A question for the FAR Gods

GlennAB1 said:
In other words, don't try this at home, your results may vary, and, not all part 91 operators may be able to do this.
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It never hurts to ask, if that sort of thing is desired, and most 91 operators don’t NEED to do this.
 
Bell206 said:
Also, I’m sure you were just paraphrasing your friend...
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No, I actually copied and pasted his response, with his permission, of course.

No dog in this fight. I was just repeating what I remembered learning in an FAA-sanctioned course.

And to me, it’s logical. An airplane that remains in service during an annual continues to compile wear and is susceptible to damage within the interval from beginning to end. That would render a sign-off at the end of said “progressive” inspection speculative at best as to its airworthiness at that time.
 
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GlennAB1 said:
Again, when does the 100 hr. clock start?[/QUO's
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Glenn:
Good question. If the IA is using the same checklist and plans to sign off an annual and 100hr, then he would have to deduct the amount of time flown since start of the inspection/maintenance. If flown 20hrs then next 100 hour would be due in 80 hours.
 
Greg Bockelman said:
It never hurts to ask, if that sort of thing is desired, and most 91 operators don’t NEED to do this.
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Greg:
I've learned more about the FARs and the workings of the FAA through researching answers to questions offered by my GA customers than all the years working for a large 135 ops and consultant.
 
FastEddieB said:
And to me, it’s logical. An airplane that remains in service during an annual continues to compile wear and is susceptible to damage within the interval from beginning to end. That would render a sign-off at the end of said “progressive” inspection speculative at best as to its airworthiness at that time.
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That is my point exactly. The sign off is a lie because the condition of the airplane is not known.
 
timwinters said:
That is my point exactly... because the condition of the airplane is not known.
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Fast and Tim:
This unknown condition as stated is a valid point within this discussion. However, when put into a larger context it becomes lost.

In this discussion the IA performs the annual work over the course of its due month and allows the plane to fly during the same period. The collective stance is the plane could sustain unknown damage during this period thus rendering the annual sign off false. The exception here is there is no obvious regulatory violation in performing the inspection in this manner and the issue of a bad sign off is only based on a possibility and not known fact. But for some this is unacceptable.

Yet in the bigger picture, the pilot owner of this aircraft picks up the plane from this IA and on the next day tweaks the wing tip on the hangar door. Nothing major but there's obvious minor damage. Since the annual was just done he makes the decision to continue to fly. The following week he's still ****ed about wing tip but forgets to close his pilot door and the wind blows it open causing a small crack in the window. Now livid he adds that item to his "next annual" list. The exception here is he is operating his aircraft with known damage in direct violation of several FARs which in effect "invalidates" the aircraft's airworthiness certificate. Yet this would be acceptable to most.

I've always been amazed how one simple question can open a dozen can of worms.
 
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Bell206 said:
Glenn:
Good question. If the IA is using the same checklist and plans to sign off an annual and 100hr, then he would have to deduct the amount of time flown since start of the inspection/maintenance. If flown 20hrs then next 100 hour would be due in 80 hours.
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Think there's a reason why Tom avoided that question?
 
GlennAB1 said:
Think there's a reason why Tom avoided that question?
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No clue. But if one were to sign off an annual as discussed AND sign off a fresh 100 hour based on the same inspection event one might find themselves on a slippery slope.
 
Bell206 said:
Fast and Tim:
This unknown condition as stated is a valid point within this discussion. However, when put into a larger context it becomes lost.

In this discussion the IA performs the annual work over the course of its due month and allows the plane to fly during the same period. The collective stance is the plane could sustain unknown damage during this period thus rendering the annual sign off false. The exception here is there is no obvious regulatory violation in performing the inspection in this manner and the issue of a bad sign off is only based on a possibility and not known fact. But for some this is unacceptable.

Yet in the bigger picture, the pilot owner of this aircraft picks up the plane from this IA and on the next day tweaks the wing tip on the hangar door. Nothing major but there's obvious minor damage. Since the annual was just done he makes the decision to continue to fly. The following week he's still ****ed about wing tip but forgets to close his pilot door and the wind blows it open causing a small crack in the window. Now livid he adds that item to his "next annual" list. The exception here is he is operating his aircraft with known damage in direct violation of several FARs which in effect "invalidates" the aircraft's airworthiness certificate. Yet this would be acceptable to most.

I've always been amazed how one simple question can open a dozen can of worms.
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14CFR61.59

That’s the reg you would be violating
 
Bell206 said:
No clue. But if one were to sign off an annual as discussed AND sign off a fresh 100 hour based on the same inspection event one might find themselves on a slippery slope.
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Except there would not be two sign offs. An annual substitutes for a 100 hour. No NEED for two sign offs.
 
Greg Bockelman said:
Except there would not be two sign offs. An annual substitutes for a 100 hour. No NEED for two sign offs.
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Greg:
Correct in a normal situation. But some people want a separate 100 hour sign off with the annual sign off. My comment was directed to the one-off goofy annual we've been discussing. What I don't know is if the flight time accrued during this example annual should be deducted from the 100 hour sign off.

As you mentioned if we SUBSTITUTE our example annual for a 100 hour inspection and that aircraft flies 100 hours for the next inspection cycle, everything inspected at an aircraft total time earlier than the TT used for the 100 hr sign off would be an overflight at the next 100 hr inspection. The annual sign off resets the clock that I'm sure of, but I'm not sure it resets on a 100 hour sign off if the aircraft flies during the original inspection. Still, an interesting situation.
 
Norman said:
Tom loves to stir the pot. Most of his questions are designed not to educate but support his distorted opinion.
He needs to take a hike.
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His questions in this thread have stimulated an interesting discussion, and I have learned from it. I hope he sticks around.
 
Palmpilot said:
His questions in this thread have stimulated an interesting discussion, and I have learned from it. I hope he sticks around.
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I wont say I want him to go away but the questions he poses are merely an attempt on his part to stir the pot. There are times he makes a valid point but....
 
65.95 Inspection authorization: Privileges and limitations.
(a) The holder of an inspection authorization may—
(2) Perform an annual, or perform or supervise a progressive inspection according to §§43.13 and 43.15 of this chapter.

43.15 Additional performance rules for inspections.
(a) General. Each person performing an inspection required by part 91, 125, or 135 of this chapter, shall—

(1) Perform the inspection so as to determine whether the aircraft, or portion(s) thereof under inspection, meets all applicable airworthiness requirements;
(c) Annual and 100-hour inspections. (1) Each person performing an annual or 100-hour inspection shall use a checklist while performing the inspection.

43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

I don't believe any reasonable individual would interpret that to mean an annual can be broken up into several inspections with several checklists, and done at different TAT's
 
Norman said:
I wont say I want him to go away but the questions he poses are merely an attempt on his part to stir the pot. There are times he makes a valid point but....
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you gotta admit.....he does make the time pass. :D
 
Norman said:
Tom loves to stir the pot. Most of his questions are designed not to educate but support his distorted opinion.
He needs to take a hike.
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Distorted ? only when you disagree.
 
timwinters said:
That is my point exactly. The sign off is a lie because the condition of the airplane is not known.
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Why wouldn't it be known? do you wear your aircraft out in a month?

IF I were to inspect the airframe portion, then the engine crapped on the next flight, I certainly wouldn't sign the annual off as airworthy.
 
Norman said:
I wont say I want him to go away but the questions he poses are merely an attempt on his part to stir the pot.
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I guess staring the pot is a way to make this web page a useful learning tool for those who don't know it all, already.
 
Norman said:
Tom loves to stir the pot. Most of his questions are designed not to educate but support his distorted opinion.
He needs to take a hike.
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That would leave your bias opinion un-rebuked, and that is when your hatred of me show up.
it's getting to be most humorous :)
 
Greg Bockelman said:
It never hurts to ask, if that sort of thing is desired, and most 91 operators don’t NEED to do this.
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Several of my customers need there aircraft to commute to work, two live here in OKH, and one lives in Friday Harbor. All three do the same job as you. I do there annuals on their 3 day turn around days, I normally do a preliminary look see and have them get their parts on hand.
My CFI owners need their aircraft most every day also, these are the owners that need a IA willing to do their annuals between flights.
No matter who whines about it, there is no FAR saying it is illegal. Those here that believe I am starring the pot, can put up or shut up, I've yet to see any of them show reason this idea can't be done.
 
Norman said:
I wont say I want him to go away but the questions he poses are merely an attempt on his part to stir the pot. There are times he makes a valid point but....
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I don't see anything wrong with stirring the pot.
 
timwinters said:
Only if you take ethics out of the equation, IMO.
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Tim:
While this has been a very interesting discussion, in all honesty, I have never heard the term “ethics” used within the aviation world I have traveled in the past 37 years. Never. But I’m just a simple mechanic.

In my aviation world, we have airworthy, unairworthy, serviceable, unserviceable, acceptable, or approved all day long. That is what all FAA guidance drives us to define.

How “ethics” made its way into a discussion on working through the FAA regulations to annual an aircraft while flying it, I’ll never understand.

But since you brought it to this discussion, I would be more than happy to show you the “ethical” side of the maintenance process, provided you can explain to me first, the “ethics” behind a majority of pilot owners purposely ignoring regulations, guidelines, and rules on a daily basis, causing tragic losses of life and property for no debatable reasons.

I think if you believe ethics are that important to aviation, we should start at the top of the food chain, IMO.
 
Tom-D said:
Several of my customers need there aircraft to commute to work, two live here in OKH, and one lives in Friday Harbor. All three do the same job as you. I do there annuals on their 3 day turn around days, I normally do a preliminary look see and have them get their parts on hand.
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OK. They get their annual inspections done on their three days off. No problem there.

Tom-D said:
My CFI owners need their aircraft most every day also, these are the owners that need a IA willing to do their annuals between flights.
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You are saying here that these particular owners need their aircraft all the time, period, end of story? They can't schedule ahead 12 months for 1 or 2 or xx days in order for them to comply with their required annual inspection? I call baloney! If they are flying that much, are they getting their oil changed at regular intervals? If so, maybe they should be on a progressive program, with a bit done at each 50 hrs to coincide with an oil change. Is that not why progressive inspections exist in the first place? To maximize aircraft utilization?
 
Tom-D said:
IF I were to inspect the airframe portion, then the engine crapped on the next flight, I certainly wouldn't sign the annual off as airworthy.
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What if the engine didn't crap out but the spar cracked on that flight instead (darn CFI fell out of a loop). Would you sign it off because you didn't know? If the CFI dumped the bird off "with a fresh annual" ('cause he's scared to keep flying in it) are you beyond reach of the feds if the new owner subsequently loses a wing?

dtuuri
 
Bell206 said:
Tim:
While this has been a very interesting discussion, in all honesty, I have never heard the term “ethics” used within the aviation world I have traveled in the past 37 years. Never. But I’m just a simple mechanic.

In my aviation world, we have airworthy, unairworthy, serviceable, unserviceable, acceptable, or approved all day long. That is what all FAA guidance drives us to define.

How “ethics” made its way into a discussion on working through the FAA regulations to annual an aircraft while flying it, I’ll never understand.

But since you brought it to this discussion, I would be more than happy to show you the “ethical” side of the maintenance process, provided you can explain to me first, the “ethics” behind a majority of pilot owners purposely ignoring regulations, guidelines, and rules on a daily basis, causing tragic losses of life and property for no debatable reasons.

I think if you believe ethics are that important to aviation, we should start at the top of the food chain, IMO.
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If you have been in this business for 37 years and have never heard of ethics please let me know how to make sure you never work on my equipment.
I’ve been in this industry for twenty years and ethics have been an integral part from the beginning.
 
That scenario is ********! Having worked for several airlines, since 1983, I will say with confidence; Airline inspectors do not dictate maintenance.
 
I agree that this is an interesting scenario and has been a decent discussion. :)
 
JAWS said:
OK. They get their annual inspections done on their three days off. No problem there.



You are saying here that these particular owners need their aircraft all the time, period, end of story? They can't schedule ahead 12 months for 1 or 2 or xx days in order for them to comply with their required annual inspection? I call baloney! I?
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tell me a year out, what the weather will be, can you tell me what the weather will be Oct.26.2018. CFIs work around the weather all the time.
I'll work with them when I can.
 
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