Destroyed and Scrapped Aircraft

[astjp2]

Newer FAA order on destroyed aircraft FAA Order 8100.19.pdf

[PA1195]

Check for other local seminars here: https://www.faasafety.gov/SPANS/events/EventList.aspx

Good time to visit Fairbanks 3/14/19 with almost 12 hrs of daylight and Ravens circling overhead. Basically one of the aircraft's primary structures must still be intact to allow repairs. Comments are requested and are available at the end of the document Tim linked:

https://www.faasafety.gov/SPANS/even...=/default.aspx
https://www.faasafety.gov/files/even...2019_FLYER.pdf

Gary

[N96337]

I hope they hang that guy from the nearest telephone pole!
John

[astjp2]

what guy? the one giving the lecture?

[PA1195]

Sadly he has no idea what aircraft owners and maintenance folks are like when coming out of a long dark cold winter:

https://www.youtube.com/watch?v=qLvGnro4Cgw

Maybe that's why they rescheduled the seminar from the University of Alaska to the Airport Police and Fire building.

Bring lots of popcorn! And remember...you can tell an engineer but you can't tell them much..Taylorcrafters and other aircraft enthusiasts excepted.

Gary

[N96337]

Tim, the guy giving the lecture is the one that wrote the rule from what I understand.
John

[Ragwing nut]

That's going to be one ugly meeting/seminar.

[PA1195]

It will become a peeing contest between FAA maintenance inspectors tasked with resolving the destroyed vs rebuildable definition and interested parties. I'd not want to be either and I know both well.

Is the Soul of an airplane one of the primary structures or the Data Plate? To be continued...

Gary

[Robert Lees]

In the UK (and I believe EASA-land), it's the fuselage and the data plate affixed thereof.

One might argue that the rudder (or landing gear or seat or door) is "primary structure"

[Hank Jarrett]

I guess you need to do enough "repair" to make it repairable before you ask them if it is still repairable.

Hank

[PA1195]

I believe that's one of the contentious topics to be yet resolved among and between the FAA and owners/operators/mechanics. The fuselage-wings-alighting gear-empennage have been suggested in various documents as Primary Structures. I "think" this was all they had before this self-generated FAA Order was issued last Fall without public comment. Now it may go forward as another Advisory Circular with teeth.

This definition has appeared previously in Advisory Circulars "Primary Structure. Primary structure is that structure which carries flight, ground, or pressurization loads, and whose failure would reduce the structural integrity of the airplane."

From 8900.19:
"All major repair data for type certificated aircraft must be approved by FAA engineers, inspectors, appropriate designees, or under the provisions of a bilateral agreement."

And:
"FAA accident investigators will apply their specialized knowledge and expertise and follow the guidelines in this order when evaluating aircraft wreckage to determine whether an aircraft is repairable or should be declared destroyed. In some cases, an ACO engineer may assist in the determination..."

When and how that's going to happen in the course of events is a question to be answered during the FAA Seminars.

Gary

[PA1195]

This is the preface to the Order 8900.19. I'll drop it here for reference:

SUBJ: Destroyed and Scrapped Aircraft

"This order provides guidance to FAA personnel responsible for evaluating aircraft wreckage and classifying an aircraft as destroyed or scrapped. This order also provides guidance related to actions that are required to be taken when an aircraft is determined to be destroyed or scrapped. Such actions include the disposition of aircraft identification plates, aircraft de-registration, and compliance with aircraft recordkeeping requirements. It addresses the re-registration of aircraft that may have previously been classified as destroyed or scrapped and describes the procedures a person may use to dispute a determination that an aircraft has been destroyed or scrapped.

Many current FAA and National Transportation Safety Board (NTSB) forms classify aircraft damage as minor, major, substantial, or indicate that an aircraft has been destroyed. Title 14 of the Code of Federal Regulations (14 CFR) § 47.41a(2) specifies that an aircraft’s Certificate ofRegistration, AC Form 8050-3, is no longer effective if the aircraft is “totally destroyed orscrapped.” In this order, we consider the report of a “destroyed aircraft” the same as an aircraft reported as “totally destroyed.”

This order provides instructions for FAA employees to assist aircraft owners in complying with the requirements of 14 CFR §§ 45.13 and 47.41 by specifying what constitutes a destroyed or scrapped aircraft and by establishing procedures to properly disposition aircraft wreckage.

This order also sets forth a process for a person to dispute a determination that an aircraft has been destroyed or scrapped.

Ali Bahrami
Aviation Safety Associate Administrator"

Gary

[Ragwing nut]

the problem is what constitutes not repairable is contradicted right in the order. It states that one major component is needed for repair, wing, fuselage, landing gear etc. However 2 paragraphs down it basically states if the fuselage has to be replaced, then its destroyed unless there is a repair schedule approved by the FAA, which is beyond me why they want that responsibility. They don't even want to do a 337 hardly anymore.

[PA1195]

I will ask my FSDO MI next time he's by for a perspective. Nothing confrontational but sometimes it's best to have a talk before the question. They may not be that all interested in inheriting the responsibility so we'll see.

Gary

[Ragwing nut]

I will ask my FSDO MI next time he's by for a perspective. Nothing confrontational but sometimes it's best to have a talk before the question. They may not be that all interested in inheriting the responsibility so we'll see.

Gary

I asked ours, and he said it's not a retroactive thing. They are not going to go out and look for aircraft to label scrap. it's more a going forward thing. Still its a an overreach imo. Plus its POLICY, not REGULATORY, and I have told more than one FAA inspector where to shove their policy. They don't like it when I have told them that, and they also don't like it when I have been right about it either. It pisses me off when they try to govern thru policy because its easier to change at the discretion of whoever is currently in charge that day, rather than change regulations.