Oh Continental, what have you done now?

My plane has many ADs that are not applicable due to serial number, manufacturer of an accessory, etc. I've checked the list and confirmed that they are NA. Neither I nor any previous owner has had a mechanic create a logbook entry stating that those ADs are NA, and I don't see any requirement to do so. Heck, where would you stop? Do I need to list all the Mooney ADs and state they're NA because my plane is a Beech?

The issue comes down the road when an unfamiliar IA looks at your plane 5 years from now and wonders, did they comply with this AD or determine it was not applicable? We have a master list of potentially-applicable ADs that indicate which ones are applicable to our plane. This is more with who should be authorized to determine applicability than whether or not applicability should be recorded somewhere.

Our airplane managed to ground itself a couple days ago for unrelated expensive reasons (flap track bracket crack caught on preflight), so we have plenty of time to comply with this...owning a 46 year old plane will be fun they said... (For the record, we go easy on the flap speeds, this is just a **** happens moment.)
 
This is more with who should be authorized to determine applicability


That’s an owner responsibility, at least for part 91 operations.

CFR 91.403(a)
(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.​

The owner might enlist an A&P to assist in determining applicability, and the FAA might disagree with the owner’s determination, but it’s still an owner responsibility.
 
We have a master list of potentially-applicable ADs that indicate which ones are applicable to our plane.


So do I, but I didn’t need an A&P to create it and it’s not a logbook entry. It’s my responsibility and determination as the owner.
 
There may be an AD that was written like you propose but I don’t recall seeing one. The finer details are usually outside the applicability area, same as this one.

People can complain all they want, it is what it is. I can’t imagine it would be too hard to find someone willing to sign off on the AD as not applying. There are other ADs that are written far worse.
The first AD that comes up in a search for IO-390 is written like I propose, back in 2012. Section (c) on applicability from AD 2012-19-01 reads:
This AD applies to Lycoming Engines [list of engine types] series reciprocating engines listed by engine model number and serial number in Table 1, Table 2, Table 3, or Table 4 of Lycoming Mandatory Service Bulletin (MSB) 569A, dated April 11, 2006, and those engines with crankshafts listed by crankshaft serial number in Table 5 of Lycoming MSB 569A, dated April 11, 2006. These applicable engines are manufactured new, rebuilt, overhauled, or had a crankshaft installed after January 1, 1997, according to Supplement No. 1 to Lycoming MSB No. 569A, dated May 27, 2009.

Is there any particular reason the new Continental AD couldn’t have been structured similarly to the Lycoming crankshaft AD from over a decade ago?

It’s not a question of finding someone willing to sign off on the AD not applying. It’s a question of the FAA immediately grounding thousands of engines that could easily have been excluded by methods the FAA has had no problem using for other crankshaft issues in the past. Maybe some of you trip over nine hungry IA’s on your way to pick up the newspaper in the morning, but some of us are based at airports with one or fewer active A&P’s who already have a backlog of actual work, much less a ton of spare time to do pure paperwork. And they don’t tend to do any of that free of charge.
 
So do I, but I didn’t need an A&P to create it and it’s not a logbook entry. It’s my responsibility and determination as the owner.

It's not a logbook entry, but is an "AD log" that is part of the aircraft records. I have plenty of aircraft records that aren't in the logbook (i.e. repair station invoices with details that aren't in the logbook).
 
Is there any particular reason the new Continental AD couldn’t have been structured similarly to the Lycoming crankshaft AD from over a decade ago?

Yes, there is a particular reason. Incompetent FAA lawyers. This is nothing new.
 
It's not a logbook entry, but is an "AD log" that is part of the aircraft records. I have plenty of aircraft records that aren't in the logbook (i.e. repair station invoices with details that aren't in the logbook).



Yes, but did you need an A&P to create that AD log? If so, why? If not, how is this AD different?
 
I am always happy to hear new euphemisms. Part of me revels in being in golden age of word smithing. Another part says we have to be close to maxing out.

But then comes along something like "manufacturing quality escape" and my faith in humanity's ability to convolute anything is restored.

I have whoever came up with that one got some reward, because that was good.
“Manufacturing quality escape” is more PC than “ol’ Clem, he done stuck them l’il clip thingies in upside down on accounta he’s hung over again.”
 
It’s not a question of finding someone willing to sign off on the AD not applying. It’s a question of the FAA immediately grounding thousands of engines that could easily have been excluded by methods the FAA has had no problem using for other crankshaft issues in the past. Maybe some of you trip over nine hungry IA’s on your way to pick up the newspaper in the morning, but some of us are based at airports with one or fewer active A&P’s who already have a backlog of actual work, much less a ton of spare time to do pure paperwork. And they don’t tend to do any of that free of charge.

You’ve wasted more time responding to comments than it would take a mechanic to sign it off. In my opinion, it’s much ado about nothing.
 
There are places now where you can't get any mechanic to pick up a phone for any price, and it'd be nice if the FAA was sensitive to that reality by wording their sh*t correctly.
 
Even so, the AD doesn't call out any required action for cranks that do not fall under (g)(1) or (g)(2). The aircraft owner is responsible for AD compliance, so if the owner determines from a build record or other source that his engine does not have a suspect crank it seems to me there is no required action at all. The owner might want to write it down somewhere and keep it with his aircraft records, but I don't know that he's required to do so, and there doesn't seem to be a need for an A&P has to sign a logbook entry.

My plane has many ADs that are not applicable due to serial number, manufacturer of an accessory, etc. I've checked the list and confirmed that they are NA. Neither I nor any previous owner has had a mechanic create a logbook entry stating that those ADs are NA, and I don't see any requirement to do so. Heck, where would you stop? Do I need to list all the Mooney ADs and state they're NA because my plane is a Beech?

I have done extensive AD searches for owners that want to sell their airplanes. This takes an awful lot of time, and it duplicates the checks done by earlier mechanics who did not record the ADs and note them as "Not Applicable by Serial Number" (or model number or date of manufacture or whatever). These guys get calls from folks wanting proof that all ADs have either been complied with or were not applicable, and so they have to get someone do go through everything and do it. Not the just engine and prop and airframe; there are numerous appliance ADs as well. I used to keep a reference list of possible ADs on them. Magnetos. Alternators. Vacuum pumps. Fuel servos or carbs. Instruments (and that is no fun, crawling under the panel and trying to read instrument serial numbers that are usually on top of the instrument, so you're fooling with mirrors and flashlights or a snake camera, sometimes even taking the stupid instrument out because it's up against the glareshield or another instrument). Wheels and brakes. Radios, transponders being an example. Autopilot stuff. Fuel valves. Seat belts or harnesses. Exhaust components. Ignition switches (and the Bendix AD is only one of them). Pretty much every time doing this I'd come across unaddressed ADs. Once in a while, going over a new customer's airplane and logs for the first time, I'd find ADs signed off as N/A, when on further inspection they were found to indeed be applicable. An example was some Superior cylinders on an IO-520 signed off as N/A, probably because the cylinders had the TCM rocker covers on them. That's just plain laziness, not looking at the cylinder head and finding the marks the AD calls out.

So that AD log should be kept up-to-date. It's a lot easier writing it up as "N/A by whatever" than it is to do it all over again the hard way when it comes time to prove to a buyer that there are no outstanding ADs. Or when the airplane goes to a different shop.

As an aside, I have found countless log entries stating that the Bendix ignition switch AD was done at every annual for over 30 years, and about half the time when I'd get under the panel to confirm that (as I did, because of the following), I'd find an ACS switch in there, which has an entirely different AD against it, and almost every time it was past compliance or the required diode wasn't installed on the starter contactor as per AD. Or I'd find a Bendix switch with a white dot, or four-digit date code, either of which terminated the AD 46 years ago.
 
Yes, but did you need an A&P to create that AD log? If so, why? If not, how is this AD different?

Yes, our IA maintains that log. Why? Because he has ready access to more information that we do. Are there some ADs we can comply with without him? Yes, the oil change filter adapter AD for our plane specifically allows for visual inspection by the person otherwise authorized to do the oil change.

My point is, yes, this AD should be worded to clearly allow an owner to determine if their plane is on the effected list. One additional sentence in the AD could have addressed this. Separately, however, is the issue of documenting that the AD doesn't apply. That shouldn't be on napkin scribble by the owner, because that will often cause compliance questions to come up later. At the next annual inspection, the IA is going to need to verify if the AD applies, if they are doing their job.
 
Yes, our IA maintains that log. Why? Because he has ready access to more information that we do. Are there some ADs we can comply with without him? Yes, the oil change filter adapter AD for our plane specifically allows for visual inspection by the person otherwise authorized to do the oil change.

My point is, yes, this AD should be worded to clearly allow an owner to determine if their plane is on the effected list. One additional sentence in the AD could have addressed this. Separately, however, is the issue of documenting that the AD doesn't apply. That shouldn't be on napkin scribble by the owner, because that will often cause compliance questions to come up later. At the next annual inspection, the IA is going to need to verify if the AD applies, if they are doing their job.


You have not stated any regulatory reason that an owner cannot determine AD applicability.

You have not stated any regulatory reason that the applicability must be recorded.

Yes, the things you say are a good idea. Bu they don’t amount to a regulatory prohibition on the owner determining the applicability of this AD, nor a requirement that he write it down

The FAA requires a record of work performed, signed by the person doing the work and including the person’s certificate number. That’s it.


...the IA is going to need to verify if the AD applies, if they are doing their job.

If the IA was so inclined, he could accept the owner’s verbal statement that the AD was NA because of the s/n and not be in violation of any reg.
 
I am on multiple forums. This is the only one where there is anyone stating that an engine which is twenty years old, never upgrade/overhauled or whatever requires an IA/AP to sign off the non-applicability of the AD.

Tim
 
I am on multiple forums. This is the only one where there is anyone stating that an engine which is twenty years old, never upgrade/overhauled or whatever requires an IA/AP to sign off the non-applicability of the AD.

Tim


Ain't POA great? :D

"We boldly go where ...", yeah you know the deal!
 
A few feel that the model list was to get you to read the AD if you have one of those engines to then look at the further restrictions to see if your engine is affected.
There's only one way to "read" an AD. I’ve mentioned AC 39.7 several times. There are other guidance docs but this one is the go-to reference for ADs. It was issued to guide individuals in how to understand ADs. In it there is a specific section that explains the Applicability statement and how to read it. It even gives a half-dozen examples for slow learners. I believe the first example covers this AD. Its pretty straight forward and has been for many years. But if you and yours want to create your own guidance, have at it. Won’t be the 1st time I’ve seen and heard this. Or the last. People tend to forget an AD is actually a new regulation. This one is Part 39.22355. Because it is a regulation there are certain requirements to follow with the main requirement to identify which product the AD applies to.

Is there any particular reason the new Continental AD couldn’t have been structured similarly to the Lycoming crankshaft AD from over a decade ago?
My guess is the TCM traceability is not at the 100% level for the crankshafts sold from spares. So conceivably those cranks could end up in any of the engine models noted in AD. Its also my understanding there are some other TCM issues that didn’t give the FAA the warm fuzzy on which left the applicability at the model level. Have there been ADs with hundreds of S/Ns in the applicability statement? Yes. And in my experience every effort is made to cull the lists within the given timeframe. However, there was an explanation in this AD docket why they expedited this AD and give the reasons why they bypassed the APA process. It happens. I've already signed-off 4 engines and will probably do another dozen if they need my help. I'm also working on an AMOC to help another friend. So I guess people can waste time beaching about it or simple get'r done.;)

SB and AD require that you measure the ring end gap. So you can't just look, you have to the the specified tool in there.
FYI: I'm assisting on an AMOC to see if we can optically measure the ear gap with a borescope, provided that is we can get the borescope inside to the weights. Film at 11.
 
You’ve wasted more time responding to comments than it would take a mechanic to sign it off. In my opinion, it’s much ado about nothing.
In my opinion, posting a few grumpy comments online is not all that much ado and it is measurably more than nothing to have my plane and thousands of others grounded by a badly worded AD until everyone can find a mechanic with spare time to review logbooks, the AD, and the MSB to decide that a 1999 VAR crankshaft is not on the list of 2021-2023 Continental crankshafts in the MSB.

I’m lucky enough that my plane is in the hangar and a local A&P trusts me to do the initial comparison of serial numbers and brand names. But what would you tell someone to do about this AD if it were issued while he was fueling up his plane halfway home on a Sunday afternoon at an airport without a mechanic within 100 miles? Wait for his AMOC of basic literacy to be approved? Fly an unairworthy plane? I’m more worried about knowing in advance what to do if that’s how the next one befalls me.
 
But what would you tell someone to do about this AD if it were issued while he was fueling up his plane halfway home on a Sunday afternoon at an airport without a mechanic within 100 miles?
Ask him where his books are and see if applicable, then sign it off??
 
Ask him where his books are and see if applicable, then sign it off??
I need to move closer to you and @mondtster … I have some good A&P friends but I’m not convinced any of them would go to my hangar on short notice on a Sunday afternoon to sign off an AD for me, even if they knew their favorite beverage was in ready supply in the hangar fridge. :)
 
But what would you tell someone to do about this AD if it were issued while he was fueling up his plane halfway home on a Sunday afternoon at an airport without a mechanic within 100 miles? Wait for his AMOC of basic literacy to be approved? Fly an unairworthy plane? I’m more worried about knowing in advance what to do if that’s how the next one befalls me.

Well, let's be realistic. Most of the owners aren't going to care (or probably even know) and are going to fly home regardless of the impact of the AD. But, if your situation occurred and I was at the airport or even close to the airport and someone got in that bind I'd work with them to remedy the problem.

Let's also be realistic about the expected effects of this AD. The majority of the affected engines are installed on aircraft that are toys. Does it really matter if it sits "grounded" for a couple of days when it was unlikely that they were going to be flown anyway?
 
Well, let's be realistic. Most of the owners aren't going to care (or probably even know) and are going to fly home regardless of the impact of the AD. But, if your situation occurred and I was at the airport or even close to the airport and someone got in that bind I'd work with them to remedy the problem.

Let's also be realistic about the expected effects of this AD. The majority of the affected engines are installed on aircraft that are toys. Does it really matter if it sits "grounded" for a couple of days when it was unlikely that they were going to be flown anyway?
I believe that the "toys" are flown more than the average GA aircraft, and "a couple of days" may be true, if you prepend "after a wait of several weeks for an appointment at your shop."
 
I believe that the "toys" are flown more than the average GA aircraft, and "a couple of days" may be true, if you prepend "after a wait of several weeks for an appointment at your shop."

I'm assuming you're interpreting my use of the word toys to only mean Cirri. I'm not. Let's face it, the majority of piston aircraft are toys and the Cirrus is no exception.

I know pretty much all the active mechanics in my area and I think I can safely say that pretty much everyone would drop what they were doing to help a customer check and see if their aircraft is affected by this AD and if it isn't, I'm sure they'd sign the AD off. If the engine required disassembly to check the retaining rings, that is another story and you'd get placed in the queue. Even then, I bet the wait time wouldn't be that long.
 
Let's also be realistic about the expected effects of this AD. The majority of the affected engines are installed on aircraft that are toys. Does it really matter if it sits "grounded" for a couple of days when it was unlikely that they were going to be flown anyway?

I believe the number is roughly 700 Cirrus have been affected. Over on COPA, there are a couple active threads related to the AD; and the super majority of the people who are posting that are affected use the plane for business purposes. This is having a very significant material impact to a lot of small business owners.

Now, this is anecdotal, but the point still applies that you might want to suspend the disdain for those who can afford said new toys. Otherwise, there would be no toys for the rest of us.

Tim
 
In my opinion, posting a few grumpy comments online is not all that much ado and it is measurably more than nothing to have my plane and thousands of others grounded by a badly worded AD until everyone can find a mechanic with spare time to review logbooks, the AD, and the MSB to decide that a 1999 VAR crankshaft is not on the list of 2021-2023 Continental crankshafts in the MSB.

I’m lucky enough that my plane is in the hangar and a local A&P trusts me to do the initial comparison of serial numbers and brand names. But what would you tell someone to do about this AD if it were issued while he was fueling up his plane halfway home on a Sunday afternoon at an airport without a mechanic within 100 miles? Wait for his AMOC of basic literacy to be approved? Fly an unairworthy plane? I’m more worried about knowing in advance what to do if that’s how the next one befalls me.
i don't understand your concern at all

FAA said:
(g) Required Action
For affected engines with an installed crankshaft assembly identified in paragraphs (g)(1) or (2) of this AD, before further flight, do the actions identified in, and in
accordance with paragraph III, Action Required, of Continental Mandatory Service Bulletin MSB23–01, Revision A, dated February 16, 2023 (MSB23–01A).
(1) Crankshaft assembly having a crankshaft serial number listed in Appendix 1 of MSB23–01A; or
(2) Crankshaft assembly that was repaired or installed on or after June 1, 2021, having a part number and crankshaft serial number listed in Appendix 2 of MSB23–01A.

Go check your engine serial number. If you don't have your crankshaft serial number handy, was it installed after June 1, 2021? No? Then you're fine
 
I believe the number is roughly 700 Cirrus have been affected. Over on COPA, there are a couple active threads related to the AD; and the super majority of the people who are posting that are affected use the plane for business purposes. This is having a very significant material impact to a lot of small business owners.

Now, this is anecdotal, but the point still applies that you might want to suspend the disdain for those who can afford said new toys. Otherwise, there would be no toys for the rest of us.

Tim

I have no disdain for anyone in this context. I'm just pointing out what the typical usage of the aircraft actually is, which is largely recreation. My comments are not directed at one aircraft type, and actually aren't even directed at the aircraft or the owners of said aircraft who are actually affected by the AD to the point of needing to disassemble and inspect the engine.

If you look at the applicability list, you'll find that there are likely more aircraft of other brands affected by this AD than there are Cirri that are affected. How all those aircraft are affected is another story, which is mainly what I've been responding to. For most this is a 30 minute paperwork shuffle, which is getting blown out of proportion.

Edit: In case someone is wondering, I actually have an engine that is affected as well.
 
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Go check your engine serial number. If you don't have your crankshaft serial number handy, was it installed after June 1, 2021? No? Then you're fine


No, it’s “or” not “and.” You have to ensure that neither (g)(1) nor (g)(2) is true. It’s not enough to satisfy just one.
 
“The manufacturing quality escape has resulted in ground engine seizures and an in-flight loss of engine oil pressure, which could lead to catastrophic engine damage, engine seizure, and consequent loss of the aircraft.”

That’s from the AD. So there was one in-flight failure. I wonder what the outcome was.

I experienced a catastrophic engine failure on a Continental O-470 in a Cessna 182. (this was in 1976). The cause was the same as that addressed by this AD, a circlip not completely seated and the counterweight retaining pin coming out. In this case, the counterweight exited the engine, punching a 6" hole in the case and breaking the right mag off of it's mounts. The engine continued to run, but was vibrating badly. I pulled the power off and dialed the prop control all the way back to alleviate the vibration.
I was able to glide back to the I airport and make a normal landing. After shutdown, I found the counterweight lying on top of the engine.

I have pictures, but I can't figure out how to post them on this forum.
 
I have pictures, but I can't figure out how to post them on this forum.
You should see an "Upload a File" button below the text entry box, next to "Post Reply." If not, then the feature may be restricted to more experienced POA users. I can't recall offhand what restrictions may be in place for the upload feature. I hope that helps.
 
That's good info, Tom.

I know it was a long time ago, but do you happen to recall whether that was a new engine? I'm wondering whether it's really something that fails early or not at all, which seems to be what Continental was suggesting with its attempt to exempt engines with more than 200 hours.
 
182 Engine, Sept. 23 (2)c.jpg 182 Engine, Sept. 23 (2)c.jpg P1000962s.jpg
That's good info, Tom.
This occurred on the second test flight of a field overhauled engine. On the first takeoff, I heard a "funny" noise just as I was lifting off. I returned, and we did an extensive runup and a compression check. Everything sounded and checked OK. I took off again and immediately started a turn to downwind and continued flying upwind/downwind legs and climbing, staying within gliding distance of the airport. When I leveled off at about 6000 ft, I pulled the throttle back to a cruise setting and immediatly heard a loud bang, and the plane started shaking badly. I pulled the power all the way off, the vibration continued, so I dialed the prop control all the way back which stopped the vibration.
I really think that the noise I heard on the first takeoff was when the trailing counterweight pin came out. Amazingly, the engine ran at climb power all the way to 6000' and the complete separation of the counterweight from the crank didn't happen until I did a major power reduction.
I'll try to get a couple of pictures posted.


I know it was a long time ago, but do you happen to recall whether that was a new engine? I'm wondering whether it's really something that fails early or not at all, which seems to be what Continental was suggesting with its attempt to exempt engines with more than 200 hours.
 
So it sounds like it was an infant-mortality situation, for your engine.
 
Edit: In case someone is wondering, I actually have an engine that is affected as well.
Affected as in you're pulling cylinders to check retainers, or affected as in you have to document that the AD doesn't apply by serial number? For you and anyone else who actually has to pull cylinders, I hope you'll share some of what you see on the forum. Despite the headache for all big-bore Continental owners and the much greater headache for a subset of them, it's fascinating to me to understand all the little bits and bobs in these engines.
 
The AD applicability statement is all controlling. If no limitations (S/Ns, alterations, certification category, etc.) are stated in the applicability statement then the AD is effective on all noted models and requires a sign-off by the appropriate person. There are no limiting factors in this AD applicability statement.

It incorporates it by reference:

"
Material Incorporated by Reference:

• For Continental service information identified in this final rule, contact Continental Aerospace Technologies, Inc., 2039 South Broad Street, Mobile, AL 36615; phone: (251) 308-9100; email: MSB23Support@continental.aero; website: continental.aero."


Then further states:

"
(g) Required Action
For affected engines with an installed crankshaft assembly identified in paragraphs (g)(1) or (2) of this AD, before further flight, do the actions identified in, and in accordance with paragraph III, Action Required, of Continental Mandatory Service Bulletin MSB23-01, Revision A, dated February 16, 2023 (MSB23-01A).

(1) Crankshaft assembly having a crankshaft serial number listed in Appendix 1 of MSB23-01A; or


(2) Crankshaft assembly that was repaired or installed on or after June 1, 2021, having a part number and crankshaft serial number listed in Appendix 2 of MSB23-01A."

So it DOES NOT apply to all engines. Only those
 
Affected as in you're pulling cylinders to check retainers, or affected as in you have to document that the AD doesn't apply by serial number? For you and anyone else who actually has to pull cylinders, I hope you'll share some of what you see on the forum. Despite the headache for all big-bore Continental owners and the much greater headache for a subset of them, it's fascinating to me to understand all the little bits and bobs in these engines.

Mine is likely just a paperwork investigation. The engine had some work in the last few years but not an overhaul and is not a factory new or reman so I’m sure it will just turn into a sign off. The airplane is stored 300 miles away so I’ll look at it when I go up there to the avionics work on it I have planned.
 
It incorporates it by reference:

It incorporates by reference, but not *in the applicability statement*. That is where the FAA screwed up. Are the FAA police going to hunt you down and throw you in FAA-jail for making the determination yourself before flying, without a "sign off"? No, they don't have the time, resources or inclination to do that. But for those of us with certified aircraft, it is an i's-doted and t-'s crossed thing.
 
Sign off the AD yourself. After your signature and cert number, put the letters "AP" which stand for "A Pilot" :D
 
No, it’s “or” not “and.” You have to ensure that neither (g)(1) nor (g)(2) is true. It’s not enough to satisfy just one.
I know it's an "or"

Disclaimer: Assume I am totally wrong
But if you read the details from Continental you can see that the only crankshafts affected which are included in that serial # list were manufactured/assembled after June 1, 2021 by Continental. If that information is wrong, then the FAA and Continental need to clarify. But the manufacturing quality escape, as they put it, was due to somebody in their shop screwing up who must have been working after June 1, 2021. Therefore if you did not change your engine or crankshaft after June 1, 2021 - this cannot apply to you
 
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