Things that get ignored

Yep. Every inspection I have certified is wrong. Every audit is wrong because they didn't catch my wrongness. :cool:

Tom is welcome to his opinions. I wish him luck. :)
 
bradg33 said:
To be clear, you don't think that the interpretation posted above from the FAA Office of Chief Counsel is of any significance at all? The FAA wrote the regulations; the FAA enforces those regulations. The FAA Office of Chief Counsel tells the FAA employees, and us, what the regulations actually mean (they are the "interpreters" of the regulations). But, your take is it doesn't matter what the FAA Chief Counsel says, all that matters is the plain words used in the regulations (as YOU interpret them), despite the fact that the FAA itself has issued an official interpretation of what those words mean?
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But who reads them correctly, when they do not understand what Shall means?

Simple stuff means a lot.

From my link above.

Until recently, law schools taught attorneys that "shall" means "must." That's why many attorneys and executives think "shall" means "must." It's not their fault. The Federal Plain Writing Act and the Federal Plain Language Guidelines only appeared in 2010. And the fact is, even though "must" has come to be the only clear, valid way to express "mandatory," most parts of the Code of Federal Regulations (CFRs) that govern federal departments still use the word "shall" for that purpose.

So was FAR 43-D written prior to 2010?
Which meaning did the FAA imply.
 
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Tom-D said:
But who reads them correctly, when they do not understand what Shall means?

Simple stuff means a lot.

From my link above.

Until recently, law schools taught attorneys that "shall" means "must." That's why many attorneys and executives think "shall" means "must." It's not their fault. The Federal Plain Writing Act and the Federal Plain Language Guidelines only appeared in 2010. And the fact is, even though "must" has come to be the only clear, valid way to express "mandatory," most parts of the Code of Federal Regulations (CFRs) that govern federal departments still use the word "shall" for that purpose.

So was FAR 43-D written prior to 2010?
Which meaning did the FAA imply.
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I read the entire document, and it sounds to me like they're saying that "Shall" shouldn't be used any more, period, due to perceived ambiguity (thank you, USSC). They're saying that new regulations should not use Shall at all, they should use "Must", but that where Shall still appears, it means Must.
 
Tom-D said:
But who reads them correctly, when they do not understand what Shall means?

Simple stuff means a lot.

From my link above.

Until recently, law schools taught attorneys that "shall" means "must." That's why many attorneys and executives think "shall" means "must." It's not their fault. The Federal Plain Writing Act and the Federal Plain Language Guidelines only appeared in 2010. And the fact is, even though "must" has come to be the only clear, valid way to express "mandatory," most parts of the Code of Federal Regulations (CFRs) that govern federal departments still use the word "shall" for that purpose.

So was FAR 43-D written prior to 2010?
Which meaning did the FAA imply.
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Good job dodging my question. Let's try it this way, correct me if I'm wrong: your position is that the interpretation of an FAA regulation by the FAA's own Office of Chief Counsel carries less weight than your own interpretation of that regulation? You have that position despite the fact that the FAA wrote the reg, is charged with interpreting and enforcing the reg, and the Office of Chief Counsel, which within the FAA is the office responsible for providing interpretations of the FAA regs, has issued an interpretation on this very point that says that the pre-inspection tasks such as removing inspection panels and cowls may be delegated?
 
bradg33 said:
Good job dodging my question. Let's try it this way, correct me if I'm wrong: your position is that the interpretation of an FAA regulation by the FAA's own Office of Chief Counsel carries less weight than your own interpretation of that regulation? You have that position despite the fact that the FAA wrote the reg, is charged with interpreting and enforcing the reg, and the Office of Chief Counsel, which within the FAA is the office responsible for providing interpretations of the FAA regs, has issued an interpretation on this very point that says that the pre-inspection tasks such as removing inspection panels and cowls may be delegated?
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not my positional all.
 
flyingcheesehead said:
I read the entire document, and it sounds to me like they're saying that "Shall" shouldn't be used any more, period, due to perceived ambiguity (thank you, USSC). They're saying that new regulations should not use Shall at all, they should use "Must", but that where Shall still appears, it means Must.
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That is my take too.
This regulation was written long ago, Prior to farther clarification of the meaning.
But every one blows it off due to the later interpretation.
 
flyingcheesehead said:
I read the entire document, and it sounds to me like they're saying that "Shall" shouldn't be used any more, period, due to perceived ambiguity (thank you, USSC). They're saying that new regulations should not use Shall at all, they should use "Must", but that where Shall still appears, it means Must.
Click to expand...

And aviation will never be the same again! :p
 
bradg33 said:
So you accept that an IA can delegate to an owner or other person tasks such as removing inspection panels, cowls, etc. in connection with an annual or 100hr inspection?
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post 88
 
Tom-D said:
post 88
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Don't know about up in the PNW, but the FSDOs and FAA seminars I've been through have been promoting owner involvement in annuals for over 25 years, specifically panels and cleaning. I guess the Feds finally had to clarify that stance with an LOI for those who are still confused by "before that inspection."
 
Tom-D said:
That is my take too.
This regulation was written long ago, Prior to farther clarification of the meaning.
But every one blows it off due to the later interpretation.
Click to expand...

Even so, the FAA's letter of interpretation that was posted earlier makes it abundantly clear that it's OK to delegate the opening of panels, cleaning, etc to someone else, yet it sounds like you disagree? Why?
 
flyingcheesehead said:
Even so, the FAA's letter of interpretation that was posted earlier makes it abundantly clear that it's OK to delegate the opening of panels, cleaning, etc to someone else, yet it sounds like you disagree? Why?
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LOI's do not delete what the AD says, this Regulation was written long before the meaning changed, You do as you like, I know you will anyway.
 
bradg33 said:
All you're proving is that you're good at dodging questions.
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IOWs you didn't read it or you can't understand what it say. either way ?
Why repeat it, you wouldn't understand then either.
 
Stewartb said:
Things that get ignored? Brake masters. Many have never been rebuilt. They need to be.
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For sure. I find sludge in them. Haven't been out in 40 years.

Another one is the fuel strainer (gascolator). I have found the bowls stuck solid to the upper body and have had to use a hammer to break them loose. The O-rings are hard and crumbling. The filter screen is full of junk. The aluminum bowl is corroded almost all the way through because nobody ever drained the water out of the thing. A fuel filter is a common-sense item, isn't it? A leaking strainer is asking for a fire. A blocked strainer kills the engine. Cessna wants that thing apart every 100 hours or one year. I can't understand how some shops can ignore an important part of the fuel system for so many years. One year is long enough.
 
Carburetor fuel inlet screens, Lycoming oil suction screens, vacuum regulator filter, vacuum system filter. Just about anything really.
 
Dan Thomas said:
For sure. I find sludge in them. Haven't been out in 40 years.

Another one is the fuel strainer (gascolator). I have found the bowls stuck solid to the upper body and have had to use a hammer to break them loose. The O-rings are hard and crumbling. The filter screen is full of junk. The aluminum bowl is corroded almost all the way through because nobody ever drained the water out of the thing. A fuel filter is a common-sense item, isn't it? A leaking strainer is asking for a fire. A blocked strainer kills the engine. Cessna wants that thing apart every 100 hours or one year. I can't understand how some shops can ignore an important part of the fuel system for so many years. One year is long enough.
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You do know there is an AD for that

And folks wonder why I like the old early glass bowl strainer assembly, with the low point drain built in.
 
Tom-D said:
You do know there is an AD for that

And folks wonder why I like the old early glass bowl strainer assembly, with the low point drain built in.
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Really? For draining or cleaning the strainer? Which one would that be?
 
Tom-D said:
LOI's do not delete what the AD says, this Regulation was written long before the meaning changed, You do as you like, I know you will anyway.
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And now an AD is being interjected into the diatribe? :confused:
 
JAWS said:
And now an AD is being interjected into the diatribe? :confused:
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You must have missed it when it was mentioned before, If you are going to eves drop, pay attention.
 
Tom-D said:
LOI's do not delete what the AD says, this Regulation was written long before the meaning changed, You do as you like, I know you will anyway.
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Tom, I don't have a dog in this fight, but I do try to keep up with the meaning of FARs. Now, what is this AD you are referring to? :dunno:
 
JAWS said:
And now an AD is being interjected into the diatribe? :confused:
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So thread creep ? So what? it happens all the time here, How come you only have a problem when I do it?
 
Tom-D said:
This is the AD I had in mind, some gascolators had a problems that caused water to not be drained, and so they corroded, This cause most inspectors to inspect them all. I was sure there was a AD to require that But I can't find it.

http://rgl.faa.gov/Regulatory_and_G...FA9F23E11131B02886256A4C004DF1D7?OpenDocument
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That was for replacement assemblies shipped between December 12, 1996 and September 5, 1997 due to manufacturing error, has little to do with the poor maintenance or corroded bowls.
 
Antennas, antenna sealing, static wicks, brake hoses, lighting lenses, plastic fairings, engine control cables, on and on.
 
bnt83 said:
That was for replacement assemblies shipped between December 12, 1996 and September 5, 1997 due to manufacturing error, has little to do with the poor maintenance or corroded bowls.
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That was the cause of the corroded bowls, corrosion was how the short tubes were discovered.
It all started with this service bulletin
ourpdf.pdf
 
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Tom-D said:
That was the cause of the corroded bowls, corrosion was how the short tubes were discovered.
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The tube that caused the AD has nothing to do with draining the bowl or causing corrosion in the bowl. The only way anyone would have ever known this tube had an issue is if they found it had fallen out or was too short to pass through the lower hole in the screen. It is pretty obvious they assume the tube was cut to correct length and are asking you to verify it was pressed into the top correctly.

https://support.cessna.com/custsupt/contacts/pubs/ourpdf.pdf?as_id=17526

upload_2018-9-14_9-51-9.png
 
Tom-D said:
That was the cause of the corroded bowls, corrosion was how the short tubes were discovered.
It all started with this service bulletin
ourpdf.pdf
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Nope. Corrosion was never blamed on that. But there are a few about draining and maintenance. Here are two::
http://www.airweb.faa.gov/Regulator...004BC384?OpenDocument&Highlight=fuel strainer

http://www.airweb.faa.gov/Regulator...006A75F3?OpenDocument&Highlight=fuel strainer

Note that they address the lack of a drain valve or the habit of never draining or cleaning. And note that they are model specific, not a general demand to drain or check all strainers, though that would be a good idea. Some guys won't do even the sensible stuff without being legislated into it.
 
Tom-D said:
This is the AD I had in mind, some gascolators had a problems that caused water to not be drained, and so they corroded, This cause most inspectors to inspect them all. I was sure there was a AD to require that But I can't find it.

http://rgl.faa.gov/Regulatory_and_G...FA9F23E11131B02886256A4C004DF1D7?OpenDocument
Click to expand...

So we're not even talking about who is allowed to open panels then? Am I getting that right?

It seems to me that the LOI has absolutely nothing to do with this AD?
 
Well...that’s not considered maintenance or inspection. But that won’t matter. :confused:
 
pig-wrestling_789027i.jpg
 
flyingcheesehead said:
So we're not even talking about who is allowed to open panels then? Am I getting that right?

It seems to me that the LOI has absolutely nothing to do with this AD?
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That was my thought. I was duly told I was eavesdropping. Whatever - consider the source!
 
Let'sgoflying! said:
Is that safety wire pulling in the right direction?
I ask b/c I just posted about a new-to-me gascolator I am looking at, in a type-forum wondering the same thing.

View attachment 67127
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Yes, in old school drafting, which that drawing is, a dashed line indicates that something is on the opposite side (backside) of the solid object.
 
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