Unapproved Parts Notification- Dan's Aircraft?

[Charlie Longley]

The "major repair" definition in FAR 1.1 seems (purposely) pretty vague. My take on form 337 gray areas is "when in doubt, fill it out". Never heard of anyone getting in trouble for covering his butt that way. I agree with John about picking your battles, and catching more flies with honey-- having an adversarial relationship with your FAA inspector(s) is not condusive to trouble-free operations. I know an IA who got into it with an FAA DPE and the airplane owner when it came to logging annual inspections in the engine logbook. He said it wasn't required and flat-ass refused to do it, and managed to piss off the DPE, the airplane owner, and the student pilot trying to get his checkride done. Along with some other hard-headed choices he made, it eventually helped lead to him being kicked off the privately-owned airport where he was based.

I always sign off the Annual in the engine and propeller log book because that's what everyone expects to see and it takes no time at all. But the hard-headed IA is absolutely correct. There's actually a history of the FAA trying to give an IA a violation over it. He didn't get the violation because it was determined when you sign off the airplane log book you're signing off the entire airplane.

 

[skywagon8a]

The IAs in my district were told by the FAA at an annual IA meeting years ago that the annual only needed to be signed off in the Airframe log book. This for the exact reason which Charlie Longley mentioned. The only items which need to be signed in the engine log are those items which were done to the engine itself. Those who disagree are just uninformed. One of the arguments presented was that the engine log always stays with the engine and engines get changed thus the records go with them.

The person who told us this may have been Bill O'Brien. Who's Bill you ask? The IAs knew him as the the top dog of IAs from FAA headquarters. Bill was the all time straight shooter good guy of the FAA mechanic department.

Don't shoot the messenger here, I'm only repeating what I was told by the FAA.

 

[Steve Pierce]

Too many people in the FAA who have never done the job they are in charge of policing.

 

[wireweinie]

Too many people in the FAA who have never done the job they are in charge of policing.

Never was a more profound statement uttered.

Web

 

[flybynite]

So, back to the original point of uncertified fabric or processes. How many stamps have to be visible to determine the entire stc was followed? Doesn't the IA's signed statement that the aircraft was covered iaw the stc indicate that certified materials were used if required by the stc? Can't see the tapes stamps. They are buried. Rib stitch materials certified? . Trust but verify? When is good enough good enough?

Wayne

 

[hotrod180]

The IAs in my district were told by the FAA at an annual IA meeting years ago that the annual only needed to be signed off in the Airframe log book. This for the exact reason which Charlie Longley mentioned. The only items which need to be signed in the engine log are those items which were done to the engine itself. Those who disagree are just uninformed. One of the arguments presented was that the engine log always stays with the engine and engines get changed thus the records go with them. ................

I was schooled on this years ago, when I took an IA to task for signing off the annual in my engine logbook as a 100 hour inspection. He explained that there is no requirement to sign off an annual there, but there is a requirement to sign off a 100-hour. So he signs the airframe books as an annual and the engine book as a 100-hour.

My take on the situation I cited is that the airplane owner was paying the IA for the inspection. It's his airplane, he's the customer & is paying the bill, if he wanted a sign-off in the engine book for the annual and that's not prohibited then just do it!

Right or wrong, most people expect to see a signoff in both logbooks (including me). What started the whole thing was a student pilot went for his private checkride in the airplane, the DPE was examining all the aircraft records (ARROW, logbooks, etc) and noticed that the "required" (in his mind) entry wasn't in the engine logs. He therefore stopped the checkride process & sent the applicant home. So he's mad, the griped to the owner of the rented airplane so he was mad, then the IA got his back up and got mad too. So much easier on everybody to just bite your tongue and sign the darn logbbok!

 

[skywagon8a]

The DPE was wrong and uninformed in this case. I have seen a similar instance where a DPE refused to give a SES ride because there was no 337 showing the floats installation on a new 172XP. The approval is on the Type certificate so was a minor alteration (no 337 required). Another uninformed DPE. I feel sorry for the student, the airplane owner and the IA in your example.

 

[Steve Pierce]

Glad my customers trust me, my knowledge and experience.

 

[hotrod180]

......... I feel sorry for the student, the airplane owner and the IA in your example.

In my example, I feel sorry for everybody but the IA.
He could have smoothed everyone's feathers and avoided a lot of aggravation for everyone including himself if he'd told them that no, the logbook entry wasn't required but that he would write it up anyway. Instead he got his back up and refused to do it because "the regs don't say I have to". Well, he showed them-- he lost any future business from the airplane owner. That guy just happened to be the airport manager, who after a few other incidents like this ended up kicking the IA off the private airport because of his attitude.

 

[skywagon8a]

I agree with you. A lot of mechanics are not very good in the diplomacy department. Honey works better than Hot Sauce.

 

[mike mcs repair]

i would have told him he's an idiot and go f*&k himself.... only required in airframe log...

 

[mam90]

I think it depends... You have to be diplomatic, but you should also guard against the requirement to do more than the regs require in some cases. Had a POI once who told us we must provide him with all of the RVSM training certificates for EVERY technician employed by an FAA Repair Station to show only properly trained techs were working on our aircraft when it was in for service...... In that case, no, I would not comply just to grease the wheels.

 

[Steve Pierce]

I have been questioned about this subject of 100 hr in engine and prop logbooks more times than I can count. I explain it and the customer/owner understands. If he wants to argue about it I figure he can go down the road, if he will argue about this he will argue about other things and I don't need customers like that. There has to be a trust between the mechanic and the owner. If the owner doesn't trust me there are a lot more A&P/IAs in the world. I have learned a lot about airplane owners over the past 20 something years, one of them is how to avoid an owner as a customer. Makes my life so much easier.

 

[wireweinie]

i would have told him he's an idiot and go f*&k himself.... only required in airframe log...

I'll buy you an beer any time.

Web

 

[aktango58]

I have been questioned about this subject of 100 hr in engine and prop logbooks more times than I can count. I explain it and the customer/owner understands. If he wants to argue about it I figure he can go down the road, if he will argue about this he will argue about other things and I don't need customers like that. There has to be a trust between the mechanic and the owner. If the owner doesn't trust me there are a lot more A&P/IAs in the world. I have learned a lot about airplane owners over the past 20 something years, one of them is how to avoid an owner as a customer. Makes my life so much easier.

Yet you still have tom Ford's plane in your shop;-)8)

It is good to have trust between owner/mechanic. The whole sign off stuff becomes problematic when a FAA inspector is confused but thinks they are right.

In the story about the student pilot checkride, why were there logs in the aircraft at all???? Not required. Only upon request with a reasonable time to present.

 

[porcuypine]

I don't usually comment on these kinds of threads but Steve hit the nail on the head in regard to dealing with the argumentative types. Just let them go find another shop. I forced myself to do this about five years ago and it really smoothed my operation. I also had a lot of flying "friends" and when I told them all they needed to be my friend or my client all but one disappeared. Surprise!

I think there is also this my shop is better then your shop BS that goes on in the dysfunctional world of aviation we live in and there is a lot of foot shooting going on in the process. Just yesterday I was called into a 135 operation to do something the DOM and his mechanics had no skill to do and had to listen to him bad mouth me about a repair I did almost 20 years ago... I'm thinking to myself WTF is wrong with this guy, I'm here to help him out? Anyway, we can be part of the problem or part of the solution. We are our own worst enemy...




As for arguing with your Fed or PMI, good luck. You probably argue with the cop over the speeding ticket, and your ex wife. Look where that got you

This is one of my solutions:


On logbook entries I print out three entries with all the engine prop and airframe line items and use the phrase I CERTIFY THAT THIS AIRFRAME, ENGINE, AND PROP… and place one in each logbook. I don't have to do it this way but after almost 20 years of maintaining aircraft it sure has made my life easier and my 135 PMI have all loved it.


I did have the NPS/OAS and a few others over the years want me to sign off their mid summer 100 hour inspections as an annual inspection and I refused.


Here is an part of an example from a 100 hour inspection but I just insert the word ANNUAL as required note it has items that would go in all three logbooks:


-REMOVED, INSPECTED, REPLACED OIL SCREEN AND SUMP PLUGS AND SAFTIED AS REQUIRED.
-DRAINED OIL AND FILLED WITH 6 GAL AEROSHELL 100 50 WT OIL.
-REMOVED PROPELLER FOR OVERHAUL AND REINSTALLED TORQUED, AND SAFTIED IAW HPC MM. P/N: HC-B3R30-4B S/N: EMA1269 NWP W/O: 25292 DATED 04.29.13.
-REMOVED PROPELLOR GOVERNOR FOR OVERHAUL AND REINSTALLED, LEAK CHECKED AND OPS CHECKED OK. WWG W/O: WW12902 DATED 03.21.13.
-REPLACED WORKING RIVETS AND CRACKS IN ENGINE BAFFLING AS REQUIRED.
-C/W R&L AILERON AD 64-09-03 ARMS DYE PEN INSPECTED-OK.
-REPLACED FLAP AND AILERON HINGE BEARINGS AS REQUIRED.
-CW AD 2008-11-11 H STAB SPAR INSPECTION. SEE AIX W/O: 4428G DATED 12.04.12
-C/W AD 81-13-01 ELEVATOR BUT RIB INSPECTION.
-REPLACED ALL FLOAT CONTROL AND RETRACT CABLES WITH NEW.
-REPLACED FLOAT WALK WIRE WITH NEW.


-ELT BATTERY GROUND TESTED-OK. RE-INSPECT ELT BATTERIES JUNE 2014.


-ALL ADS LISTED AND COMPLIED WITH.


-I CERTIFY THAT THIS AIRFRAME, ENGINE, AND PROP HAS BEEN INSPECTED IN ACCORDANCE WITH A 100 HOUR INSPECTION AND WAS DETERMINED TO BE IN AIR WORTHY CONDITION.


I really enjoy reading everyones perspective here regardless if i agree or not, I really enjoy a good chuckle, and hope I can add a little perspective to the dialog as well.


Rocket

 

[mike mcs repair]

.. You have to be diplomatic, ..

sorry, I was born with out a diplomatic thingy... or a filter thingy... or a put up with whiny people thingy... or a tell me how to do something like someone else did it thingy...

but i got a zillion time "FOCUS on the issue at hand" thingy...

 

[T.J.]

Yep. I've got a sign on the hangar door that says... "This ain't Burger King. You don't get it your way. It's either my way or the hiway." I learned a long time ago, that some customers are more trouble than their worth. If you think about it, It isn't an attitude thing, its a business decision. If I can't make a living working on good folks planes, I'll go to work at Burger King.

 

[mam90]

sorry, I was born with out a diplomatic thingy... or a filter thingy... or a put up with whiny people thingy... or a tell me how to do something like someone else did it thingy...

but i got a zillion time "FOCUS on the issue at hand" thingy...

I agree, Mike. Every once in a while focusing on the issue at hand for me has meant "get this done" and I have given the FAA something that there was no basis in the regs for. More often I will ask them to show me the reference in the regs or the 8900 for what they're asking me to provide or do. If they can't show me, the request usually goes away. If I worked for myself, my filter would look more like yours......

 

[bat443]

If you sign off the logs the way the DPE wants it and he is wrong as in this case then you have done a dis-service to every future check ride applicant he does it to. He is a representative of the FAA Administrator by definition and held to a higher standard. If he wants to enforce maintenance regulations he should know the rules. If he can't show you where it is required in the regulations, maybe you should ask his boss at the FSDO to explain to him where he is wrong. For those of you that say, I have to work with this DPE again, all I can say is you are letting a bully get away with his ego trip that "I am a DPE and I am right". He owes an apology to the check ride applicant, the aircraft owner, and the mechanic. If he can't do that, and there are complaints from others, the FAA should review the DPE's behavior and if required revoke his DPE authority. If the FSDO doesn't do the review they are not doing their job.

As you can tell, I have a problem with people placed in positions of authority on ego trips who feel they are never wrong. Both inside and outside the FAA.

Tim

 

[hotrod180]

....In the story about the student pilot checkride, why were there logs in the aircraft at all???? Not required. Only upon request with a reasonable time to present.

I know normally you aren't required to have your logs, in the case of a ramp check request the "reasonable time to present" applies. Don't recall about in the case of a private pilot checkride, it's been a long time but I kinda remember having to present more than the standard ARROW. I've never met him, but from some pireps the DPE involved in this situation is a piece of work. I have heard that he requires the applicant to meet with him ahead of the checkride, along with his instructor-- maybe a good thing to be sure that all the i's are crossed and the t's dotted, but I sure didn't have to do that back in the day.

 

[hotrod180]

i would have told him he's an idiot and go f*&k himself......

That's exactly NOT the way I think it should be handled. Seems like a good way to get punched in the nose. If nothing else, it pretty much guarantees poor relationships with everyone involved. The IA in my story took that attitude and it ended up hurting him in the long run.

I don't have the logs from any of my old airplanes, but looking through the engine logbooks from my current mount I see that every year there is a sign-off for either an "annual inspection" or a "100 hour / annual inspection". This is over the course of 22 years and six different IA's.So required or not, apparently some people do want to see those entries and some IA's don't mind providing them.

If an IA told me to go f*** myself re this logbook entry issue:
1) I would be very reluctant to pay for a job that wasn't done to my satisfaction.
2) He would never get any more of my business or see another penny of my money, EVER.
3) I would tell everyone I know and ànybody else who would listen about the poor service he provided.


So I guess you have to ask yourself if proving you're right that way is worth the repercussions. If it is, go for it. But if you treat very many customers this way, pretty soon you might not have very many customers.

 

[S2D]

I was schooled on this years ago, when I took an IA to task for signing off the annual in my engine logbook as a 100 hour inspection. He explained that there is no requirement to sign off an annual there, but there is a requirement to sign off a 100-hour. So he signs the airframe books as an annual and the engine book as a 100-hour.

My take on the situation I cited is that the airplane owner was paying the IA for the inspection. It's his airplane, he's the customer & is paying the bill, if he wanted a sign-off in the engine book for the annual and that's not prohibited then just do it!

Right or wrong, most people expect to see a signoff in both logbooks (including me). What started the whole thing was a student pilot went for his private checkride in the airplane, the DPE was examining all the aircraft records (ARROW, logbooks, etc) and noticed that the "required" (in his mind) entry wasn't in the engine logs.

He therefore stopped the checkride process & sent the applicant home. So he's mad, the griped to the owner of the rented airplane so he was mad, then the IA got his back up and got mad too. So much easier on everybody to just bite your tongue and sign the darn logbbok!

Bill O'Brien Had an article in AMT quite a few year ago about this subject. He was one of the smartest , most common sense people the FAA ever employed.( in my feeble mind) He said in writing that You annual an aircraft not an Engine. Only one entry is needed. I had to look it up when one of the Flight examiners told the local flight instructor he had to have a 100 hr signoff in the engine logbook for the annual. You don't but now we put one in that airplane so the student doesn't have to take the wrath.
So It is in writing by someone in the FAA. Most FAA types don't have the I.F. to do that any more. O'Brien did.

It also get to the question about annualing an airplane every 100 hours instead of giving it a 100 hr.
If you go 3 hrs over the last annual, is your ANNUAL only good for 97 hrs if you are using it for hire.

 

[irishfield]

Yep. I've got a sign on the hangar door that says... "This ain't Burger King. You don't get it your way. It's either my way or the hiway." I learned a long time ago, that some customers are more trouble than their worth. If you think about it, It isn't an attitude thing, its a business decision. If I can't make a living working on good folks planes, I'll go to work at Burger King.

This one TJ.... wife bought it for camp to give guests a hint! LOL

 

[mvivion]

It also get to the question about annualing an airplane every 100 hours instead of giving it a 100 hr.
If you go 3 hrs over the last annual, is your ANNUAL only good for 97 hrs if you are using it for hire.

Exactly. Which is why OAS/DOI did every 100 hour as an annual....many of those airplanes worked in remote areas where maintenance may not be available. The option to fly past a 100 hour occasionally permitted us to avoid the need for a ferry permit which would be required if there wasn't enough time left to get to maintenance after an annual expired. And, yes, it was almost always possible to just get the plane to maintenance "on time", but on rare occasion weather or ??? interfered.

And, if the customer is willing to PAY for an annual every 100 hours, why should the maintenance professional care? Are you going to refuse to sign off an annual inspection a month early if a customer wants it?

As to DPEs wanting to see the aircraft's logbooks prior to conducting a check ride, I've seen a case where an annual inspection had actually been done, but the "maintenance professional" had not signed same off in the airframe logbook. If the DPE had flown in that airplane, he would have been in violation, at least technically. The owner of the plane (a club) was partially at fault for not verifying that the signature got entered. In that case, the "maintenance professional" signed the logbook, and the checkride went forward.

We placed a COPY of the airframe logbook annual/100 hr signoff page and a copy of the AD compliance record in the airplane's "Binder", which the student/instructor took out to the plane when they went to fly. That served as verification to an examiner (and everyone else) that the airplane was in annual, and any "in between" AD's were complied with.

As an examiner, that's what I wanted to see. It's called CYA.

MTV

 

[cubpilot2]

Once upon a time we used to have these 2"x2" "Annual inspection reminder" stickers that we would put in the airplane. We would just enter the date that the next inspection was due. I always thought that they were a great idea and they were produced and available from the FAA. What ever happened to those??

Customers used to think that it was a required item; sort of like a vehicle inspection sticker in the windshield.

It was usually all that was needed to satisfy currency questions.

 

[ak49flyer]

Any updates on the proceedings of this investigation? Heard a rumor that the shop in question "got shut down by the FAA" recently- any truth to this? Sad if true...

 

[mike mcs repair]

.. that the shop in question "got shut down by the FAA" recently- any truth to this? Sad if true...

again??

any updates on what the original issue was,

i still don't understand this thread.....???

 

[ak49flyer]

Read the letter that is linked to in the first post... Sounds weak at best...

 

[Steve Pierce]

The owner of the airplane in question called me last week.The FAA pulled Dan's tickets and the air worthiness on the airplane. Now the owner has a pile of Super Cub parts.