ANNUAL INSPECTIONS
THE MAN, THE MYTH AND THE MISCONCEPTION
First Edition Vol. 1
Introduction; Welcome to the first edition of this series of my monthly blog(s). These articles are based on my experiences of nearly thirty years in the aviation business as a professional wrench twister, and over forty years in aviation total. I won’t bore you with any background information here, you can read all about my colorful career in the “About Us” section of this website. What I will attempt to do here in this space on a monthly basis, or when the spirit moves me, is to share some of my experiences and knowledge on different topics that have stood out, or have in some other way stuck in my craw long enough for me to finally say something about the chosen topic that doesn’t allow for a personal heated debate with the misguided opinions of misinformed or otherwise unknowledgeable “experts” arguing the finer points of their unsubstantiated opinions of subjects they have no clue what they’re talking about.
I have for years had the privilege to be in many of these “debates” over a plethora of subjects with individuals whom have either been taught incorrectly or have read somewhere the writings of some other fool and his misguided opinions on a subject he has no business discussing in any type of forum whether it be on the internet (where everything is true), or with a bunch of his buddies roasting wieners around a camp fire at some back country airstrip in the middle of nowhere. (I’m sure you already have a visual of this).
I don’t claim to be an “expert” on anything. Nor do I claim to know everything. I know what I know, have the facts to back up my “opinions”, and will argue any point until the cows come home on their own. I also know what I don’t know and won’t get into a heated conversation with someone over a subject I have no real knowledge about until I have done some diligent research on the subject and am able to have an intelligent conversation on the chosen topic. I’m from German descent, and hate to be wrong. So, to avoid any embarrassment regarding “foot-in-the-mouth” disease, I find it best to be correct in your opinion and don’t speak until you know you’re right. And of course, have the facts to back up your opinion no matter how unwelcomed it may be.
The intent of these stories is to inform, educate and entertain interested parties whom have nothing better to do, but read my monthly diatribe on mutually shared common subject matter. Most of these articles will be aviation related, as this is our main business, but sometimes I may visit a topic on Volkswagens, Porsches, other automotive topics, and/or whatever topic is bothering me at the time of writing. A lot of these articles will involve the aircraft owner/pilot as the antagonist in each story. This is not by accident. Most of these stories are over the aforementioned “debates” and opinions of the aircraft owner/pilot, whom has spent almost forty hours of instruction to get his pilot’s license, while I, and the majority of my fellow A&P’s, have had to put in nearly 3,000 hours of instruction for the privilege to work on the expert’s aircraft. Not to mention the experience gained from years of countless hours working on these “Wonders of Wichita” and everything else that ascends the surly bonds of earth on a day-to-day basis.
Per the advice of our legal counsel, I must present this disclaimer. If you are easily offended or feel like you’re being picked on or bullied by my persona, take this as a warning. I’m an equal opportunity offender. I don’t sugar coat anything. I won’t hold your hand and offer my sympathies or apologize for my perceived “attack” on your feelings. Airplanes are inherently expensive. You knew this when you signed up for flight training. Aviation as a whole is a very serious business, and I don’t have time to lend anyone any comfort through a group hug or a chorus of Kumbya. The way I see it, you have two choices. You can suck it up, put your big boy pants on and read along with an open mind and maybe learn something, or you can simply deny yourself the opportunity for abuse and refrain from reading my articles. At the risk of sounding sexist, aviation is predominantly a man’s hobby. Although there are many women in aviation, (my mother being one of them at one time), men are the majority leaders in this field, so I will speak in terms that address “men” as a generality. Besides, most women are more mature when it comes to their aircraft than men seem to be. O.K., now that that’s out of the way, on to this month’s topic.
ANNUAL INSPECTION; If you fly your aircraft under Code of Federal Regulation 14, Part 91, (aka FAR 91) then this month’s subject is for you. As you should know, your aircraft has to have an Annual Inspection every twelve calendar months. This means that if your aircraft was inspected per Federal Aviation Regulation Part 91 §91.409 (a) on March 12th. 2017, your aircraft will be out of Annual on April 1st. 2018. The “Annual Inspection” is just that. An inspection of the aircraft performed annually meeting the requirements of FAR(s) Part 43, Part 65, and part 91. Including complying with the Inspection Checklist contained within the aircraft manufacturers inspection procedures for an “annual inspection”. Or, utilizing a checklist of one’s own design drafted by the authorized inspecting individual, (IA) and must include all items listed in FAR Part 43 Appendix “D”. If no manufacturers or individual checklist exists, then the Appendix “D” checklist shall be used. Now, keep in mind. The checklist in Appendix “D” is very non-specific in its guidance on in-depth inspections. Therefore, a more precise checklist is needed, preferably one that is designed for that particular aircraft. We use one that I drafted twenty-plus years ago and have amended it a few times to included specific tasks that aren’t generally included in the checklist provided by the manufacturer. We use both the manufactures and our own checklist when we can. We also lubricate the aircraft per the provided lube charts while we’re deep in the bowels of your aircraft. I have seen hundreds of aircraft that haven’t been lubed in quite some time. Doesn’t anybody buy lubricants anymore?
THE MAN; As per the regulations, only an Authorized Inspector can perform an Annual Inspection. What this means is that only a person holding a valid A&P license with an Inspection Authorization (IA), endorsement can perform the required Annual Inspection. A guy with just his A&P can open up the necessary panels, disassemble the wheels, clean the bearings and brakes, etc., but the IA must perform the actual “inspection” of each component. The scope and detail of the inspection your aircraft receives, is directly proportional to the experience of the guy doing the inspection, and the type of checklist he is using. In FAR 43 Appendix “D” for example; (c) “Each person performing an annual or 100 hour inspection shall inspect (where applicable) the following components of the cabin and cockpit group”: (3) states; “Windows and windshields-for deterioration and breakage”. O.K. alas gut Right? Wrong. It states nothing about looseness, crazing, fogginess, or any other commonly found anomaly in window inspections. What about the material? Is it the correct stuff? I inspected a Cessna 170 years ago that the owner replaced all of the stationary glass in his trusty steed himself to “save a few bucks”. During my scrutinizing inspection, I questioned the materials used to replicate the side windows, and to my amazement, the owner truthfully exclaimed that he had gone down to the local “gettin’ place” and purchased a 4 X 8 sheet of Lexan® and proceeded to “re-manufacture” his new side windows. Now, unless you’re using a checklist that specifically states to check for the material, (and proper thickness), this discrepancy would not have been detected. But, because of my years of experience and training and a little airport gossip, I suspected something wasn’t transparent about the plastic used and questioned the owner about it. Not catching this would have affectively caused the aircraft to be unairworthy. Why you ask. Well, for starters, Lexan is not an approved material by the aircraft manufacturer. It has a different structural matrix which makes it very tough, which equates to being brittle. But, most importantly, it puts off cocktail of fatal toxins in the smoke created when it burns. “Lexan” is a trade name for Polycarbonate thermoplastic material. We predominantly use Acrylic thermoplastic sheet in aircraft applications for these reasons, and the fact that when it burns, the smoke isn’t nearly as toxic Plus the coefficient of expansion and contraction is more suitable for aircraft applications. A common trade name for this Acrylic product is “Plexiglas”. The fact that Lexan is not an “approved” material, brings us to the other “man” in our lives.
THE OTHER MAN; This person would be our friendly FAA personnel that are always here to help. Which, they really are. Just some are better at it than others. (A topic for another day). The FAA kind of frowns upon owner/operators performing maintenance or preventive maintenance that they’re not qualified to accomplish. The above case in point, is when the 170 owner disputed my opinion on the findings of his expertly executed window installation and the use of his chosen material. It wasn’t until my PMI at the time had to step in and clarify the proper procedure and corresponding regulation that this owner failed to comply with, that he finally accepted the fact that I was only looking after his best interest in more ways than one. He did protest the fact that his Maintenance Manual and Illustrated Parts Catalog didn’t specify which material to use, but after explaining that the IPC listed part numbers for the windows in question, and the he could purchase these parts from an Authorized Cessna Dealer or an approved aftermarket supplier, he finally for the last time conceded to let the professionals maintain and repair his aircraft. The burden of legalities is now on me/us.
THE MYTH; The scenario above now brings us to a topic that I have heard more than once when it comes to complying with the Maintenance Manual. I had a client bring in his newly acquired 1954 Piper PA-22 which had been converted to a taildragger making it a PA-22/20 that he had just purchased from a guy who was an A&P /IA. The aircraft had the correct Lycoming O-320 no suffix engine in it and new Slick/Champion 4300 series magnetos installed in place of the original Bendix 20 series units it came out of the factory with. While perusing through the poorly kept logbooks, and staring at the cornucopia of unapproved and undocumented alterations, I noticed that the 500 hour magneto inspection hadn’t been complied with. I brought this revelation to the attention of the new owner, and he, of course disputed my “opinion” on the validity regarding this required inspection. He then enlisted the opinion of another shop here on the field, and they told him that “he didn’t need to comply with that inspection, because he didn’t fly under FAR Part 135”. WTF? My PMI was visiting us for another reason a few days later, and when I mentioned this to him, he seemed very alarmed at me for not understanding the intent of FAR §43.13 (a). This regulation states;”………………………………shall use the methods, techniques, and practices prescribed in the current manufacturers Maintenance Manual or Instructions for Continued Airworthiness prepared by its manufacturer……….. “. Sounds good right? Wrong again. The discussion became a debate, and the debate then became an argument. My PMI proceeded to explain to me that the term “current” referenced to the current Maintenance Manual at the time when the aircraft was manufactured. I strongly disagreed, and proceeded to voice my disagreement, which then led to the debate. My reasoning was this; when the aircraft was built, it had Bendix 20 series magnetos installed as original equipment. It now has FAA/PMA approved Slick Electro model 4300 magnetos on it. The “current” manual that would have been needed and used back in 1954 is no longer relevant because of the simple fact that the components in question are no longer installed on the aircraft, and the manual that is “current” now, is the Slick Electro Master Service Manual or its latest revision. The argument ensued when I stated that if I used Slick’s “current” manual yesterday, and they came out with a new manual, or a revision today, then this new manual now becomes the “current” manual. He disagreed with my interpretation of “current”. I’m sorry, but the notion that “current” meant when the aircraft was built was a bunch of whowee, and in no uncertain terms I continued to let him know my position on this subject. He wasn’t amused by my analogy of the term “current”, but I didn’t care. I was right and he wasn’t. If his interpretation were the case, then we all better start hitting those “Fly-Markets” at Oshkosh and the Seattle and Wichita Antique stores in search of those old manuals so we can stay legal. “Current” means current. Look it up if you don’t believe me.
THE MISCONCEPTION; The confusion here seems to be that no one really seems to know the FAR’s as they are written. Most of the time you have to have a law degree to even read some of the regulations we have to comply with. Most people have a pretty good grasp on what is being communicated, while others simply interpret them differently. Very little seems to be standardized when it comes to dealing with some FAA personnel. I experienced this lack of consensus in Redlands. The opinions and interpretations at the Riverside FSDO varied as much as the opinions and interpretations of each Inspector employed there. Their O&I’s differ greatly from the Spokane FSDO, and it seems that I am very fortunate to be able to work with a bunch of people whom are on the same page on issues that I deal with each day, and to have good working relationship with those folks. Their job isn’t easy, and it’s much harder when they have to deal with me or guys like me. The atmosphere at Spokane FSDO is far better than Riverside ever was though and I don’t know why. Maybe it’s the summer heat and those Riverside guys don’t want to leave their cool comfy office. Not sure what the reason in the spring, winter or fall is though. One area of non-confusion for me is this. If you’re flying under FAR Part 91 rules, you need to follow with the current Maintenance Manual for whatever component you’re working on and must have that manual in close proximity to your work area and be using it. As well as complying with all A.D. Notes including those pesky recurring ones. If you’re operating under FAR Part 135, then in addition to the above referenced criteria, you must also comply with all manufacturers Service Bulletins, Mandatory Service Bulletins, Service Instructions, Service Letters, recommended TBO’s , all Time In Service and Calendar Time life limited instructions, etc., [FAR§ 91.403 (c)], That’s a lot of paperwork for a small Part 135 operator to keep up on. Most importantly, all of these documents have to be “current”.