Data Tag = Airworthiness

[Tom-D]

Can a 0-235 Lycoming be airworthy with out a data tag?

Far 45 (b) Aircraft engines . A manufacturer of an aircraft engine produced under a type certificate or production certificate must mark each engine by attaching a fireproof identification plate. Such plate—

(1) Must include the information specified in §45.13 using an approved method of fireproof marking;

(2) Must be affixed to the engine at an accessible location; and

(3) Must be secured in such a manner that it will not likely be defaced or removed during normal service, or lost or destroyed in an accident.

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If the data tag was removed after installation of the engine in the aircraft, is it still airworthy?

From http://www.sacskyranch.com/lycoming.htm

What is a wide-deck and narrow-deck engine

For many Lycoming engines the same engine model may be a narrow deck or a wide deck. Each engine takes entirely different parts. How do you tell the difference. All wide deck engines have a engine serial number ending in A (except O-235 series engines). Lycoming serial numbers can be found on the engine data plate and also on the crankcase at the top parting surface.

Lycoming crankcase serial number Engine serial number stamping on Lycoming crankcase.

WE know the S/N and we have logs. but no data tag.

 

[Skylane81E]

Good question, we talked about it on a O-520 on another forum.

Perhaps Lycoming would provide a new tag (for a fee)
When was the engine built, different requirements at that time? <-- wild guess

 

[Tom-D]

Good question, we talked about it on a O-520 on another forum.

Perhaps Lycoming would provide a new tag (for a fee)
When was the engine built, different requirements at that time? <-- wild guess

This aircraft has been annualed 12 times since the overhaul, and we believe the tag was removed for sump cleaning and never replaced. the holes are painted over and the place the tag sets shows no shadow of where one has ever been.

How could 12 A&P-IAs sign it off as airworthy, if there isn't an authorized way?

 

[Let'sgoflying!]

I know one just like it; maybe 10yrs. I guess they all figured it was working just fine without the 'paperwork'!

 

[Skylane81E]

12 years? Isn't that about the calendar TBO time (is on a TCM)?

Just tell the owner it's in need of overhaul...


...KIDDING!!!

 

[Skylane81E]

Oh and I annualed a Cherokee that had had the wrong prop on it for longer than I'd been alive a few years ago.

I made the owner bight the bullet on a re-pitch

 

[Let'sgoflying!]

Cherokee that had had the wrong prop

the prop one is very common, even I have seen a few and heard of many others!
I think we are so busy looking for what the owner is concerned about during prebuys we miss the big stuff: "Exactly what is for sale here?"

 

[Tom-D]

12 years? Isn't that about the calendar TBO time (is on a TCM)?

Just tell the owner it's in need of overhaul...


...KIDDING!!!

Who would overhaul it with out a tag?

 

[Capt. Geoffrey Thorpe]

Oh and I annualed a Cherokee that had had the wrong prop on it for longer than I'd been alive a few years ago.

I made the owner bight the bullet on a re-pitch

Why?

Nonsense like this is why I don't own a certified aircraft.

 

[Jeff Oslick]

My $0.02: You have the information you need to know the engine's pedigree. The reg says "not likely" to be removed, not "impossible". Therefore, I would first go to the manufacturer and ask for a replacement tag. If they are unwilling to provide one, then make one up with the required information, with a notation in the log that the manufacturer could not provide the tag, so this is an owner-produced part.

Jeff

 

[BiffJ]

This aircraft has been annualed 12 times since the overhaul, and we believe the tag was removed for sump cleaning and never replaced. the holes are painted over and the place the tag sets shows no shadow of where one has ever been.

How could 12 A&P-IAs sign it off as airworthy, if there isn't an authorized way?

Thats a good question.....I did a pre purchase on a plane that had a dataplate with a different serial number than what was in the logbooks and it didn't get noticed til the last annual. It had been through many annuals since the last overhaul in 1972. How many A&P's even compare the numbers or look at the dataplates when they do an annual. I know I looked when I bought the plane I ended up with.
I suppose the only real answer is to talk to the FSDO guys and see if you can make up a replacement tag. We see engines all the time that have been through overhaul and had all the paint washed off the dataplate leaving nothing but a serial and model number with no other info. They are frequently the only numbers actually stamped in the plate since the rest is printed via the printing process. Since there is a train of history in the logs and the engine serial# stamped on the case halves it should be doable.

Good luck
Frank

 

[Tom-D]

My $0.02: You have the information you need to know the engine's pedigree. The reg says "not likely" to be removed, not "impossible". Therefore, I would first go to the manufacturer and ask for a replacement tag. If they are unwilling to provide one, then make one up with the required information, with a notation in the log that the manufacturer could not provide the tag, so this is an owner-produced part.

Jeff

Where do we get authorization to make up a data tag?

quote a reg for me.

 

[Jim Logajan]

Far 45 (b) Aircraft engines . A manufacturer of an aircraft engine produced under a type certificate or production certificate must mark each engine by attaching a fireproof identification plate. Such plate—

(1) Must include the information specified in §45.13 using an approved method of fireproof marking;

(2) Must be affixed to the engine at an accessible location; and

(3) Must be secured in such a manner that it will not likely be defaced or removed during normal service, or lost or destroyed in an accident.

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If the data tag was removed after installation of the engine in the aircraft, is it still airworthy?

The above quoted regulation appears to be a dictate ONLY to the manufacturer: "A MANUFACTURER [...] MUST [....]"

It does not impose anything on any subsequent entity. While there may be regulations elsewhere that require owners or operators to maintain the identification plate in a readable state, I can't see any way the quoted regulation could be read as requiring that.

 

[Keith Lane]

Might ask Charlie Melot.
I'll bet he's seen this more than once.

 

[Jim Logajan]

The above quoted regulation appears to be a dictate ONLY to the manufacturer: "A MANUFACTURER [...] MUST [....]"

It does not impose anything on any subsequent entity. While there may be regulations elsewhere that require owners or operators to maintain the identification plate in a readable state, I can't see any way the quoted regulation could be read as requiring that.

Did a quick check and section 45.13(b) dictates that no one else may change or remove the identification information.

 

[Tom-D]

Did a quick check and section 45.13(b) dictates that no one else may change or remove the identification information.

It says....

(2) Remove an identification plate required by Sec. 45.11 when necessary during maintenance operations.
(e) No person may install an identification plate removed in accordance with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.

You can remove them, but it must go back to the place from which it came.

Wish I had one to put back

 

[Jeff Oslick]

It says....

(2) Remove an identification plate required by Sec. 45.11 when necessary during maintenance operations.
(e) No person may install an identification plate removed in accordance with paragraph (d)(2) of this section on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.

You can remove them, but it must go back to the place from which it came.

Wish I had one to put back

That only says you can't put a data plate from another engine on this one. It doesn't say you can't put a "new" replacement plate on this engine. You seem to be looking for permission to do something, but not recognizing there is no reg saying you can't do it.

First, has Lycoming said they will not provide a new plate?

Jeff

 

[Tom-D]

That only says you can't put a data plate from another engine on this one. It doesn't say you can't put a "new" replacement plate on this engine. You seem to be looking for permission to do something, but not recognizing there is no reg saying you can't do it.

First, has Lycoming said they will not provide a new plate?

Jeff

Yer right IF we had the correct Data tag we could put it back,,,,,,, we don't.

Lycoming does not provide new data tags because there are several after market engine builders that will make you an engine kit if you have a data tag.

Charley Malot builds these engines and requires you to provide the tag. and then the core engine becomes one of these engine with out a tag.

This was not an option 12 years ago when this engine was re-built.

But that does not guarantee this tag wasn't used for that purpose.

 

[Let'sgoflying!]

TCM will

 

[Skylane81E]

Why?

Nonsense like this is why I don't own a certified aircraft.

Cuz it was illegal, not because it didn't work.

 

[Jeff Oslick]

Lycoming does not provide new data tags because there are several after market engine builders that will make you an engine kit if you have a data tag.

If you know the pedigree of the engine, this should not be your problem. Fer gripe's sake, how hard would it be to fake a data plate if someone was that determined to get around the rules? The procedure and cost in the TCM bulletin seems entirely reasonable. This should not be any more difficult to accomplish than replacing an airworthiness certificate (which I did a couple months ago, and it took all of about 30 minutes at the FSDO).

Jeff

 

[Tom-D]

If you know the pedigree of the engine, this should not be your problem. Fer gripe's sake, how hard would it be to fake a data plate if someone was that determined to get around the rules? The procedure and cost in the TCM bulletin seems entirely reasonable. This should not be any more difficult to accomplish than replacing an airworthiness certificate (which I did a couple months ago, and it took all of about 30 minutes at the FSDO).

Jeff

You have the logs in one hand and look at the engine with no data tag, how do you prove that the two belong to each other?

How do I as an A&P-IA know there are not two engines out there with this S/N?

 

[Skylane81E]

If you know the pedigree of the engine, this should not be your problem. Fer gripe's sake, how hard would it be to fake a data plate if someone was that determined to get around the rules? The procedure and cost in the TCM bulletin seems entirely reasonable. This should not be any more difficult to accomplish than replacing an airworthiness certificate (which I did a couple months ago, and it took all of about 30 minutes at the FSDO).

Jeff

Unfortunately it isn't that easy, the data tag comes from the manufacturer and the airworthiness paper comes from the FAA.

Now maybe it should be that easy...

Oh and say hi to Mike for me:wink2:

 

[Jim Logajan]

You have the logs in one hand and look at the engine with no data tag, how do you prove that the two belong to each other?

How do I as an A&P-IA know there are not two engines out there with this S/N?

You need to read this FAA advisory circular, which is directly pertinent to your situation:

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 43-213.pdf

One extracted quotes:

"Part marking is not essential for determining the continued airworthiness of an in-service article, provided the operator and/or its maintenance provider can determine that it conforms to its approved design and is in condition for safe operation."

 

[Tom-D]

You need to read this FAA advisory circular, which is directly pertinent to your situation:

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 43-213.pdf

One extracted quotes:

"Part marking is not essential for determining the continued airworthiness of an in-service article, provided the operator and/or its maintenance provider can determine that it conforms to its approved design and is in condition for safe operation."

Very good.......!

It is airworthy with out the tag attached.. AC 43.213 as long as it is already in service.

 

[Skylane81E]

Noted for later!!!!

 

[Jeff Oslick]

How do I as an A&P-IA know there are not two engines out there with this S/N?

How do you know there aren't two *insert name of any serialized approved part* out there with the same S/N? Isn't that the point of serial numbers? They're serial...

Jeff

 

[Jeff Oslick]

Unfortunately it isn't that easy, the data tag comes from the manufacturer and the airworthiness paper comes from the FAA.

Now maybe it should be that easy...

Oh and say hi to Mike for me:wink2:

My point was that the FAA could readily issue the paperwork needed by the manufacturer to provide the replacement...as TCM apparently accepts.

Will give MJ a shout out from you...


Jeff

 

[Tom-D]

How do you know there aren't two *insert name of any serialized approved part* out there with the same S/N? Isn't that the point of serial numbers? They're serial...

Jeff

How many components do you know of that cost $44,000 new and rebuilt cost 30,000+ and are in direct competition for the market with the manufacturer. and are required to have their own maintenance records?

Superior will/can build you a totally new 0-235, but they are not allowed to attach a new data tag that says "Lycoming" theirs says "EXP" So, if you have a data tag.............. you have a new engine at about half the cost.

http://www.xp-series.com/slideshow.asp?showId=2

 

[Tom-D]

You need to read this FAA advisory circular, which is directly pertinent to your situation:

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 43-213.pdf

One extracted quotes:

"Part marking is not essential for determining the continued airworthiness of an in-service article, provided the operator and/or its maintenance provider can determine that it conforms to its approved design and is in condition for safe operation."

Thanks for that link.....