Annual condition inspection without oil change?

[S3flyer]

Not a big deal but it is highly likely that I would not otherwise need an oil change at my next annual. The annual checklist calls for one but it also defers to Rotax for all things engine. I won't be anywhere near the 'required' or even 'recommended' intervals.

Mostly just curious.

[Tom Baker]

Not a big deal but it is highly likely that I would not otherwise need an oil change at my next annual. The annual checklist calls for one but it also defers to Rotax for all things engine. I won't be anywhere near the 'required' or even 'recommended' intervals.

Mostly just curious.

 

Rotax says for the annual to follow the 100hr checklist, and the oil change is on the 100hr list.

[sandpiper]

If my oil is not close to needing to be changed, which I do every 40 hours or 4 months, then I don't do it at annual or 100 hour.

[Roger Lee]

The oil change just needs to be documented for its change intervals. If you only have 10 hrs on a change it doesn't need to be done again at the 100 hr or annual. Just document on the inspection checklist it was just done 10 hrs ago and is not due. It isn't mandatory to be done. It's the same with plugs. Just document because your logbook will show the oil and or plug changes when done on your regular schedule. If you want to or if the oil and or plugs are due then do it and log it with the 100 hr or annual condition inspection. I always log both the 100 hr and Annual together and do them at the same time. There is only a few differences so it is usually only an additional initial on the check list.

 

The check list means; " If it already hasn't been done, do it".

 

 

Remember the checklist are written for world wide use. Some people do good maintenance and keep regular schedules, SOME NOT SO GOOD? So Rotax wants the bases covered.

[Doug Hereford]

S3Flyer,

An oil change is not a part of any inspection. I don't know the checklists by heart, but any engine inspection must include a requirement to inspect it for metal and/or foreign particles/matter. One popular way to do this is to remove the pressure filter/screen, and open it to inspect. Of course, Rotax 912 series, like many other aircraft engines, allows for removal of the spin-on filter, without draining the oil. This must be done at the Condition inspection. Then the filter must be cut open, and the internal media inspected for foreign material. One could argue that the magnetic plug should also be removed and inspected as well.

Remember, a condition inspection is done on the entire aircraft, including engine and propeller. Without an inspection for internal oil system contamination, one cannot legally certify the aircraft as in a condition for safe operation.

 

Example: Oil change was done 10 hours before inspection, all was well. Subsequently, the engine became contaminated with foreign matter (doesn't matter how). Ten hours later, a Condition inspection was done with out inspection of the engine for foreign matter because it was assumed that the previous oil change covered this requirement. Mechanic, pilot, and owner are in a bad spot.

 

Summary: Condition inspection requires inspection of the engine for contamination regardless of when the last oil change was done.

Doug Hereford.

 

P.S. Just to re-state, Condition inspections are the same scope and detail regardless of whether performed on an annual requirement of when, or a 100 hr. requirement of when, and do not require any additional (or different) sign-off language. To state another way, the 100 hr, and annual inspections (condition) are the same inspection.

 

The check list means "do it" if it is an inspection item. Otherwise, the inspection is incomplete.

[Roger Lee]

Hi Doug,

 

The 100 hr, the annual and the 200 hr have a few different items. They are almost the same, but aren't totally the same. I will check, but I still believe that if the oil was changed 10 hrs before the 100 hr or annual and it is documented and it is within the scope of the Rotax parameters for an oil change then it doesn't need to be done.

Documentation here is the key. Leaving it blank or not documented in the logbook would cause an issue.

That said I will check with two different people up the chain to make sure and get back here.

[Doug Hereford]

Roger,

I am familiar with the fact that most checklists (FD and others) have different items for Annual vs 100 hr. inspections, however.................I have said this a bunch before, and will keep saying it. There is only ONE required inspection for SLSA, and that is a CONDITION INSPECTION. It is an ENTIRE aircraft inspection. When one signs off a Condition inspection (whether on an annual basis, or 100 hr. basis) they are certifing the ENTIRE aircraft to be "In a Condition for Safe Operation". Obviously, the inspector cannot make this statement, unless, the entire aircraft was inspected. No different sign off, no different work scope. Both "next due" items reset (calendar, and time in service) either way.

 

Since after the Condition inspection, the inspector is certifying the ENTIRE aircraft to be in a condition for safe operation, they must have (in the course of the inspection) checked the engine(s) for contamination (metal or other foreign matter).

 

My statement stands.

1. Remove and cut open that filter.

2. Inspect that magnetic plug (if installed).

 

If you can do items 1 and 2 without draining the oil, no oil change is necessary. Even if you have to drain the oil, there is nothing prohibiting you from saving the drained oil and putting it back into the engine after the inspection is complete.

 

Summary: Oil changes are not required during Condition inspections, but inspection of the engine for oil contamination, is required (100 hr. or annual) regardless of previously documented oil/filter changes.

 

Doug Hereford

 

PS. From a legal (and safety) stand point, there is no such thing as a 200 hr. inspection.

[Roger Lee]

Hi Doug,

 

So then what do you do with the items on the check list for the annual that says only at the 200 hr inspection? Since you are only doing annuals it isnt listed with the annual's only yhe 100 hr. inspections. They aren't included in the Rotax annual check list for the annual just at the 200 hr. You can just check the mag plug, but then you may need to check the oil filter, but why stop there because we can't see contamination all the time so why not do an oil analysis every annual? Technically Rotax does want oil analysis every annual as part of the extended 2000 TBO allowance.

 

I fired off my emails for this and I'm curious on the answer. I sent one to Rotax and the FAA.

[Doug Hereford]

Roger,

First of all, I do agree with you that oil analysis is a good thing, and recommend it to all of my customers.

 

As for the inspection items that FD does not list in their annual check list......My recommendation is to do them each and every time. To clearify, though, I am talking only about inspection stuff. If it says change hoses at five years, that is not an inspection, and therefore not required.

 

As I have tried to convey, (and not done very well apparently). A condition inspection is a whole aircraft inspection. The inspector is responsible for his/her certifying statement. Inspect the entire aircraft each and every time.

 

The regulations require inspections (Condition) annually or each 100 hrs. TIS depending on aircraft operation. There is no such thing as a 200 hr., 600 hr, or five year, or any other inspection for SLSA aircraft.

 

 

Also Roger, please post the replys from FAA as soon as you get them. I can't wait. Be prepared to give the name, contact info, and regulatory reference for your source though.

 

Doug Hereford

[Roger Lee]

Hi Doug,

 

I'm in Mexico until this coming Friday. So calls will have to wait. I have Rotax's answer, but the FAA will have to wait.

The FD maint. Check list is what you are following. It states in section 3.4 to inspect all systems as required by the Rotax maint. Manual. That locks you into the Rotax check list which has some different time tables. Following just the FD check list would make you miss items on the Rotax check list.

Since we are "certifying the entire plane" and hose is one of them and let's for fun pick the 5 year mark then one would have to pull all the hoses in fire sleeve to inspect them and then put them back on. You can't certify what you can't see. Do you pull all hoses in fire sleeve to inspect and certify them as safe? I just did a hose change last week and the hoses looked okay from the outside at its 5 year mark, but two of the coolant hoses where smashed on the inside from someone over tightening wire ties. Wouldn't have found it if I hadn't pulled the hose off.

 

So bottom line is where do you draw the line as to what and how far to inspect. From so of the inspections I have seen from non Rotax trained A&P's they only did about half an inspection and called it good and The documentation was even worse.

 

So where is the line to be drawn and how do you get everyone inspecting the same items and in any detail?

[Doug G.]

The regs (FAR 91.327) says, "The aircraft is maintained...in accordance with the applicable provisions of part 43 ...and maintenance and inspection procedures developed by the aircraft manufacturer... "

FD has the authority via the industry consensus standards and if they say follow Rotax on a particular issue that is a part of the FD checklist and must be followed.

As far as oil analysis, have you ever done work on a Rotax based on stuff you could not see in the filter or on the mag plug?

[Roger Lee]

Hi Doug g,

Thanks,

That's my point is FD says to use the Rotax check list for inspections. It has certain times and different items than the FD list, plus some duplicates too.

 

 

Except for once on a failed lifter which I knew would show up all through the engine the answer is no, I have never really found anything in the filters or the mag plug. There have been some that have found slivers and chunks on mag plugs. These engine are more like motorcycle engines than air cooled aircraft engines and you don't tend to normally have issues with those either.

[Doug Hereford]

Roger, and Doug,

I fully agree that one has to use the FD checklist when performing a required inspection, and when the aircraft checklist sends you to the Rotax checklist, then it (Rotax checklist) must be followed as well.

 

An inspection checklist is nothing more than a list of items to be inspected. When FD, or any manufacturer puts other items in their checklist, like due times, and minimum certification levels, these additional items are NOT a part of the inspection procedure, and therefore not regulatory. In fact, as with the FD inspection checklist, there are numerous instances where FD apprears to allow a pilot to perform certain inspection items. This is actually contrary to regulation, as pilots are not authorized to perform any required inspection (pre-flights are technically not required inspections).

 

As for the additional inspection items that you referenced Roger (200 hr, and 600 hr.) I would do them as a part of every condition inspection.

 

As for the hoses change example that you gave above. Again, you made a very good find on the damaged hoses, but the problem that you uncovered was due to an improperly installed tye strap, and not age of the hose. How long had that tye strap been in place? My bet is that it had been there a while (maybe through one or more Condition inspections). Fire sleeved hoses have been around for decades. As far as I know, there has never been an inspection practice requiring removal of sleeving during any inspection. There are however numerous hose AD's out there that address certain specific unsafe conditions related to hoses. If FD is really worried about their hoses, they need to issue a Safety Directive mandating necessary corrective action (hose change at 5 years for example).

 

I agree with Roger, in that I have not found any unusual amounts of contamination in filter media or magnetic plugs. The advantage of oil analysis comes from trend establishment. Analysis results are kind of like an oil signature for the engine. The significance is not in the minutia of the values, but in noted major changes that occur as internal components wear. Oil analysis is not a substitute for proper inspection practices, it supplemental to them. It is also fairly inexpensive.

 

Doug Hereford

[Philip Welsch]

Do you actually pull the wings every year?

 

PRW

[Roger Lee]

Hi Philip,

 

Do you mean every two years or 600 hrs which ever comes first?

[Doug Hereford]

I would pull the wings and inspect the pins at each condition inspection.

One might be able to consider borescope as a possible alternative to the wing pull, but I don't think it would be as good due to the nature of carbon fiber. Tap test is better. Also I would want a procedure from FD first.

Doug Hereford

[Doug G.]

Hmmm...I am going to look into the owner items - it makes sense that if the owner can do them, the person doing the annual should not need to, but that doesn't fit the rules since an LSRM cannot supervise anyone.

[Roger Lee]

The wing pull is cited in the FD inspection list and confirmed by Tom P. to be done every two years or 600 hrs which ever comes first. I'm getting ready to ask FD for 3 years since nothing has been found. Under section 3.6 of the inspection list it says an LSRM-A must do the wing pull and inspection.

 

The more often those wings get pulled and shoved back on and the pins yanked in and out the higher the possibility of causing something to become loose fitting.

[Doug Hereford]

Roger,

I do agree, that repeated disassemble of things in general can cause problems. In this case though, It appears to me that FD designed the wing installation to allow for quick and easy removal. An unfortunate side effect of this is that some of the attachment features (pins) are hard to properly inspect without at least a partial disassembly. I also would be concerned with corrosion in these areas without proper grease applied. Since the wing is strutless, it appears to depend greatly on the pins for prevention of movement due to twisting moment. I don't think that complete wing removal is necessary for proper inspect, but it must be separated from the root enough to allow for full visual inspection of the pins, and re-application of grease.

I woud also perform a tap test of the root rib to insure no hidden delam, especially near pin mounting bases.

 

With a fabricated jig on wheels, and some practice, I bet one or two people could do all of this fairly quickly. It goes without saying, that wing attachment is critical to safety. I will personaly want a look at these items at each Condition inspection before certifying the aircraft as safe. It would be dangerous to assume that previous inspections coved this requirement, and there may be no outward evidence of damage due to turbulence, over-weight/hard landing or rough ground handling.

 

Also, I will say again, that pilot/owneres are NOT authorized to perform any part of any required inspection (SLSA or otherwise). Regardless of what FD states in their manual, the federal regulations (FAR's) are the controlling rules with regard to who can do what maintenance-wise. Consensus standards do not give SLSA mfg. any additional authority here.

 

Doug Hereford

[Roger Lee]

I use two 6' ladders to support and pull the wings. I can do it by myself, but it's more of a pain. Much easier with two people. When I pull the wings sight tubes are always changed no matter what. Depending on what you are doing the wings can be pulled out about 15" without disconnecting any wires or tubes. This makes it easy to just replace sight tubes, take care of leaks at the bulkhead or replace the short rubber fuel line. Because of the way the rectangle spares fit into their holes the wings can not tip off the ladders.

[S3flyer]

Roger,

Did you hear back from the FAA and Rotax?

 

[Roger Lee]

Hi Dave,

 

I won't be back from Mexico until late this afternoon. The call may have to wait till Monday.

[Doug Hereford]

Hmmm...I am going to look into the owner items - it makes sense that if the owner can do them, the person doing the annual should not need to, but that doesn't fit the rules since an LSRM cannot supervise anyone.

Dggrant,

 

The relevant reg here is FAR 43.3(d). As a repairman, you are allowed to supervise someone (pilot or other individual) performing maintenance that you are authorized to perform. You just need to fully understand FAR 65.107, and insure that you are in compliance with its requirements before supervising. However, FAR 43.3(d) does not allow the supervising of required inspections.

 

One of my points with regard the the FD inspection checklist relates to these very rules, in that even though the FD checklists have notations in them that authorize pilots/owners to perform certain inspection items, this is contrary to the above noted rule (43.3(d)). That is why I have said before, that FD has no legal authority to say who can perform mx. on the aircraft (inspections are by definition a type of maintenance).

 

Doug Hereford

[Doug G.]

I don't think so Doug H. If you go up to 43.1 ((2) it says part 43 does not apply to E-LSA part 21.191(i)(3) or SLSA part 21.190. Which leads you right back to 91.427 which does not allow for maintenance or inspection by anyone but a certificated repairman, or A&P. An A&P can supervise. A repairman cannot. At least that is my understanding of the rules - and what I was told in my training.

[Doug G.]

OK so b ) without the space is

It should be 43.1 ( b ) ( 2 )