What is an I/A responsible for???

[Pearson]

The post regarding the wing tanks in a BL model Taylorcraft has brought a question to my mind that I think warrants a new thread. The title says it all. When you take your airplane in for an annual, just exactly what is it your are paying for? What is an I/A responsible for when they sign off an annual?

I thought that when you get an annual, the Inspector was saying that on THAT day your airplane was safe, and that the Inspector saw no reason it wouldn't remain safe for another year.

Does a signoff for an annual mean that every bit of paperwork since the birth of the aircraft is 100% legal. With as complicated as the FARs are, I would think that an I/A would need a law degree to determine the legalities of every logbook entry and 337 on each aircraft he annuals.

What are your impressions of an annual? Is it fair to expect an I/A to be responsible for the legality of every mod or repair for the history of an aircraft? How about it I/As, what are your thoughts?

[Guest]

Re: What is an I/A responsible for???

Hi Richard,

I/A is responsible to make sure that 1) the airplane complies with (meets) its type data and 2) is in a condition for safe operation, this is the definition of airworthy.

Item 1 above implies all that legal stuff that you mentioned. That's what the FAA requires of I/A's.


Notice that the signoff shown in the FAR below says "I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition”. That's where the I/A gets saddled with checking that the airplane has only legal installations on it at that time of the inspection. Richard that is not the same as checking that the past log book entries are correct or legal.


§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.”


Another relevent FAR says this;
§43.15 Additional performance rules for inspections.
(a) General. Each person performing an inspection required by part 91, 125, or 135 of this chapter, shall—

(1) Perform the inspection so as to determine whether the aircraft, or portion(s) thereof under inspection, meets all applicable airworthiness requirements; and




If I left something out I am sure other IA's will jump in.

I have been an I/A for about 15 years and I respect the guys that do annuals, I don't do many annuals at all neither do I desire them.

Dave

[Guest]

Re: What is an I/A responsible for???

It always make me nervous when I have the last word.

I wish someone else would jump in here.

Dave

[M Towsley]

Re: What is an I/A responsible for???

Hi Dave, feel better?

[Pearson]

Re: What is an I/A responsible for???

Dave,

Is that kinda like when you are the last I/A to sign off a logbook? Yes, I was trying to get a discussion started on the pros & cons of the various aspects of an annual inspection.

[Garry Crookham]

Re: What is an I/A responsible for???

Richard, I'll jump in with Dave. What aspects of an annual inspection would you like to discuss? As Dave indicated the annual inspection consists of 1. a conformity inspection and 2. an inspection to determine if the aircraft is safe for flight.

Garry Crookham
A&P/IA CFI
Tulsa
N5112M

[Hank Jarrett]

Re: What is an I/A responsible for???

The "regulators" want it in the order Gary shows, I want it in the other order. The annual has to cover both. The FIRST priority should be to insure the plane is safe for flight. Once that is done I worry about if it meets the conformity requirements (something the bureaucrats in the FAA demand).

Don't get me wrong, I DO believe in maintaining a proper history showing ALL changes to the aircraft to ENABLE the IA to insure the aircraft is safe for flight, but conformity DOES NOT GUARANTEE THE AIRCRAFT IS SAFE, it just fulfills a regulatory requirement. A good IA will ALWAYS put safety first, and fulfill the conformity requirement as a part of doing that. (You have to have BOTH to do an annual.)

Most of our planes have MANY undocumented modifications on them, that are not even known to the IAs looking at them. That is not really the IAs fault. How many of US know what all the legal configurations are? The IA's fulfilled their REAL need and insured the planes were SAFE first. Unfortunately that can leave them open to action from the bureaucrats who think the "rules" exist to be enforced, not to enable safety. It is OUR RESPONSIBILITY to get our planes in conformance to protect our IAs! WE KNOW what the configurations should be (here and in our records) not the IAs. WE NEED TO make the records match the configuration sitting on the ramp. The TCs show what the original configuration was. EVERY CHANGE TO THAT SHOULD BE DOCUMENTED! Most of us have NUMEROUS undocumented changes. That isn't the end of our world. Just get with your IA when you find something that isn't in conformance, with a copy of where another member of the Tribe has made the change and get your logs changed to make the logs match the configuration.

A good example is the number of pre-war planes with "blown" post war, one piece windshields. There were NO pre-war Taylorcrafts with blown windshields. The technology to make them was developed by the British in WW-II. If you have a curved, one piece windshield on a pre-war plane, with no log entry, you are NOT in conformity! Easy to fix. MAKE THE LOG ENTRY! If we had FAA inspectors who knew our planes we would be in trouble. The post war windshields are stronger, easier to see out of and safer, but without the entry THEY ARE NOT LEGAL on a pre-war. Just get with your IA and start a list NOW for your next annual of what needs to be documented.

Hank

While you are at it, make sure WHAT PLANE YOU HAVE! Just because it has an A-65 on the front does NOT make it a BC-xxxx. If your plane was BUILT with a Franklin it WILL ALWAYS be a BF! If it was built with a Lyc, it will ALWAYS be a BL, REGARDLESS of what is on it now. You need to use the TC for the actual plane, NOT for a post war BC-12D! Show the engine change in the conformity inspection and in the log. If we let our IAs get screwed by some bureaucrat, WE get screwed too. WE NEED TO PROTECT THEM!

[M Towsley]

Re: What is an I/A responsible for???

Hank, that is all great except how do I know if my plane 'conforms'? My logs prior to the 60's are lost. Much of this stuff does not show on the FAA CD. Did the wing tank fuel valves under my dash come that way, or were they at the wing root? I don't know. Are my 'pretzel' yokes original to my plane or the cast magnesium? Again, I don't know. It is all that little stuff that adds up that is not in the Type Certificate that not everybody knows. Someone here on the forum may know, but there is no central repository for this knowledge. Is is scattered all over our forum that you have to dig out piece by piece.

I try to make sure my plane conforms to its configuration 'to my knowledge'. My knowledge is only as good as what I read and research. And realistically, how many of us really do that or want to do that? (Besides me and you, and that is because we are both OCD)?

[Garry Crookham]

Re: What is an I/A responsible for???

but conformity DOES NOT GUARANTEE THE AIRCRAFT IS SAFE, it just fulfills a regulatory requirement. A good IA will ALWAYS put safety first, and fulfill the conformity requirement as a part of doing that. (You have to have BOTH to do an annual.)

You might want to reconsider the above. The conformity inspection does more than fulfill a regulatory requirement. A prop that isn't approved on a certain airframe should be discovered during the conformity inspection. That prop could have vibration and/or harmonic problems on the airframe/engine. A thrown prop blade is certainly a safety problem. That's just one example of problems I've found during the conformity phase of an annual. I wish every one could sit through a few of the "annuals from hell" that every IA endures.


Garry

[Guest]

Re: What is an I/A responsible for???

An I/A inspects the aircraft not the logbooks.

The aircraft has a conformity requirement not the aircraft records other than listed in part 91.417(a)(2) as stipulated in part 91.417(b)(2).

There is no requirement to correct past log errors but rather to correct the aircraft to its type data.

So don't be worried about historical log book issues.

In fact the maintenance/alterationrecords are legally required to be held for just one year (see part 91.417(b)(1)) of course buyers like that to be a longer period.

BTW- logbooks has no specific legal meaning. FAR refer to aircraft records. They can be invoices, labels, letters, log books ...

Food for thought, Dave.

[Hank Jarrett]

Re: What is an I/A responsible for???

I am working with several people right now but the process is the same. Find out what your plane REALLY is first. What was it ORIGINALLY. My own plane, I just found out, was BUILT with a FRANKLIN engine! Before it was delivered to the original owner, the Franklin was taken off and the Lyc was put on. OK, it left the factory doors with the Lyc, but was originally a Franklin. Which is it now? I am not sure any more. The FAA currently has her as a BC, but that is in error, and they know it now. From a safety standpoint, it really doesn't matter, except that my plane was "obtained" from the first owner by Uncle Sam after the Pearl Harbor dust up in 41. They didn't return any records from the war years, but sold the plane back into the civil inventory as a BC with a Continental engine.

What have I got? A BF with a Continental conversion? A BL with a Continental conversion, or a BC? So far, no one with the FAA really cares, AS LONG AS The Continental is installed correctly. I doubt they want to try and figure out what the heck the War Dept and CAA did, not to mention what Taylor did without proper paperwork. What my logs will say is that the firewall forward was converted to the BC configuration in WW-II and it is safe to operate that way. No one but me seems to care when it even happened. This is just one thing on my plane. There were HUNDREDS of them! Safety first, then conformance. I actually think there are probably only two or three people IN THE WORLD who can find anything out of conformance on my plane that is not documented, and those are being corrected, BUT ARE SAFE now.

The way Marty is doing his is great. Ask the question, find what is correct, and put paper in place to show the deviation or put it back to original. Not sure exactly when the change from pretzels to cast control wheels happened, but I KNOW they were pretzels in 45 and early 46 (old factory photos show them). Who has the oldest original photo of a cast wheel? I suspect some time in 46, but I don't know for sure. Anyone? The thing is, if Marty's plane came with cast wheels, it is no big deal, just show they were changed to pretzels (unless you WANT the cast ones, then just to be safe, show you changed to that). A conformity inspection just shows the plane matches the paperwork, NOT that it is all original. As Gary said, the conformity inspection does more than just fulfill a regulatory requirement, it is a major tool for the IA to show the plane is SAFE. If the logs show one prop, and another is on the plane, you are out of conformity, and I would say GROUNDED, until you not only get the paper to match the plane, but make sure the prop is in fact a legal one. Even if the prop IS LEGAL, if it is not the one shown in the paperwork, you are OUT OF CONFORMITY. The conformity inspection is SUPPOSED to be a check to help the IA know the plane is safe, but it has become just an administrative hammer for some IAs and admin types.

The nice thing about "Annuals from Hell" is we learn SO MUCH from them. That is why I like to hear about groups in the Tribe getting together and doing group annuals. WE ARE THE BEST SOURCE OF INFORMATION on our planes! When we disagree, that is the driver to find out which way is RIGHT. In the interim, a log entry will "usually" allow the plane to fly, IF IT IS SAFE. I can't imagine ANY IA grounding Marty's plane for the wrong control wheel, but I know darned well they would for the wrong wheels with the tires or the wrong prop! I wouldn't want anything different from my IA on my plane.

As to Drude's comment, every annual I have had the IA spent more time with the logs than the plane. Every year, as he learned about Taylorcrafts (mostly from me, or this group), he spent more time with the plane, and less with the logs. The aircraft does carry the burden of the conformity requirement not the records, but the aircraft conformity is BASED on the original TC and the records of any changes made. You have to have both. I agree, you DO NOT change the records. Past screw ups are a part of the history of the plane, but you DO make new entries showing that any deviation from the prior recorded configuration have been looked at and returned to the recorded configuration, or evaluated and accepted. When that is done. the paper will match the plane and you are in conformity. For my plane, I returned as many changes to "factory configuration" as I could. It is simpler than trying to run down who changed what when. Watch for taking an AD off!

OK, you probably will NOT catch all of the changes because there will always seem to be some item that is discovered that someone changed and was hidden, but that is NOT a problem, just fix it, or get it accepted, just NEVER hide it from your IA. He is on OUR side (or if he isn't, you need a new IA).

Hank

[Pearson]

Re: What is an I/A responsible for???

My reason for posing the question comes from the thread regarding the BL65 which passed an annual with fuel tanks installed in the wing. Unless an I/A is familiar enough with the various models of Taylorcraft the only way one would know that the BL 65 is not typed with wing tanks is to look at the TCDS. I have never heard of the need to review the TCDS and basically do a full conformity inspection for an annual. If this is a requirement, or just good operating practice, what does an I/A do when a mod such as wing tanks is discovered and the log books are not complete? Would one then be required to postpone the inspection until the FAA CD arrives? What about mods that can’t be seen, such as roller bearing pullys? This seems like an unfair burden on I/As to me. I know the dozen or so times I have had my BC12D annualled the I/A has never consulted a TCDS.

[Guest]

Re: What is an I/A responsible for???

Well, a few more thoughts on this.

An I/A cannot inspect something that he is not familiar with so the I/A needs to decide what he is capable of inspecting and how much self education that he wants to do in order to get ready. He needs access to a lot of data to do these inspections and the FAA requires that he have access to that data. We have to sign a statement every other year declaring that we have access to such data.

Also the conformity to type data is not an option. It is an FAA requirement as is the "in condition for safe operation" clause. Fair doesn't enter into it.

It is somewhat of a conundrum that records only need to be held for a year but they may actually may be needed establish type data conformity many years later.

There are some half a$$ed annuals being done out there perhaps the BL65 is part of that group as was the strut fitting failure was a few years ago that resulted in the strut AD.

One should also note that making sure that airplane complies with its type data and is in a condition for safe operation is actually the minimum that an I/A must do at annual you can always request more but not less. It appears that many of you do go that extra mile (or have your I/A go it). That is a good thing.

Usually when I inspect my t-craft its at least 10-14 hours of labor.

Dave

[Guest]

Re: What is an I/A responsible for???

My reason for posing the question comes from the thread regarding the BL65 which passed an annual with fuel tanks installed in the wing. Unless an I/A is familiar enough with the various models of Taylorcraft the only way one would know that the BL 65 is not typed with wing tanks is to look at the TCDS. I have never heard of the need to review the TCDS and basically do a full conformity inspection for an annual. If this is a requirement, or just good operating practice, what does an I/A do when a mod such as wing tanks is discovered and the log books are not complete? Would one then be required to postpone the inspection until the FAA CD arrives? What about mods that can’t be seen, such as roller bearing pullys? This seems like an unfair burden on I/As to me. I know the dozen or so times I have had my BC12D annualled the I/A has never consulted a TCDS.

Hi Richard,

It is a requirement.

I would check to see if the tanks are listed in the TCDS, if so then a record entry only was required, no 337. I would also want to know if the W&B includes the tanks.

If the existing records did not show the the tanks but the equipment list (309 form as I recall) and W&B did then I am ok with it.

If it is not on TCDS and not in a/c records as a 337 then get the CD and look there (however long it takes).

If there is a 337 on the CD covering it as a field approval or STC or some other approved data and on the W&B then I am ok.

If there is no 337 to cover the tanks on the CD then either 1) write a discrepency list that includes this item and reject the annual or 2) begin an approval process like a field approval, look for an STC, hire a DER or 3) remove that offending tank.


I am pretty sure that roller bearing pulleys can be seen but unseen mods are problem. If an A&P installed the mods the records should indicate the change. Are roller bearing pulleys an approved mod? Is there an STC? PMA alone is not sufficient.

Dave

[N96337]

Re: What is an I/A responsible for???

Dave's right on the money. One of the very basic criteria for any inspection (annual or 100 hour) is a conformity to the TCDS (or aircraft listing as it used to be) or other "avenues" of approval (field approval, service letter/bulletin, group 2 approval, etc). No if's and's or but's.... It's one of the first things I was taught in A&P school many years ago. I can't think of one aircraft I've done an annual on, that I haven't had to consult the T/C on...if you're IA isn't following this BASIC info, you need a better IA! If you are performing an annual and an FAA inspector walks in, and you don't have access to all of the data that is required to inspect that aircraft, you're in deep trouble. Many people don't understand just what it entails for us to be able to do annuals. It's a whole lot more involved than owning a flashlight and mirror. In the past it was much more difficult and expensive just to have the technical library that was minimum requirement to do inspections. The "online" and computer age has reduced the difficulty as well as the expense considerably! Remember when we used to have to subscribe to AD's in paper form and get revisions every 2 weeks, Dave....not to mention all the manuals for anything we worked on?! Now I don't have anything but a laptop and internet access and I've got more and quicker information at my fingertips than ever before!
I've run across situations like this (the BL fuel system) more than once, and am blessed to have a great relationship with my FSDO, so a problem has never risen. That being said, I'm usually the first one to call and ask their opinion on stuff, just to get their "blessing" as to what avenue to take.... a little goes a long ways usually. I know many IA holders that act like they're afraid to talk to the FAA, and therefore never do get any relationship established, or even worse establish a "relationship" only when there's a problem. I've had to straighten a couple of those messes out in the past. I'm guilty of complaining about the FAA as much as many, but they have a job to do, and we're a small part of it... so they make better friends than enemies... and I've found that they can be a nice sight to see in my corner! Sure, there are those who have no idea what a Taylorcraft is... so take a bit of time to educate them. Like my Grandma used to say, "you catch more flies with honey than vinegar!"
It's been pounded into my head from the day I got my A&P, that when you sign the logbook on an inspection, you own what's been done to that aircraft. Plain and simple. I got a 250 Commanche in for an annual one time that hadn't been flown in over 20 years. There was an oil pump AD that had been due just about the time of the last annual. The statement at the end of the annual entry was "All AD's complied with"... every IA's seen that one a few times!!.... yet there was no specific reference to THAT AD being completed. It could be inspected and if certain conditions weren't present, it could be signed off for a repetitive inspection, if I remember, but if there was certain conditions present, it had to be replaced.... chances were that it was complied with, but we'd have to split the accessory case off to see. I called my FSDO (GADO in those days) and talked to them about it. We both agreed that it most likely was complied with, but he explained to me that if I signed it off, and it hadn't been complete, I was the one that they'd be after if there was a problem.... as soon as the IA signs that maint/inspection record, they OWN the work previously done.
I also have a good friend who did an annual on an aircraft and one of the AD's that was signed off as previously complied with, had not actually been complied with. It was on a mag, if I remember right... and a few hours past the inspection, the mag failed, aircraft was damaged, and the FAA got involved. He wound up losing his license for 90 days because it hadn't been done.... him and every IA that had signed off that aircraft since the due date of the AD. It stinks to high heaven, but that's how the system works.
Hank brings up a great point.... the IA is on YOUR side...don't try to hide things from them!! Dealing with old/antique planes is tricky enough, and I've learned that usually the owners have a done a great deal of research on their aircraft...sometimes that's good, sometimes that's just confusing, but 9 times out of 10, it's a good thing.
One of the problems we run into with these old aircraft is that they sometimes left the factory in less than strict and perfect compliance with the TC. I have had many conversations with a great friend of mine that worked in the Taylorcraft factory in the 40's, and he says that if they didn't have the part they wanted, a lot of times they grabbed what was on hand. The factory was always on a shoestring, so you used what you had... and that's proven many times over with things like the door frames, etc. Things were a lot more relaxed back then, and there weren't so many bureaucrats that needed to justify their jobs, so it was business as usual.
I agree that the paperwork wont necessarily make the aircraft safe to fly, but a lot of the mods I've seen on older aircraft weren't necessarily the model of safety. It may be something that has lasted forever, but that doesn't make it safe. It also doesn't make it legal. I once had a J3 brought in for annual that had been covered with a blue tarp and nitrate/butyrate dope. It flew in, and had been flown a few years, and from about 50' it looked pretty good....at least no worse than some cover jobs I've seen. I guess nobody had bothered to actually LOOK at the fabric. They'd cut tapes and everything from blue tarps... sure seemed like a helluva lot of work to me. Needless to say, it went NO further. As an IA, we are required to prove compliance with approval on anything that has been done to that aircraft..... that's our job. Sometimes that means I'll send in a 337 for something that had been done previously... like a friend of mine who was my PMI for years said..."I've never seen anyone get a violation for sending in a 337...but I've seen a few get them for NOT sending one in"! So, when in doubt, a phone call to the FAA and maybe some correspondence and a bit of paperwork, and it can be sorted out.
When I get an aircraft in for annual that I haven't ever seen before, I usually allot at least a day to do nothing but the paperwork and compliance inspections... then we can get down to the rest of the annual.... if it's an aircraft I see every year, it takes less time.

So yeah Richard, we take on a lot when we sign an annual off. Some take it lightly and play the "odds"... some of us don't! Sorry for being so long winded!
John