Can owner install different fire extinguisher bracket?

[wsuffa]

Why I am unlikely to own a certified aircraft again unless I'm independently wealthy.

Is the fire extinguisher required equipment? If not, either leave it out or velcro it to the seat or something. Like I used to do with my second o2 cylinder (put it in a bag, and ran a rear seat belt through the strap). At some point, the FAA regs become an impediment to health and safety, just like the medical exam & SI regs kept a lot of pilots from seeing the doctor for fear of a diagnosis.

 

[unsafervguy]

#26 replacement or adjustment of nonstructural standard fasteners incidental to operations.

He is replacing or adjusting fastners securing fire extinguisher, clearly they are non structural.

Wrong. He is not adjusting fasteners, he is not replacing fasteners, he is replacing a bracket. That is not covered. Period, never mind that everyone is forgetting the incidental to operations part. What part of replacing a bracket is incedental to what operation. Whether you like it or not, it's a job that requires an A&P. Whey do people try to bend appendix a?

Bob

 

[5QK]

Just do it already. Who's gonna check that?

 

[Stewartb]

Nobody cares about your airplane and your family's safety like you do. Apply common sense and install it. Mention it to your mechanic if you can't sleep for the stress of being an outlaw who didn't abide by letter of the rules.

 

[James331]

Wrong. He is not adjusting fasteners, he is not replacing fasteners, he is replacing a bracket. That is not covered. Period, never mind that everyone is forgetting the incidental to operations part. What part of replacing a bracket is incedental to what operation. Whether you like it or not, it's a job that requires an A&P. Whey do people try to bend appendix a?

Bob

Sounds like someone was potty trained at gun point


[As for just replacing with a different but same size extinguisher with a bracket that mounts in place of the old one, not what the OP was doing with the heavy extinguisher and drilling the seat frames]


§1.1 General definitions.
Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.


§43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.
g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under Part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

 

[Sinistar]

@teejayevans - thanks for pointing out one duh!! moment

Here is what I plan to do until the next time I see the A&P:

1.) Keep this slightly larger Halon extinguisher (H3R). I'd rather have more than less and another 2lbs is just a blip for skylane.
2.) Drill two new holes in the new bracket to match the old one.
3.) Install the new bracket and extinguisher. I will be confident that any nasty chop or turbulence won't knock it free.
4.) Print out a entry for the aircraft log book indicating I removed the old extinguisher and bracket and replaced with a new one using the same mouting location and screws. I will also note the old weight and new weight. I will return it to service. In this way our A&P is clearly not responsible and I have also been as forthcoming as possible.
5.) This new entry will only be clipped to the next log page (not permanent - yet).
6.) When I bring the plane in to get the nose strut looked at I will let him know about it. At that time he can do what it takes to get it right. I definitely do not want to sneak it by him.

 

[unsafervguy]

Sounds like someone was potty trained at gun point





§1.1 General definitions.
Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.


§43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.
g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under Part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

Great, you read the definition. Now read the reg. 43 appendix a specifically (c).

Limited to

Sorry, those 31 are it.

(c)Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

(1) Removal, installation, and repair of landing gear tires.

(2) Replacing elastic shock absorber cords on landing gear.

(3) Servicing landing gear shock struts by adding oil, air, or both.

(4) Servicing landing gear wheel bearings, such as cleaning and greasing.

(5) Replacing defective safety wiring or cotter keys.

(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.

(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.

(8) Replenishing hydraulic fluid in the hydraulic reservoir.

(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.

(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.

(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.

(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.

(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.

(14) Replacing safety belts.

(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.

(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.

(17) Replacing bulbs, reflectors, and lenses of position and landing lights.

(18) Replacing wheels and skis where no weight and balance computation is involved.

(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.

(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.

(21) Replacing any hose connection except hydraulic connections.

(22) Replacing prefabricated fuel lines.

(23) Cleaning or replacing fuel and oil strainers or filter elements.

(24) Replacing and servicing batteries.

(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.

(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.

(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.

(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificiate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.

(29) Removing, checking, and replacing magnetic chip detectors.

(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:

(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under § 147.21(e) of this chapter; (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under § 21.24 of this subchapter; or (3) issued by another entity that has a course approved by the Administrator; and

(ii) The inspections and maintenance tasks are performed in accordance with instructions contained by the special inspection and preventive maintenance program approved as part of the aircraft's type design or supplemental type design.

(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.

 

[James331]

Great, you read the definition. Now read the reg. 43 appendix a specifically (c).

Limited to

... cockpit interior when removal or disassembly of any primary structure or operating system is not required.

....Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.

... Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.

... Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.


.....Replacement or adjustment of nonstructural standard fasteners incidental to operations.

You're right, what I said is correct and can be argued on a few different aspects of that FAR.

 

[Sinistar]

Just do it already. Who's gonna check that?

I recently had a pilot deviation which also resulted on a scouring of our aircraft, engine and prop logs. So I guess I'm a bit gunshy. I elected to meet them at the FSDO and not the hangar though

That being said the AP ASI did find a wrong entry kind of like this (for a headlight). He guided me on how to correct the entry and had me place the correct entry over the wrong one. He wanted the planes history to be correct.

Now I'm sure the following is in the FSDO's best interest but his advise went like this: Log this stuff. Be clear what was done. Make it as easy for them as possible to determine if something is wrong so they can help make it right. Once he finds a discrepancy between the aircraft and the logs all bets are off and he said he'll dig forever and find whatever he can to be sure the aircraft can be made fully airworthy again. Maybe that was his way of saying: "Don't sneak **** in there without document it". Those are my words, not his but thats the way I heard it.

 

[Tom-D]

You're right, what I said is correct and can be argued on a few different aspects of that FAR.

(c ) never mentions a prop.

 

[unsafervguy]

No your flat wrong. And I'm done arguing with a moron.

Bob

 

[James331]

No your flat wrong. And I'm done arguing with a moron.

Bob

My friends kids call names too when they can't debate logically.

Time for bed little one

 

[Sinistar]

Please be nice guys. I am learning a lot from this thread.

I will admit that updating a fire extinguisher should just be common sense. Then again, its mounted under the pilots seat and if the extinguisher, it's bracket or the aluminum channel piece on the seat were to come free, especially during landing it could present a risk.

 

[Sinistar]

An argument on Easter about a fire extinguisher...POA

 

[Bell206]

Here is what I plan to do until the next time I see the A&P:

Close enough.

Once he finds a discrepancy between the aircraft and the logs all bets are off and he said he'll dig forever and find whatever he can to be sure the aircraft can be made fully airworthy again.

100% correct. It's better to try and follow the rules than not. Having the record even if it's wrong gives you the option of "plausible deniability." Not having the record leaves you in a bad place when caught.

 

[MooneyDriver78]

I’m willing to be I can go through any aircraft that’s 30+ years old and find missing information including work not recorded, W&B errors, etc. And this is from A&P and IAs that should know better.

 

[Bell206]

I’m willing to be I can go through any aircraft that’s 30+ years old and find missing information including work not recorded, W&B errors, etc. And this is from A&P and IAs that should know better.

That's correct. The problem arises when you become the owner of that aircraft, all that missing info and those errors fall under your responsibility. And regardless who made the error, except for specific maintenance tasks that fall under 43, the owner assumes the position.

 

[Tom-D]

I’m willing to be I can go through any aircraft that’s 30+ years old and find missing information including work not recorded, W&B errors, etc. And this is from A&P and IAs that should know better.

This struck me as kinda humorous. The aircraft I'm working with Starts the logs with this entry.
" this entry is to start new maintenance records for ( _____) Total time unknown with a Tach time of 5473.8. on (_date_ ) ."
It is in a new ADlog filing system.
I've verified all the ADs

So you don't always have any records to go with.

 

[MooneyDriver78]

That's correct. The problem arises when you become the owner of that aircraft, all that missing info and those errors fall under your responsibility. And regardless who made the error, except for specific maintenance tasks that fall under 43, the owner assumes the position.

So if that’s the case, then wouldn’t it be better to “lose” all the old logbooks? I’ve been told you only need a record of recent maintenance items (since last annual ) to be legal. And then miraculously find them when you sell.

 

[Tom-D]

So if that’s the case, then wouldn’t it be better to “lose” all the old logbooks? I’ve been told you only need a record of recent maintenance items (since last annual ) to be legal. And then miraculously find them when you sell.

Actually I believe its 12 months, but be reminded that you must be able to prove part 39 compliance.

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

 

[Sinistar]

So let's say a AD required a hose to be replaced 3yrs ago. You did it and the A&P signs off that year's annual. Next annual goes fine too, he signs off that one too. But your log book is now out of entries.

So you buy a new logbook. Another annual by the same A&P. This most recent annual is the first entry in the new log book.

Now for some reason you can no longer find the old logbook.

But you have the current one with the most recent annual. In this example is the signed off annual proof enough (under that FAR's) that that hose AD 3yrs ago was actually complied with?

 

[Bell206]

then wouldn’t it be better to “lose” all the old logbooks?

You could but then that would probably lead to other problems. If your signed AD entries/list, last overhaul write ups, total time in service (tach/hobbs time doesn't count), etc. were only listed in your "old" logbooks then you would still need to keep them handy or transfer that info out into your "current" record.

I’ve been told you only need a record of recent maintenance items (since last annual ) to be legal

As mentioned above, yes for 1 year on your records per 91.417(a)(1) or until the same work is repeated. But that doesn't always mean "since last annual." If you changed a tire 6 months after your annual that record must be retained to the same date of the following year. Plus there are other records that must be retained for the life of the aircraft and transfered when the aircraft is sold (see below).

then miraculously find them when you sell.

Sure if you want. But if by your previous posts those records had 30 years of missing info/errors which you had conveniently "lost" while you operated the aircraft, were to be reviewed during that next pre-buy... And the buyer's mechanic notes missing info and errors you may "lose" up to 25% on your sale price due to incomplete records. Pay now or pay later.

 

[Bell206]

In this example is the signed off annual proof enough (under that FAR's) that that hose AD 3yrs ago was actually complied with?

No. An aircraft requires a current signed entry/list of each applicable ADs. Read 91.417 for all your records requirements.

 

[JAWS]

No. An aircraft requires a current signed entry/list of each applicable ADs. Read 91.417 for all your records requirements.

You mean an entry like "AD's completed" isn't good enough?

Been there, done that, learned to do better!

 

[MooneyDriver78]

Sure if you want. But if by your previous posts those records had 30 years of missing info/errors which you had conveniently "lost" while you operated the aircraft, were to be reviewed during that next pre-buy... And the buyer's mechanic notes missing info and errors you may "lose" up to 25% on your sale price due to incomplete records. Pay now or pay later.

No one but an anal retentive engineer (me) would find these errors: example my old battery was replaced but there was no log entry and there is mistakes in the W&B (transposed numbers, math errors), fortunately the mistakes mostly cancel each other out. Too bad owners can’t modify W&B.

 

[Tom-D]

Too bad owners can modify W&B.

If that is to read "can't, I don't see why you can't
Simply make an entry correcting the error.

 

[Tom-D]

So let's say a AD required a hose to be replaced 3yrs ago. You did it and the A&P signs off that year's annual. Next annual goes fine too, he signs off that one too. But your log book is now out of entries.

So you buy a new logbook. Another annual by the same A&P. This most recent annual is the first entry in the new log book.

Now for some reason you can no longer find the old logbook.

But you have the current one with the most recent annual. In this example is the signed off annual proof enough (under that FAR's) that that hose AD 3yrs ago was actually complied with?

Advantage ADlog.When this method of record keeping is applied correctly, all ADs are verified signed off, and all your old records can go away.
Then all new compliance for part 43,39 & 91 are recorded as they happen.

 

[MooneyDriver78]

If that is to read "can't, I don't see why you can't
Simply make an entry correcting the error.

Yes, was supposed to be can’t...that doesn’t seem to be a “maintenance “ item?

 

[Tom-D]

Yes, was supposed to be can’t...that doesn’t seem to be a “maintenance “ item?

it would only be "record keeping" maintenance is when you do some thing to the aircraft, or appliances

 

[Bell206]

Yes, was supposed to be can’t...that doesn’t seem to be a “maintenance “ item?

It all depends. If your empty weight and balance is recorded on a sheet with an A&P sign off then you can't alter those figures. If your empty W&B is recorded on a continuous change form (Form C) with no signatures, i.e., the A&P signature is in the log entry that caused the W&B change with a reference to the Form C, then you can get away with correcting the mathematical error on the Form C.

FYI: an aircraft empty weight and balance, along with its equipment list, is part of the TC and referenced in the TCDS. Any aircraft alteration or repair that changes the certified empty W&B more than 1lb requires an update and sign off by an A&P.

 

[Tom-D]

It all depends. If your empty weight and balance is recorded on a sheet with an A&P sign off then you can't alter those figures. If your empty W&B is recorded on a continuous change form (Form C) with no signatures, i.e., the A&P signature is in the log entry that caused the W&B change with a reference to the Form C, then you can get away with correcting the mathematical error on the Form C.

FYI: an aircraft empty weight and balance, along with its equipment list, is part of the TC and referenced in the TCDS. Any aircraft alteration or repair that changes the certified empty W&B more than 1lb requires an update and sign off by an A&P.

It all depends. If your empty weight and balance is recorded on a sheet with an A&P sign off then you can't alter those figures. If your empty W&B is recorded on a continuous change form (Form C) with no signatures, i.e., the A&P signature is in the log entry that caused the W&B change with a reference to the Form C, then you can get away with correcting the mathematical error on the Form C.

FYI: an aircraft empty weight and balance, along with its equipment list, is part of the TC and referenced in the TCDS. Any aircraft alteration or repair that changes the certified empty W&B more than 1lb requires an update and sign off by an A&P.

There are a multitude of aircraft that have no equipment lists, and the type certificate says nothing about individual W&B. It will give Empty weight CG limits but that is all.
Individual aircraft weight varies and why we have the requirement for individual W&B sheets to be carried in the A/C

Plus the mistakes by an A&P can be corrected by the owner, simply by making a entry in the proper log.

Example:
It is noted on the weight and balance calculations the number 1721 has been transposed to read 1271 now is corrected to read properly which moves the empty weight C/G to 18.2 inches aft of datum. owner hand book W&B info up dated.
-------- Owner --- no pilot number or A&P is required.

In this case I would get the A&P back to make the correction, but it is legal for the owner/operator to do it.

 

[Stewartb]

An equipment list establishes what the aircaft empty weight configuration is. Without it how can you do a W&B????

 

[Tom-D]

An equipment list establishes what the aircaft empty weight configuration is. Without it how can you do a W&B????

This W&B is as configured on (date) yada yada

and after that date..
Just an entry
"Radio removed from station (inches) weighing 3 pounds.
new W&B computed new empty weight C/G is ( inches )"

 

[Bell206]

As we have discussed before. Maybe in WA but....

There are a multitude of aircraft that have no equipment lists,

Then they are not in compliance with their TC and Airworthiness Certificate. In other words the aircraft are unairworthy. In order for an aircraft to pass its annual inspection it must conform to its type certificate data of which the equipment list and empty W&B are a part of.

Every TCDS, which is a summary of the TC, has this statement, or something similar, in Note 1:

NOTE 1. Current weight and balance report including list of equipment included in certificated weight empty, and loading instructions when necessary, must be in each aircraft at the time of original certification and at all times thereafter (except in the case of air carrier operators having an approved weight control system).

the type certificate says nothing about individual W&B

Yes it does. See above.

legal for the owner/operator to do it.

If you're talking about the owner creating a separate write up then ok. But he can not alter an existing entry above an A&P sign off. Unfortunately in the case of an empty weight correction unless it follows my Form C example several posts ago then he can not.

 

[Tom-D]

the current W&B. just what I said
What do we teach each students about what is carried in the A/C ?
The TCDS does not address individual A/C
The Cessna singles have that requirement in the POH/Owner's Manual. But only the later models will have an equipment list.

 

[Tom-D]

The 170 TCDS does give every piece of equipment allowed to be installed on a 170. and it gives the weight and arm for each.
But it does not say that you must carry that list or any other list of equipment in the aircraft.
It does tell you by equipment number what is required to be installed to be a sea plane, land plane and so forth.

your form "C" can you show it ? I must have missed it. The content and form of maintenance records for part 91 are in FAR 43 and who is allowed to make these entries is there too.

 

[JAWS]

An equipment list establishes what the aircaft empty weight configuration is. Without it how can you do a W&B????

As Bell206 stated, part of the TCDS.

From the Cessna 170 TCDS:

NOTE 1.
Current weight and balance report including list of equipment included in certificated empty weight, and
loading instructions when necessary, must be in each aircraft at the time of original certification and at all
times thereafter (except in the case of air carrier operators having an approved weight control system).

 

[JAWS]

The 170 TCDS does give every piece of equipment allowed to be installed on a 170. and it gives the weight and arm for each.

The TCDS gives the equipment, weight and arm that Cessna normally installed or would want to install. One off or special items would be a separate entry, as would all subsequent additions and removals. Such as adding a new halon fire extinguisher to a small aircraft, with an added weight of 2 lbs.

 

[Tom-D]

The TCDS gives the equipment, weight and arm that Cessna normally installed or would want to install. One off or special items would be a separate entry, as would all subsequent additions and removals. Such as adding a new halon fire extinguisher to a small aircraft, with an added weight of 2 lbs.

Agreed, each change in the W&B would be an entry, removing, adding or a change in configuration (wheels to floats)
Plus anything that would normally require a 337 be submitted, should comply with the advice given in AC 43-210.
Your 2 pound addition placed near Datam would normally be negligible change, and need not be noted.

 

[JAWS]

Your 2 pound addition placed near Datam would normally be negligible change, and need not be noted.

From AC43.13;1B, Chapter 10, Section 1:

c. Negligible Weight Change is any
change of one pound or less for aircraft whose
weight empty is less than 5,000 pounds; two
pounds or less for aircraft whose weight empty
is more than 5,000 and 50,000 pounds; and
five pounds or less for aircraft whose weight
empty is more than 50,000 pounds. Negligible
c. g. change is any change of less than 0.05%
MAC for fixed wing aircraft, 0.2 percent of the
maximum allowable c. g. range for rotary wing
aircraft.