FlyingMonkey Posted May 20, 2014 Author Report Share Posted May 20, 2014 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. That makes sense, thanks Tom. Link to comment Share on other sites More sharing options...
Doug G. Posted May 20, 2014 Report Share Posted May 20, 2014 Thanks, so it sounds the same as what I do as LSRM-A - follow the factory check lists. Link to comment Share on other sites More sharing options...
Tom Baker Posted May 20, 2014 Report Share Posted May 20, 2014 Thanks, so it sounds the same as what I do as LSRM-A - follow the factory check lists. Doug, for standard category you do not have to follow the manufacturers checklist. You have to follow a checklist, but it can one of your own. Like I said it must include the scope and detail of CFR 43 appendix D. Link to comment Share on other sites More sharing options...
Doug G. Posted May 21, 2014 Report Share Posted May 21, 2014 That is different from what Andy is saying. Thus the confusion. Do I as LSRM-A have to follow the manufacturer's list? (That is what I have been taught and follow.) Link to comment Share on other sites More sharing options...
Doug G. Posted May 21, 2014 Report Share Posted May 21, 2014 On my SLSA airplane? Link to comment Share on other sites More sharing options...
Anticept Posted May 21, 2014 Report Share Posted May 21, 2014 Hi Doug! Read your airworthiness certificate limitations section, that's where it tells you what you have to follow. S-LSA must follow manufacturer's inspection and repair instructions (note: doing a repair according to manufacturer instructions, and performing a repair as a result of an inspection, are two different things. The former is required, the latter is not). It will state this on the certificate. E-LSA and experimental will have the limitation that requires you to follow App D for condition inspections. Standard airworthiness aircraft usually don't state the requirements except for some regs. I don't have one in front of me right now to look at it. If the airworthiness certificate does not have a limitations section, then that certificate is VOID. You must contact your local FSDO to get a new one issued. I realize that I will be strongly disagreed with here, but the fact is that the wing removal inspection is technically/legally never required. I would disagree, because your airworthiness certificate says you have to follow the manufacturer's inspection instructions, or it is void. Link to comment Share on other sites More sharing options...
Roger Lee Posted May 21, 2014 Report Share Posted May 21, 2014 I agree that the wing inspection is required. Link to comment Share on other sites More sharing options...
FlyingMonkey Posted May 21, 2014 Author Report Share Posted May 21, 2014 Every two years...why not do the wing inspection? It's a bit of money and time, but wing attach points are kind of important. Is there any structural component you would *not* want to inspect at least every two years? Link to comment Share on other sites More sharing options...
Roger Lee Posted May 21, 2014 Report Share Posted May 21, 2014 It should take about 1.5 hrs to do. It isn't a game changer or a bank breaker to be done every two years. Here's part of the mind set problem. Too many don't want to do some maint. and many have different reasons. Some say too much maint. causes problems, some say it cost too much, some just say you can't make me do it for no good reason. This one always gets me because they want to skirt any law or rule with any loop hole possible. The big but here is as soon as something goes wrong related to that omission of maint. regardless of the reason "obvious good reason" (sarcasm) every single person will point a finger and say why didn't you do it or make me do it. Then of course the mechanic gets sued whether he was on board with the original bad idea or not because certainly someone has to be at fault for a poor decision which didn't seem like a bad idea to start. It should be thought of as a safe and "best practice" issue. Not viewed as "How can I get out of this". We have all been guilty in our decisions some time or some place and it becomes a crap shoot hoping nothing will happen, but it does happen at times and we have all been there at sometime in our lives when we wish we had done something a little better and not try that end run. I have changed over the years because of my job as a fireman. Without these people there wouldn't big as big a demand for the fire dept., medics or police. It has become job security. Mind set for safety is everything. How is your mind set today? Link to comment Share on other sites More sharing options...
Doug G. Posted May 21, 2014 Report Share Posted May 21, 2014 I do what is required and a bit more. The only thing you and I disagree on Roger is the usefulness of oil analysis, and the need for constantly speeding money on recurrent training from Rotax. (There are not that many LSRM-As that see anywhere near the number of engines that you do. Recouping the costs can be an issue.) I have tried to understand some of the arguments put forth that seem to say the opposite of what we are told by the people who were involved in setting up LSA. 1) I don't think they are right, and 2) I will follow the manufacturer's recommendations and lists, as well as the FAAs rules anyway. I agree with you that an attitude that seeks to skirt or avoid doing things the proper way is not good and can only lead to problems. Link to comment Share on other sites More sharing options...
Anticept Posted May 21, 2014 Report Share Posted May 21, 2014 To be fair, some of it stems from mistrust of manufacturers. They are in a powerful position once you buy their plane. We're fortunate that the FAA has the PMA and STC system in standard aircraft, because it keeps the manufacturer from having a complete monopoly over the aircraft, but still allows safe aftermarket parts. Before I continue, there's something I need to put forward. I think cessna aircraft are alright. It's the company that is garbage. Cessna has, multiple times, tried to stiff customers. I am just going to give the example related to PMAs. The windshields for the Citation series aircraft were produced here in Ohio, and the contract got cancelled because the profit margins weren't high enough (they moved manufacturing somewhere else). That company went to the FAA and got a parts manufacturing authorization, and now sells those windshields for a fraction of the cost. Because of this, Cessna decided that anytime a citation was found with that company's windshield installed, they would refuse to service the airplane until the windshield was replaced. Lawsuits abound result, and prices go up. Anyways, that's the one thing that worries me about S-LSA, they DO have the monopoly over their aircraft parts and procedures. If flight design becomes a powerhouse leader, will their customer support still be the same? Link to comment Share on other sites More sharing options...
Doug Hereford Posted May 21, 2014 Report Share Posted May 21, 2014 Anticept, It's is back to the WHO, WHEN and HOW components of aircraft maintenance. The SLSA regs and limitations DO NOT require one to follow manufacturer inspection "instructions". They require following the maintenance and inspection "procedures". A procedure is the HOW component. When FD says in their manual to remove the wings and inspect every 2 yrs. or 600 hrs. they are speaking to the WHEN component, and this is not their within their authority. Anticept, you stated earlier that AFS610 affirmed that TBO's are not mandatory. This is correct because again, TBO's speak to the WHEN component. Same for the infamous "Rotax training requirement". This is not regulatory either because it speaks to the WHO component. The only thing that the manufacturer has control over (by way of the rules) is the HOW........or "procedures". FD does not get to say when to change hoses, or pull the wings, or what training is required, (other FAR's do these things). When maintenance does need to be performed, FD then must tell HOW that maintenance is to be performed. The only option FD has to extend its authority to the WHEN component is by way of a Safety Directive. So if they feel strongly that the wing removal and inspection has to be done every two years or 600 hrs. then issue a Safety Directive to the effect, and there will be no wriggle room. I stated that the wing removal and inspection is not legally required. What I mean is that a stand-alone 2 yr. 600 hr. wing remove and inspect task is not legally required. There is only one inspection required on SLSA.....................Condition inspection. So if an operator says that their wing inspection is going to go past two years, before their next condition inspection is due, my advice to them is to fly on, and have the wings pulled at the Condition inspection. They will have broken no rules. The converse is that if an operator brings me his plane for Condition inspection and tells me that he has just had the wings pulled and inspection done 3 months ago, I will regretfully inform him that I will not be able to sign off the Condition inspection unless I am able to pull the wings and inspect them myself. Think about it this way, he just had the wings pulled and inspected three months ago. Maybe it was done in conjunction with some other work that required wing removal. Either way, should I just trust that everything was, and is still ok, and certify the aircraft? I would not do that. When it comes to inspections, one should be very careful about accepting another's word for anything. Repairs and component replacements are another matter. Either way, I am not passing judgement on anyone else's position on inspecting the wings. My personal position is that while the stand-alone 2 yr 600 hr requirement is not regulatory, I will have to pull and inspect wings that attach the way the CT wings do, at each Condition inspection. I realize that I probably won't have a line of CT customers by doing this. I won't require arbitrary 5yr. hose changes either, so maybe it balances out. Doug Hereford Link to comment Share on other sites More sharing options...
Anticept Posted May 21, 2014 Report Share Posted May 21, 2014 Hi Doug! That's an interesting perspective on the matter! I an going to do more research and get some confirmation on what you said. By the way (and this is to everyone), I do enjoy debate, and I mean no disrespect to anyone when it comes to understanding the FAA regs, I just like to analyze them in depth, even though for most people it is overkill Link to comment Share on other sites More sharing options...
Doug Hereford Posted May 21, 2014 Report Share Posted May 21, 2014 Anticept, No worries from me. I make the assumption of this forum and in general, that EVERYONE is interested in safety first. Understanding and following the rules promotes safety, and that is good business. Inferences about cutting corners, loop holes, or mediocrity are counter productive (I know you haven't inferred any of these). My perspective on this matter is not new. This same debate has been vetted out in other portions of GA for years. SLSA is just kind of cutting its proverbial teeth right now. Like you eluded to, the last thing any of us wants to have happen, is manufacturers, or any individual getting too much authority. Prices will sky-rocket. Plus, as time goes on, it will be the field that knows the most about maintaining these machines, not the manufacturer. After all they manufacture, we maintain. As for advice from the FAA, I am very careful what I believe from that organization. They don't maintain aircraft either. Doug Hereford Link to comment Share on other sites More sharing options...
Roger Lee Posted May 21, 2014 Report Share Posted May 21, 2014 If the wings were done 3 months ago and logged in the book by an appropriate mechanic then he is on the hook because wings aren't required every annual. That's saying that if I have a plane come to my shop from you and you logged an annual I shouldn't trust you and the logbook means nothing and I should do it all over. Part of the other problem over the last few years is that aircraft Mfg's have been wrong, the FAA has been wrong, mecahnic's have been wrong and owners have been wrong in some of the interpretations and the language has not been precise. For all intents and purposes LSA is the new kid on the block and it has growing pains. Pulling wings too often may cause loosening in close tolerance parts. I have seen some wings that can move fore and aft with free play.. "Inferences about cutting corners, loop holes, or mediocrity'. I do infer these (not at anyone here) because these are a part of our society and I see it all the time in all walks of life and so have all of you. It would do no good to pretend they don't exist or play a part in aircraft maint. It's just like buyer be ware, but can also mean owner beware of mechanic. They are out there. For every top 1% of the best mechanics there are the bottom 1%. Link to comment Share on other sites More sharing options...
Anticept Posted May 21, 2014 Report Share Posted May 21, 2014 Intents At least you didn't say "intensive purposes"! Link to comment Share on other sites More sharing options...
Roger Lee Posted May 21, 2014 Report Share Posted May 21, 2014 Fixed, thanks. :blush: I hate being illiterate as an adult. It gives me nightmares of third grade. Link to comment Share on other sites More sharing options...
FastEddieB Posted May 21, 2014 Report Share Posted May 21, 2014 Just don't loose your sense of humor! Link to comment Share on other sites More sharing options...
Doug Hereford Posted May 21, 2014 Report Share Posted May 21, 2014 Roger, The problem I have with your logic on the wing inspection is this: If I perform a Condition inspection, I am "On the Hook" for the ENTIRE aircraft. If inspecting the wings is a safety issue, then I have to inspect them myself. It is obvious to me that FD does not understand this concept (FAA has not made them understand). That is why they have these "special" inspection items that fall outside of the Condition inspection. Condition inspections need to be clearly defined. So far, the FAA has not forced them to be. This leaves all of us "On the Hook". So for now at least, I will exercise my right to not certify an aircraft unless I feel that I have performed a complete inspection (add BRS to the list as well). I'm not sure I follow your example of the plane in your shop after my Condition (you said annual) inspection. If the plane is in your shop for a Condition inspection anyway, then I agree, you should not trust me, and do it all over. Otherwise it would be in for some other type of maintenance, and performing a condition inspection would seem inappropriate and likely unauthorized. Your are right, there are corner-cutters every where, but I think you know what I meant. Doug Hereford Link to comment Share on other sites More sharing options...
FlyingMonkey Posted May 21, 2014 Author Report Share Posted May 21, 2014 If the tolerances in wings get wide, how can that repaired? Link to comment Share on other sites More sharing options...
Anticept Posted May 22, 2014 Report Share Posted May 22, 2014 Washers are one way. I do not want to think about the nightmare of a repair required if the pins cracked though. Link to comment Share on other sites More sharing options...
Roger Lee Posted May 22, 2014 Report Share Posted May 22, 2014 Anticept is right on the washers. You have two alignment pins that protrude out of the wing side into the fuselage side. You place a washer over the pin then slide the pin assembly back in place. The washer will take out the fore and aft free play. Link to comment Share on other sites More sharing options...
FastEddieB Posted May 22, 2014 Report Share Posted May 22, 2014 Recalling what I know about "dissimilar metal corrosion"... ...best to point out that not just any washer will do! Link to comment Share on other sites More sharing options...
Roger Lee Posted May 22, 2014 Report Share Posted May 22, 2014 Hi Doug H, First please know there is no disrespect here just throwing this debate around a little. I'm also not sure why you feel the wings have to come off every annual? You have FD's specs for this in writing for every other annual, backed by their own admission which would carry you in court or with the FAA, plus this is the standard of care which you would be judged against in any legal action. What I meant was, if you don't trust the guy who just did a wing inspection prior to yours and want to do it again then why shouldn't I distrust the last annual that might only be two months old and do it all over again? Where would this finally stop? Each person would always redo the last guy's work. Once in the logbook (a legal and more or less binding article that you performed the work to proper standards) why not leave it alone unless something of course is glaringly wrong? Link to comment Share on other sites More sharing options...
Doug Hereford Posted May 22, 2014 Report Share Posted May 22, 2014 Roger, What I am trying to say is that in my opinion, the wing inspection is part of the aircraft Condition inspection "procedure". Not pulling the wings and inspecting them at every Conditon inspection is (in my opinion) an incomplete aircraft inspection. This is how I keep coming back to the fact that SLSA aircraft only have ONE required inspection. We as inspectors, "have to make it count", so to speak. Whether any of us likes it or not, this is the system in the country. FD has not been made to understand this. They obviously think that pulling and inspecting the wings is important. That is why they included a requirement to do it. I also think it is very important. It is just that they (FD) have tried to specify WHEN it is done, and that is not their job. Inspections are the absolute most critical maintenance tasks that we perform, because they are done to discover unsafe conditions. Repairs are the maintenance tasks performed to correct these unsafe conditions. Preventive maintenance tasks are performed to prevent unsafe conditions. Arbitrary replacement or overhaul of parts just because the manufacturer says to, doesn't even rank in my book. If a plane comes into your shop Roger, likely the owner has contracted with you to perform some type of maintenance. Maybe his main tires are worn-to-limits (unsafe condition discovered on pre-flight INSPECTION), and he wants them replaced. This would constitute a repair maintenance task. As a maintenance provider, you may want to take a cursory look at his historical maintenance records (good business). Say you notice that his Condition inspection was performed by me (and aircraft was approved for return to service) two months ago. This has no direct bearing on the maintenance that the owner has asked you to perform. You are simply making a repair. Even if I am known to "cut-corners" on my maintenance, if you suggest to the owner that you do not trust my inspection, and that it needs to be repeated, the next thing you see is likely to be the rudder of a plane with two bald tires, flying away at a high rate of speed. If the same aircraft comes into your shop, and the owner says that he is due for, and wants you to perform his Conditon inspection. You perform the necessary records research, and see that the last inspection was done be me 12 months ago. You should then not trust a word of my inspection, and perform a full Conditon inspection youself. If this same aircraft had come into my shop for a Condition inspection, and in the course of my required records research, I see where you had pulled and inspected the wings 2 months ago, I would unfortunately have to repeat this task because for me to perform a complete aircraft inspection (and certify the aircraft as safe), it must be done. I am not worried about being sued, or warranty, at this point. I am simply performing what I believe to be a complete aircraft inspection using the manufacturer's inspection procedures. I'm also aware of the fact that the manufacturer apparently doesn't fully "get it" with regard to our maintenance system in this country, and am carefully crafting my work scope (with the owner's prior permission) to comply with the law even though the manufacturer has not. Doug Hereford Link to comment Share on other sites More sharing options...
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