Oh Continental, what have you done now?

[Bell206]

The real question I have is whether I need a mechanic to sign off "AD N/A this serial number."

Yes. There's no provision stated in the applicability section allowing a pilot.

Does the mechanic have to be an IA?

No.

I need a ferry permit to bring my obviously-not-affected aircraft to a mechanic

If not applicable, that's up to the mechanic.

Emergency ADs like this are frustrating because they force airplane owners to do legal research,

Its not an emergency AD. Those are different. How is it frustrating? Owners are already required by Part 91 to ensure AD compliance. This AD is no different.

There's no obligation to do anything if it isn't one of those,

FYI: since the S/N listing is not part of the AD applicability statement every aircraft with those engine models named in the applicability statement will require a sign off. Even if N/A. Had the S/N listing been part of the AD applicability statement then no further work or entry would have been required if not within the S/N range.

 

[iamtheari]

Its not an emergency AD. Those are different. How is it frustrating? Owners are already required by Part 91 to ensure AD compliance. This AD is no different.

Labeled an emergency AD or not, the FAA issued the AD (1) without a comment period before it takes effect, (2) without allowing any flight at all until the AD is complied with, and (3) without any way for a pilot to fly his not-affected aircraft until he gets a mechanic to either review the AD and sign the engine logbook or get a ferry permit with specific oil filter inspection requirements per the AD. My obviously not affected airplane is grounded without regard to whether and when I can get a mechanic to look at the AD and the engine logbook to confirm that my crankshaft predates the affected serial numbers by maybe a decade. That frustrates me.

Most airplane owners comply with most ADs by taking their plane in for an annual inspection and trusting the mechanic to research ADs and log which of them are inapplicable, already complied with, or newly complied with by the mechanic's work. I think the average POAer who owns a plane goes above and beyond that. But I think that an AD that legally grounds a fleet of planes it doesn't apply to without so much as a public comment period is outside of even the most conscientious airplane owner's norm.

Thank you for answering my questions, though. I'm still frustrated with the FAA but at least I can save a research step and start pestering the very limited number of local mechanics to look at my logbook and verify that they don't have to pull cylinders and unnecessarily add to my maintenance-induced risks.

 

[Bell206]

Most airplane owners comply with most ADs by taking their plane in for an annual inspection

FYI: an owners responsibility for AD compliance is 365 days a year and not just at annual time. Regardless, I'd be pizzed at TCM. Think of all the guys who have to open a brand new engine on a brand new plane in some cases. I guess it depends on your point of view. I know of one person with two of the affected engines that require 3 cylinders pulled on each. But I get it.

 

[iamtheari]

FYI: an owners responsibility for AD compliance is 365 days a year and not just at annual time. Regardless, I'd be pizzed at TCM. Think of all the guys who have to open a brand new engine on a brand new plane in some cases. I guess it depends on your point of view. I know of one person with two of the affected engines that require 3 cylinders pulled on each. But I get it.

I agree that owners are responsible for AD compliance at all times. But prescriptive and descriptive viewpoints differ on how owners go about their AD compliance. This is one of those places where the burden of following the rules is needlessly greater than the burden of blissful ignorance.

Don't get me wrong. I'm displeased with TCM. Their lack of QA controls in 2021 has led to the FAA grounding thousands of engines that were safely in the air at the time. The FAA is still the one that performed surgery with a chainsaw instead of a scalpel.

 

[Bell206]

This is one of those places where the burden of following the rules is needlessly greater than the burden of blissful ignorance.

You can always try an AMOC to gain some time considering your engine/crank is not applicable. I'm aware of several that are trying for similar reasons. Don't know of their success or not, but all they can say is no.

 

[150Mike]

Did you have to flip the retaining ring, or did you tap it into place?

Do you think you could snake a borescope in to see the rings before cylinder removal? Or if the engine requires 2 or 3 cylinders off, do you think a borescope could see the other rings with only one cylinder off?

The AD requires you to follow the accomplishment instructions under Section III of the MSB. It specifies how many cylinders to remove based on engine type; it does not give you an option to pull fewer cylinders and use a boroscope. Besides which, you have to be able to reach inside the engine and check the snap rings on each counterweight/harmonic balancer with the special tool specified - essentially a "go-no go" gauge that must be placed flat against the cover plate on each c/w and fit in between the end tabs of each snap ring. That being said, there is an option to request an AMOC from the FAA, but I don't think that your boroscope idea will cut it.

 

[schmookeeg]

Wait, why does a mechanic need to sign this off as a N/A? The Applicability lists basically all conti 6-bangers, but the Required action is preambled as "For affected engines" which Ari (and I) do not have.

So this seems like Schrodinger's AD. "You must do, for all engines" ... "Nothing". I feel like they left out a "For non-affected engines, bugger off" paragraph on the AD. As it stands, though, the Required Action for a non-affected engine is null. You would need to have an A&P to perform the required action. There is no action. I'd argue you don't need an A&P to do nothing.

Would the FAA burn an owner for signing, correctly, N/A by serial number and going about his flying business? For what?

(not trying to argue, trying to understand the diseased logic of the A&P requirement here)

 

[iamtheari]

Wait, why does a mechanic need to sign this off as a N/A? The Applicability lists basically all conti 6-bangers, but the Required action is preambled as "For affected engines" which Ari (and I) do not have.

So this seems like Schrodinger's AD. "You must do, for all engines" ... "Nothing". I feel like they left out a "For non-affected engines, sign and fly" paragraph on the AD. As it stands, though, the Required Action for a non-affected engine is null. You would need to have an A&P to perform the required action. There is no action. I'd argue you don't need an A&P to do nothing.

Would the FAA burn an owner for signing, correctly, N/A by serial number and going about his flying business? For what?

(not trying to argue, trying to understand the diseased logic of the A&P requirement here)

You've really never paid an A&P to do nothing? Are you sure you've even seen an airplane in person?

 

[schmookeeg]

You've really never paid an A&P to do nothing? Are you sure you've even seen an airplane in person?

I AM an A&P and I'm doing nothing right now. My thought is that I am not exercising my certificate (or anything else) by sitting here grouching forums.

 

[Bell206]

there is an option to request an AMOC from the FAA, .

That's what we're working on and trying to get as much input as possible. So even with one cylinder off you don't think a borescope will get around case webbing to see the other retainer rings? FYI: I'm fully aware of what the AD requires for the inspection.

 

[Bell206]

why does a mechanic need to sign this off as a N/A? The Applicability lists basically all conti 6-bangers,

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.

 

[schmookeeg]

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.

Ugh. So the feds pooched it by not incorporating a reference to the MSB in the Applicability section. Okay.

 

[iamtheari]

Ugh. So the feds pooched it by not incorporating a reference to the MSB in the Applicability section. Okay.

I think that was a baby-and-bathwater thing. The AD reads like "The MSB doesn't go far enough!" but then throws out the part of the MSB that makes this a question of 2,000 airplanes rather than 200,000. (Numbers fabricated to make a point, that point being that I want to go flying.)

 

[Tokirbymd]

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.

Just had a discussion with my IA about this. They recently discussed it at an IA seminar. If your SN is not in the list the AD doesn't apply and don't need a sign off saying that. They even went so far as to say that if an AD is not applicable to your plane then you do not have to have a record for it. Makes sense, otherwise my Piper would have a whole logbook of signoffs on every AD for every other make and model saying NA.

 

[Bell206]

If your SN is not in the list the AD doesn't apply and don't need a sign off saying that.

As I stated above, it all depends where the S/N list is whether you need a sign off. If the S/N list is in the AD Applicability Statement, and your aircraft does not fall within that list, then the AD is not applicable and requires no sign off or record. Period. If the S/N list is not in the AD Applicability Statement as with this TCM AD (below), then the AD is applicable and requires a sign-off and record even if the sign-off states the AD is not applicable. Been this way for years. Its the same route that can make ADs applicable to E/AB as well with how the Applicability Statement is worded. There are also several guidance docs out there.

 

[tspear]

Labeled an emergency AD or not, the FAA issued the AD (1) without a comment period before it takes effect, (2) without allowing any flight at all until the AD is complied with, and (3) without any way for a pilot to fly his not-affected aircraft until he gets a mechanic to either review the AD and sign the engine logbook or get a ferry permit with specific oil filter inspection requirements per the AD. My obviously not affected airplane is grounded without regard to whether and when I can get a mechanic to look at the AD and the engine logbook to confirm that my crankshaft predates the affected serial numbers by maybe a decade. That frustrates me.

Most airplane owners comply with most ADs by taking their plane in for an annual inspection and trusting the mechanic to research ADs and log which of them are inapplicable, already complied with, or newly complied with by the mechanic's work. I think the average POAer who owns a plane goes above and beyond that. But I think that an AD that legally grounds a fleet of planes it doesn't apply to without so much as a public comment period is outside of even the most conscientious airplane owner's norm.

Thank you for answering my questions, though. I'm still frustrated with the FAA but at least I can save a research step and start pestering the very limited number of local mechanics to look at my logbook and verify that they don't have to pull cylinders and unnecessarily add to my maintenance-induced risks.

Where in the AD does it ground any plane with an engine not listed in the serial number list?

Tim

 

[tspear]

As I stated above, it all depends where the S/N list is whether you need a sign off. If the S/N list is in the AD Applicability Statement, and your aircraft does not fall within that list, then the AD is not applicable and requires no sign off or record. Period. If the S/N list is not in the AD Applicability Statement as with this TCM AD (below), then the AD is applicable and requires a sign-off and record even if the sign-off states the AD is not applicable. Been this way for years. Its the same route that can make ADs applicable to E/AB as well with how the Applicability Statement is worded. There are also several guidance docs out there.

View attachment 115334

That is not controlling. Read the whole AD. The applicable text is the following:

This AD requires accomplishing the actions specified in paragraph III, Action Required, of MSB23-01A, except as discussed in “Exception to the Service Information.”

The exception is the 200 limit and ferry time. In any case, you really should read the full AD; not just the preamble from which your excerpt was taken.

Tim

 

[Bell206]

In any case, you really should read the full AD; not just the preamble from which your excerpt was taken.

My attachment above is from the AD itself and not the preamble as shown below. If you don't think the Applicability Statement is not controlling have at it. But you may want to review AC 39-7 again on how applicability statements actually work.

 

[Tokirbymd]

My attachment above is from the AD itself and not the preamble as shown below. If you don't think the Applicability Statement is not controlling have at it. But you may want to review AC 39-7 again on how applicability statements actually work.

View attachment 115336

"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 for engines not identified in g(1) or g(2), there is no required action. I don't think every Continental engine owner has to rush out and immediately have their logbooks amended with NA prior to further flight. Nor do I think the FAA intended this either. Maybe an oversight in their rush to publish the AD and one that should be addressed with followup public comments.

 

[Bell206]

have their logbooks amended with NA prior to further flight.

You're off one paragraph. See (f). The before flight applies to the NA as well as any inspection except for a ferry permit.

 

[Half Fast]

...though it is handy to note that you've determined the AD doesn't apply to you.

Agreed. When I was getting ready for my first annual, I compiled a list of all the ADs for my airframe, engine, and prop, then annotated which ones were NA and why (serial # not in range, affected part not installed, etc.). Also which ones had been TCO'd previously. Took away some worries and made things easier for my A&P-IA. Plus it's good to have for prospective buyers if I ever decide to sell.

ADs are an owner responsibility. Who can legally prove compliance varies, but it's still the owner who is responsible.

 

[Half Fast]

Maybe they were mixing Conti and Lyco parts in a lab and had an accidental release.

Too soon?

No. Too late.

 

[tspear]

@Bell206

Hmm, that looks like a screw up.

Tim

 

[Half Fast]

So for engines not identified in g(1) or g(2), there is no required action.

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

How do you check the crankshaft serial number without opening the engine? Is there a build record by engine s/n that records it?

 

[Dan Thomas]

Since these are newer engines, most will be under warranty.

Aircraft and aircraft engine warranties are not as generous as automobile warranties. No competition, basically. This is Continental's warranty for new engines:




For factory rebuilts (zero-timed):



For factory overhauls:




None of these five-year warranties like automakers offer. So, how old are these affected engines?

 

[iamtheari]

How do you check the crankshaft serial number without opening the engine? Is there a build record by engine s/n that records it?

Yes. There is probably a document somewhere with a record of component serial numbers. But finding that document might prove challenging. My current engine logbook (the one I brought home tonight to study) doesn’t have the number. So my search continues.

 

[iamtheari]

Where in the AD does it ground any plane with an engine not listed in the serial number list?

Tim

(c) Applicability
Continental Aerospace Technologies, Inc. (Continental) GTSIO-520-C, -D, -H, -K, -L, -M, -N, and -S; IO-360-A, -AB, -AF, -C, -CB, -D, -DB, -E, -ES, -G, -GB, -H, -HB, -J, -JB, -K, and -KB; IO-470-D, -E, -G, -H, -J, -K, -L, -M, -N, -P, -R, -S, -T, -U, -V, and -VO; IO-520-A, -B, -BA, -BB, -C, -CB, -D, -E, -F, -J, -K, -L, -M, and -MB; IO-550-A, -B, -C, -D, -E, -F, -G, -L, -N, -P, and -R; LTSIO-360-E, -EB, -KB, and -RB; LTSIO-520-AE; O-470-A, -B, -E, -G, -H, -J, -K, -L, -M, -N, -R, -S, -T, and -U; TSIO-360-A, -AB, -B, -BB, -C, -CB, -D, -DB, -E, -EB, -G, -GB, -H, -HB, -JB, -KB, -LB, -MB, -RB, and -SB; TSIO-520-A, -AE, -AF, -B, -BB, -BE, -C, -CE, -D, -DB, -E, -EB, -G, -H, -J, -JB, -K, -KB, -L, -LB, -M, -NB, -P, -R, -T, -UB, -VB, and -WB; TSIO-550-A, -B, -C, -E, -G, -K, and -N; TSIOF-550-K; and TSIOL-550-A, -B, and -C model reciprocating engines.

(f) Compliance
Comply with this AD within the compliance times specified, unless already done.

(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.

(k) Special Flight Permit
Special flight permits may be issued in accordance with 14 CFR 21.197 and 21.199 to permit a one-time, non-revenue ferry flight to operate the aircraft to a location where the maintenance actions can be performed, provided that:

(1) The engine oil filter pleats or screen are first inspected and there is no evidence of metal contamination; or

(2) An oil change has been done within the previous 5 flight hours, and there was no evidence of metal contamination in the oil filter pleats or screen.

So it depends on who is allowed to determine if the crankshaft serial number is in the cited appendices to MSB23-01A. The first part of (g) is poorly written, probably because they issued it in a hurry without waiting for public comment or even for their counsel to get enough coffee to proofread it that morning. But it is clearly prohibited to fly a plane with any of the models of engine listed in (c) until you comply with (g), which definitely requires some action and possibly requires that a mechanic perform that action.

 

[Bell206]

Is there a build record by engine s/n that records it?

My current engine logbook (the one I brought home tonight to study) doesn’t have the number. So my search continues.

Depends. If you have a TCM engine they keep build records for many years. If it was bought or OH'd elsewhere things may get a bit more complicated. However, if you have documentation the last time the engine was split outside the production dates of these crankshafts you may have a route to get the AD signed via an AMOC or other possible TCM approval. Look in your logbooks for when the engine was installed and trace it back. I wouldnt pull a cylinder until you extinguish all possibilities.

 

[Dan Thomas]

I have been kindly corrected regarding the warranty provisions. The applicable Service Bulletin has this in it:

 

[Ryan Klems]

How do you check the crankshaft serial number without opening the engine? Is there a build record by engine s/n that records it?

Serial number should be on the flange of the crankshaft

 

[Half Fast]

Depends. If you have a TCM engine they keep build records for many years. If it was bought or OH'd elsewhere things may get a bit more complicated. However, if you have documentation the last time the engine was split outside the production dates of these crankshafts you may have a route to get the AD signed via an AMOC or other possible TCM approval. Look in your logbooks for when the engine was installed and trace it back. I wouldnt pull a cylinder until you extinguish all possibilities.

Glad I’m not directly affected as my Beech has a Lycoming, but it sounds like there may be considerably more planes involved than the 2000 or so estimated. This will have some impact on everyone, though, no matter what they fly, as shops become backed up.

 

[Daleandee]

This will have some impact on everyone, though, no matter what they fly, as shops become backed up.

Not so fast, Half Fast ... I'm hugging my non-TCM equipped experimental again!

 

[Bell206]

but it sounds like there may be considerably more planes involved than the 2000 or so estimated.

I don't think so. There's a bit of chicken little going on similar to the Piper spar AD but as legit info makes the rounds things should calm down. That said, if you have one of these new cranks/engines then yes there will be hiccups in the near future.

 

[NordicDave]

Just had the engine majored a few months ago. The engine model is listed, however both the engine and crankshaft serial numbers are outside the list. I made sure any new parts required came from sources other than Continental.

 

[tspear]

@Bell206

This was the answer I got when I basically posted your comments about the controlling section.
1. They’re incorrect. The beginning of the AD says “for certain Continental…”
2. Reading further down, Section (g) gives the limitations, defining “certain” from the beginning of the AD

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.

Tim

 

[Pinecone]

Did you have to flip the retaining ring, or did you tap it into place?

Do you think you could snake a borescope in to see the rings before cylinder removal? Or if the engine requires 2 or 3 cylinders off, do you think a borescope could see the other rings with only one cylinder off?

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.

 

[mondtster]

@Bell206

This was the answer I got when I basically posted your comments about the controlling section.
1. They’re incorrect. The beginning of the AD says “for certain Continental…”
2. Reading further down, Section (g) gives the limitations, defining “certain” from the beginning of the AD

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.

Tim

I think there’s a misunderstanding of what Bell is trying to convey. The applicability section seems quite clear to me, and I read it the same way he does. So it applies to all the engines listed, but the action for compliance may be as simple as reading the AD to confirm that the engine in question may not have the affected parts installed.

In other words, even if you know your engine doesn’t have the affected parts installed but is listed in the applicability section, you have to do something.

 

[iamtheari]

I think there’s a misunderstanding of what Bell is trying to convey. The applicability section seems quite clear to me, and I read it the same way he does. So it applies to all the engines listed, but the action for compliance may be as simple as reading the AD to confirm that the engine in question may not have the affected parts installed.

In other words, even if you know your engine doesn’t have the affected parts installed but is listed in the applicability section, you have to do something.

My opinion remains that they did this surgery with a chainsaw instead of a scalpel. The applicability section should be limited to engine serial numbers listed in the SB plus those that have been overhauled or had a crankshaft replaced on or after 6/1/2021. That would seem to capture all potentially affected engines and crankshafts without requiring action or creating confusion and frustration for the more numerous definitely-not-affected engines and crankshafts.

My VAR crankshaft installed in 1999 is very clearly not a cause for concern, but because the AD applies to all IO-520 engines I need to either find a mechanic with spare time to sign off on that or wait for the FAA to moderate its knee-jerk AD with an amended AD or other guidance. This didn’t need to be a problem and all it would have taken was a competent lawyer proofreading the AD.

I hope I have time to submit a comment to that effect. Unlike the last time a federal agency upended part of my life due to not having one of the 500,000 lawyers receiving a GS salary proofread a sweeping edict, the FAA at least reads public comments.

 

[mondtster]

My opinion remains that they did this surgery with a chainsaw instead of a scalpel. The applicability section should be limited to engine serial numbers listed in the SB plus those that have been overhauled or had a crankshaft replaced on or after 6/1/2021. That would seem to capture all potentially affected engines and crankshafts without requiring action or creating confusion and frustration for the more numerous definitely-not-affected engines and crankshafts.

My VAR crankshaft installed in 1999 is very clearly not a cause for concern, but because the AD applies to all IO-520 engines I need to either find a mechanic with spare time to sign off on that or wait for the FAA to moderate its knee-jerk AD with an amended AD or other guidance. This didn’t need to be a problem and all it would have taken was a competent lawyer proofreading the AD.

I hope I have time to submit a comment to that effect. Unlike the last time a federal agency upended part of my life due to not having one of the 500,000 lawyers receiving a GS salary proofread a sweeping edict, the FAA at least reads public comments.

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.

 

[Half Fast]

It appears to me that this phrase from (g)

For affected engines with an installed crankshaft assembly identified in paragraphs (g)(1) or (2) of this AD...​

should have been in section (c) as it is really an applicability statement, not a required action.

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?