Silk thread vs sealant

[JAWS]

But what if there are no set practices or products for the aircraft or task you need to work on? Most aircraft don't have a procedure for every possible maintenance task nor does every aircraft have a MM.

I totally agree. I freely admit to using other practices where there is nothing mentioned, following the term "standard industry practices".

But, in this case of using or not using silk thread, there is a set practice, in the O200 overhaul manual. Not following this guidance is, as mentioned above, the prerogative of the person certifying the work.

But why go down that path? That is the part I don't get.

 

[Cap'n Jack]

Man. If you ever make a professional mistake - it’s going to be fun to watch karma strike back. Universe is nice that way. Your obsession that causes you to continually post a reference to a NTSB report involving Tom in Tom’s threads tells everyone a lot about you.

The NTSB investigated. The FAA handled it. However that doesn’t mean Jack is done with it!

I know who I’d rather hang with. The guy who turns wrenches and tries to help. Versus the guy who picks on elder veterans and can’t ever let an issue drop.

You choice, Jesse. I really don't care who wants to hang with me. I respect and appreciate his service military service, although I don't understand why that need to be mentioned here, since that isn't pertinent to anything. It's like saying a veteran should be absolved of wrong-doing because s/he is a veteran. The link in question never said who worked on the plane, I didn't bring up any other aspects of the report, nor any links to anything else. I only mentioned the portion that was on-topic, the possibility of the sealant getting into places it shouldn't. I also questioned the use of "hylomar" in this thread.

BTW- your signature link is bad- leads to an page saying it is expired.

 

[Bell206]

You mention two terms that are misunderstood by many people. "acceptable data", "acceptable methods". Explain the difference.

Technically there is no difference. Both fall under the more general tag "acceptable to the Administrator." Depending on the specific guidance reference used you might see separate terms like #1 below. But reference #2 combines it all.

a. Acceptable Data. Data is acceptable to the Administrator when used within the context of maintenance, a minor repair, or an alteration if the data substantiates that the product has been returned to its original or properly altered condition. Acceptable data may establish that the fabricated part complies with applicable airworthiness standards (i.e., regulations). When acceptable data is used to substantiate that the article meets the regulatory requirements and will be returned to its original or properly altered condition, it can be considered acceptable to the Administrator.
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2.2.2.2 Acceptable Data.

2.2.2.2.1 Acceptable data means data acceptable to the FAA. The terms “acceptable to the Administrator” and “acceptable to the FAA” appear numerous times in the maintenance regulations. They refer to any item addressed in the regulation (e.g., data; methods, techniques, and practices; manual contents; tools; materials; equipment; etc.) that must meet regulatory standards. If the regulation requires only that an item must be “acceptable to,” it does not necessarily follow that the FAA requires the item to have specific FAA review and acceptance before it may be used. A person making a determination of whether an item is “acceptable to” the agency must ensure the item addresses specific applicable section(s) of the regulations.


2.2.2.2.2 Items required by regulation to be “acceptable to” the FAA or to the Administrator (unless otherwise required by regulation to be approved) do not necessarily require FAA review and acceptance prior to a person using the item. A person using an item that must be acceptable to the FAA should be able to demonstrate that the item meets all applicable regulatory requirements. If, however, upon subsequent review of the item, the FAA believes the item is not acceptable, the agency has the burden of demonstrating its unacceptability in any related enforcement matter. In any event, if an ASI finds an item unacceptable to the FAA, the ASI must immediately inform the maintenance provider/certificate holder, in writing, of the potential noncompliance and request compliance.

Sending parts to a uncertified repair station, and then not testing the equipment is totally beyond the realm of proper maintenance IAW FAR 43.13

i.e., unacceptable to the Administrator

 

[Bell206]

I totally agree.

FYI: my original comments were in general to Dan's general post, not to the specific silk thread issue.

But why go down that path? That is the part I don't get.

I know of several shops that no longer use silk and use an in-house technique. But how does that saying go: "Necessity is the mother of invention."

 

[Cap'n Jack]

SNIP

I know of several shops that no longer use silk and use an in-house technique. But how does that saying go: "Necessity is the mother of invention."

Not intending as a critique, but how would an aircraft owner know the in-house techniques are acceptable? If an owner is responsible for airworthiness, what can tell them what deviations from the manufacturer's overhaul manual are acceptable?

 

[JAWS]

I know of several shops that no longer use silk and use an in-house technique. But how does that saying go: "Necessity is the mother of invention."

Interesting. Would these alternative techniques be formally approved?

 

[Tom-D]

Interesting. Would these alternative techniques be formally approved?

Minor alterations need no specific approval. the decision is that of the mechanic.

 

[JAWS]

Not intending as a critique, but how would an aircraft owner know the in-house techniques are acceptable? If an owner is responsible for airworthiness, what can tell them what deviations from the manufacturer's overhaul manual are acceptable?

My point, sort of. The aircraft owner can only do so much. As long as the certification is there, that is all he can do. He wouldn't know what deviations occurred, though he gets to deal with the end results. Same with the installing mechanic.

I have installed many overhauled engines and I wouldn't know if Bob used X product instead of Y product. I have to trust that the references (if any) in the certification actually were followed.

Gosh I love the wonderful world of aviation!

 

[Bell206]

but how would an aircraft owner know the in-house techniques are acceptable? If an owner is responsible for airworthiness, what can tell them what deviations from the manufacturer's overhaul manual are acceptable?

Actually there is no regulatory requirement for the owner to personally know the details of the maintenance performed. The owner’s responsibility changes when he turns over the aircraft to the mechanic. It resumes once he receives the aircraft back from the mechanic. Since Part 43 is a “performance regulation” the mechanic owns everything in between until death or that specific maintenance task is repeated. And Part 91, i.e., owner airworthiness requirement, follows that same basic path.

Should an owner understand the details of all work performed, sure. And an engaged owner will. But it’s my experience a majority of owners usually want to know only 2 things: how much and how long.

 

[Bell206]

formally approved?

Depends. Two of the shops are CRSs. So they more than likely have the procedure listed in their RSM which would make is quasi-approved. The other is/was a single man shop. But as mentioned above it would only require “formal approval” if it met the definition of a major alteration or repair. Otherwise a simple note in the logbook entry of the deviation is the only thing that is required—which he does/did.

 

[JAWS]

Should an owner understand the details of all work performed, sure. And an engaged owner will. But it’s my experience a majority of owners usually want to know only 2 things: how much and how long.

I agree.

 

[JAWS]

Depends. Two of the shops are CRSs. So they more than likely have the procedure listed in their RSM which would make is quasi-approved. The other is/was a single man shop. But as mentioned above it would only require “formal approval” if it met the definition of a major alteration or repair. Otherwise a simple note in the logbook entry of the deviation is the only thing that is required—which he does/did.

Making note of the deviation in the maintenance entry makes sense. Though I would still be very careful about such eliminations or deviations. I wouldn't eliminate the silk thread myself and use the recommended sealant, but that is me.

Fly (and maintain) safely!

 

[Tarheelpilot]

There sure is a lot of hair splitting going on in here. I don’t see what the dispute is about.

It’s true that a mechanic is not bound to the overhaul manual for all things related to the work performed. We enjoy quite a bit of freedom in deciding what’s best as an A&P in the US. Personally I choose to follow the manufacturers manual to limit my personal liability. That’s the same reason I don’t work on aircraft no longer being supported by a TCDS holder.

To each their own. If Tom wants to go on his own he needs to be ready to defend those choices when something goes wrong. His choice.

 

[Tom-D]

Technically there is no difference. Both fall under the more general tag "acceptable to the Administrator." Depending on the specific guidance reference used you might see separate terms like #1 below. But reference #2 combines it all.

Acceptable data, and acceptable methods have different meanings.

Acceptable data, is data acceptable for the administrator to be approved for an engineering change. Some Paragraphs in AC43,13 is in some cases is Acceptable data.

Acceptable Method, is a way to do something, it may not be the only way to do the deed, but it is acceptable way to get it done.
To me they do not mean the same thing.

 

[Tom-D]

To each their own. If Tom wants to go on his own he needs to be ready to defend those choices when something goes wrong. His choice.

Get it right, Tom does not go on his own, he complies with 43.2 to the letter.

 

[JAWS]

Acceptable data, and acceptable methods have different meanings.

Acceptable data, is data acceptable for the administrator to be approved for an engineering change. Some Paragraphs in AC43,13 is in some cases is Acceptable data.

Acceptable Method, is a way to do something, it may not be the only way to do the deed, but it is acceptable way to get it done.
To me they do not mean the same thing.

Go read the introduction page of AC43.13-1B.

 

[Tom-D]

Go read the introduction page of AC43.13-1B.

And your point is?

 

[Tarheelpilot]

Get it right, Tom does not go on his own, he complies with 43.2 to the letter.

Yeah. That’s what I was referring to. Didn’t mean to infer otherwise