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Thread: A question about AD's

  1. #1

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    A question about AD's

    I have a PA-12, it has PA-18 rudder and elevators installed per STC.

    If a PA-18 gets an AD placed on it pertaining to the tail feathers and associated superstructure , does the PA-12 inherit the AD by association due to the PA-18 Tail feathers.?

    Need to know this as I want to get all AD's checked and out of the way as well as documented pertaining to if it is a reoccurring AD or not.

    I have searched for this info but cannot come up with a definitive answer as yet. My search skills do not work well sometimes.

    Common sense is telling me to treat the tail feathers as if it has an AD and document the check up as well as any other items that may be associated with a an AD on similar type of plane installed on my PA-12.

    Thanks for the help on this.
    Ken

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    Steve Pierce's Avatar
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    The AD will list the models it applies to. There are no ADs on the PA18 tail feathers. If an AD comes out that might pertain to other Cub types I am sure it will be cussed and discussed here first. The FAA has a team that deals specifically with Piper aircraft. When airworthiness issues with our airplanes come up they reach out to us for comment. The propensity for tail post cracking comes to mind in which an airworthiness concern sheet was released.
    Steve Pierce

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    Quote Originally Posted by Steve Pierce View Post
    The AD will list the models it applies to. There are no ADs on the PA18 tail feathers. If an AD comes out that might pertain to other Cub types I am sure it will be cussed and discussed here first. The FAA has a team that deals specifically with Piper aircraft. When airworthiness issues with our airplanes come up they reach out to us for comment. The propensity for tail post cracking comes to mind in which an airworthiness concern sheet was released.
    More often than not, if parts from another model are installed via STC, and a later AD is issued on those parts, the applicability section of the AD will indicate aircraft modified by the STC along with the original model. The problem comes in when the installation is done by Field Approval as there is no data base of field approvals and FAA has no way of knowing those parts are installed on other models. When I do Field Approvals like that’s, I note in the ICA that any future AD issued against this parts on the original model will also be applicable on this aircraft.


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    Quote Originally Posted by Kahles56 View Post

    If a PA-18 gets an AD placed on it pertaining to the tail feathers and associated superstructure , does the PA-12 inherit the AD by association due to the PA-18 Tail feathers.?




    Ken
    Short answer ............................YES

    Example:
    PA11 with a PA-18 fuel system (via STC or Field approval)
    If you have the original PA-18 Fuel Valve you are now responsible to comply with AD 60-10-08 each 100 hrs even tho it isn't listed in the PA-11 AD's

    That is one of the reasons Major Alteration paperwork stays with the aircraft record indefinetly.
    I may be wrong but that probably won't stop me from arguing about it.

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    I think I agree with Steve. An AD only applies to what it says it applies to. It may be smart to ckeck such parts, but there is no legal requirement to do so unless the AD itself says something like "any other aircraft on which these components are installed" or words like that. These things are legal documents, and generally interpretation starts with the words, not common sense or original intent.
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    Stretch it out further. If an AD is issued for a certified component and my experimental uses that component? I have to comply with the AD. So said my DAR during my AW inspection and it was repeated by FSDO during my repairman cert interview. Where it is in legal-ese? No idea.
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    Thank you for the replies on this issue./question.
    Tail post issue will be reviewed/noted before sealing the craft up.

    As for other items they will be gone over as preventative measure as this craft has not been in the air for a couple of years.

    Thanks again,
    Ken

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    Quote Originally Posted by stewartb View Post
    Stretch it out further. If an AD is issued for a certified component and my experimental uses that component? I have to comply with the AD. So said my DAR during my AW inspection and it was repeated by FSDO during my repairman cert interview. Where it is in legal-ese? No idea.
    That is correct, although I don't know what FAR or handbook they use as a basis for that conclusion. A number of years ago a friend dinged his amateur built experimental plane with an O-320-H2AD powerplant during a forced landing after it threw a tip off the wooden prop. The FAA inspector got all exorcised about lack of compliance of the A.D for inspecting the center bore of the prop hub for corrosion and pitting. The hub and crank didn't fail.

    -Cub Builder
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    Steve Pierce's Avatar
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    Quote Originally Posted by Cub Builder View Post
    That is correct, although I don't know what FAR or handbook they use as a basis for that conclusion. A number of years ago a friend dinged his amateur built experimental plane with an O-320-H2AD powerplant during a forced landing after it threw a tip off the wooden prop. The FAA inspector got all exorcised about lack of compliance of the A.D for inspecting the center bore of the prop hub for corrosion and pitting. The hub and crank didn't fail.

    -Cub Builder
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    skywagon8a's Avatar
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    AC 39-7D Subject: Airworthiness Directives
    https://www.faa.gov/documentLibrary/...AC%2039-7D.pdf

    9. APPLICABILITY OF ADs. Each AD contains an applicability statement specifying the product (aircraft, aircraft engine, propeller, or appliance) to which it applies. Unless stated otherwise (see subparagraph 9b of this AC), ADs only apply to type-certificated (TC) aircraft, including ADs issued for an engine, propeller, and appliance.

    Sorry stewartb, but both your DAR and the FSDO were wrong. Is it a good idea to at least check the possible applicability to your E-AB airplane? Yes of course, but you are not required to do so.
    Last edited by skywagon8a; 04-09-2019 at 05:11 AM.
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    Until you’re the authority issuing my repaiman’s certificate I think I’ll stay with the advice I was given, but I will ask my inspector about it.

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    Steve Pierce's Avatar
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    EAA has addressed it as well with the regulations to back up their take on it.
    Steve Pierce

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    It didn’t take long to find the applicable CFR. Honestly for me common sense drives my AD attitude more than trying to rationalize that an AD might not apply to me due to the experimental AW certificate. For instance, if your wing struts are the subject of an AD? I probably need to take similar corrective action with mine.

    https://www.ecfr.gov/cgi-bin/retriev...9#se14.1.39_17

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    Quote Originally Posted by stewartb View Post
    Until you’re the authority issuing my repaiman’s certificate I think I’ll stay with the advice I was given, but I will ask my inspector about it.
    When you are in the process of acquiring any type of FAA authorization, you always agree with the examiner. However it is still to your advantage to "trust but verify". It is the written word on an official document which will over ride an opinion. In this case your people were only giving you their opinion. You gave them the proper answer which was "Yes Sir​".
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    Steve Pierce's Avatar
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    I agree with you Stewart, probably a reason that AD was issued and practicing due diligence in our field is a good thing. Luckily in recent years I can't think of any ridiculous ADs that have been issued with folks at AOPA, EAA and type specific organizations working with the FAA. I can think of a few old ADs that in my opinion create more problems doing the inspection that they solve but that is a whole nother issue. There will always be the minimalists and the diligent.
    Steve Pierce

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    When you do a condition inspection, you are certifying the aircraft is safe for flight. When FAA issues an AD, the AD is supposed to address a safety issue. Kind of hard to say something is safe for flight when FAA has said you need to do XXX for this product to be safe, yet you haven’t done XXX.

    As a DAR, the guidance I have to follow says if a TCd product is installed in an aircraft being presented for certification, then all the ADs for that product need to be in compliance. That’s part of the logic for a 20 hour phase 1 if a certified engine prop combination is installed, and a 40 hour phase 1 if either the engine, prop or the combination isn’t certified.


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    skywagon8a's Avatar
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    Quote Originally Posted by dgapilot View Post
    As a DAR, the guidance I have to follow says if a TCd product is installed in an aircraft being presented for certification, then all the ADs for that product need to be in compliance. That’s part of the logic for a 20 hour phase 1 if a certified engine prop combination is installed, and a 40 hour phase 1 if either the engine, prop or the combination isn’t certified.
    This makes sense and it is logical that you as a DAR must cover yourself. Now, does the written guidance which you must follow contradict AC39-7D? If so, will you please note that particular section for our reference.
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    This discussion will go on until airplanes and/or the FAA doesn't exist anymore. And it's one of those issues that is polarizing. There aren't many people who are "in the middle" on this one. You either believe adamantly that ADs do apply to experimental aircraft, or you adamantly believe they don't. And no amount of "discussion" seems to make any difference on either side.

    So with that preamble, I will submit that I and others have done considerable research on the issue, and have come to the conclusion that the answer is "maybe"! FAA has issued several documents that support the claim that ADs do not directly apply to non type-certificated aircraft and products. Aircraft that hold experimental airworthiness certificates are, by definition, non type-certificated. Here's just one example of an FAA document that supports the claim that ADs don't directly apply:

    "The FAA has become aware of some confusion regarding the applicability of certain Airworthiness
    Directives. An AD is issued to address an unsafe condition that is likely to exist or develop in
    products of the same “type design,” which, in general, means products that have a U.S. Type
    Certificate. Under current certification requirements, an aircraft with an experimental certificate is
    not considered to have an approved “type design.” This means that an aircraft with an experimental
    certificate is not required to comply with Airworthiness Directives."

    This is from FAA SAIB ACE 97-04-1.

    There was also some language in the preamble to the Sport Pilot/Light-Sport Aircraft rule that indicated that ADs do not directly apply to experimental aircraft. I can't find this one right off the bat, but it's hiding in the federal register somewhere.

    At any rate, you'll note that I keep saying that ADs don't "directly" apply to experimental aircraft. That is specific and on purpose. This is due to the fact that operators of experimental aircraft are required by regulation and by operating limitation to operate the aircraft in "a condition for safe operation". So, even though an AD might not "directly" apply to the aircraft or component, it does point out a known safety-of-flight issue. That being the case, you certainly couldn't simply ignore the AD and go happily along. In order to be able to truthfully say that your aircraft is in a condition for safe operation, you would need to address the known safety issue called out by the AD in some fashion. You would need to document the method by which you address this safety issue. Note that "address" is not the same as "comply with". While in many instances the easiest way to address the issue is to simply comply with the AD, that is not legally required. You can come up with your own "AMOC" as long as you document your solution. As long as you can show that you have addressed the safety issue, you are within the regulations.

    And last, the FAA has started to add verbiage to new ADs that specifically state that the AD applies to "non type-certificated" products. If this is specifically called out in the AD itself, then the AD applies regardless of my comments above.

    That's my story and I'm sticking to it. Fire away!!
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    Just remember, the FAA can only take your license at best if you ignore an obvious safety issue.

    But have that as the cause of an accident that kills or hurts someone and you will wish you were only dealing with the FAA.
    I may be wrong but that probably won't stop me from arguing about it.

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    Quote Originally Posted by skywagon8a View Post
    This makes sense and it is logical that you as a DAR must cover yourself. Now, does the written guidance which you must follow contradict AC39-7D? If so, will you please note that particular section for our reference.
    Advisory circulars are only advisory in nature. AC39-7D is in direct conflict with 14CFR39.3, 39.7 and 39.9. I go with the rule over an AC any day.


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    ACs are advisory and CFRs are the letter of the law, right? When I read the CFR that I linked a few posts earlier I don't see any exception for experimental aircraft. That makes it pretty simple to interpret until I see another CFR that provides an exception. Interesting topic from the intellectual perspective. From the practical side I want parts I can trust and would probably already have a problem corrected in advance of an AD. It isn't like ADs take us by surprise. I took the FAA comments as instructions to document the AD compliance in my logs since it's my first go as a repairman.
    Last edited by stewartb; 04-09-2019 at 10:48 AM.

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    Quote Originally Posted by stewartb View Post
    When I read the CFR that I linked a few posts earlier I don't see any exception for experimental aircraft. That makes it pretty simple to interpret until I see another CFR that provides an exception.
    See, I told you that nobody gives up this discussion without a fight!!

    No, there is no exception, but the regulation does specifically use the term "type design". FAA legal has stated that this means something that holds a type certificate. This would be the "exception" that supports my comments above, since no experimental aircraft holds a "type design".

    Now, I'm not advocating that someone ignore an AD. I already covered that in my previous post too. I certainly encourage everyone to operate their aircraft in a safe condition, regardless of certification category. Just trying to point out that the FAA does have some documentation that disagrees with many inspectors in the field regarding strict compliance with ADs on experimental aircraft.

    That is all!
    Joe

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    Quote Originally Posted by dgapilot View Post
    Advisory circulars are only advisory in nature. AC39-7D is in direct conflict with 14CFR39.3, 39.7 and 39.9. I go with the rule over an AC any day.
    14CFR39.3, 39.7 and 39.9. do not address the question of whether an AD note applies to an E-AB licensed aircraft. I respect your position as a DAR however, in this case I'll accept Joe Norris's explanation over yours.
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    Quote Originally Posted by skywagon8a View Post
    14CFR39.3, 39.7 and 39.9. do not address the question of whether an AD note applies to an E-AB licensed aircraft. I respect your position as a DAR however, in this case I'll accept Joe Norris's explanation over yours.
    Please read 39.3, 39.7 & 39.9. They talk about “products”, and include aircraft, aircraft engines, propellers and appliances. With reference to Joes comment about Type Design, engines and propellers have Type Designs that are independent of the aircraft on which they are installed. Part 39 makes no distinction regarding the type of certification of the specific aircraft, it says if you use a Product that has an AD, and it is not in compliance with that AD, you are in violation of Part 39.7. Now granted they do say Operate and we are talking inspecting. I dare say when inspecting, the owner would expect us to try and keep him out of trouble, but I have been known to be wrong in the past!


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    I got royally chewed by my inspector a few years ago for not doing an AD on a Starduster with an obsolete Bendix fuel injection. I showed paperwork when the obsolete pump was sent in for overhaul by the owner but overhaul was not possible due to a lack of needed parts. However the pump got R&R'd and sent back with "Experimental Part" stamped on all the paperwork from the manufacturer. "Experimental airplane-experimental part doesn't matter, Joe. The AD applies." So if I ever see that Starduster again I'm gonna tear into that pump for the AD the very first thing.
    You can't get there from here. You have to go over yonder and start from there.

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    Quote Originally Posted by dgapilot View Post
    With reference to Joes comment about Type Design, engines and propellers have Type Designs that are independent of the aircraft on which they are installed.
    Been down that rabbit hole too. Here's what I have learned by talking with FAA at the highest levels....

    Yes, engines and propellers do have type designs. However (you knew that was coming, didn't you) once these products are installed on an airframe and operated under an experimental airworthiness certificate, they no longer MEET their type design. Since part 43 does not apply, ANYONE is allowed to repair or modify these components at will, and just the possibility of non-certificated people performing maintenance and repair on these components places them outside their type design. (Remember, since part 43 does not apply, there is no requirement for anyone to log maintenance or repair either, so there is no documentation of possible work by non-certificated individuals.) Thus, even though an engine may have been produced under a type design, that type design no longer applies once the component is installed on an experimental aircraft (Except those that were originally TCed aircraft and are in experimental category temporarily due to some work in progress that will result in an STC or other approval. This is covered in 14 CFR 43.1).

    Even if you claim that all work was done and documented by properly-certificated mechanics, the engine/prop/or whatever is still not considered as meeting the type design due to the reasons I just mentioned. There's no way to verify what work may or may not have been done by non-certificated individuals, so the only way to make the engine/prop or whatever come back into compliance with its type design is a full conformity inspection and proper documentation from an approved source.

    Again, please don't take my comments an condoning the practice of "dodging" an AD. By all means, make sure the aircraft is in a condition for safe operation, and do so with utmost care. I'm just trying to relay some of the knowledge I have gained through my years of involvement in the amateur-built aircraft world, both as an EAA representative and as a DAR. Believe me, I know that this is a controversial subject. I've had these discussions countless times before (mostly with the same results). I just feel like people should hear all sides of the story.
    Joe

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    skywagon8a's Avatar
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    Quote Originally Posted by dgapilot View Post
    Please read 39.3, 39.7 & 39.9. They talk about “products”, and include aircraft, aircraft engines, propellers and appliances. With reference to Joes comment about Type Design, engines and propellers have Type Designs that are independent of the aircraft on which they are installed. Part 39 makes no distinction regarding the type of certification of the specific aircraft, it says if you use a Product that has an AD, and it is not in compliance with that AD, you are in violation of Part 39.7. Now granted they do say Operate and we are talking inspecting. I dare say when inspecting, the owner would expect us to try and keep him out of trouble, but I have been known to be wrong in the past!
    I have reread 39.3, 39.7 & 39.9. They do not address the applicability of an AD to an E-AB aircraft. Joe makes it quite clear that E-AB aircraft are not required to comply with an AD note. Yes, it is a good idea for an operator to comply with an applicable AD note. Yet it is not required. As a DAR issuing a certificate I find no fault in your asking the applicant to comply with certain AD notes should they improve the safety of the particular aircraft. There does have to be a certain comfort factor in your issuing the certificate whether it is required or not.

    Edit; Since they are not required for an E-AB aircraft, a person would not be in violation for operating that aircraft without an AD being accomplished.
    Last edited by skywagon8a; 04-09-2019 at 04:59 PM.
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    I am absolutely not an expert on this subject. But from reading a recent KitPlanes article, I understand the FAA has very recently begun to issue "Operating Limitations" for EAB that mandate compliance with applicable ADs, and because complying with the EAB's Operating Limits is a regulatory compliance issue, this may well be the end of the argument that ADs don't apply to EAB types.

    I discussed this article with our local EAA chapter's resident DAR. He stated that he has seen this wording included in some of the OLs that have been issued, but even though he's a DAR for EAB, he still doesn't entirely understand the ramifications of those "instructions"... He says that in the past, the FAA has stated that once a "certified" component (such as an engine or propeller) has been installed in an EAB airframe, that component is presumed to no longer meet the original TCDS, and thus the component is no longer "FAA certified". This is because (as someone previously stated) "anyone" can maintain and modify an EAB.

    As I understand that reasoning, if I were to install a certified factory-new Lycoming O-360 on my EAB, the minute I get the FAA airworthiness sign-off (and operating limitations) for that airplane, that O-360 would no longer comply with the relevant Type Certificate. If I then removed that zero-time factory engine, and sold it to someone else for use on a type-certified aircraft, an IA would have to go through that engine to confirm compliance with the Type Certificate - basically the engine would have to be completely disassembled, all the parts verified as correct, verify that all applicable ADs have been complied with, etc. before it could be deemed to once again comply with the TC... The cost of all that means that for all practical purposes, once experimental, always experimental...

    So if the new EAB Operating Limits require compliance with all applicable ADs, but the FAA says ADs apply to Type Certified components, whose Type Certificate is invalidated the minute the items is installed on an EAB... I'm still left in total confusion as to what is and isn't required. Personally, I will elect to comply (to the best of my ability) with ADs that seem to apply to components installed on my EAB. But I have no idea whether I would be legally required to or not. Just a "belt and suspenders" thing for me...
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    There is actually precedent here in the PA-18 community. If you look at the Sutton exhaust STC it is specific that should an AD occur on the Grumman exhaust, it applies to the STC. Might want to check the text of your STC.
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    skywagon8a's Avatar
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    Quote Originally Posted by JimParker256 View Post
    As I understand that reasoning, if I were to install a certified factory-new Lycoming O-360 on my EAB, the minute I get the FAA airworthiness sign-off (and operating limitations) for that airplane, that O-360 would no longer comply with the relevant Type Certificate. If I then removed that zero-time factory engine, and sold it to someone else for use on a type-certified aircraft, an IA would have to go through that engine to confirm compliance with the Type Certificate - basically the engine would have to be completely disassembled, all the parts verified as correct, verify that all applicable ADs have been complied with, etc. before it could be deemed to once again comply with the TC... The cost of all that means that for all practical purposes, once experimental, always experimental...
    Except, if the engine were maintained properly in accordance with part 43 by an appropriately licensed mechanic your example would not be true. If you altered that engine in some manner which raised some question then ??? It's in the record keeping and who does what to it.
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    Quote Originally Posted by skywagon8a View Post
    Except, if the engine were maintained properly in accordance with part 43 by an appropriately licensed mechanic your example would not be true. If you altered that engine in some manner which raised some question then ??? It's in the record keeping and who does what to it.
    The FAA says that's not true. See my previous post about the aircraft (including the installed engine) not being subject to 14 CFR Part 43. That means that there is NO record keeping requirement for maintenance or repair that is performed by a non-certificated individual, there is no way for anyone to verify that the records that are there are complete. Just the mere possibility that the component can be legally maintained by a non-certificated individual casts the entire component into question as to whether is has or has not had such maintenance or repair completed. Since nobody knows for sure, nobody can "certify" that the component meets the TC. Once the component (engine, prop, etc) has been installed and operated on an experimental aircraft it is an experimental product until such time that it has had a conformity inspection done under controlled conditions and properly documented.

    Now, of course having said all that, If there is a certificated mechanic that is willing to put his signature on a statement saying that the component does in fact meet its TC after being installed and operated on an experimental aircraft, then I guess all is well. Hopefully that wouldn't come back to bite that individual someday down the road. Forewarned is forearmed.
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    Quote Originally Posted by jnorris View Post
    Now, of course having said all that, If there is a certificated mechanic that is willing to put his signature on a statement saying that the component does in fact meet its TC after being installed and operated on an experimental aircraft, then I guess all is well. Hopefully that wouldn't come back to bite that individual someday down the road. Forewarned is forearmed.
    Isn't that what I said using different words?
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    Quote Originally Posted by skywagon8a View Post
    Isn't that what I said using different words?
    Well, I didn't quite understand it that way, but if that's what you said then we are on the same page. No need to prolong the agony.
    Joe

    Fortis Fortuna Adiuvat
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  34. #34

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    Back to the original idea- an AD that specifies an airframe or series of airframes applies only to those airframes, even though somebody may have approval to use parts from those airframes on some other aircraft. The guy with the tailfeathers would do well to do what the AD says, but unless the AD says so, it is limited to those airframes/components/ engines specified.

    oh, yeah - Opinion.
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  35. #35
    hotrod180's Avatar
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    I used to own a C150/150 with the Texas Taildraggers (formerly ACT) 320 conversion (now owned by DelAir).
    There was an AD on the Avcon muffler used for some 320 conversions, applicable (or not) to specific Avcon conversion kit serial numbers.
    The previous owner's mechanic noted "AD not applicable due to Avcon kit not being installed".
    However, right on the muffler's tailpipe was a big old Avcon data plate!
    I checked the parts list in the STC paperwork-- yep, an Avcon muffler was listed.
    And sure enough, the muffler cracked out at the outlet--
    just like the AD warned about.

    So even if maybe technically / legally not applicable,
    it's probably a good idea to pay attention to those ADs.
    Cessna Skywagon-- accept no substitute!

  36. #36

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    If the AD says “Avcon Muffler” then it applies to Avcon mufflers. If it says “Piper Aircraft with Avcon mufflers”, then no matter how important to safety of flight, it does not apply to Cessnas with Avcon mufflers.

    As to mechanics who make mistakes with ADs? I know of one large FAA repair station that missed Mooney ADs for almost 20 years in a row! We had a Super Cub with only one muffler inspection in 800 hours! Owner likes a different shop each year, so it wasn’t just one mechanic. When I got to do the ninth annual, it received a brand new Atlee muffler.

  37. #37
    hotrod180's Avatar
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    Quote Originally Posted by bob turner View Post
    If the AD says “Avcon Muffler” then it applies to Avcon mufflers. If it says “Piper Aircraft with Avcon mufflers”, then no matter how important to safety of flight, it does not apply to Cessnas with Avcon mufflers...…
    As I recall, the AD didn't apply to all Avcon mufflers, just the ones supplied with an Avcon engine conversion kit in a certain s/n range.
    "Applicable to Avcon kit s/n xxx through s/n XXX" or similar wording.
    Kinda like the situation cited in post #1--
    does an AD for PA18's pertaining to the rudder apply to the PA18 rudder fitted to your PA12, PA22, or homebuilt?
    Both yes and no could be argued-- as per this discussion.
    Cessna Skywagon-- accept no substitute!

  38. #38

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    I disagree. An AD is a legal document. You either do it or you are in violation - but it is not binding on any component outside the specified group or serial numbers.

    If you are arguing common sense or safety that is different. Sure, do it, and you must make a logbook entry. "AD --- does not apply to this component. The requirements of AD --- have been met by ---." But you are not legally required to do so.

  39. #39

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    By the way, all my aircraft have complete lists of ADs. Even the Nelson crankshaft ADs are listed, even though I have no Nelson crankshafts. The latest lift strut ADs are there - "previously c/w". I believe that is now necessary.

  40. #40
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    Quote Originally Posted by bob turner View Post

    If you are arguing common sense or safety that is different. Sure, do it, and you must make a logbook entry. "AD --- does not apply to this component. The requirements of AD --- have been met by ---." But you are not legally required to do so.
    Wrong !!!!!!!!
    You can not take a possibly defective part out of an airplane that falls in the s/n range and put it in an airplane that is outside of that s/n range or a different model. So it does apply to the component. Conversely if you did it before the ad was issued, it would still apply to that component.
    Last edited by S2D; 04-13-2019 at 01:27 PM.
    I may be wrong but that probably won't stop me from arguing about it.

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