12 year mandatory overhaul

[Anticept]

Doug: I know of one where an oil hose has to be a certain type with fire sleeving and I'm sure that's the one you're talking about. But I've also heard, admittedly only through others, of one on a piper aircraft where there are several hoses with those life limits. Having said that and realizing I've not actually read such an AD, I probably shouldn't have said anything about it.

As for hoses: I've removed hoses on a Rotax on the 5 year where they were very stiff, and the end of the hose would crumble with a hard twist. The rubber used doesn't seem to hold up very well with age or exposure to elements.

[Doug Hereford]

Anticept,

My point was that the FD hose change requirement should be looked at in the same way as the engine overhaul requirement. If changing all the hoses on FD rotax aircraft arbitrarily every 5 years is really a safety of flight issue, it should be made a Safety Directive......................................in the same way that AD's very specifically require actions to correct very specific unsafe conditions.

In the Piper oil cooler hose AD, there were 26 reported incident/accidents, and 24 SDRs submitted from field A&P and repair station mechanics, in an eight year period. It is quite possible that some of those incidents were off field landings. Had those gone unreported (self rescue maybe) or had diligent mechanics not submitted SDR's in the other non-operational cases, the AD may have not been issued and injuries could have resulted. It is well to note that once an owner has the proper TSO'd hoses installed correctly on their aircraft, the AD is no longer applicable (no further life-limitation to the oil cooler hoses at all).

I ask again of all the guys who routinely perform this type of maintenance.........................

How many off field landings or flight plan changes have occurred after arbitrary changing all the hoses and subsequent debris induced into the fuel system?

How many off field landings or flight plan changes have happened due to NOT changing all of the hoses? And of these, how many were actually due to a problem with all of the hoses on the aircraft that could not have been detected with proper inspection techniques at the aircraft's required "condition inspection"?

It is absolutely amazing to me that there is a video on the internet showing pilots how to perform "self rescue" maintenance on their aircraft after an off field landing due to debris in a carb bowl. That maintenance task is absolutely not within a pilot's privileges as an airmen operating an SLSA................................................................. which is the least worrisome fact in that scenario. I am left to assume that off field landings due to carb debris are common enough that someone thought that it was a good idea to create a video which clearly shows maintenance tasks being performed to correct what could possibly be a symptom of some unknown larger problem, and then to imply that anyone can do it to "self rescue". Any pilot who performs the procedures shown in this video on an SLSA that he/she just landed in a field due to power loss should take a serious gut check because it is highly unsafe, and correspondingly, completely illegal.

What is next I wonder, a self rescue engine overhaul?

[Roger Lee]

" it should be made a Safety Directive"

So you're proposing more regulation to protect people from themselves.

I don't see it that way. There are many "Best Maint. practice"  items that aren't flight issues, but should be done. With this Safety  Directive thinking why not make oil changes,  plug changes, gearbox friction torque test,  brake pads, ect.. mandatory at a specific hour. If left long enough they can cause engine issues and bring a plane down. Why change tires, why not wait until one  goes flat.

Smart and intelligent maint. practices should be common sense and not need more regulation that affects  everyone else to make some sloppy owner or mechanic maintain their aircraft from hurting themselves and someone else.

Why do helicopters have timed maint. Because some idiots would go until more fell out of the air and killed people.

You shouldn't have to mandatorily regulate good maint. practices into someone's head. A few people will always cause the rest more aggravation  from being over regulated because they just don't get it. 

Why do we have so many laws and regulations in everything we do with more coming everyday. The few  cause the rest of us grief.

"It is absolutely amazing to me that there is a video on the internet showing pilots how to perform maintenance"

Then you should be really offended by all the Rotax owner videos.

Have you EVER watched any video on maint. they you were to preform? 

" Any pilot who performs the procedures shown in this video on an SLSA that he/she just landed in a field due to power loss should take a serious gut check because it is highly unsafe, and correspondingly, completely illegal."

With this thinking you think owners are too dumb to dump a bowl and not be left stranded? You're right you could just sit there and do nothing and or let another non educated mechanic that knows nothing about your Rotax try and figure it out.  Your plane and you could sit at some oddball airstrip for days when 30 minutes of your time puts you back on your way. You can be proactive and educated or just another helpless victim. 

I know many of these pilots here and I fully believe all of them are smart enough and proactive enough to handle this minor situation.

No Thanks. There have been many that have self rescued themselves on continued on home. Dumping a carb bowl isn't rocket science  and not an invasive procedure.

You do what you need to do when things aren't in a nice neat package sitting at your mechanic's shop.

[Roger Lee]

I think we should regulate more mechanics while we're at it. They don't know what the correct plug gaps are, they rotate the prop to get more oil out after the system has been drained, they use the wrong type of clamps,  they don't know how to check the gearbox for friction torque, they don't know what a magnetic plug is or when to check it, they have no clue where the fuel filters are, they rarely ever balance tires, they don't know how to set a prop pitch. They have no clue where to find SB's for the aircraft or engine and they have no clue where to find nor do most use a maint. manual or checklist so they miss half the items.

And don't even get me started on the 2-3 liner garbage logbook labels. The FAA considers those the bottom 1%, but legal. How unfortunate for the owner.

Most engine and aircraft issues are "MIFs". Mechanic induced failures. So we don't need to abandon and disregard good and best maint. practices. We need to educate mechanics and owners to proper procedures.

Just had a CT in and looked at the logbooks. Looks like the last two annuals were nothing more than general maint. on just 3 items. You don't even know if it was the annual for sure. That mechanic is hanging in the wind.

You can regulate everything and we should start with all the above with the mechanics. 

[Ed Cesnalis]

1 hour ago, Roger Lee said:

" it should be made a Safety Directive"

Your read it wrong Roger Doug isn't advocating more regs.  He said "if"

[Tom Baker]

Roger, Doug is on our side. He doesn't think that the hose change should have a mandatory hard 5 year date, rather it should be on condition. The same for engine overhaul. When he said "it should be a safety directive", he meant if it is truly a safety of flight issue then it needs to be safety directive. He is not implying that it is a safety of flight issue.

[Doug Hereford]

The topic of overhaul requirement time limits are really a symptom of the bigger "required vs mandatory" discussion that has gone on and on. I mention Safety Directives in this thread because it directly pertains to the mandatory side of things. I  mentioned the Piper AD that was referenced by Corey earlier because it is an example of how an otherwise non-mandatory maintenance event is correctly made mandatory in an effort to enhance aviation safety.

As for the video, Roger you are DEAD WRONG here, but I will make this concession to placate you:

Pilots, if you do perform this illegal maintenance on your aircraft to self rescue, please properly document your action in the maintenance records for your aircraft, and do so before you depart from the field or road. This is already required by regulation. I have to warn that you will be incriminating yourself by doing so, but it will save the poor inspector that performed your last condition inspection. See, his entry may very well be the last one in your records prior to the "self rescue" event. This way when the FAA and NTSB come to investigate, if there is anything left of the records, they will be able to discover why the carburetor bowl fell off, and not pin it on the poor inspector.

[Tom Baker]

Doug, I have performed several rubber replacements. I have one aircraft that I have done twice. I have had zero issues with carb debris on aircraft when I have performed the replacement. I did have one customer with an off field landing due to rubber debris, but I had not performed the rubber replacement.

I have found some issues during rubber replacements that I had not found during condition inspections.

[Doug Hereford]

Tom,

That's fair enough. Do you think in your experience that rubber changes need to be made mandatory?

Maybe I don't have my facts straight, but there seems to be a lot of discussion about how the 5 yr. rubber thing is vitally important to safety. It sounds to me like it might be. I have much more limited experience with Rotax, but I have changed hoses here and there do to inspection findings or pilot reports. I haven't seen chronic repeat issues on the engines that we have maintained through several thousand hours of operation. None of our aircraft have ever had a flight plan change due to hoses, but it seemed like this forum had a number of them in years past.

Like I said, maybe I got my facts a little wrong.

 

Roger,

Just for the record, I don't think that pilots or owners are dumb, and I am not at all against training videos for maintenance tasks. My issue with the aforementioned video is the context for which it is presented. I stand firmly on that, and the very bad situations that I think could be created by pilots using it as a "self rescue". Disassembling a carburetor is not a preventive maintenance task. Even if it were, a maintenance record is required, and I would have serious doubts about the aircraft safety unless I found the root cause of the debris, which the video does not speak to.

I gave the example above where a previously done condition inspection could be called into question by unauthorized and undocumented maintenance performed. To be fair, if the person using the video happens to be a mechanic or repairmen, they would be fine, so long as they document their work. I would still make the case for reporting to promote the continued airworthiness system of Safety Directives and/or Airworthiness Directives if the aircraft had an incident.

I am also not an advocate for needless regulation. But I am an advocate for trying to properly follow existing regulations whenever possible.

[Roger Lee]

This is such a sore subject matter to me because I see so much poor and wrong work done by supposedly "trained mechanics". They have all kinds of excuses. I don't know where to get manuals, what checklist,  what  SB's and I don't know where to find them, I don't usually see a Rotax or CT, if I don't write it in the logbook they can't get me if something goes wrong, why can't I do what I want, it takes too long to write all that in the logbook,  and the list goes on.

So you want to give these same people the authority to decide for someone that a hose is good or bad? No Thanks.

The video is not  meant  to target just CT owners.  That's thinking in the box. Experimental guys can do that without an issue. A lot more people have experimentals than SLSA. There are over 50K Rotax engines out there and most can do their own work.

"I am also not an advocate for needless regulation."

Needless regulation has usually been caused by mechanic and owner failures in history. So the government tries to protect those people and all the others that may fly in that plane unknowingly of what someone may not have doner correctly that may have put their life in danger.

If you want to stop more regulations then help educate everyone and stop people from making bad decisions that cause the rest of us more regulation.

Who decides if a hose is at an on condition state? The same people that can't get the other very basic things during an annual right.

How do these people see under fire sleeve? How do these people see under clamps and inside  the hose and under those clamps? How do you know the clamp wasn't applied too tight from the last guy and has been cutting into the inner liner? Most mechanics can't tell you if a hose is collapsing under the fire sleeve. happens a lot on a CTSW on the hose out of the cooler and back into the oil pump housing.

Some one had to draw a line in the sand from past hose failures and past mechanic and owner failures to recognise a potential problem. So these people that caused these initial issues had this 5 year replacement decision  made for the rest of us because of their failures so we all get regulated. Hose companies help make these decisions. They were made in a vacuum.

Too many would like to make maintenance reactive and not proactive. If there are problems with the maint. it should be blamed on a 5 year replacement program, but directly on the mechanic for failing to do a good job and not just a mediocre job.

The human factor is very unreliable because many let the wallet rule and fail to take preemptive safety precautions.

An owner that can change oil, spark plugs and other FAA owner approved maint. and If that person has been shown the way to pull the carb and look for debris they can be more qualified than many mechanics that don't have a clue. I see that proof in the pudding every week from A&P's that know less than the owner. I just did a pre-buy on an SW and because of the A&P mechanic it needs about $900 worth of repairs. I trust A&P's less than most owners. An owner will seek the correct way because they don't know. A mechanic does it without a clue anyway because he's been doing maint. work for 20-30 years.

 

Following the rules can be different than following regulations. The Rotax 5 year rubber is a rule by Rotax and aircraft Mfg's. A regulation for the same is making it legally mandatory.

 

On the carb debris issue I have a call into the FAA on their take on the procedure. I had to leave a message, it's Friday. I don't think bowl removal will be considered carb disassembly.

[Doug Hereford]

       

Roger,

I am not sure if I am understanding you correctly. If you are asking a leading question about whether I have ever been violated by the FAA, you are seriously out driving your headlights.

I see the FAA about once a month for normal surveillance and other oversight activities. This has been the norm for me for about 17 years due to the fact that I am DOM for two 135 charter certificates, operate a 145 repair station, perform and manage mx for the area's only 141 flight school, and perform/manage mx for numerous corporate flight departments and small part 91 operators in the area as an A&P IA. I also occasionally exercise my pilot privileges.

The FAA knows just where to find me. I have NEVER been violated by the FAA……………………ever. I have never had any kind of enforcement activity initiated against me or my employees.  I have never had so much as a verbal warning or written notice in my file.

None of this makes me an expert at anything, and I would not even post it were it not for your offensive inference.

I suspect that you are referring the ridiculous Rotax training issue that came up back in 2009. That whole thing was based on a bunch of misinformation put out by self-proclaimed experts in the field and some in the FAA. The only ones who conceded there were AFS 300 in Washington (not me).   Discussion threads like this one on mandatory stuff are likely due in large part to that very type of misinformation. I haven’t seen a lot of retractions or corrections though over the years.

Please report back to the forum about what the FAA thinks of the video on “self-rescue”. Had you asked my opinion ahead of time, I would have strongly advised you to take it down, and never go to the FAA about it, but looks like that ship may have sailed.

                                                                                                                       

 

 

 

 

 

 

 

[FlyingMonkey]

I know nobody asked me, but I have an opinion on "mandatory" maintenance.  I don't think ANY maintenance should be mandated on a light single engine airplane that is not used for commercial purposes.  Encouraged strongly, yes.  But mandated...no.  Let people who choose to do so assume the risk.  Just like people who defer maintenance on their cars.

However, I am a libertarian and do recognize I'm in the minority on this.  

[Doug Hereford]

Andy,

I do not think that you are in the minority. In my experience, when one really digs into what the GA regs. require, there is a lot of room for personal responsibility and judgment. At the same time, the general public has a very reasonable expectation of safety don't they? If you thought that I did not care about following the rules, would you be ok with letting your family fly with me in my FD? It is not unreasonable to have some level of oversight. I think that if one compares the system in this country to other developed countries, you would find that we allow a lot of latitude to the individual, and still maintain a very high level of safety.

 

Roger,

I am probably going to hound you for the results of your inquiry to the FAA on your "self rescue" video. I hope you just referred them to the internet link so that they can watch for themselves just like everyone else in the field would. I am sure that you will have something to report back with on Monday, if not before. Please feel free to actually read any/all of my posts on this site and quote them to your beloved FAA contact.

[Roger Lee]

Hi Andy,

Regulations get made to protect people from themselves due to poor or uneducated decisions and to protect others that fly with them. If there had never been issues through history we wouldn't have as many regulations as we have now. If more people do foolish things we can expect more regulations.

The ignorant few that hurt themselves and others due to their actions or inactions have laid the way for all the regulations that we now have. Judging from what I see weekly some certainly need those regulations and some are certainly wise enough to not need them, but a governing agency needs to draw the line in the sand because they can't oversee every decision so they make some of these regulations for the not so wise people. It's the way it's always been and I'm sure those few people will cause more regulations to be heaped upon us.

How do you decide who is smart enough and trained well enough to make those (at times) subjective decisions that may put other people at risk.

If there is a foolproof way to weed problem people out I'm sure everyone would like to know and get onboard. 

When drawing a line in the sand for safety decisions you try to error on the safer side vs the oops I waited too long side.

[Roger Lee]

I usually don't get into heated or vehement debates, but I'm passionate about doing to right maint. at the right time  and keeping my friends and clients as safe as possible. After being a firefighter 30 years and having to bail people out from not very bright decision making and  from what I have seen coming from other shops I'm pretty biased anymore..

[Doug Hereford]

Roger,

Glad you are listening. Don't forget to post your response from the FAA on your video. My customers have seen it too and have asked me about it, otherwise I wouldn't have known that it existed.

Resume time again.

A&P since 1990

Pilot since 1986

Coincidently, I am also in the fire service...................................Fire Medic since 1991 in Kansas City. WHO cares. Say something that makes sense and stop lecturing with half-truths.

Also, go back through all of your posts since day one and correct all of the misinformation that you have spread as fact. Then get with Carol Carpenter and have her do the same.

You are obviously a very competent technician and aviator, but some of this stuff is hard to stomach.

[Runtoeat]

We live in an age of marvelous technology.  Let's say I get stranded in some an abandoned airport in some God forsaken location.  Nothing around for many miles.  I see that at least I've got a cell phone signal.  I've got tools and I'm mechanically adept. How about "phoning home" and hooking up with my A&P with my smart phone that's got video and make a remote video supervised field repair?  If I'm lucky, it just may be a simple thing........like some dirt in a carb bowl? 

FAA-8083-30_Ch08.pdf

[Roger Lee]

"but some of this stuff is hard to stomach"

My medical training says Pepto Bismol or Prilosec will help.

[Doug Hereford]

Runtoeat,

Good news, you survived an aircraft incident. You may want to thank God (or whoever) that you have the option to appreciate cell phone coverage but if not, just sit tight. Help is on the way......................... Very appropriate attachment, and as I think you are aware, video supervision doesn't count.

Roger,

You may want to actually read the attachment. Things aren't always what they seem to be.

Be sure to update the group on what the FAA says about your "self rescue" video so that Runtoeat can get home.

[Runtoeat]

Doug, for my information, can a non-certified person perform inspections/maintenance on LSA aircraft when supervised by a certified A&P?  Is this approved for GA aircraft?

[Anticept]

https://www.ecfr.gov/cgi-bin/text-idx?SID=ca8b7dd123d6b832b2bbd4f851e79833&mc=true&node=se14.1.43_13&rgn=div8

See (d)

There isn't a definition for major repair or alteration in S-LSA as far as I know, but I have seen a light sport AC refer to procedures not in the maintenance manual as such, but I feel like it wasn't trying to use the regulatory version of "major", just poor wording.

Roger: I do agree it's rediculous how lenient things are on mechanics. But I've seen junk work from LSRMs too. Short log entries, amateur repairs, etc. In fact I've got a plane in the shop where the guy that did an avionics mod used tin snips on a metal backplate and didn't file off the razor edge, left burrs a quarter inch long, cut up the radio tray support and now the radios rest on the firewall as support, and used pop rivets a mile long and they are deformed like crazy. Plus all this use of vinyl electrical tape...

SomehowI think it's not so much the training as it is just people being lazy in general. But I won't completely discount a lack of proper training!

[Roger Lee]

"But I've seen junk work from LSRMs too."

Absolutely. Wait until I post the last two entries from planes I just saw. What are people thinking or not.

[Doug Hereford]

Runtoeat,

I think Corey posted the link to the relevant reg. 43.3(d). To me, the important details in that rule are: Supervisor must have prior experience with the work that he/she is supervising. The supervisor must be physically there, and required inspections cannot be supervised.

If those conditions are met, then a non-certificated person can perform maintenance.

Another detail to remember in the case of the self rescue scenario is that even if a pilot were supervised disassembling and cleaning float bowls, the aircraft still has to be approved for return to service after they PERFORM the supervised maintenance. This would be done by the supervisor, and must include a maintenance record entry. So if I were to supervise you, we would need to make a maintenance record that has all of the items in FAR 43.9. I would be the one that actually approves the aircraft for return to service when I sign the entry.

I was corrected on this forum years ago with regard to LSRM supervising maintenance. Although the regs. are a little vague, the Light Sport rule preamble clearly states that LSRM are not allowed to supervise. I have a personal problem with this, but nonetheless, I was incorrect in my initial thoughts back then.

[Doug Hereford]

Another thing about supervising that is interesting to me. I generally looked at the supervising provision in the regs. and thought of it as a nice perk. I think that it may have had a more practical intended purpose.

As an example: When installing solid rivets, may times one person cannot access the manufactured head, and the tail at the same time. Obviously two people are then necessary to install the rivet. Driving the manufactured head and bucking the shop head are both critical functions, and both are arguably maintenance functions. Once the work is done, only one person signs the maintenance record entry though. It would seem to me that the other person would have therefore been supervised technically speaking.

Installing larger flight controls and some torqueing operations would be another example.

Basically anytime two or more people are simultaneously performing maintenance subtasks, supervising is necessary.

[Tom Baker]

7 hours ago, Runtoeat said:

Doug, for my information, can a non-certified person perform inspections/maintenance on LSA aircraft when supervised by a certified A&P?  Is this approved for GA aircraft?

An A&P can supervise maintenance, but not inspections.