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Service Bulletin Requirements

T

todehnal

Well Known Member
This has probably been answered, but I can't seem to find it. We basically have three classifications of our RV-12s: ELSA, EAB, and SLSA. The question is, who must do, and log service bulletins to remain legal? I'm sure that they are required for SLSA. So, what about ELSA, and EAB??

Thanks, Tom
 
On SLSA and ELSA, service bulletins noted as mandatory are just that, mandatory. The only difference is who can perform them and sign the log book. On a SLSA, it requires a minimum of an A/P. On ELSA, it requires a minimum of a LSA Repairman Inspector rating, which you can qualify for my attending a mandatory 16 hour training class and filing the paperwork with the FAA.

On EAB, service bulletins are not required legally. (but probably a good idea).
 
Service bulletins are not mandatory on any experimental aircraft.
They are required on SLSA.
E-LSA and E-AB, anyone can do any and all maintenance, mods, etc.
The repairman certificate only allows for the sign off of the condition inspection.
For S-LSA, the person signing off a service bulletin must hold an LSA repairman certificate/maintenance, an appropriate aircraft mechanic certificate, or anyone authorized by the aircraft manufacturer.
 
Although not legally mandatory, lawyers will have a field day with uncompleted service bulletins that are in any way related to an accident.
 
I wouldn't consider not complying with one of Van's service bulletins. I think that we are very fortunate to be getting them. It is comforting to know that someone is looking out for our best interest. I was just curious, mostly about ELSA, but my guess is that, since it is still considered Experimental, it is not mandatory, even though highly recommended.

Tom
 
Mel said:
Service bulletins are not mandatory on any experimental aircraft.
Click to expand...

I believe you Mel, but this directly conflicts with what I was just taught in the 16 hour repairman class. The instructor and the class material (and a test question I think) stated that they are mandatory on ELSA because they are issued by the manufacturer (Van's).

Also on Van's SB's for the -12, there is a "level of certification" listed for ELSA and SLSA on who can sign off on the work. If there's no compliance needed for ELSA, I'm not sure why this would be listed.

Perhaps I misinterpreted somehow. I'll go back over the class material to see if there is anything written down about it. I am certainly no expert on this topic but it sure is confusing.
 
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Wow!! I'm glad I asked the question.

I'm sure that we will get to the bottom of it. Who knows, we may even get page and paragraph information before this is over.

And, it is important to get it right!!

Thanks for the responses.............Tom
 
Mandatory service bulletins are not even mandatory for certified aircraft flying under part 91.
Only airworthiness directives are mandatory.

Example: What if you have modified your ELSA RV-12 by removing the fuselage fuel tank and installed wing tanks. That's perfectly legal on ELSA.
Now Van's issues a SB on the fuselage tank. Do you have to reinstall the tank and comply?
 
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Part of the problem is with the FAA and the ASTM's.
They require that certification levels be specified when they are issued.
But if you read them carefully, you will find that for E-LSA it says it can be done by Owner, LSR- I, or A&P. For S-LSA it says it must be a A&P or LSA Repairman Maintenance

But as Mel said, there is nothing regulatory in the FAR's that make them mandatory for anything other than S-LSA (but as already mentioned, it probably wouldn't be smart to ignore them).
 
Tom,

The flexibility E-LSA gives us allows us to evaluate each SB as they affect our own flying. Personally I made the choice to not make all those fuel tank mods. On the other hand I did the landing gear upgrade at the first annual after publication.

I see nothing wrong with the pick and choose flexibility as long as the aircraft logs reflect the configuration. The lawyers are going to screw us no matter what we did if there is an incident!😜

Rich
 
Mel said:
Mandatory service bulletins are not even mandatory for certified aircraft flying under part 91.
Only airworthiness directives are mandatory.

Example: What if you have modified your ELSA RV-12 by removing the fuselage fuel tank and installed wing tanks. That's perfectly legal on ELSA.
Now Van's issues a SB on the fuselage tank. Do you have to reinstall the tank and comply?
Click to expand...

Yep, makes perfect sense to me. The instructor corrected me in the class when I said something similar to that.
 
SB's aren't legally mandatory for ANY LSA. Only SD's are FAA regulated as true mandatory items even if someone like Rotax or whom ever writes mandatory on them. Rotax being a Euopean country believes mandatory over ther means the same in the US. I fully believe they should all be followed and adhered to, but the FAA says ony SD's must be complied with and not an SB. This has been beaten to death on numerous websites and tons of people have contacted the FAA on this matter. This was brought to the FAA legal department years ago and ruled on.

I would still highly recommend that ALL SB's be followed. There was a good reason it was issued in the first place. It either evolved from broken planes or crashs ones.
 
Loki said:
SB's aren't legally mandatory for ANY LSA. Only SD's are FAA regulated as true mandatory items even if someone like Rotax or whom ever writes mandatory on them. Rotax being a Euopean country believes mandatory over ther means the same in the US. I fully believe they should all be followed and adhered to, but the FAA says ony SD's must be complied with and not an SB. This has been beaten to death on numerous websites and tons of people have contacted the FAA on this matter. This was brought to the FAA legal department years ago and ruled on.
Click to expand...

True Roger, but not for much longer.

A rewrite of the pertinent regs and ASTM's is under way, which will close some of the holes in the regulatory net in the not to distant future.
 
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