Runtoeat Posted February 10, 2017 Author Report Share Posted February 10, 2017 The following is an excerpt from a legal interpretation issued by Mr. Paul Greer, Office of the Chief Counsel, FAA, which pertains to "manufacture's recommendations" pertaining specifically to Rotax. Note in particular the part of footnote 1 which deals with the lack of an Airworthiness Limitations Section which normally is found in an aircraft's Airworthyness Operating Instructions. LSA aircraft do not contain Airworthiness Limitations sections. So, the mechanic is allowed to "...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, and practices acceptable to the Administrator. (Underlining and bold done by me). The full text of Mr. Greer's letter is attached. Mr. Charles WillettePresidentDodge Center Aviation, LLC802 South Airport RoadDodge Center, Minnesota 55927Dear Mr. Willette: This responds to your e-mail dated March 14,2013 in which you requested a determinationas to whether information contained in the maintenance manuals for aircraft issued specialairworthiness certificates in the light-sport category (S-LSA) is mandatory. You specificallyquestion whether component replacement and engine overhaul times specified bymanufacturers as being mandatory must be complied with. The rules applicable to the performance of maintenance, preventive maintenance, rebuilding, and alteration of S-LSA are contained in part 43 of Title 14, Code of Federal Regulations (14 CFR). Section 43.13 sets forth the performance rules applicable to persons performing work on these aircraft. Paragraph (a) of that section specifically states that: Each person performing maintenance, alteration, or preventive maintenance onan aircraft, engine, propeller, or appliance shall use the methods, techniques,and practices prescribed in the current manufacturer's maintenance manual orInstructions for Continued Airworthiness prepared by its manufacturer, orother methods, techniques, and practices acceptable to the Administrator,except as noted in § 43.16. I Part 43 does not mandate that a person specifically perform maintenance, alteration, or preventive maintenance solely in accordance with those instructions specified in a manufacturer's maintenance manual. It also permits a person to perform such work in accordance with other methods, techniques, and practices acceptable to theAdministrator. I Section 43.16 refers to Airworthiness Limitations. A person performing an inspection or other maintenancespecified in the Airworthiness Limitations section ofa manufacturer's maintenance manual must perform thatwork in accordance with that section or as otherwise specifically approved by the Administrator. Maintenancemanuals for S-LSA do not have an Airworthiness Limitations section to which the provisions of this sectionwould apply. greer legal interpretation-2013.pdf Link to comment Share on other sites More sharing options...
Roger Lee Posted February 10, 2017 Report Share Posted February 10, 2017 Also if you read some of Rotax's service bulletins it says or equivalent. So you have to read all the service letters, service bulletins, service instructions because some of those supercede what's in a book. Rotax usually only updates books once a year. Is it tough to be 100%, yes, but most of us do a fine job without any hitches. Link to comment Share on other sites More sharing options...
WmInce Posted February 11, 2017 Report Share Posted February 11, 2017 . . . what does "refer" mean here in a legal context?. . . That stands for reference. That "reference" term means a source document with authority. Link to comment Share on other sites More sharing options...
FlyingMonkey Posted February 11, 2017 Report Share Posted February 11, 2017 That stands for reference. That "reference" term means a source document with authority. Right, but authority in terms of technique, or legally binding to the owner/operator? Not trying to be obtuse, I'm genuinely curious. Sourcing acceptable methods and conferring a legal duty to use those methods are different things. Link to comment Share on other sites More sharing options...
ct9000 Posted February 12, 2017 Report Share Posted February 12, 2017 This is typical thread creep caused by someone who wants to nit pick, give it a rest guys. You are both right and you both know it. We were talking about float bowls. Link to comment Share on other sites More sharing options...
Tom Baker Posted February 12, 2017 Report Share Posted February 12, 2017 This is typical thread creep caused by someone who wants to nit pick, give it a rest guys. You are both right and you both know it. We were talking about float bowls. You can call it nit picking if you want. As someone who has been working in the aviation maintenance sector for almost 35 years I feel it important to speak up when someone who is respected within the light sport community offers advice that goes against the manufacture's recommendations and standard practice within the aviation community. Link to comment Share on other sites More sharing options...
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