Van's Air Force
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Condition Inspection with Discrepancies
- Thread starter barryrv10
- Start date
DanBaier
Well Known Member
I don't think so.
What will govern is the letter of operating limitations - for example, mine says:
(23) Condition inspections must be recorded in the aircraft maintenance records showing the following, or a similarly worded, statement:
"I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation." The entry will include the aircraft's total time-in-service, and the name, signature, certificate number, and type of certificate held by the person performing the inspection. (Emphasis original)
So, it's not the same as an annual inspection in the certified world. Here, the person making the entry is concluding that the aircraft is in a condition for safe operation (or, if not I would think that, simply, no entry is made at all).
I don't know about getting a ferry permit for an experimental - I think the issue might be that with experimentals there is no concept of "airworthiness" as defined.
Dan
What will govern is the letter of operating limitations - for example, mine says:
(23) Condition inspections must be recorded in the aircraft maintenance records showing the following, or a similarly worded, statement:
"I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of appendix D to part 43, and was found to be in a condition for safe operation." The entry will include the aircraft's total time-in-service, and the name, signature, certificate number, and type of certificate held by the person performing the inspection. (Emphasis original)
So, it's not the same as an annual inspection in the certified world. Here, the person making the entry is concluding that the aircraft is in a condition for safe operation (or, if not I would think that, simply, no entry is made at all).
I don't know about getting a ferry permit for an experimental - I think the issue might be that with experimentals there is no concept of "airworthiness" as defined.
Dan
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Kahuna
Moderatoring
Does the word discrepancy have any special meaning to the FAA or an A&P?
For example, what is considered safe today, may not be safe 50 hours from now. Or 5000 hours from now. Lets say a throttle cable shows signs of heat damage. It may be perfectly safe right now, but may need attention at a later date and perhaps before the next condition inspection. Is that an example of a discrepancy?
For example, what is considered safe today, may not be safe 50 hours from now. Or 5000 hours from now. Lets say a throttle cable shows signs of heat damage. It may be perfectly safe right now, but may need attention at a later date and perhaps before the next condition inspection. Is that an example of a discrepancy?
DanBaier
Well Known Member
See FAR 43.11 (a) (5) - http://www.ecfr.gov/cgi-bin/text-id...4db20c8d2&node=14:1.0.1.3.21.0.363.8&rgn=div8
Dan
Dan
Discrepancy
My idea of a discrepancy is anything that could effect the safe operation of that aircraft now or in the foreseeable future. It is certainly a judgement call and being I usually have no control after the aircraft is signed off, I am pretty conservative. Some squawks can be monitored one way or another, but it takes an active willingness to do so. My criterion is if I would feel comfortable having my family fly in the aircraft.
In the past I have had problems with owners not wanting to follow my suggestions on how to fix or address a problem, such as an AD or SB on a certain part in their aircraft. I know there is a lot of debate about AD's and SB's but they are usually issued because of a problem. I believe the owner should make the decision in that situation, but I cannot sign off an aircraft that has an open AD or SB against any part in that aircraft. If there was a problem with that aircraft because the AD or SB was not complied with, I have not been able to figure out how I could defend myself in court, or worse to someone's widow.
I very much believe it is the owner's responsibility to keep the aircraft in a condition for safe operation and to make the decisions about it's maintenance, but if I am hired to inspect it I have to use my best judgement and sometimes that conflicts with the owner's ideas on how to maintain the aircraft.
My idea of a discrepancy is anything that could effect the safe operation of that aircraft now or in the foreseeable future. It is certainly a judgement call and being I usually have no control after the aircraft is signed off, I am pretty conservative. Some squawks can be monitored one way or another, but it takes an active willingness to do so. My criterion is if I would feel comfortable having my family fly in the aircraft.
In the past I have had problems with owners not wanting to follow my suggestions on how to fix or address a problem, such as an AD or SB on a certain part in their aircraft. I know there is a lot of debate about AD's and SB's but they are usually issued because of a problem. I believe the owner should make the decision in that situation, but I cannot sign off an aircraft that has an open AD or SB against any part in that aircraft. If there was a problem with that aircraft because the AD or SB was not complied with, I have not been able to figure out how I could defend myself in court, or worse to someone's widow.
I very much believe it is the owner's responsibility to keep the aircraft in a condition for safe operation and to make the decisions about it's maintenance, but if I am hired to inspect it I have to use my best judgement and sometimes that conflicts with the owner's ideas on how to maintain the aircraft.
I just watched a Webinar on this from the EAA and Mike Busch.
You can find it in the EAA archives. I believe it is titled "How to fail an Annual."
It was geared for the Certified world but I believe it is the same.
According to Mike Busch this is something that should be done on a regular basis.
Yes it can be signed off as inspected but with discrepencies. A condition Inspection or Annual Inspection is only an inspection.
The original IA or A&P does not even have to re-inspect. Another IA can sign of that particular discrepancy.
To fly with a discrepency would require a ferry permit.
You can find it in the EAA archives. I believe it is titled "How to fail an Annual."
It was geared for the Certified world but I believe it is the same.
According to Mike Busch this is something that should be done on a regular basis.
Yes it can be signed off as inspected but with discrepencies. A condition Inspection or Annual Inspection is only an inspection.
The original IA or A&P does not even have to re-inspect. Another IA can sign of that particular discrepancy.
To fly with a discrepency would require a ferry permit.
pierre smith
Well Known Member
We had a ferry permit during phase 1 on our -6A to get it to a radio shop.
Best,
Best,
ifixf15
Active Member
43.11(a)(5)
§43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:
(1) The type of inspection and a brief description of the extent of the inspection.
(2) The date of the inspection and aircraft total time in service.
(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.
(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”
(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”
§43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:
(1) The type of inspection and a brief description of the extent of the inspection.
(2) The date of the inspection and aircraft total time in service.
(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.
(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”
(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”
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Correct Barry! If Mel was around (he's on a vacation from the internet I think...), I think he could give an authoritative answer, but legally, the "Annual Inspection" that you do on a certified airplane has no direct correlation to the annual "Condition Inspection" we do on experimentals - despite that in some respects, they appear similar. Therefore, what we all know about "Annuals" doesn't apply.
The signoff for an "Annual" is more about whether or not the certified airplane meets its type Certificate or not.The signoff for a Condition Inspection certifies that the airplane is safe - so I don't think you can morally or legally sign it off if you see things that you believe aren't safe. There are, of course, differences of opinion on what is safe or not.
P
paul mosher
inspection
As a ia if a discrepancy is not addressed to my satisfaction I won't sign off a annual no matter how much crying the owner does.
This is why it is smart to get paid up front.
As a ia if a discrepancy is not addressed to my satisfaction I won't sign off a annual no matter how much crying the owner does.
This is why it is smart to get paid up front.
ifixf15
Active Member
43.11(a)(5)
Then the 12 calendar month inspection does not apply either. Unless one is specified in the Operating Limitations. And that is normally done by referring to Part 43.
Then the 12 calendar month inspection does not apply either. Unless one is specified in the Operating Limitations. And that is normally done by referring to Part 43.
rocketbob
Well Known Member
Technically correct but if you sign the logbook as stated 43.11(a)(5) then nobody can question what you've done.
Really we're talking about chronology in the logbook. These sorts of entries are meant to protect the inspector and make it clear to the aircraft owner that it is not airworthy. At the end of the day the repairs have to be done and someone has to sign off the inspection AFTER the work was completed.
Barry, you certainly can sign an annual on an aircraft with open SB's. They are not mandatory for airworthiness. Most 135 certs will specify that all mandatory SB's be complied with, but it doesn't affect the actual sign-off. It just can't be operated 135 until complied with.
Incorrect. Paragraph 22 of the ops Limits require the inpsection within the previous 12 Months:
"(22) No person must operate this aircraft unless within the preceding 12 calendar months it has had a condition inspection performed in accordance with the scope and detail of appendix D to part 43, or other FAA-approved programs, and was found to be in a condition for safe operation. "
With all due respect (and I mean that) to all of the fine A&P's and IA's here on the board, you're just confusing everyone when you try and mix what you know about certified aircraft annuals and experimental aircraft condition inspections. It is all written down - cite the references, not what you think you remember that you might have been told by someone at one time or another....or not.
Actually that's not correct.
All experimental operating limitations specify the inspection requirements and interval, and generally give guidance to what the logbook entry is supposed to say, but they never make any reference to to Part 43 (only appendix D).
The FAA goes out of there way to make sure there is a well defined boundary between certificated aircraft and experimental.
The very first paragraph of Part 43 is where it states that it does not apply to any aircraft that has an experimental airworthiness certificate. Even so, that is still what the FAA refers to as guidance for making a proper log book entry for experimental.
Looks like Paul types faster than I do.........
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Walt
Well Known Member
There are no AD's against EAB aircraft and SB's are not legally mandatory so you can sign off an airframe as "safe" if you feel it is safe even if there is a SB that has not been accomplished. In this case I make a notation in the log that the owner was notified that SB (s) xxx has not been accomplished. If the SB calls for an inspection that the area in question was inspected and there were no defects were noted. If there are defects, then they must be repaired IAW the SB.
"Most" engines in EAB aircraft are not "certified" any longer so applicability of AD's are questionable. In addition, many times its virtually impossible to tell if an AD is even applicable do to incomplete records or without a major disassembly. I always run an AD report with the info I have, but if I cannot determine if an AD is applicable I will make this statement on the AD report. I list the AD report in the signoff so it becomes part of the "record" and again include a statement in the log that the owner was notified and provided a copy of the AD (s). I will sign off the engine as inspected and safe if everything else looks good otherwise.
AD props are pretty popular on RV's and I see quite a few of the non-suffix AD hubs. In these cases I do about the same as the engine, inspect the prop as noted in the manual, inspect the specific area referenced by the AD, indicate that I did not find any discrepancies, advise the owner that AD xxx is not in compliance and provided him a copy.
Once the owner is notified then I believe I have done my job, now the onus is on owner/operator to get the AD/SB done if that is what they want to do.
The above is for AD/SB's only, part of the agreement I have with every customer is no airplane leaves the shop unless it's safe, and we "WILL" do whatever repairs are necessary to make it that way. If he doesn't agree he can take it somewhere else.
"Most" engines in EAB aircraft are not "certified" any longer so applicability of AD's are questionable. In addition, many times its virtually impossible to tell if an AD is even applicable do to incomplete records or without a major disassembly. I always run an AD report with the info I have, but if I cannot determine if an AD is applicable I will make this statement on the AD report. I list the AD report in the signoff so it becomes part of the "record" and again include a statement in the log that the owner was notified and provided a copy of the AD (s). I will sign off the engine as inspected and safe if everything else looks good otherwise.
AD props are pretty popular on RV's and I see quite a few of the non-suffix AD hubs. In these cases I do about the same as the engine, inspect the prop as noted in the manual, inspect the specific area referenced by the AD, indicate that I did not find any discrepancies, advise the owner that AD xxx is not in compliance and provided him a copy.
Once the owner is notified then I believe I have done my job, now the onus is on owner/operator to get the AD/SB done if that is what they want to do.
The above is for AD/SB's only, part of the agreement I have with every customer is no airplane leaves the shop unless it's safe, and we "WILL" do whatever repairs are necessary to make it that way. If he doesn't agree he can take it somewhere else.
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LettersFromFlyoverCountry
Well Known Member
FYI, Mike Busch did a whole EAA webinar a couple of weeks ago called "How to Flunk an Annual."
I was disappointed in it because I stupidly thought it was a catchy title for a webinar on how to do a good inspection, but, in fact, it actually was all about discrepancies.
All of these questions -- and the experimental -- were answered here.
I was disappointed in it because I stupidly thought it was a catchy title for a webinar on how to do a good inspection, but, in fact, it actually was all about discrepancies.
All of these questions -- and the experimental -- were answered here.
ifixf15
Active Member
Yard Ornament
Well Barry I guess you really do have a problem on your hands. If you insist that it is not airworthy and he refuses to pay for the work you feel is warranted then I guess you have a slightly used yard ornament. How long does it take for the FAA to process a mechanics lien?
Well Barry I guess you really do have a problem on your hands. If you insist that it is not airworthy and he refuses to pay for the work you feel is warranted then I guess you have a slightly used yard ornament. How long does it take for the FAA to process a mechanics lien?
ifixf15
Active Member
The lightbulb is on
OK, I went through everything one more time and now I see where I took the proverbial 'Left Turn at Albuquerque.' Part 43.11 does not apply because Part 43 does not apply to E-AB. Part 42 Appx D does because the Operating Limitations says so. The light bulb is now on. It is only a 25 watt bulb, but it is on. I apologize for any consternation I may have caused.
Tom
OK, I went through everything one more time and now I see where I took the proverbial 'Left Turn at Albuquerque.' Part 43.11 does not apply because Part 43 does not apply to E-AB. Part 42 Appx D does because the Operating Limitations says so. The light bulb is now on. It is only a 25 watt bulb, but it is on. I apologize for any consternation I may have caused.
Tom
Thanks
Thanks to everyone for their input; I like Walt's approach for the inspection. I believe it keeps the owner in control of the maintenance and protects the inspector. I think talking with the owner up front so he knows exactly what will be involved and what my concerns are is a good place to start. As more E-AB's get sold to second owners, I believe this will become a larger issue.
Thanks to everyone for their input; I like Walt's approach for the inspection. I believe it keeps the owner in control of the maintenance and protects the inspector. I think talking with the owner up front so he knows exactly what will be involved and what my concerns are is a good place to start. As more E-AB's get sold to second owners, I believe this will become a larger issue.
Walt
Well Known Member
I've had some questions asked about doing SB's and condition inspections so I wanted to clarify my postition on this. I revised a previous post with the BOLD section below:
There are no AD's against EAB aircraft and SB's are not legally mandatory so you can sign off an airframe as "safe" if you feel it is safe even if there is a SB that has not been accomplished. In this case I make a notation in the log that the owner was notified that SB (s) xxx has not been accomplished. If the SB calls for an inspection that the area in question was inspected and there were no defects noted, if there are defects, then they must be repaired IAW the SB.
So that means that I would not sign off a condition inspection if I find cracks in the Horizontal until the repair is done or I release the aircraft "with discrepancies".
There are no AD's against EAB aircraft and SB's are not legally mandatory so you can sign off an airframe as "safe" if you feel it is safe even if there is a SB that has not been accomplished. In this case I make a notation in the log that the owner was notified that SB (s) xxx has not been accomplished. If the SB calls for an inspection that the area in question was inspected and there were no defects noted, if there are defects, then they must be repaired IAW the SB.
So that means that I would not sign off a condition inspection if I find cracks in the Horizontal until the repair is done or I release the aircraft "with discrepancies".
Reference to the second question of the thread; can an experimental get a ferry permit. Here at RTS, a RV-7A showed up from somewhere in WA to base his aircraft at Stead and had a ferry permit to complete his Phase I here. Dan
The exact wording is listed in the operating limitations.
Deweyclawson
Well Known Member
Discrepancies
deleted. Previously answered
deleted. Previously answered
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Radioflyer
Well Known Member
"There are no AD's against EAB aircraft and SB's are not legally mandatory so you can sign off an airframe as "safe" if you feel it is safe even if there is a SB that has not been accomplished."
I think this is no longer the case with the newest version of the operating limitations being issued by the FAA now. (The .2H version) There is a paragraph included that says if using a certificated product, that it must be maintained according to the published procedures fit that component. That includes ADs, SBs, etc.
I suppose one can "de-certify" something by removing the data plate, and thereby not having to comply.
I think this is no longer the case with the newest version of the operating limitations being issued by the FAA now. (The .2H version) There is a paragraph included that says if using a certificated product, that it must be maintained according to the published procedures fit that component. That includes ADs, SBs, etc.
I suppose one can "de-certify" something by removing the data plate, and thereby not having to comply.
