Cessna C337 SID

[tropical]

Originally Posted by Ernie Martin

They also consider Service Bulletins and Emergency Service Bulletins mandatory, and IAs don't require them for Part 91 operators.

Ernie

But there is FAA guidance that specifically states SB's are not mandatory for Part 91 operators.

Use of the Approved Aircraft Maintenance Manual is recommended by the FAA. Cessna will incorporate these SB's into their Maintenance Manual. Now the person holding the Inspection Authorization has to make the determination of how far to stick his neck out.

[skymstr02]

This is the primary reg that all mechanics perform to:

§ 43.13 Performance rules (general).

(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator, except as noted in §43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

It is up to the individual as to what or how that is accomplished. Keep in mind, that should anything go awry, he will be answering to the attornies and the local FAA airworthiness inspectors on his actions for that inspection.

Are inspections for continued airworthiness the same as SIDS? That will have to be determined by a judge eventually. Whether its a NTSB or civil court at law remains to be seen. This is a question that begs for resolution.

[Ernie Martin]

All good points, but take a look at the specific elements I cite from the FAA's Final Rule (page, column and paragraph is listed for each citation). It's hard to believe that SIDs will be required when the FAA explicitly states that they "will not apply to" certain operations, such as Part 135 cargo-only and on-demand.

Ernie Martin

[skymstr02]

As an A&P IA, today's part 91 Skymaster could be tomorrows part 135 car parts hauler, and the same annual inspection is still valid in both cases.

[Ernie Martin]

No need to. The Part 135 cargo/on-demand is just an example. The Final Rule applies only to Part 121, multi-engine Part 129 and multi-engine Part 135 (with the Part 135 exclusion mentioned earlier). It does not apply to Part 91. Period.

Ernie Martin

[skymstr02]

What I'm saying is that I could perform an annual inspection on a Skymaster today, the owner sells it tomorrow, with a fresh annual, and the new owner puts the aircraft on a 135 certificate the next day.
The annual that I performed is still in effect, and not due for another 12 months.

[tropical]

Originally Posted by skymstr02

What I'm saying is that I could perform an annual inspection on a Skymaster today, the owner sells it tomorrow, with a fresh annual, and the new owner puts the aircraft on a 135 certificate the next day.
The annual that I performed is still in effect, and not due for another 12 months.

True. But in order to put the Skymaster on a Pt 135 Certificate requires a "Conformity Inspection" by the FAA. In order to comply with a conformity inspection all SB's must be complied with.

[tropical]

Originally Posted by Ernie Martin

All good points, but take a look at the specific elements I cite from the FAA's Final Rule (page, column and paragraph is listed for each citation). It's hard to believe that SIDs will be required when the FAA explicitly states that they "will not apply to" certain operations, such as Part 135 cargo-only and on-demand.

Ernie Martin

The real question here is will Cessna incorporate these inspections into the maintenance manual? If so any IA doing an annual inspection will have to think long and hard about ignoring them.

[WebMaster]

Originally Posted by tropical

The real question here is will Cessna incorporate these inspections into the maintenance manual? If so any IA doing an annual inspection will have to think long and hard about ignoring them.

Cessna is re-writing the service/maintenance manual to include the SIDs.

It is up to the owner/operator to convince the IA that the new manual can be ignored. Personally, I think that if you take your aircraft to any shop, as opposed to an independent contractor, they will want compliance with the new manual.

[Ernie Martin]

After you show the IA or shop the FAA document referenced by Roger? I don't think so.

Read it carefully. There is zero room for interpretation, zero ambiguity: for Part 91 the Manual at time of manufacture governs. What is even more empowering is the reasoning expressed in the document.

That's not to say a greedy or dinosauric mechanic may push for doing the SIDs, but a) that should be the exception, and b) most will come around when they read the FAA paper.

Ernie

[tropical]

Originally Posted by Ernie Martin

After you show the IA or shop the FAA document referenced by Roger? I don't think so.

Read it carefully. There is zero room for interpretation, zero ambiguity: for Part 91 the Manual at time of manufacture governs. What is even more empowering is the reasoning expressed in the document.

That's not to say a greedy or dinosauric mechanic may push for doing the SIDs, but a) that should be the exception, and b) most will come around when they read the FAA paper.

Ernie

We live in a legal world of Tort Law. Any IA would have to think long and hard before signing off an inspection that does not comply with the manufacturers instructions. The liability that will follow them is staggering. And a good attorney can argue that the manufacturer placed these extra inspection measures from a safety standpoint. Just imagine how this would look in front of a jury.

I don't think it's necessarily a "greedy or dinosauric" mechanic that would push for accomplishing the SIDs but one that is using CYA.

[Skymaster337B]

I can see the law suits already. If an IA says he wants to use a newer inspection program then he is creating his own rules....a catch 22 for a larger maintenance facility that hold itself open to the public.