Pilot’s Airworthiness Responsibilities
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Pilot’s Airworthiness Responsibilities
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Pilot’s Airworthiness Responsibilities
- 1. Federal Aviation AdministrationSouthern Region FAASTeam Pilot’s Airworthiness Responsibilities Presented by: Mark L. Laughridge FAASTeam Program Manager Date: March, 2012
- 2. Federal Aviation Administration 2March, 2012 Objective – Define and understandObjective – Define and understand the term “Airworthy”the term “Airworthy”
- 3. Federal Aviation Administration 3March, 2012 ObjectiveObjective --To review the requirements thatTo review the requirements that must be met for an aircraft to be “airworthy”must be met for an aircraft to be “airworthy”
- 4. Federal Aviation Administration 4March, 2012 Objective – Address the owner/operator and PICObjective – Address the owner/operator and PIC responsibilities for the airworthiness of an aircraftresponsibilities for the airworthiness of an aircraft
- 5. Federal Aviation Administration 5March, 2012 Understanding “Airworthy” The term “airworthy” is often used but was not specifically defined in the regulations until recently.
- 6. Federal Aviation Administration 6March, 2012 14 CFR PART 3.5 • § 3.5 Statements about products, parts, appliances and materials. • (a) Definitions. The following terms will have the stated meanings when used in this section: • Airworthy means the aircraft conforms to its type design and is in a condition for safe operation. • Product means an aircraft, aircraft engine, or aircraft propeller.
- 7. Federal Aviation Administration 7March, 2012 CIVIL AIRCRAFT AIRWORTHINESS 91.7 • No person may operate a civil aircraft unless it is in an airworthy condition. • The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight….
- 12. Federal Aviation Administration 12March, 2012 CIVIL AIRCRAFT AIRWORTHINESS 91.7 • No person may operate a civil aircraft unless it is in an airworthy condition. • The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.
- 15. Federal Aviation Administration 15March, 2012 STANDARD AIRWORTHINESS CERTIFICATE UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 1. NATIONALITY AND REGISTRATION MARKS N12345 2. MANUFACTURER AND MODEL Boeing 747-400 3. AIRCRAFT SERIAL NUMBER 197142 4. CATEGORY Transport 5. AUTHORITY AND BASIS FOR ISSUE This airworthiness certificate is issued pursuant to the Federal Aviation Act of 1958 and certifies that as of the date of issuance, the aircraft to which issued has been inspected and found to conform to the type certificate, therefor, to be in condition for safe operation, and has been shown to meet the requirements of the applicable comprehensive and detailed airworthiness code as provided by Annex 8 to the Convention on International Civil Aviation, except as noted herein: 6. TERMS AND CONDITIONS Unless sooner surrendered, suspended, revoked, or a termination date is otherwise established by the Administrator, this airworthiness certificate is effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with Parts 21, 43, and 91 of the Federal Aviation Regulations, as appropriate, and the aircraft is registered in the United States. DATE OF ISSUANCE 11/29/92 FAA REPRESENTATIVE John Q. Publican DESIGNATION NUMBER DMIR ANM 1234John Q. Publican Any alteration, reproduction, or misuse of this certificate may be punishable by a fine not exceeding $1,000, or imprisonment not exceeding 3 years, or both. THIS CERTIFICATE MUST BE DISPLAYED IN THE AIRCRAFT IN ACCORDANCE WITH APPLICABLE FEDERAL AVIATION REGULATIONS. FAA Form 8100-2 EXEMPTION NO. 1013A FAR 25.471(b): Allows lateral displacement of C.G. from airplane centerline.
- 16. Federal Aviation Administration 16March, 2012 5. AUTHORITY AND BASIS FOR ISSUE This airworthiness certificate is issued pursuant to the Federal Aviation Act of 1958 and certifies that, as of the date of issuance, the aircraft to which issued has been inspected and found to conform to the type certificate therefore, to be in condition for safe operation, and has been shown to meet the requirements of the applicable comprehensive and detailed airworthiness code as provided by Annex 8 to the Convention on International Civil Aviation, except as noted. Exceptions: 6. TERMS AND CONDITIONS Unless sooner surrendered, suspended, revoked, or a termination date is otherwise established by the Administrator, this airworthiness certificate is effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with Parts 21, 43, and 91 of the Federal Aviation Regulations, as appropriate, and the aircraft is registered in the United States.
- 17. Federal Aviation Administration 17March, 2012 WHAT DOES TYPE DESIGN MEAN? The type design consists of – (a) The drawings and specifications, and a listing of those drawings and specifications, necessary to define the configuration and the design features of the product… (b) Information on dimensions, materials, and processes necessary to define the structural strength of the product… (c) The Airworthiness Limitations section of the Instructions for Continued Airworthiness as required…
- 18. Federal Aviation Administration 18March, 2012 www.faa.gov then select “Type Certificate Data Sheets”
- 19. Federal Aviation Administration 19March, 2012 TYPE DESIGN DATA SHEETS
- 20. Federal Aviation Administration 20March, 2012 TYPE DESIGN DATA SHEETS
- 21. Federal Aviation Administration 21March, 2012 TYPE DESIGN DATA SHEETS
- 22. Federal Aviation Administration 22March, 2012 AIRCRAFT OPERATOR RESPONSIBILITIES • An aircraft operator is responsible for the following items [91.203 & 91.403]: – Ensuring that the aircraft has a current Airworthiness Certificate and Certificate of Registration in the aircraft. and – Verifying that the aircraft is airworthy and in compliance with all applicable AD’s
- 25. Federal Aviation Administration 25March, 2012 AR(R)OW • A-Airworthiness Certificate • 91.203(a)(1) • R-Registration • 91.203(a)(2) • (R)-Radio Station License, when required • O-Operating Limitations • 91.9(b)(1)&(2) • W-Weight and Balance • 23-1519, 23-1583, 23-1559 & 91.9
- 26. Federal Aviation Administration 26March, 2012 AIRCRAFT OPERATOR RESPONSIBILITIES – Complying with the Operating limitations specified in the Approved Airplane flight manual, markings, and placards. including weight and balance, are in the aircraft and complied with.
- 27. Federal Aviation Administration 27March, 2012 “What's one more box, its doesn’t weight much, just throw it in the back”
- 28. Federal Aviation Administration 28March, 2012 AIRCRAFT OPERATOR RESPONSIBILITIES – Complying with the Operating limitations specified in the Approved Airplane flight manual, markings, and placards, including weight and balance, are in the aircraft and complied with. – Assuring that maintenance is properly recorded.
- 29. Federal Aviation Administration 29March, 2012 AIRCRAFT OPERATOR RESPONSIBILITIES – Assuring that maintenance is properly recorded. – Ensuring that the aircraft operating limitations, including weight and balance, are in the aircraft and complied with. – Verifying that the aircraft is safe for flight.
- 30. Federal Aviation Administration 30March, 2012 WHAT HAPPENS WHEN THINGS BREAK?
- 31. Federal Aviation Administration 31March, 2012 WHAT HAPPENS WHEN THINGS BREAK? 91.213 Inoperative Instruments and Equipment • Minimum Equipment List – MEL – Developed for a specific aircraft – Letter of Authorization from the FSDO required – Must be used by everyone who flies the aircraft – Training and records are required
- 34. Federal Aviation Administration 34March, 2012 WHAT HAPPENS WHEN THINGS BREAK? 91.213 Inoperative Instruments and Equipment • No MEL decision chain – Regulations – 91.205 and TCDS – Manufacturer – equipment list – Remove or deactivate, and placard (91.405) – Determination of safety
- 35. Federal Aviation Administration 35March, 2012 WHAT HAPPENS WHEN THINGS BREAK? 91.213 Inoperative Instruments and Equipment • No MEL decision chain – Regulations – TCDS and 91.205 – Manufacturer – equipment list – Remove or deactivate, and placard – Determination of safety
- 36. Federal Aviation Administration 36March, 2012 “Inoperative equipment can cause a career changing moment”
- 37. Federal Aviation Administration 37March, 2012 PREVENTIVE MAINTENANCE
- 38. Federal Aviation Administration 38March, 2012 PREVENTIVE MAINTENANCE Definition: “Simple or Minor Preservation Operations” and “The Replacement of Small Standard Parts, Not Requiring a Complex Assembly Operation”
- 39. Federal Aviation Administration 39March, 2012 PREVENTIVE MAINTENANCE Appendix A, FAR Part 43: “requires” • The use of the Manufacture’s Instructions • The use of Calibrated Tools if called for • All Preventive Maintenance requires a maintenance record entry.
- 40. Federal Aviation Administration 40March, 2012 AIRCRAFT MAINTENANCE RECORD DATE DESCRIPTION OF WORK PERFORMED 01/26/11 Replaced Main landing light, P/N:4596, in accordance with the Cessna 172 Service Manual. . Ima B. Good Ima B. Good PP #123456789 NOTE: Tach Time (Optional) PREVENTIVE MAINTENANCE
- 41. Federal Aviation Administration 41March, 2012 SPECIAL AIRWORTHINESS CERTIFICATE
- 43. Federal Aviation Administration 43March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 44. Federal Aviation Administration 44March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 45. Federal Aviation Administration 45March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 46. Federal Aviation Administration 46March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 47. Federal Aviation Administration 47March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 48. Federal Aviation Administration 48March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 49. Federal Aviation Administration 49March, 2012 406MHz ELT No current U.S. domestic requirement • After 1 February 2009, 121.5/243-MHz distress signals transmitted from ELTs operating on the lower frequency will only be detected by ground-based receivers such as local airport facilities and air traffic control facilities or by overflying aircraft. • Existing 121.5-MHz ELTs, although still legal from the FAA's perspective, will provide limited assistance if an aircraft crashes, especially in a remote location.
- 50. Federal Aviation Administration 50March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171
- 51. Federal Aviation Administration 51March, 2012 REQUIRED INSPECTIONS • Annual inspection 91.409(a) • 100 hour inspection 91.409(b) • Progressive inspection 91.409(d) • Pitot-static/Altimeter 91.411 • Transponder 91.413 • ELT 91.207 • 30-day VOR check 91.171 • Current GPS data base 91.103 / 91.7
- 52. Federal Aviation Administration 52March, 2012 Appendix D – Scope and Detail of Items to be included in Annual and 100 – Hour Inspections (a) Each person performing an annual or 100 – hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine. (b … j)
- 54. Federal Aviation Administration 54March, 2012 Airworthiness Directives Part 39.3 “Airworthiness Directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.” Part 39.7 “Anyone who operates a product that does not meet the requirements of an applicable airworthiness directive is in violation of this section.”
- 55. Federal Aviation Administration 55March, 2012 AIRWORTHINESS DIRECTIVES
- 56. Federal Aviation Administration 56March, 2012 Part 91.417 (a) (2) (v) “The current status of applicable AD’s including for each, the method of compliance, AD number and revision date and if the AD involves recurring action, the time (aircraft time) and date when the next action is required”
- 57. Federal Aviation Administration 57March, 2012 AD COMPLIANCE RECORD
- 58. Federal Aviation Administration 58March, 2012 Responsibilities • 14 CFR Part 91, section 91.417 states that an aircraft owner/operator shall, keep and maintain aircraft maintenance records. • 14 CFR Part 43, sections 43.9 and 43.11 state that maintenance personnel are required to make the record entries.
- 59. Federal Aviation Administration 59March, 2012 What Must Be In The Maintenance Records? • Description of the work performed • Date the work was completed • Signature and certificate number of the person approving the work Ι χερτιφψ τηατ τηισ αιρχραφτ ηασ β εεν ινσπεχτεδ ιν αχχορδανχε ωιτη α ν αννυαλ ινσπεχτιον ανδ ωασ δετερ µινεδ το βε ιν αν αιρωορτηψ χονδιτι ον SIGNATURE ΙΑ 4456782435
- 60. Federal Aviation Administration 60March, 2012 REVIEW OF RESPONSIBILITIES • DOCUMENTS – Airworthiness – Registration – Operating Limitations – Weight & Balance • AIRWORTHINESS DIRECTIVES • REQUIRED MAINTENANCE RECORDS • INSPECTIONS – Annual - Transponder – 100-hour - ELT – Pitot-static - VOR and GPS data base
- 62. Federal Aviation Administration 62March, 2012 Preflight • 14 CFR section 91.103 • “Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight”…
- 66. Federal Aviation Administration 66March, 2012 We in the FAA stand ready to join with you, to guide, and assist you in every way possible – but the primary responsibility for aviation safety rest with You!
- 67. Federal Aviation Administration 67March, 2012 The Southern Region FAASTeam is dedicated to quality customer service and we would appreciate your feedback on the critique sheet provided. Thank You
Hinweis der Redaktion
- This program has been developed by the FAA Safety Team to review the requirements that an aircraft operator must know to make an informed decision about the airworthiness of an aircraft. It’s also a valuable resource for pilot examiners, instructor pilots, and individuals who wish to become instructors. CFI’s are required to teach airworthiness requirements to pilots and Designated Pilot Examiners are required to evaluate a pilot’s knowledge of airworthiness during a practical test.
- The word airworthy is often used in the regulations and pilots and mechanics both have certain responsibilities for it, but if you looked for a definition of the term in Part 1 of the FARs, you won’t find it.
- Part 3.5 is the only place in the regulations where the definition of Airworthy is referenced.
- CFR 14, part 91 contains the general operating rules . For all intents and purposes, that means PILOT RULES . I’m emphasizing that because many things that pilots assume are the responsibility of a mechanic or repair station, are actually contained in this section of the regulations. Section 91.7 specifically identifies responsibility for operating an airworthy aircraft. Person – Operate – Civil Aircraft and Airworthy have meanings that must be understood in order to know what is actually being said.
- Lets preflight this typical Flight School Cessna 172.
- Is this a problem? Did Cessna design the cowling like this? Is it Airworthy?
- Another cracked plastic end cap on the elevator. What could happen if part of that plastic end cap got wedged between the elevator balance horn and the horizontal stabilizer?
- Yes there are holes in the exhaust stack, but there not very big. I think it will fly! But is it airworthy? What's the rest of the exhaust system like?
- The second section places the responsibility for determining whether the aircraft is in condition for safe flight on the pilot in command. It also uses the imperative word SHALL when specifying that the PIC discontinue the flight if an unairworthy mechanical, electrical, or structural condition occurs. So, what does discontinue mean? Does it mean land in the nearest open field? At a location where repairs can be made? At the nearest suitable airport? How about back at our departure airport where our car is parked? The answer is, as it so often is in aviation, IT ALL DEPENDS . If the situation is such that landing in the nearest open field is the only way to save the aircraft or protect people within it, then discontinue means exactly that. If, in the pilot’s best judgment, the aircraft can be safely flown to the nearest suitable airport, then that’s what discontinue means. It probably does not mean over-flying suitable places to land and continuing to our destination, or returning to our departure point because to do otherwise would be inconvenient. The point being is, this is a regulation by-which our actions as a pilot in command will be judged. Whatever action you decide to take will be evaluated against this rule.
- Have you ever had a weak radio, or broken and grabled reception? It could be something besides the radio itself. This was discovered on an aircraft that had recently been repainted.
- What does the manufacturer’s inspection program say about cracks?
- A typical Standard Airworthiness Certificate, lets look at it a little closer.
- Does block 5 sound familiar?
- Let’s say I’m going to build an aircraft. In order to get this aircraft certified, it will have to meet Part 23 certification rules of the FARs. Those rules dictate certain qualities that the aircraft must have regarding its construction. When I think I have accomplished that, I will turn some prototypes over to the FAA for testing, and if they verify that I have met the certification requirements a TYPE CERTIFICATE will be issued, and I will become the Type Certificate Holder . The type certificate will specify everything that is on the aircraft at the time it was certified, such as the engine, propeller, etc., and it will also contain limitations , such as airspeeds, maneuvers that may be performed, and weight and balance . I highlight weight and balance here because we will see it again later. Parallel with applying for my type certificate, I will develop a maintenance program that will provide continued airworthiness of my aircraft.
- If you are interested in looking at a type certificate data sheet you can go to www.faa.gov which is the FAA Home Page, then select Aircraft Topics. That will bring you to this page and if you go to Technical Information you will see that one of the links is to Type Certificate Data Sheets (TCDS).
- Selecting that link will bring you to this page where a TCDS can be searched by the various ways provided.
- If you search by current models you can pick aircraft based on the holder (manufacturer) of the type design. In this example, we selected the Cessna Aircraft Company…
- …you can look at all the data sheets for all the aircraft that Cessna ever produced. Remember, the limitations for the aircraft are included on the type certificate data sheet in the notes section, so it is an excellent resource for any airman, and a terrific tool for CFI’s and DPE’s. If I’m going to teach you how to fly in a Cessna 172B, what a great place to begin your first lesson, with an in-depth review of the aircraft and the equipment on it. Perhaps as a pilot examiner, you find yourself scheduled to give an evaluation in an aircraft that falls under your designation, but a model you have never been in before. Here’s a resource you can go to find out everything you ever wanted to know about it before you show up for the ride.
- One of the responsibilities assigned by Part 91.203 is that an aircraft operator must ensure there is a current airworthiness certificate and certificate of registration in the aircraft. Remember a temporary registration (pink copy) is only good for 90 days. Part 91.403 requires the owner or operator to also verify compliance with part 39, in that all the applicable airworthiness directives have been complied with. Right about now anyone who rents an aircraft should be asking; “Hey wait. Does that mean I’m responsible for the ADs on an aircraft that I rent?” We’re not responsible for doing them, but remember 91.7? It makes the PIC responsible for the airworthiness of the aircraft. So we are responsible for verifying that they have been done. An acronym often used by flight instructors when teaching new students about documents required in the aircraft is ARROW. The A stands for airworthiness certificate and the first R refers to the registration. The rule that requires these documents is 91.203. Acronyms are good tools to use for teaching, but it’s also good to know that there is a rule that is the basis for the requirement.
- Example of Registration
- Example of Pink Slip ( Registration application ) that may be in aircraft ( good for 90 days ).
- Throughout this presentation I have provided the source of the information I have given you. This is an expectation for all instruction. It is not only vital to provide the correct information, but we should give references where the information can be found. In aviation, we have a lot of good techniques and rules of thumb , but we need to identify and separate them from regulations and rules , and actions required by rules .
- Another responsibility of the operator is to ensure that any maintenance that has been performed has been properly recorded. This is an area where a lot of us really don’t have a clue and totally rely on the mechanic to get it right. Fortunately, most mechanics do get it right, but not always. It may not be the operator’s responsibility to make the correct entry, but it is their responsibility to ensure that it is there.
- The W part of ARROW refers to weight and balance. If you read through part 91 you won’t find any rule that says “weight and balance must be on the aircraft”. As I said earlier, weight and balance is a limitation . It might be more accurate to teach ARROW as A-R-R-Ow . The W is actually part of the O and 91.9 is also the reference for W being required in the aircraft. The reason it is identified individually is because on older aircraft it is often carried as a separate document, usually stuffed in the document holder behind the registration. In later aircraft, weight and balance is in a separate chapter of the AFM. The W in ARROW is just a reminder to check to be sure we have it, and that it is up to date.
- Verifying that the aircraft is safe for flight essentially means performing a thorough preflight inspection to ensure that everything is there and working properly. It sounds simple, but it is actually not simple at all. Why would I NOT be interested in finding something wrong with the aircraft I am about to fly? What’s my motive for being there? I’m there to fly – not find things wrong with the aircraft. If I have been planning this aeronautical outing with friends all week, and I see this, I might not be motivated to investigate what it is or why it’s there. I could easily rationalize that this condition has been there for some time and it’s really nothing to be concerned about. I mean, other pilots have flown it this way – right? In this example, one of the ways I might reduce the likelihood that I will put myself into a position to make a poor decision, could be to go out to the airport the day prior to the flight and look the aircraft over thoroughly. If I find something wrong, I can address it without being under the gun to make an immediate go/no go decision. If nothing else, if I didn’t see this on the aircraft yesterday, I’m going to really have to admit that something has changed since then. I can’t rationalize that it’s been there for a long time. The fact is, I really don’t know if this represents a problem or not, and it’s just not a good idea to takeoff with things going on with the aircraft that I haven’t investigated to determine if they will affect the safety of my flight.
- If confusion exists about what constitutes an “airworthy” aircraft, it can easily spill over into what to do if something on the aircraft becomes inoperable. It would be a rare day indeed if everything on an aircraft worked all the time. Yet, that’s what is implied when we say, “conforms to the type certificate”. Most of us are willing to overlook things that are not required on a flight we are about to make, but there are two real dangers in doing that. The first is that in complex systems , seemingly unrelated things have a way of linking together in unexpected ways leading to disaster. Recall that on the Titanic, the lookouts didn’t have any binoculars. Would a pair of binoculars have prevented the disaster? We’ll never know, but probably it wouldn’t have seemed like a serious problem as the ship sailed away on it’s maiden voyage. The second problem is even more insidious. Overlooking inoperable equipment can become a slippery slide. Pretty soon we begin to accept more and more defects and we end up flying a piece of junk. I once had an applicant show up for a check ride in an aircraft that was so poorly maintained that one aileron could be held immobile and the other could still be moved full travel. When I asked the pilot why he flew such a wreck, his answer was that the aircraft had always been that way since he had learned to fly in it. He had been inoculated to accept that flying junkyard as the norm.
- It’s pretty typical of the type of personality that gets involved in flying to be goal-oriented. If my goal is to fly, I’m not particularly interested in examining reasons why I can’t. There is a way within the rules however, that will allow me to continue with my flight – and do it legally. 91.213 gives us guidance on how to operate with a minimum equipment list, or MEL. An approved MEL will allow us to operate an aircraft with certain equipment inoperable. In many cases an MEL can be very useful, but it is not a panacea for flying a broken aircraft. There are a few hooks we need to be aware of. The first, and key word is; approved . Each MEL is individually developed for a specific aircraft. Before it may be used, a letter of authorization must be issued by the FAA Flight Standards District Office where the operator is based. The letter authorizes the operation of the aircraft under the MEL, and, along with the MEL, must be kept in the aircraft. Once an approved MEL exists for the aircraft, it must be used . The PIC doesn’t have the option of either using or not using it. Furthermore, other airmen who are going to use the aircraft must be trained on the use of the MEL. Anytime the word TRAINING is used, you can be assured that a record of that training will need to be kept. If you own the aircraft and fly it frequently, an MEL might be a good thing to have. If several people fly the aircraft, it might be wiser not to develop one unless you’re sure everyone will play by the rules. Nothing is more difficult for us to defend than when we fail to comply with our own procedures.
- 91.213 also provides guidance on how to defer maintenance and operate a rotorcraft , non-turbine aircraft, glider, lighter than air, or light sport, that doesn’t have an MEL. To determine if we can fly we need to use a decision chain. The first thing to determine is if the piece of inoperable equipment is required to be working. The type design data sheet and 91.205 have lists of equipment required for VFR during daylight and at night, and for IFR flight.
- For the purpose of this presentation, let’s assume that our landing light is not working and we are not going to be flying for hire. We can see by reviewing 91.205 that a landing light is not required for either day or night operations as long as we are not flying for hire. The next link in the chain is to determine if the inoperative piece of equipment is required to be operational by the manufacturer. Depending on the type and age of the aircraft, this may take some research. It can be found on the type design data sheet, but it can also be found if the aircraft has an approved flight manual – AFM. Usually the same chapter that contains the weight and balance lists the equipment on the aircraft and indicates whether it is required to be operational. For my example, the manufacturer does not require the landing light to be working.
- A description of what these terms mean can be found in Appendix A of part 43.
- As an operator, I am authorized to perform Preventive Maintenance. In this definition, COMPLEX may have several meanings depending on your knowledge and capabilities. Heck, I don’t even know what size hammer is used to change a spark plug, so just about any operation is complex for me, and if I don’t know what I’m doing, it’s time to call in an expert.
- Since you may be more capable than I am, if you are going to do Preventive Maintenance, use the Manufacturer’s Instructions if they are available, and calibrated tools – I guess that means the correct size hammer! All Preventive Maintenance requires an entry in the aircraft maintenance records.
- 24 The entry should include when the maintenance was performed, both the date and aircraft time. What maintenance was performed. The results of the operational check and finally, WHO DID THE WORK including your name, type of certificate and the number. Remember: Student pilots may not perform preventative maintenance.
- A special flight permit will be issued by the Flight Standards District Office after a determination is made that the aircraft can be flown safely to a location where repairs, alterations, or maintenance can be performed. It usually comes with specific limitations such as: day VFR, minimum crew, or other conditions the issuing office considers important for safety. Remember the Operating Limitations are part of the Special Flight Permit. One is no good without the other. Both must be in the aircraft and available to the pilot at all times.
- An annual inspection is required for all aircraft unless they are certificated as experimental, light-sport, or provisional, or they are operated under an approved inspection program . Most air carriers, many corporate and fractional owned aircraft are on a continuous inspection program that ensures the airworthiness of the aircraft, but doesn’t necessitate it being out of service for an extended period. A maintenance technician holding Inspection Authorization (IA) is required to perform an annual inspection. When it is completed, it must be identified as an “Annual Inspection” in the aircraft records and signed-off by the IA who conducted it. The two additional entities authorized to perform annual inspections are the manufacturer, and certificated repair stations when they hold a rating to perform annual inspections. When the inspection is signed-off, the status of the aircraft must be indicated. The outcome of an annual inspection is not always an airworthy aircraft. If the inspection is performed and the technician finds discrepancies that make the aircraft unairworthy, a list of those discrepancies must be given to the aircraft owner. Those discrepancies must be fixed before the aircraft is airworthy. When reviewing the aircraft records, I need to ensure that not only has the annual inspection been performed, but that the aircraft was found airworthy.
- The 100 hour inspection is required for aircraft that are operated “for hire”. A 100-hour inspection may be performed and signed-off by a maintenance technician who holds an A&P certificate. There is a provision in the regulations that allows the 100 hour limitation to be exceeded by not more than 10 hours while enroute to reach a place where the inspection can be done, however, during this time the aircraft may not be used “for hire”. Just as a reminder, some aircraft have AD’s that are due at hourly intervals and may come due at 100 hours. There is no provision in the FAR to over-fly an AD. The operator must ensure that all required AD’s have been complied with prior to exceeding the 100 hour limitation as authorized by the FAR.
- As mentioned earlier, progressive inspections allow the aircraft airworthiness to be verified by an approved method over an extended period of time, so the aircraft is not on the ground for a lengthy period. The key word with regard to progressive inspections is – approved . Operators desiring to use a progressive inspection program must submit a request to the Flight Standards District Office having jurisdiction over the area in which the applicant is located.
- The pitot-static/altimeter inspection is required for aircraft that will be operated in controlled airspace under IFR. If the aircraft is only going to be operated VFR, then this inspection is not required . Some caution needs to be addressed here. If I operate an aircraft that is certified and equipped for IFR flight, but I only fly VFR, I don’t need the inspection. However, if something changes, if I put myself in a position where I may want to operate IFR, like being caught ON TOP, I must remember that the aircraft isn’t legal for that purpose.
- Appendix F of FAR Part 43 specifies the way a transponder must be tested. 91.413 says that if the transponder hasn’t been tested and inspected in compliance with that appendix within the preceding 24 months, it can’t be used. As a related issue, we need to look at 91.215(c), which is the rule regarding the use of the transponder. It specifies that each person operating an aircraft equipped with an operable transponder maintained in-accordance-with part 91.413, SHALL operate the transponder in controlled airspace. Controlled airspace is identified as: Class A, B, C, D, and E. The bottom line to these various references is that we must operate a transponder that has been properly tested and inspected anytime we are in controlled airspace. If the transponder fails the inspection, or hasn’t been tested and inspected within the preceding 24 months, then it cannot be used . There is another section of 91.413 that an operator should be aware of. Part (b) says: Following any installation or maintenance on the ATC transponder where data correspondence error could be introduced, the integrated system has been tested, inspected, and found to comply with paragraph (c), appendix E, of part 43. If we swap a transponder from one aircraft to another, even if it is the same kind of transponder, we should have the unit tested and inspected.
- The ELT inspection requirements are not found in Subpart E of part 91, but are included in the regulation about Emergency Locator Transmitters at FAR 91.207. There are actually two requirements that an operator needs to verify about the ELT. The batteries must be recharged or replaced if the transmitter has been in use for more than 1 hour or when 50% of their useful life has expired . The expiration date of the batteries must be legibly marked on the outside of the transmitter and entered into the aircraft maintenance record. There is also an inspection requirement every 12 calendar months to check proper installation, battery corrosion, operation and signal strength. It is not unusual for this inspection to be accomplished during an annual inspection, but it should be specifically identified either as a separate entry, or included with the annual sign-off, indicating the new expiration date for the batteries. If the transmitter has been temporarily removed for inspection, repair, modification, or replacement, no person may operate the aircraft unless the aircraft records contain an entry which includes the date of initial removal, the make, model, serial number, and reason for removing the transmitter, and a placard located in view of the pilot to show “ELT not installed.” The aircraft may not be operated more than 90 days after the ELT is initially removed. As of February 1, 2009, the international COSPAS-SARSAT satellite system will discontinue satellite-based monitoring of the 121.5/243-MHz frequencies, in part because of a high number of false signals attributed with these frequencies. While there's no requirement in the United States to replace the first- and second-generation 121.5-MHz ELTs, after this date, 121.5/243-MHz distress signals transmitted from ELTs operating on the lower frequency will only be detected by ground-based receivers such as local airport facilities and air traffic control facilities or by overflying aircraft. It is important to note that after 2009, existing 121.5-MHz ELTs, although still legal from the FAA's perspective, will provide extremely limited assistance if an aircraft crashes, especially in a remote location.
- The 30-day VOR check is not really an inspection, but I have included it here because it is something the pilot in command needs to check before operating the aircraft IFR using the VOR equipment. The procedures for making the check are included in 91.171 and each person making the VOR operational check SHALL enter the date, place, bearing error, and sign the aircraft log or other record. This is something a CFI may want to pay particular attention to. If the weather changes unexpectedly during a training flight, and the destination airport goes below VFR minimums, the CFI may decide it’s a good idea to request a clearance and execute an instrument approach. That would not be the time to begin wondering if the required checks have been completed.
- Since I added the VOR check, it just seemed natural to include the GPS data base if the aircraft has an IFR approved GPS and it’s going to be used for an IFR flight. My intention in this program is to identify those things we are responsible for as an aircraft operator, and to provide regulatory basis for them. There is no specific rule in part 91 that requires a current data base in the GPS, other than 91.103, which requires the pilot in command to become familiar with all available information concerning that flight. A current data base is regulatory, however it sort of slides in through the back door. A current data base becomes regulatory because the unit comes with a supplemental flight manual which has operating limitations. Remember back a few slides during the discussion of ARROW I mentioned that “O” referred to Operating Limitations, and 91.7 and the certification rules make operating limitations mandatory and require them to be in the aircraft. Part 43, appendix A (31) & (32) is the regulatory guidance for updating the data base. If the operation complies with those requirements, it is preventive maintenance . Both sections of the rule have requirements for an operational check to be performed and recorded . In order to do that correctly, you will have to wander around through a few more regulations, specifically, §43.5, §43.7, and §43.9.
- Are there any questions? Discuss the fact that where you maybe able to over-fly a 100 hr inspection, ADs give no such allowance.
- Sometimes during service the aircraft may encounter problems that may compromise the aircraft's safety, which were not anticipated or detected in prototype testing stages. The aircraft design is thus compromised and airworthiness directives will be issued. The directives normally consist of additional maintenance or design changes that are necessary to restore the type's airworthiness. Compliance is mandatory. Aircraft maintenance records are required to include a summary of Airworthiness Directives applicable to the aircraft. The records must include the AD number, revision date and method of compliance. Recurring ADs must indicate the next time the AD is due for compliance See FAR 91.417 for more information.
- The current status of applicable airworthiness directives (AD) including, for each, the method of compliance, the AD number, and revision date. If the AD involves recurring action, the time and date when the next action is required. Sec. 39.3 [ Definition of airworthiness directives. ] [ FAA's airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances. ]
- Throughout this presentation I have mentioned that the operator is responsible for ensuring that all applicable ADs have been complied with. An AD compliance record should be included in the aircraft records and available to the operator to make a proper airworthiness determination. There is no standardized form for presenting the information, but the basic information included here should be present. Of particular interest should be the due date or aircraft hours for recurring ADs. It is not proper to enter the interval, such as 100 hours, but rather the aircraft time when compliance is due.
- When we defined the word airworthy at the beginning of this presentation we mentioned that both pilots and mechanics have a responsibility for it. These are the rules that further define our shared responsibilities for the maintenance records.
- § 91.417 is our source for guidance on the information we should find in the aircraft maintenance records. When we review the records to verify airworthiness, we’re basically looking for What, When, and Who. If the entry we are looking at appears to be Greek, it might be a good time to seek clarification. As the pilot in command, if I’m expected to make the final decision regarding the airworthiness of the aircraft, I need to be able to understand what I’m reading. Further, the last time I checked, A&P mechanics are required to be able to read, write and understand the English language. §43.9 also contains wording that specifically requires the name of any person working on the aircraft and the certificate type of the approving person. If I’m working with an A&P who is allowing me to do some of the work on my aircraft, my name needs to be entered into the maintenance record, along with the name and certificate number of the A&P who is approving my work.
- So. Here’s a review of our responsibilities as an aircraft operator: I must verify that I have the correct documents – Airworthiness , Registration , FCC Radio License if I will be operating outside the US, the Operating Limitations and Weight and Balance . I’m responsible for ensuring that any applicable Airworthiness Directives have been accomplished. I need to verify that any maintenance performed has been properly recorded, and also that required inspections and operational checks have been completed. I am also responsible for reporting an accident to the National Transportation Safety Board – NTSB.
- Finally, the pilot is responsible for ensuring that the aircraft is SAFE FOR FLIGHT by conducting a thorough preflight.
- There are numerous publications produced by the FAA and commercially, that we can go to get accurate information about our responsibilities as an aircraft operator.
- Advisory Circulars are located at www.faa.gov then go to Regulations and Policies.
- The Southern Region FAA Safety Team is dedicated to quality customer service and we like your feedback. Please provide us feedback on the critique sheet provided. Thank you.