in March this year.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2015/schober%20-%20(2015)%20legal%20interpretation.pdf

 

This now opens up even more of what a mechanic can do without specific training. It relaxed the rules even more. Bottom line you really don't need any training on a specific procedure and if you have ever done anything that is minutely similar you're good to go. An SLSA MFG can no longer demand that anyone has specific training for their aircraft. 

 

Here is two other good reads as to regs.

 

This was sent by FAA legal. Macmillan April 2011

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/macmillan%20-%20(2011)%20legal%20interpretation.pdf

 

Here is the other sent by FAA legal.  Carpenter Feb. 2012

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/carpenter%20-%20(2012)%20legal%20interpretation.pdf

 

FAA quote:

The FAA strongly encourages mechanics and repairmen to obtain both initial and recurrent training. Training provided by a manufacturer may provide mechanics and repairmen with a means of obtaining necessary understanding of the methods, techniques, and practices required to properly perform work on an aircraft and its components. A manufacturer may not, however, use a maintenance manual to impose a training requirement on a certificated mechanic or repairman that is not set forth in a regulation."

 

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Now for check list and logbooks and labels. The FAA stated that these regs are only bare minimums and stress owners and mechanics do more than the minimums.

I guess that boils down to the bottom 10% and then having professional pride above the minimums.

 

One of the debates here was that you did not have to include what the inspection was i.e. annual condition, 100 hr. ect. in your logbook entry.

The FAA says yes you do. You can not just say it was inspected. Inspected for what? You may have only inspected one item like the gearbox or brakes.

CFR 43.11 (7)

(7) If an inspection is conducted under an inspection program provided for in part 91, 125, or §135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

 

You put an LSA back in service for a simple repair like brakes, oil change, ect.. 

For the 100 hr. or the annual condition inspection it must be documented that it was inspected within the scope and detail of ???? and found to be in a safe condition for operation.

After the annual it isn't just returned to service for an LSA.

Confirmed by two FAA admins.

 

You do not need to even have logbooks just document the work done and and it should be in two different books in case the engine and fuselage separate, but we all seem to use logbooks.

The FAA said that the way it is written in the codes that just writing the basics like time, date and the lowly three line logbook label with IAW was strictly a minimum and they would prefer to see that backed up by detail, but it would pass for a bare minimum. Their take on this was like mine that when you have to face them or go to court better documentation wins out and protects you. They surely would know since they see this daily. The point they made was if anything comes into question you better be able to spit out all the detail later that you performed on that one aircraft. I would bet 6-8 months later and several aircraft later most mechanics details are gone with old age.

The FAA said you do not need to make two entries that it can be all inclusive with the inspection sign off and the detailed work involved.

 

You can also put duplicate all encompassing labels in a fuselage book and the engine book and there is no need to separate all the detail out. They can be all inclusive because you really don't need separated entries in each book according to the FAA. It just needs to be documented and be able to go with the fuselage or engine if they part ways.

 

Check list. YOU MUST use one. Over 2/3 of the mechanics I talk to on LSA don't use them. You don't have to give it to the owner, but it better be available and or on hand and show that it pertains to that specific aircraft and you better have some manuals or access to them for that same plane. Hard copy or computer doesn't matter any more.

 

CFR 43.15c

http://www.flightsimaviation.com/data/FARS/part_43-15.html

 

© 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. 

 

Appendix D:

(a) Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine.

(B) Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the fuselage and hull group:

(1) Fabric and skin—for deterioration, distortion, other evidence of failure, and defective or insecure attachment of fittings.

(2) Systems and components—for improper installation, apparent defects, and unsatisfactory operation.

(3) Envelope, gas bags, ballast tanks, and related parts—for poor condition.

© Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the cabin and cockpit group:

(1) Generally—for uncleanliness and loose equipment that might foul the controls.

(2) Seats and safety belts—for poor condition and apparent defects.

(3) Windows and windshields—for deterioration and breakage.

(4) Instruments—for poor condition, mounting, marking, and (where practicable) improper operation.

(5) Flight and engine controls—for improper installation and improper operation.

(6) Batteries—for improper installation and improper charge.

(7) All systems—for improper installation, poor general condition, apparent and obvious defects, and insecurity of attachment.

(d) Each person performing an annual or 100-hour inspection shall inspect (where applicable) components of the engine and nacelle group as follows:

(1) Engine section—for visual evidence of excessive oil, fuel, or hydraulic leaks, and sources of such leaks.

(2) Studs and nuts—for improper torquing and obvious defects.

(3) Internal engine—for cylinder compression and for metal particles or foreign matter on screens and sump drain plugs. If there is weak cylinder compression, for improper internal condition and improper internal tolerances.

(4) Engine mount—for cracks, looseness of mounting, and looseness of engine to mount.

(5) Flexible vibration dampeners—for poor condition and deterioration.

(6) Engine controls—for defects, improper travel, and improper safetying.

(7) Lines, hoses, and clamps—for leaks, improper condition and looseness.

(8) Exhaust stacks—for cracks, defects, and improper attachment.

(9) Accessories—for apparent defects in security of mounting.

(10) All systems—for improper installation, poor general condition, defects, and insecure attachment.

(11) Cowling—for cracks, and defects.

(e) Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the landing gear group:

(1) All units—for poor condition and insecurity of attachment.

(2) Shock absorbing devices—for improper oleo fluid level.

(3) Linkages, trusses, and members—for undue or excessive wear fatigue, and distortion.

(4) Retracting and locking mechanism—for improper operation.

(5) Hydraulic lines—for leakage.

(6) Electrical system—for chafing and improper operation of switches.

(7) Wheels—for cracks, defects, and condition of bearings.

(8) Tires—for wear and cuts.

(9) Brakes—for improper adjustment.

(10) Floats and skis—for insecure attachment and obvious or apparent defects.

(f) Each person performing an annual or 100-hour inspection shall inspect (where applicable) all components of the wing and center section assembly for poor general condition, fabric or skin deterioration, distortion, evidence of failure, and insecurity of attachment.

(g) Each person performing an annual or 100-hour inspection shall inspect (where applicable) all components and systems that make up the complete empennage assembly for poor general condition, fabric or skin deterioration, distortion, evidence of failure, insecure attachment, improper component installation, and improper component operation.

(h) Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the propeller group:

(1) Propeller assembly—for cracks, nicks, binds, and oil leakage.

(2) Bolts—for improper torquing and lack of safetying.

(3) Anti-icing devices—for improper operations and obvious defects.

(4) Control mechanisms—for improper operation, insecure mounting, and restricted travel.

(i) Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the radio group:

(1) Radio and electronic equipment—for improper installation and insecure mounting.

(2) Wiring and conduits—for improper routing, insecure mounting, and obvious defects.

(3) Bonding and shielding—for improper installation and poor condition.

(4) Antenna including trailing antenna—for poor condition, insecure mounting, and improper operation.

 

(j) Each person performing an annual or 100-hour inspection shall inspect (where applicable) each installed miscellaneous item that is not otherwise covered by this listing for improper installation and improper operation.

 

 

CFR 43.13a

 

You can't just do what you want. For most of us you follow the MFG's maint. manual and check list or something acceptable to the FAA admin. The FAA admin according to the FAA pretty much will follow what the MFG wants inspected and how it should be maintained to be airworthy so if you deviate you should check with the FAA to make sure it's acceptable because  waiting until after the fact could easily be a day late and dollar short and not be acceptable.

 

Title 14 of the Code of Federal Regulations (14 CFR) part 43, § 43.13(a) states that each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance must use the methods, techniques, and practices prescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, or practices acceptable to the Administrator .

 

 

Your methods may not past muster.

Instead of reinventing the wheel it would be easier to just grab the MFG's check list and document what you did.

It's easier than fighting the FAA or court when called on the carpet.

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As a point to make roger, 43.15c does not apply to S-LSA. It only applies to standard and experimental airworthiness certificates. I'm not sure if E-LSA is the same; I don't think it is. LSA is governed by the limitations section of the airworthiness certificate, and it states we must use the manufacturer's inspection procedures. The manufacturer does state that we need to use a checklist :P

 

The reason why I say it doesn't apply, is because of the Scope and Detail of App D requirement. I know for a fact App D is NOT allowed to be used. It must be procedures developed by the manufacturer, or a person acceptable to the FAA (the latter of which, I know of none who exist).

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So…how does an SLSA owner write in the logbook preventative maintenance such as an oil change? Should they detail what they did (magnetic plug check, oil filter cut, amount/type oil) and then write 'returned to service' ….or is there a format that is both legal and proper?

 

 Is logging EFIS software updates considered 'preventative maintenance'? EG. SV 12.0 included activating auto-trim for autopilot with a series of items which calibrated the servos. How would this be logged? Or is this something a LSRM qualified person would do, not the non-qualified pilot-owner?

 

Sample of good log-book entry? :unsure:  :huh:  Thanks!

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So…how does an SLSA owner write in the logbook preventative maintenance such as an oil change? Should they detail what they did (magnetic plug check, oil filter cut, amount/type oil) and then write 'returned to service' ….or is there a format that is both legal and proper?

 

 Is logging EFIS software updates considered 'preventative maintenance'? EG. SV 12.0 included activating auto-trim for autopilot with a series of items which calibrated the servos. How would this be logged? Or is this something a LSRM qualified person would do, not the non-qualified pilot-owner?

 

Sample of good log-book entry? :unsure:  :huh:  Thanks!

 

Off the top of my head:

 

Performed an oil and filter change IAW Rotax Line MM, Edition 3, Rev 1, Chapter 12-20-00, Section 11.2. Replaced filter with Rotax Oil Filter, Part ###-###, and installed IAW with filter instructions. Serviced with 3 liters of Aeroshell Sport Plus 4. Inspected Oil Filter IAW with aforementioned Rotax MM, Chapter 12-20-00, Sec 11.4. Findings are within acceptable limits. Ground run and leak check good. Printed Name, Signed Name, Type of Certificate, Certificate Number.

 

It's very good to cite the sections of the manual (AND SPECIFY WHICH EDITION AND REVISION. DATE IF NEED BE!), and maybe put in the really important points like I did to show diligence. It's still a pretty short logbook entry, but as you can see it's information dense.

 

A lot of people keep templates of their signoffs like the above too. Nothing wrong with that, just don't be lazy and make sure you have the latest manual and do a quick review for changes and notes. Rotax is famous for changing even simple procedures often.

 

By the way, I don't think you are supposed to check the magplug as an owner. Not sure :)

 

EDIT: I derped and forgot which chapters. Put them in my sample.

 

EDIT2: seems most believe the magplug check can be done by owners. I have no idea, I use my A&P :P

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Roger,

The interpretation for training is not new. It is just that the answer to David Schober's particular request was finally answered. I think I may be the reason he made that request in the first place since I questioned him on an article he wrote over two years ago where he claimed that SLSA manufacturer's control who can do what on their aircraft. I am anxious to see if he issues a correction to that article.

 

Carol Carpenter's letter was most definitely due to my questioning her on several articles she wrote in which she claimed that mechanics (she too singled out A&Ps) must attend Rotax training. Again, not a new FAA position, just new news to some. Like I told you, she was wrong on most everything thing she said, and fronted herself as an authority on the subjects.

 

Your citation of 14 CFR part 43.15 © and 43 appendix D is completely inappropriate for SLSA. This rule applies to Annual and 100 hr. inspections. SLSA aircraft DO NOT get Annual or 100 hr. inspections. SLSA aircraft are also NOT inspected IAW the scope and detail of appendix D (although I have said many times that app D is a good place to compare to the MGFs procedure to make sure that the entire aircraft gets inspected).

 

Did you happen to ask Edsel about the phrase "Approved for Return to Service"?

 

Also even though 14 CFR part 43.13(a) give us three sources for accepted tech data, in the SLSA world, if we maintenance providers don't use the MFGs maintenance and inspection procedures exclusively, we have rendered the airworthiness certificate for the SLSA invalid per operating limitations. Your bold and underlined portion of this rule will get the pilot in trouble if we use anything other than the first source for data.

 

Better call him back Roger.

 

Doug Hereford

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So…how does an SLSA owner write in the logbook preventative maintenance such as an oil change? Should they detail what they did (magnetic plug check, oil filter cut, amount/type oil) and then write 'returned to service' ….or is there a format that is both legal and proper?

 

Is logging EFIS software updates considered 'preventative maintenance'? EG. SV 12.0 included activating auto-trim for autopilot with a series of items which calibrated the servos. How would this be logged? Or is this something a LSRM qualified person would do, not the non-qualified pilot-owner?

 

Sample of good log-book entry? :unsure: :huh: Thanks!

And, as an LSRM, do I need to always write " return to service" after all maintenance? (i.e. oil change, tire repair, brake pads) I have always entered this in the logbook, but have only used the " return to service on inspections. I may have some amending to do.
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Doug,

You never need to write return to service. Your signature constitutes "approval for return to service" on regular maintenance and preventive maintenance. 43.9. Use the phrase in your operating limitations item 15 for the certifying statement after a condition inspection.

 

Doug Hereford

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Hi Corey,

 

According to the FAA the new legal interpretations bridged that gap. Just like the Macmillan interpretation bridged from GA to LSA in its interpretation.

 

Hi Doug,

 

"Your citation of 14 CFR part 43.15 © and 43 appendix D is completely inappropriate for SLSA. This rule applies to Annual and 100 hr. inspections. SLSA aircraft DO NOT get Annual or 100 hr. inspections. SLSA aircraft are also NOT inspected IAW the scope and detail of appendix D (although I have said many times that app D is a good place to compare to the MGFs procedure to make sure that the entire aircraft gets inspected)." 

 

 

You'll have to argue this with the FAA. They say it does. We spent a lot of time on the phone going over these debates we have been having. I think there are crossovers that some are missing. If you read all these documents you can see where FAA legal started on the interpretation for GA, but then later on included LSA.

 

Also what was discussed was if the mechanic doing something wrong or in appropriate, does it make the entire sign off invalid. No it didn't, but definetly put the mechanic on the hot seat. Even if nothing happened to the plane to get the FAA investigating a report from the owner could and you'ed still be in the hot seat.

 

"Did you happen to ask Edsel about the phrase "Approved for Return to Service"?"

 

Good for general maint., but can't be the only phrase for LSA annual condition inspections. I forgot the rule he cited for all this. I tried to write a lot down, but it was quite involved.

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You just can't write Approved for Return to Service after an annual condition inspection.

Found in the FAA Operating Limitations for light sport

 

 

http://www.faa-aircraft-certification.com/light-sport-operating-limitations.html

 

(15) Condition inspections must be recorded in the aircraft maintenance records showing the following, or a similarly worded, statement: “I certify that this aircraft has been inspected on [insert date] in accordance with the manufacturer’s maintenance and inspection procedures, and was found to be in a condition for safe operation.” The entry will include the aircraft’s total time-in-service, and the name, signature, certificate number, and type of certificate held by the person performing the inspection.

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Roger,

Again, I am not calling the FAA on anything. What I told you has been that way from the beginning of the Light Sport Rule. SLSA aircraft DO NOT get Annual or 100 hr. inspections, so 43.15© does not apply.

SLSA aircraft get CONDITION inspections IAW MFG maintenance and inspection procedures. If Edsel told you different, have him cite rules.

The misinformation continues.

 

Doug Hereford

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Hi Corey,

 

Nice label. I would add the mag plug check too.

I always include at the top of the entry date, TTSN hrs, tail #, aircraft serial and eng. serial. It's just my personal preference.

 

"Performed an oil and filter change IAW Rotax Line MM, Edition 3, Rev 1, Chapter 12-20-00, Section 11.2. Replaced filter with Rotax Oil Filter, Part ###-###, and installed IAW with filter instructions. Serviced with 3 liters of Aeroshell Sport Plus 4. Inspected Oil Filter IAW with aforementioned Rotax MM, Chapter 12-20-00, Sec 11.4. Findings are within acceptable limits. Ground run and leak check good. Printed Name, Signed Name, Type of Certificate, Certificate Number."

 

 

For those making a label like this I would consider it more the top of the line documentation. It's a good label, but you could get away without the section reference and still have a decent label. Just food for thought and your personal preference. 

 

Always keep in mind there are minimum requirements and then those that go the extra mile like Corey. You get to decide if you want a "C" grade for that label or be at the top of the class with an "A" grade. This was FAA's analogy on logbook entries.

 

Yes you can inspect the magnetic oil plug as an owner because it is part of that owner allowed maint.. It is a requirement from one of the Rotax SB's for an oil change to be done every oil change.

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Doesn't that SB say you can do it every 100 hours though? I thought every 50 was also if you are running avgas. I can't remember, and I have my head stuck up the butt end of an airplane right now so I can't poke around in the bulletins.

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The actual manual says oil changes up to 100hrs., but no one teaches that in class and everyone would like to see that changed. Getting manual changes is an act of God. We teach 50 hr. changes with auto fuel. The book and SB's do spell out 25 hr. changes for 100LL.

 

Even my Polaris Razor 1K has 50 hr. oil changes.

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One of the debates here was that you did not have to include what the inspection was i.e. annual condition, 100 hr. ect. in your logbook entry.

The FAA says yes you do. You can not just say it was inspected. Inspected for what? You may have only inspected one item like the gearbox or brakes.

CFR 43.11 (7)

(7) If an inspection is conducted under an inspection program provided for in part 91, 125, or §135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

 

I don't recall anyone saying you didn't need to say what kind of inspection you were doing.

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