Annual Condition Inspection - Engine

In an aviation group on Facebook someone asked why people build their own airplanes.

Of course someone mentioned that they did it so they could perform their own inspections. To which an IA jumped in and said, incorrectly, that the engine still needs to be signed off by an IA.

It turned out he convinced the people on his field this was the case and had homebuilders paying him to inspect their engines.

(Needless to say, he wasn't pleased with being called out on this.)

Has anyone here ever run into this before?

N941WR said:

In an aviation group on Facebook someone asked why people build their own airplanes.

Of course someone mentioned that they did it so they could perform their own inspections. To which an IA jumped in and said, incorrectly, that the engine still needs to be signed off by an IA.

It turned out he convinced the people on his field this was the case and had homebuilders paying him to inspect their engines.

(Needless to say, he wasn't pleased with being called out on this.)

Has anyone here ever run into this before?

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First that I have heard of an FAA certified individual, such an A&P not understanding the rules that he was tested and certified on. In seriousness, I tend to give these folks the benefit of the doubt that they just aren't very detail oriented and not simply crooks, though I am sure that some are. You do have to ask yourself if this lapse in knowledge or judgement makes you concerned about their other knowledge and skills. It often seems that the least knowledgeable folks are the most adamant that they are correct. I suppose that is a survival mechanism.

Larry

lr172 said:

First that I have heard of an FAA certified individual, such an A&P not understanding the rules that he was tested and certified on. In seriousness, I tend to give these folks the benefit of the doubt that they just aren't very detail oriented and not simply crooks, though I am sure that some are. You do have to ask yourself if this lapse in knowledge or judgement makes you concerned about their other knowledge and skills. It often seems that the least knowledgeable folks are the most adamant that they are correct. I suppose that is a survival mechanism.

Larry

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It happens all the time. The local Avionics Repair Station won't do EAB transponder certification without a certified encoder. Needless to say, he doesn't have any EAB business anymore. The sad thing is some of this FUD actual came from a FSDO representative.

I recently convinced a friend that is an A&P/IA that anyone can do maintenance on EAB. Once he read the information for himself, he responded with "I stand corrected" but still felt there are people that own and EAB that should not be touching wrenches, to which I agreed.

How could so many builders fall for this? They should know the rules under which they operate.

I wonder what this IA is writing in the records? Certainly can't be "conformance with the TCDS"... What is he inspecting for, and why does his IA pixie dust make him uniquely qualified?

Some people love rules so much they just create them out of thin air, I guess

When Van's sold certified engines, what I was told was, if the motor was to keep it's certified standards, it would need to be maintained and signed off by an IA just like a certified aircraft.

gasman said:

When Van's sold certified engines, what I was told was, if the motor was to keep it's certified standards, it would need to be maintained and signed off by an IA just like a certified aircraft.

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Also incorrect. If it were later installed on a plane with a type certificate (eg. Piper), it would require an IA sign-off at that time, including AD compliance.

gasman said:

When Van's sold certified engines, what I was told was, if the motor was to keep it's certified standards, it would need to be maintained and signed off by an IA just like a certified aircraft.

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Once it is placed in an experimental airframe, it becomes an experimental engine.

But that is the logic the IA was using to increase his business flow.

Most IA's I have spoken to said the only way they would sign off a former Experimental engine being installed in a certified airplane was if it was freshly overhauled by a reputable shop. How else would they know it meets its type certificate?

Raymo said:

Also incorrect. If it were later installed on a plane with a type certificate (eg. Piper), it would require an IA sign-off at that time, including AD compliance.

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I would enjoy watching you argue that with the FSDO or accident investigator. Once that engine is installed in an experimental aircraft, the owner can do whatever he/she wants to it with whatever parts he feels like. That is simply not allowed in the certified world and why I don't think that the FAA would allow it to be reinstalled in a certified aircraft. Simply no assurances exist that the engine still meets the certificates standards, regardless of an inspection. How does the IA know that the crank wasn't red tagged before being installed eventhough it looks good during his inspection? An overhaul, where every part is documented and inspected with 8130's may be another matter but still not sure they would allow it.

Larry

rleffler said:

It happens all the time. The local Avionics Repair Station won't do EAB transponder certification without a certified encoder. Needless to say, he doesn't have any EAB business anymore. The sad thing is some of this FUD actual came from a FSDO representative.

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Similar thing here with local FBO, except they wouldn't work on anything experimental. When called out on this they shifted the blame from the FAA to their their insurance. Why that would be, I have no idea.

N941WR said:

Once it is placed in an experimental airframe, it becomes an experimental engine.

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I've often wondered EXACTLY what this statement means.

The engine doesn't magically change its part number. It is still associated by that number to a TCDS.

Why couldn't the "experimental" engine simply be inspected against its TCDS and other approved data (especially the parts list) and be checked for AD compliance. After all that, couldn't it be installed onto a certified AC?

Of course, the inspection could be very difficult / impractical to accomplish. For example if I remove an internal part (tachometer drive?) that might be hard to detect.

Is my thinking totally incorrect?

Part of the engine conforming to the TCDS is the processes in place to maintain that engine - notably - licensed mechanics. With the EAB world that important element of configuration control is gone. Yes the data plate might have a part number that aligns with a TCDS, but there is a very distinct possibility that some very important internal engine parts do not, or the parts you CAN see have NOT been maintained in accordance with the TCDS. Remember, ANYBODY can maintain an engine, and there are very few records required to be maintained.

Since it is impractical to tear an engine down and confirm 100% conformance to the TCDS, and the engine either conforms or it does not conform, the only reasonable argument is to consider the engine (or more directly, the process) has been tainted with the EAB label.

In a the big picture, you can bolt a certified engine to your airframe, and it can stay "legal" to transplant back to a certified airplane IF you keep your ducks in a row. That means having an IA work with you to make sure the engine is maintained with certified parts and with the IA looking over your shoulder (at least) to make sure you don't do anything that takes it out of that status. The IA would also need to make logbook entries around any work done on the engine.

When the time comes to transplant the engine back to (say) a C-172, it wont be a problem (legally) as long as the IA is willing to certify that the engine matches its TCDS.

I won't say it is never done this way, but it isn't done frequently.

You may think it only happens to experimental airplanes....

The owner of a Piper Arrow at my home field installed high compression pistons in his O360 between annual inspections..... no a&p help, no IA help or inspection. He passed away after 6 years and his estate sold the aircraft.

As far as the next IA sign off, it is still a certified motor. Nothing is guaranteed.

A good example is the O-290d2 my plane stared life with.

I'm not an A&P, yet I removed all the cylinders and replaced the O rings, one piston (I scratched the original one. Duh!), Removed the sump, replaced the accessory case, changed the cam gear, added a plunger for the fuel pump, added an oil filter adapter, added electronic ignitions, but did not change anything inside

Who in their right mind would sign that back into service on a certified plane?

N941WR said:

A good example is the O-290d2 my plane stared life with.

I'm not an A&P, yet I removed all the cylinders and replaced the O rings, one piston (I scratched the original one. Duh!), Removed the sump, replaced the accessory case, changed the cam gear, added a plunger for the fuel pump, added an oil filter adapter, added electronic ignitions, but did not change anything inside

Who in their right mind would sign that back into service on a certified plane?

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Not me but theoretically if the engine in a experimental that is certified and maintained by a A&P and annuals signed by a IA I would think it would still be a certified engine.

Tommy123 said:

Not me but theoretically if the engine in a experimental that is certified and maintained by a A&P and annuals signed by a IA I would think it would still be a certified engine.

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And what assurances are in place for the FAA that nothing was added or worked on by the owner between annuals? In the certified world, federal laws insure that specified process and parts are used. Sure, people break the law, but it's limited and is accepted as a reality, the same as we accept having our cars stolen occassionally. Once an engine is installed in an experimental a/c, anything can be done to it by the owner legally. This all means that the engine cannot be trusted to be in compliance with certifications, as there were no laws in place to prescribe maintneance procedures and parts control while installed in an experimental a/c. The fact that you paid an A&P to do maintenance does not mean that you didn't also do things to the engine on your own, as is your legal rigth.

Larry

when its all said and done the only thing that matters when putting an ex-exp engine on a type certificated aircraft is the IA's john Henry in the log book. that iswhat a IA is for, to certify that the aircraft or engine meets the type certificate. now, for the practicality of that. I would not sign one off without a complete conformity inspection. that means a tear down and check of every part. if the part does not have a paper trail then it gets replaced. only then, would I put pen to paper. in the real world the best way to do that is to just do a overhaul on it to the specs with proper paper trail and then sign it off.

bob burns
RV-4 N82RB

I think Bob nailed it; it becomes experimental when installed on an experimental, and the signature is the last word to make it legal to return to a certified a/c. But if someone can't see the logic to the original rule, consider not just the possibility of internal mods, but the *environment* the engine is operating in. For example, not all props are certified for all engines, sometimes because nobody's done the testing, but often because someone *did* do the testing & found that damage could be done. Also (and more to the point), not all engines are certified for all airframes, because they haven't been tested and found safe on every airframe. That's the reason you see STCs for engine swaps/upgrades on certified a/c. Since there's never been any FAA-formalized testing to certify the safety of any certified engine/experimental airframe, there's no *official* way to say that the combination won't cause issues that could become evident at a later time.

At one point, FSDOs even were forcing the removal of data plates when a certified engine was installed on an experimental airframe (it happened multiple times to a rather prolific friend of mine). They've since been instructed by HQ to stop the practice, because it makes it difficult/impossible for experimental owners to determine whether their engines might be at a safety risk when service bulletins/ADs are issued.

Charlie

jcaplins said:

Similar thing here with local FBO, except they wouldn't work on anything experimental. When called out on this they shifted the blame from the FAA to their their insurance. Why that would be, I have no idea.

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Their loss. My airplane has been gravy money for the guy that does our checks. Takes longer to setup and do the paperwork than to do the test. Never had a leak or a goofy sensor out of calibration knock on wood!

lr172 said:

I would enjoy watching you argue that with the FSDO or accident investigator. Once that engine is installed in an experimental aircraft, the owner can do whatever he/she wants to it with whatever parts he feels like. That is simply not allowed in the certified world and why I don't think that the FAA would allow it to be reinstalled in a certified aircraft. Simply no assurances exist that the engine still meets the certificates standards, regardless of an inspection. How does the IA know that the crank wasn't red tagged before being installed eventhough it looks good during his inspection? An overhaul, where every part is documented and inspected with 8130's may be another matter but still not sure they would allow it.

Larry

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FSDO isn't involved. It's up to the IA to make the determination. Finding one that will sign it off may be difficult, I agree.