IA's required to sign off on N/A AD's?

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macgyver3280

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Macgyver
To all IA's out there. Is it specifically addressed anywhere in the FAR's that an IA is required to sign off an AD that is considered N/A for that particular airframe in the maint. logs?

By N/A I mean that the P/N listed in the AD is not installed on the aircraft. I understand that it is a good idea to have the AD list contain all of the N/A ones for ease of future reference but is it required by the FAR's?
 
It is not required, But it is customary to sign it off as does not apply by Part number installed.
It's just proper paper work.
 
macgyver3280 said:
Is it specifically addressed anywhere in the FAR's that an IA is required to sign off an AD that is considered N/A for that particular airframe in the maint. logs?
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FYI: an A&P doesn't need an IA to sign off ADs. But the AD applicability statement will determine how it needs to be signed off. As noted above, it's not required to sign off an AD as N/A as the AD is only applicable to the specific condition listed, e.g., PA-18 with STC 123456 installed. But it's to your advantage especially if the product or appliance model is listed in the App Statement. Otherwise every subsequent AD search will require duplicate research.
 
Checkout_my_Six said:
who can determine if it's "N/A"?
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An owner, operator, or mechanic. But it falls to the owner/operator to ensure compliance. If the owner/operator doesn't have the technical means to determine the applicability of the AD then they must find the appropriate person to do so.
 
Bell206 said:
FYI: an A&P doesn't need an IA to sign off ADs. But the AD applicability statement will determine how it needs to be signed off. As noted above, it's not required to sign off an AD as N/A as the AD is only applicable to the specific condition listed, e.g., PA-18 with STC 123456 installed. But it's to your advantage especially if the product or appliance model is listed in the App Statement. Otherwise every subsequent AD search will require duplicate research.
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That’s why they call it research. First you search. If you don’t document it, then next year you have to research.
 
Thanks for the replies. As you can guess, I was asking because I was approached by a client that was told by an FAA FSDO Maintenance Inspector that his aircraft was not airworthy because there were 2 AD's that were not signed off as required per 91.417 (V). He explained to the FSDO inspector that the AD was N/A due to that specific P/N not being installed on the aircraft but the inspector would not budge. The inspector advised him that the aircraft was not airworthy until he got the specific AD's signed off in his maintenance log. Be careful out there everyone!!!
 
macgyver3280 said:
Thanks for the replies. As you can guess, I was asking because I was approached by a client that was told by an FAA FSDO Maintenance Inspector that his aircraft was not airworthy because there were 2 AD's that were not signed off as required per 91.417 (V). He explained to the FSDO inspector that the AD was N/A due to that specific P/N not being installed on the aircraft but the inspector would not budge. The inspector advised him that the aircraft was not airworthy until he got the specific AD's signed off in his maintenance log. Be careful out there everyone!!!
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Prior to making any judgement on that one must know the exact wording in the AD.
 
I read and verified that the AD's the inspector was requiring a sign off for were in fact N/A for that particular air frame. Verified via a cross reference between the P/N's listed on the AD and P/N installed on the aircraft. The point is that the inspector acknowledged the AD was NA but was requiring the owner/operator to sign it off as N/A in the maint. log but there is no FAR that I can find that requires this sign off.
 
macgyver3280 said:
Verified via a cross reference between the P/N's listed on the AD and P/N installed on the aircraft
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AD applicability statements can be cryptic at times. It has caught me and others above my skill set. If the ASI was only concerned about 2 ADs then there must have been reason. However, without looking at the AD couldn't venture why.
 
You had to inspect the part to determine if it was affected by the AD. Sign it off as N/A by visual inspection of part number.
 
If an AD does not apply for any reason, there is no requirement to record it. If there were a requirement all ADs in the FAA register would be required in all aircraft records.
 
Besides, "you gotta pick your battles"....sign it as requested - done. On to a real crisis.
 
There is no real standard for how AD’s are written. Some may specifically state that you verify a certain part number/serial number and some even require partial disassembly to accomplish this. In those cases it’s required to sign off the accomplishment of that directive even if it ends up being N/A. But this is a level below the standard filtering of make/model/serial number. You don’t have to sign off an unapplicable AD that only applies to a PA28-140 if you’re working on a PA28-235. Within the standard filter though it is normal to include unapplicable AD’s in a compliance list even if they are not logged as such just to give a complete picture. The compliance report can be a separate page or it might be permanently entered into the logbook. In the old days before word processors and Avery labels it was usually hand written in the back of the book. Nowadays some A&P’s use software to create rediculously lengthy compliance reports that kill a lot of trees. For no good reason.
 
Tom-D said:
If an AD does not apply for any reason, there is no requirement to record it. If there were a requirement all ADs in the FAA register would be required in all aircraft records.
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Also, the search result for AD's for a model from the FAA, or other Regulatory sources will be different based upon their own interpretation. My search will be different than the last IA who did the Annual Inspection. Some just presume that the already existing AD compliance sheet from the past has every thing and just print out another search result from one of these vendors trusting that it is accurate. But they are not. Try it. Search the FAA AD site engine for the model only - nothing else ex. 172M then do a comparison search with a regulatory vendor. I guess the authority is the FAA search engine.
 
Believe an A&P can sign off many/most ADs. However, only an IA can sign the annual, and many ADs have limits of compliance up to an annual, so a first sign off is often the IA.

A few ADs allow owner sign-off, but not many. N/A by not installed or not applicable is generally A&P and/or IA.
 
macgyver3280 said:
To all IA's out there. Is it specifically addressed anywhere in the FAR's that an IA is required to sign off an AD that is considered N/A for that particular airframe in the maint. logs?

By N/A I mean that the P/N listed in the AD is not installed on the aircraft. I understand that it is a good idea to have the AD list contain all of the N/A ones for ease of future reference but is it required by the FAR's?
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I agree with the inspector. Someone had to determine the ADs were not applicable and record in the logbooks. If it isn’t recorded, the determination never happened.

At the annual inspection following the issuance of the ADs, the IA should have placed a statement the ADs were not applicable.
 
Seems to me that signing off an AD as N/A is right up there with signing off landing gear test or pressurization check on a J-3 as N/A. If it doesn’t apply, why does it need to be noted, except as a convenience for next year’s AD search or for when the plane is sold?
 
Clip4 said:
I agree with the inspector. Someone had to determine the ADs were not applicable and record in the logbooks. If it isn’t recorded, the determination never happened.

At the annual inspection following the issuance of the ADs, the IA should have placed a statement the ADs were not applicable.
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So, you print out the entire AD database for every aircraft ever certified and go through each one, one by one? It'd be easy, but how far do you take it.

LOL Seriously though, I struggled with this when I did my engine overhaul. There were thousands of AD's that hit on Lycoming O-360. The vast majority was on Fuel injection and Turbo equipment, which my engine had neither. But I tossed and turned over whether I should track them as "reviewed and determined n/a" or just not track them at all.
 
I put an AD log together to track all this stuff. N/A is in there for most of them....it just makes it easier on the next guy and cheaper for the next shop you take your plane to...
 
By now most AD records are pages long and most will also be N/A or PCW. Just print them out and keep with aircraft records. First pass is the most tedious of course if they weren’t well documented previously.
 
John B Reed said:
I guess the authority is the FAA search engine.
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Its always been the authority. Prior to the DRS going live those 3rd party AD search engine vendors utilized the old RGL AD database in different ways. So you could perceivably get different results from each type search engine.

Once DRS went live I have no idea how that affected the 3rd party vendor’s data access and results. Regardless, those vendors products were simply work aids and nothing more. It still fell to the owner or mechanic using those products to ensure the search results accuracy against their aircraft. Even with my favorite AD system, ADLog, it is only as good as the information given to them by the user. And especially when you get to the appliance ADs.
Steamflyer said:
Believe an A&P can sign off many/most ADs.
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An A&P can sign off all ADs. No IA needed.
ateamer said:
If it doesn’t apply, why does it need to be noted, except as a convenience for next year’s AD search or for when the plane is sold?
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It all depends on what the AD applicability statement directs. It is the controlling part for the whole AD. So if your product or articles is not covered specifically by that statement then no N/A entry is required nor would I recommend one.

For example, if the AD app statement said Cessna 172M SN xxx to xxx and you owned a Cessna 172 D outside that SN range then no entry should be made. N/A’ing just because you have “172” in common falls outside the existing guidance and creates excessive records of no value.
 
Salty said:
So, you print out the entire AD database for every aircraft ever certified and go through each one, one by one? It'd be easy, but how far do you take it.

LOL Seriously though, I struggled with this when I did my engine overhaul. There were thousands of AD's that hit on Lycoming O-360. The vast majority was on Fuel injection and Turbo equipment, which my engine had neither. But I tossed and turned over whether I should track them as "reviewed and determined n/a" or just not track them at all.
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If I have need to search AD compliance in a logbook, a logbook entry “All ADs current through #####” is worthless, especially when it turns out they aren’t.

I know of a flying club that was fined $10,000 after an accident when an AD was missed 10 years before the accident and was not the cause of the accident. They had an aviation attorney argue it and the FAA didn’t budge.

It literally takes seconds for your mechanic to make a does not apply entry.
 
ateamer said:
Seems to me that signing off an AD as N/A is right up there with signing off landing gear test or pressurization check on a J-3 as N/A. If it doesn’t apply, why does it need to be noted, except as a convenience for next year’s AD search or for when the plane is sold?
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You're not "signing off" an AD as N/A you're just making note of it in in the compliance list. You had to look it up and read it and determine that it was N/A so why not just leave a note so the next guy (or maybe your aging self a couple of years later) doesn't have to do it again. Even if the next guy doesn't trust your work there could be a hint that hey, this is N/A and this is why.

Also, as previously discussed, finding out that an AD is N/A may in some cases require a maintenance action such as partial disassembly so that has to be recorded.
 
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I use AdLog, so have a page for each AD and if N/A it gets marked as N/A. Simple.
 
airworthiness directives are at the core inspections. inspections are not preventative maintenance. unless the AD specifically allows a non-certificated person to complete the task, they simply cannot. a certificated mechanic is required to perform inspections. if an AD is released against your type certified aircraft it would be good practice to note that it either doesn't apply or to start entering it into your AD compliance list
 
pfarber said:
airworthiness directives are at the core inspections. inspections are not preventative maintenance.
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iu
 
pfarber said:
found the guy that never read 39.11

its literally the first sentence.
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And you didn’t even bother reading the other parts of that sentence.

Regulations has to be read as a whole, not cherry picked.
 
I just ran across two ADs that the inspection part was, do you have this part. If so, you have to replace it.
 
And I have encountered AD’s that say “replace part xxxxx with p/n xxxx before next flight”.

Again, the whole regulation must be taken into account, not just a section in a sentence.
 
The "required action" in the AD usually includes the inspection, rather than the broad applicability.

For instance, all the big continentals are subject to AD-2023-00265-E, If I still had the GO-435 in my plane, I'd not log anything.
The required action says apply the MSB if you have one of the affected crankshaft serial numbers. You don't have to disassemble anything to read the S/N, but you in this case need to look at it to comply with the AD (unless you've already done the MSB).
 
I had to go through 87 ADs to evaulate whether they were applicable to the aircraft I was annualling. In the end there was actually 4 ADs that were relevant to look at each year. Other ADs were already complied with - mostly engine ADs at the last overhaul. The rest were added to the model of the aircraft by the FAA and third party applications. A real time consuming event as well that I didn't get paid for. So doing Annual inspections isn't worth the effort, especailly since there is so much more that is expected of an IA to do with this task that adds to the time taken, and eats into my own time. I could be doing something else besides working for free. But I am obligated to complete the task and have no choice. It would be more efficient if the maintenance records were kept in a pristine condition, but good luck with that.
 
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John B Reed said:
I had to go through 87 ADs to evaulate whether they were applicable to the aircraft I was annualling. In the end there was actually 4 ADs that were relevant to look at each year. Other ADs were already complied with - mostly engine ADs at the last overhaul. The rest were added to the model of the aircraft by the FAA and third party applications. A real time consuming event as well that I didn't get paid for. So doing Annual inspections isn't worth the effort, especailly since there is so much more that is expected of an IA to do with this task that adds to the time taken, and eats into my own time. I could be doing something else besides working for free. But I am obligated to complete the task and have no choice. It would be more efficient if the maintenance records were kept in a pristine condition, but good luck with that.
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Why don’t you charge for your time doing that?
 
If I were paying for this research I'd expect a report with your findings. I do a spreadsheet of all applicable ADs (AD log) with the disposition. This reduces the work load for the next guy and gives the owner an easily readable record (vs digging thru the log books).
 
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