Continental A65 Serial Number ID
- Thread starter RON NORMARK
- Start date
Steve Pierce
BENEFACTOR
Graham, TX
You must log what you did. I thought the whole issue hee was total time. If you don't have total time you overhaul and write ttal time unknown and 0.0 since overhaul. That is what the FAA told me 20 plus years ago and what I read in the FARs..
skywagon8a
MEMBER
SE Mass MA6
AND after all that, it is still a minor repair!
Appendix A to Part 43 - Major Alterations, Major Repairs, and Preventive Maintenance
(2) Powerplant major repairs. Repairs of the following parts of an engine and repairs of the following types, are powerplant major repairs:
(i) Separation or disassembly of a crankcase or crankshaft of a reciprocating engine equipped with an integral supercharger.
(ii) Separation or disassembly of a crankcase or crankshaft of a reciprocating engine equipped with other than spur-type propeller reduction gearing.
(iii) Special repairs to structural engine parts by welding, plating, metalizing, or other methods.
https://www.law.cornell.edu/cfr/text/14/appendix-A_to_part_43
********
http://www.faa-aircraft-certification.com/faa-definitions.html#M.
Minor Repair. A repair other than a major repair.
Grant
FRIEND
At Work.....
There is a clear misunderstanding among some between the two regulations.
Part 43 says what the maintenance/inspection record must contain, how it must be recorded and who can do it.
The "Sprit" of this regulation is to tell the mechanic (Or other qualified person) Hey! Do really good work, Dont Lie about it, Keep really good records by accurately describing what you did, Sign and date your records, in some cases provide the Total Time in Service. Oh, and by the way here are some other really important things (appendicies)....
Part 91 says who is responsible for keeping these records and which records required by part 43 must be retained & for how long.
The "Spirit" of this regulation is to tell the owner - Hey the guy qualified to do the work required by Part 43, just spent a bunch of time, effort (and your money) performing work (maintenance/inspections) on your aircraft, engine, or propeller. Some of those records are important to us(FAA)and to you. We only want to see these records if stuff goes bad, so make sure you keep these specific records. You, as an owner, will need the records when you sell the aircraft because the next owner will need these records and you are required to provide these records to the new owner. They dont have to take them, but you must provide them.
Part 43 says what the maintenance/inspection record must contain, how it must be recorded and who can do it.
The "Sprit" of this regulation is to tell the mechanic (Or other qualified person) Hey! Do really good work, Dont Lie about it, Keep really good records by accurately describing what you did, Sign and date your records, in some cases provide the Total Time in Service. Oh, and by the way here are some other really important things (appendicies)....
Part 91 says who is responsible for keeping these records and which records required by part 43 must be retained & for how long.
The "Spirit" of this regulation is to tell the owner - Hey the guy qualified to do the work required by Part 43, just spent a bunch of time, effort (and your money) performing work (maintenance/inspections) on your aircraft, engine, or propeller. Some of those records are important to us(FAA)and to you. We only want to see these records if stuff goes bad, so make sure you keep these specific records. You, as an owner, will need the records when you sell the aircraft because the next owner will need these records and you are required to provide these records to the new owner. They dont have to take them, but you must provide them.
mike mcs repair
Registered User
chugiak AK
So what’s the difference between them building this engine based on a data tag and logs out of random parts. compared to building an airplane based on a data tag and logs and new or random parts....
Sent from my iPhone using SuperCub.Org
Sent from my iPhone using SuperCub.Org
wireweinie
FOUNDER
Palmer, AK
Nothing
Web
Web
wireweinie
FOUNDER
Palmer, AK
As OJ said '. . . let me take a stab at this . ..'
Another way to put it is that we are not required to put ttsn in each and every log entry. It's nice to do it for the next mechanic but not required by regulation. Most IAs will update all times as of the annual they are performing. But as been pointed out in copious ways, something somewhere has to show total time since new (in service) of the engine, in this case. The easiest way to show this on an engine is to keep the paperwork from the overhaul shop. Even better if the shop is able to 0 time the engine.
Now, if you actually don't have this paper trail, you'll need to calculate total time. How you 'calculate' this time is on you. Just remember that you don't have to rely solely on the engine logs themselves. If the engine was previously installed on another aircraft, check those airframe logs. Talk to the pilots and calculate how much time they have in the aircraft/engine in question. Look for old invoices for engine work done previously.
And, finally, remember that for most small aircraft, piston engines, total time since new is meaningless as far as safety is concerned. There are very few of our engines with life limited parts, which means that there is a calendar time or hour limit at which the part must be removed and replaced. The biggest concern we have with unknown total time is going to be AD compliance. And all the mechanics here have been down that road. Example; I once had an owner that read the regs that said he 'didn't need to keep his old logs'. So when his annual came due and he'd thrown out all of his old logs, we had no written record of ANY of his AD's being complied with. Started from scratch. So check for AD compliance with a fine tooth comb. No excuses.
Do your IA a favor and 'calculate' your engine/airframe/prop total time BEFORE your annual is due if not already documented. Write a log entry stating 'Total time of this (engine/airframe/prop) as of this date and tach time is XYZ hrs. This total time was calculated from previous maintenance and pilots logs and repair station invoices.'
Web
Another way to put it is that we are not required to put ttsn in each and every log entry. It's nice to do it for the next mechanic but not required by regulation. Most IAs will update all times as of the annual they are performing. But as been pointed out in copious ways, something somewhere has to show total time since new (in service) of the engine, in this case. The easiest way to show this on an engine is to keep the paperwork from the overhaul shop. Even better if the shop is able to 0 time the engine.
Now, if you actually don't have this paper trail, you'll need to calculate total time. How you 'calculate' this time is on you. Just remember that you don't have to rely solely on the engine logs themselves. If the engine was previously installed on another aircraft, check those airframe logs. Talk to the pilots and calculate how much time they have in the aircraft/engine in question. Look for old invoices for engine work done previously.
And, finally, remember that for most small aircraft, piston engines, total time since new is meaningless as far as safety is concerned. There are very few of our engines with life limited parts, which means that there is a calendar time or hour limit at which the part must be removed and replaced. The biggest concern we have with unknown total time is going to be AD compliance. And all the mechanics here have been down that road. Example; I once had an owner that read the regs that said he 'didn't need to keep his old logs'. So when his annual came due and he'd thrown out all of his old logs, we had no written record of ANY of his AD's being complied with. Started from scratch. So check for AD compliance with a fine tooth comb. No excuses.
Do your IA a favor and 'calculate' your engine/airframe/prop total time BEFORE your annual is due if not already documented. Write a log entry stating 'Total time of this (engine/airframe/prop) as of this date and tach time is XYZ hrs. This total time was calculated from previous maintenance and pilots logs and repair station invoices.'
Web
SuperCub MD
Registered User
Collins, Wisconsin
It is saying that If you have records that do contain total time in service they must be retained in accordance with paragraph (a).
(Quote)
So if this interpretation of 2(i) is correct, anytime tt is recorded, even a oil change, that it legally must be retained till the plane is sold.
(Quote)
So if this interpretation of 2(i) is correct, anytime tt is recorded, even a oil change, that it legally must be retained till the plane is sold.
Grant
FRIEND
At Work.....
Thats how I read it. But I'm no attorney. I suppose it could be interpreted differently, but as a matter of practice it is extremely common to see engines and propellers with an unknown total time. But I have NEVER found an Aircraft where total time in service could not be precisely calculated. In part 43, it only requires that the total time of the aircraft be recorded at the time of inspection. This is why they use the terms aircraft vs. airframe/engine/powerplant. I religiously try to asertain the correct total time for each component but sometimes it is simply unknown. That in and of itself does not render that component unairworthy. I take the literal writing of the regulation to mean exactly what it says. I bounce that off of my experience and others experiences that confirm, through actual practice, that this is the spirit of the regulations, otherwise we would all be in trouble.
bob turner
Registered User
So if this interpretation of 2(i) is correct, anytime tt is recorded, even a oil change, that it legally must be retained till the plane is sold
I had to read 2(i) again. I will paste it here in a minute:
I had to read 2(i) again. I will paste it here in a minute:
bob turner
Registered User
14CFR sect 91.417(a)
The preamble says the owner or operator shall maintain. . . .
(2) Records containing the following information:
(i) The total time in service of the airframe . . .
—————
the owner has no choice - he or she must “maintain” records with total time. It simply says so. It does not say “oil changes”.
If an owner decides not to “maintain” “records” having total time in service (in some form) then he/she is in violation of 14 CFR sect. 91.417(a)(2)(I). That much should be clear.
Grant is saying that the aircraft is not in violation. Fair enough. If an aircraft flies without an annual inspection the aircraft is likewise not in violation - the pilot is, and the owner is, but not the aircraft.
When the aircraft is transferred, the new owner is likewise required to maintain records containing total time.
Sure, you can fly without that, in the exact same way you can fly without an annual inspection. The FARs are not arranged in order of seriousness; you are either in violation or not.
This is all my opinion. I would hate to go in front of an ALJ and argue Grant’s point. I think I would lose fairly quickly. What do I know; I have only taught Administrative Law once (great fun).
The preamble says the owner or operator shall maintain. . . .
(2) Records containing the following information:
(i) The total time in service of the airframe . . .
—————
the owner has no choice - he or she must “maintain” records with total time. It simply says so. It does not say “oil changes”.
If an owner decides not to “maintain” “records” having total time in service (in some form) then he/she is in violation of 14 CFR sect. 91.417(a)(2)(I). That much should be clear.
Grant is saying that the aircraft is not in violation. Fair enough. If an aircraft flies without an annual inspection the aircraft is likewise not in violation - the pilot is, and the owner is, but not the aircraft.
When the aircraft is transferred, the new owner is likewise required to maintain records containing total time.
Sure, you can fly without that, in the exact same way you can fly without an annual inspection. The FARs are not arranged in order of seriousness; you are either in violation or not.
This is all my opinion. I would hate to go in front of an ALJ and argue Grant’s point. I think I would lose fairly quickly. What do I know; I have only taught Administrative Law once (great fun).
arcticairalaska
Registered User
Fairbanks, Alaska
I built a light cub with the FAA inspector helping all the way. data plate from totaled cub. Soars 4130 fuselage, wings from two different aircraft. left wing had 60.5 gal tank. Added that to right wing. added the extra ribs as per atlee etc. Scout toe brakes . all mounting pieces for piper pilot blocks rear throttle mount cut off. Throttle handle only part from original cub. no rear stick provisions. cable all the way. 2000# wip gross weight kit. Aircraft had full gyro panel, Delco alternator ( self regulating) under seat battery with solenoids . Working 135 aircraft on the north slope oil fields. 940# useful load. Very warm in cabin to -40. then left foot of passenger would get cold. I can't recall how many engines I went thru. started with 150hp than went to A2B 160hp.I was flying 1400 hours a year at that time wit cub at about 2/3 and C- 185 the other third.When FAA took my medical for having too much fun (Bob Hoover letter] that was the end of my career . Did the 3.25 hr test and passed with flying approval. Hired attorney to appeal to the NTSB. He was happy to take me $865 for consult. Said I would be pissing my money away as the german rt seater hat driven the commercial aircraft into the side of the mountain. The TT from the original wreck is still following the aircraft around. Sold to one of my x pilots for $1.00 as it needed to keep flying. He and his wife love it.
Grant
FRIEND
At Work.....
I wrote a really long response but, in the end, I know how it turns out. So here you go everyone.. This will save us both many hours of our time...
Bob, you are correct. I am wrong.
You are a super educated attorney. I am not.
You have tons of experience. I fell off the truck yesterday.
You will continue to provide advice to those here. I will just keep what little I have learned to myself.
I am sorry to have even brought this up.
bob turner
Registered User
Too bad. This thread was way more interesting than most.
