IA's reliance on prior inspections

[DonMuncy]

I picked this topic off another thread.

We know that at annual, the IA looks back in the logs for AD compliance. If he finds a record that John Doe, A&P, complied with ADxx, etc,, he can note that "all ADs have been complied with".

Can a following IA  then rely on his statement, or must he go back and find the specific log entry again.

It would seem to me that if one IA can rely on the written word of an A&P, then another IA should be able to rely on him.

I know that at annual, some IAs create a written AD compliance list and include it in with the logs books. I know that some do not, or at least have not provided me with a copy.

My plane had passed annuals for many years until one IA found (actually, didn't find) evidence that a piston pin AD had been complied with. I got to pay for the removal and replacement of a piston pin.  

Maybe someone needs to come up with an official AD list with an IA sign off and then only updates like we do weight and balance.

I hate to think about the number of combined hours of IA's looking back through for the same things another IA did the year before.

The weather is too crappy to fly; I have too much time on my hands. 

[FlyDave]

Don,

 

I think the metric for this is "annual". When the year that this annual inspection is up, the previous IA should have no responsibility/liability. If I were an IA signing an airplane off for another year, I would complete all AD compliance research, etc. that is required to sign it off for another year. If an IA is the only one maintaining an airplane then he should trust himself to be in compliance the year before.

My previous IA did not rebuild engines for this reason - limiting his liability to 1 year per sign off. I don't know if this is valid but that was his thought on the process.

 

Dave

[orionflt]

When I look at a airplane i haven't inspected before or if I am doing a prebuy I will look for the specific sign off for every AD, If i do not see a sign off for a specific ad I will look at that closer to see if the AD applies or if it still needs o be complied with. If i have been inspecting the aircraft for a while I will only research back to where I confirmed the AD's were complied with.

[1964-M20E]

I have been using ADLOG at the request of my IA since I became an airplane owner almost 4 years ago.  This service seems to help at least keep things organized so it is easier to assure that everything has been take care of.  The end of the day a new IA could go back and double check everything just to make sure.  I guess that is the advantage to using the same IA each year and the advantage of going to another shop every few years.

 

 

http://www.adlog.com/

[MB65E]

I try to believe the prior IA's signature, but I have pulled apart 3 engines that said the oil pump Lycoming AD had been signed off when it had not been. So unless I have a warm and fuzzy feeling that the AD was accomplished, I do not rely on anyone else's signature. One of the engines came from a MSC in the Midwest!

When was the last time you have seen a 2 piece oil pump housing with aluminum gears? Hopefully not in a long long time!!

Frustrating when signatures are taken for granted for 10+years! There are companies that you pay for for AD research that offer compliance logs. I still like listing each AD in the logs. The reports are only good if they stay with the aircraft. For some reason the paper copies of the AD logs get legs faster than the log books themselves.

[MB65E]

Good topic!

Adalog is nice too because it actually provides a hard copy of the AD in a reasonable easy to understand format. Nice for the owner to read/see what's going on. All the other only provide a place for the AD, Complied by, who, next due. Most of the time, the AD still needs to be searched.

-Matt

[RocketAviator]

With my recent FAA Ramp Check and 44709, I was told and showed the Reg that basically stated that I as the Pilot of the plane had complete responsibility for the compliance by means of documentation that such compliance was met for all AD's.....  ie full responsibility without any ability to make a change!!!  When I asked for example that I did not own the airplane nor had any first hand ability to confirm the previous AD compliance.  Both of the FAA stated "if compliance is not reasonably documented then the FAA does not not have to consider it as complied with".  This was specifically regarding a exhaust cross over tube that the previous AD was complied many times in the past, but a new cross over tube had just been installed and logged as such the new tube does not require same frequency for testing.... and since the new exhaust simply stated new exhaust without a specific part # of each part of the exhaust then the FAA person said he would treat based on the AD history!  They grounded me and threatened me with a sanction, which I had to appeal where the sanction was removed...  Even though I had to have the AD complied with before my check ride at a remote airport...   Bottom line what a mess and there was no absoulute and methodical standardized means of AD compliance in my opinion.  The IA is responsible for what they sign off of but if he missing something YOU the Pilot are still responsible for what he missed or in my case did not document properly.  Bottom line you as the Pilot are completely responsible and must know and have documented everything there is to document regarding AD....   You can not win!  Kind of like knowing everything there is to know about a particular flight.... how many of you know ALL there is to KNOW!!!  I can answer that NONE of us!

Thankfully most of the FAA people are reasonable but like all things some are not!

 

Fly safe...

[laytonl]

I made my own AD log and listed the date in the logbook where the applicable AD compliance is mentioned. This makes it easy for a mechanic to verify for himself. Lee

[DonMuncy]

Lee, I have done the same thing, and try to keep an eye out for new ones which might be applicable to my plane.

[cliffy]

I also have a complete AD list and ADlog with the log book pages noted where the AD is complied with. A sign off should include the method of compliance and not just "complied with". 

 

MB65E if I could please add something here on the oil pump AD -

I too had a 2 piece housing with aluminum gears for many years after the AD and only by finding the AD "Preamble" that is not published with the usual AD sites was I able to determine that it was specifically excluded (and noted in the preamble) from the oil pump AD. No where in the body of the AD does it address the 2 piece oil pump, ONLY in the hard to find "Preamble".

I did change it out at overhaul just because it was original to the 64 engine.

You can feel the cotter pin holding the shaft through one of the mag mounting holes, ), it's still legal from what I can determine. Below is a clip from the AD

 

"One commenter states that the AD omits a required modification of older pump housings, as referenced 

in SB's 1164 and 1341. The FAA does not concur. The earlier configuration incorporates a fixed shaft 

and cotter pin with a different aluminum impeller. That configuration is not affected by this AD. The 

FAA has clarified the applicability of this AD to state that only aluminum impellers, P/N LW 13775, are 

affected. 

 

Some commenters state that only aluminum impellers, P/N LW 13775, should be affected by this AD. 

The FAA concurs and has revised this AD accordingly. "

 

I know this is "old news" I just wanted to clarify the point.

[MB65E]

Hi Cliff, on the oil pump AD...

Good point on the housing not having an AD itself. Oil low oil pressure was the concern and like you said its original from 64-65...

I had actually never seen the 2 piece housing. I'd have to look at the AD in full and the 2 piece housing itself. My issue was I has a 2 piece housing that I could not verify the gears from the overhaul in the late 80's. The gears were aluminum. With a signature stating they were steel. Actually, I had one steel gear and one aluminum gear. All the parts were scorn. I was just surprised to find it after 18 years of signatures.

Thanks!

-Matt

[N601RX]

We were very careful about this when we overhauled my engine 2 years ago.  We made a chart of all the engine AD's and how they were complied with and put in the engine logbook.  I also cut the label off the box each part came in and put them all in an envelope.  The label contains the manufacturer, Pn, Version rev and date code. If there is ever an internal engine AD, I will know if any of my parts are affected without tearing the engine down to find out.

[Sabremech]

Great topic. I'm of the opinion that there should be no recurring AD's. Fix the problem right and be done with it. I could certainly be doing something more productive with my time than searching through logbooks looking for compliance times and dates.

 If I'm doing the airplane inspection for my first time, then I'm stuck verifying compliance in the logbooks with the thought in my mind that is it really done or not? The liabilty does not end with the annual running out. As long as your name and number are in the books, you're liable.

 

 David

[DonMuncy]

I agree that it is a pita to keep up with, but I think it is likely to pay off somewhere. I started with a review of my logbooks and generating a list of everything on the plane with model numbers and part numbers of everything I could find; propellers, starter, radios, etc.

Then a review of all ADs from the Feds, creating a list of all that could possibly apply. (Airframe, engine, propeller & appliances)

Then back to the log books to check for compliance and creating a list, with notes of which are not applicable (and why), which are done and which are recurring.

Somewhere you are likely to find an IA has created a list to work from, but I would double check them. Also, keep up with added equipment or replacement of some part.

Like I say, I probably have too much time on my hands.

[John Pleisse]

IA's have updated software for nearly every model and it's not that big of a deal to keep up. Think of it this way, we have a low AD list with our Mooneys compared to other brands. IA reliance is reset with each annual.

[Sabremech]

IA's have updated software for nearly every model and it's not that big of a deal to keep up. Think of it this way, we have a low AD list with our Mooneys compared to other brands. IA reliance is reset with each annual.

 

Since I take care of a very limited number of small airplanes, (2) I do not subscribe to any AD software programs. It's quite expensive and is possible for errors in that service too. The lower number of AD's on the Mooney airframe is nice, but the engine, prop and accessories are no less a chore to remain on top of.

 David

[Guest]

In Canada Transport Canada places the responsibility for AD compliance with the owner/ operator of the aircraft. Transport's view is that the owner may delegate the task to another person but not the ultimate responsibility for compliance.

Transport Canada has for about 50 years had an AD log to record compliance with AD's, S/B's, etc.

Like the FAA, transport publishes all AD's on line for everyone to read.

I prefer to help my clients produce as complete a list as possible, with complete compliance records, last done, next due, terminating action, etc. Sure simplifies AD research.

My suggestion is to compile your own list for your own serial number in some form of log book.

Clarence

[fluffysheap]

When I bought my plane, I sent it to Don Maxwell for a thorough going-over - a pre-buy that turned into an annual.  It took a lot longer than I expected, but he found an AD that wasn't properly complied with *and* some prior damage that wasn't previously known.  Because of this, I think any time a plane undergoes an ownership change, or a change in maintenance regime, it ought to get an annual from square one.  Just so there are no surprises.

 

That doesn't mean I think it should be mandatory - as if we need more costs and things to be liable for - but as a conscientious owner, that's what I'd want done.

[1964-M20E]

Great topic. I'm of the opinion that there should be no recurring AD's. Fix the problem right and be done with it. I could certainly be doing something more productive with my time than searching through logbooks looking for compliance times and dates.

 If I'm doing the airplane inspection for my first time, then I'm stuck verifying compliance in the logbooks with the thought in my mind that is it really done or not? The liabilty does not end with the annual running out. As long as your name and number are in the books, you're liable.

 

 David

Well there is one recurring AD that cannot be fixed and all airplanes shall comply with.

 

 

The annual inspection.   

[Sabremech]

Well there is one recurring AD that cannot be fixed and all airplanes shall comply with.

 

 

The annual inspection.   

 Huh? Maybe I'm being critical, but an annual inspection is not an AD.

 

 David

[PLN_FXR]

It would be great if all AD's offered terminating action, but many do not.  It would also be great when records are signed off if the person doing the signoff would state "exactly" what they did.  As an I.A., it is very frustrating first time I'm going through an airplane, and the signoffs state "All AD's complied with" or "Complied with AD such & such".  Unless I know what they did, I will not sign off the inspection without verifying compliance with or accomplishing the AD.  As noted in threads above, I have disassembled numerous engines for overhaul that have had the oil pump AD signed off as "complied with", yet they have had aluminum/steel or sintered iron impellers installed. (As an aside, I have never seen an aluminum/steel impeller that caused any trouble ... can't same the same for the sintered iron ones.)

 

As an owner/operator, the FAA holds you responsible for AD compliance ... but they will still violate the A&P/IA who missed an AD (they are equal-opportunity when it comes to issuing violations).  I'll get off my soapbox, but there are good, conscientious A&P/IA,s and there are those who will sell you a signoff.  There are also owners that maintain their aircraft scrupulously, and those that have an Annual Inspection accomplished every three or four years.

[Sabremech]

It would be great if all AD's offered terminating action, but many do not.  It would also be great when records are signed off if the person doing the signoff would state "exactly" what they did.  As an I.A., it is very frustrating first time I'm going through an airplane, and the signoffs state "All AD's complied with" or "Complied with AD such & such".  Unless I know what they did, I will not sign off the inspection without verifying compliance with or accomplishing the AD.  As noted in threads above, I have disassembled numerous engines for overhaul that have had the oil pump AD signed off as "complied with", yet they have had aluminum/steel or sintered iron impellers installed. (As an aside, I have never seen an aluminum/steel impeller that caused any trouble ... can't same the same for the sintered iron ones.)

 

As an owner/operator, the FAA holds you responsible for AD compliance ... but they will still violate the A&P/IA who missed an AD (they are equal-opportunity when it comes to issuing violations).  I'll get off my soapbox, but there are good, conscientious A&P/IA,s and there are those who will sell you a signoff.  There are also owners that maintain their aircraft scrupulously, and those that have an Annual Inspection accomplished every three or four years.

 

 So what would you prefer the AD sign off to state besides complied with/ accomplished AD XXXX-XX-XX? Will any more detail convince us that it was actually done? Some things have to be trusted when they are signed off previously unless an obvious red flag appears during your inspection.

 

 David

[PLN_FXR]

 So what would you prefer the AD sign off to state besides complied with/ accomplished AD XXXX-XX-XX? Will any more detail convince us that it was actually done? Some things have to be trusted when they are signed off previously unless an obvious red flag appears during your inspection.

 

 David

Sign it off something like this:  "Complied with AD XXXX-XX-XX by [visual inspection or similar] per [para (a) and SBXXX or similar]. Inspection constitutes terminating action "or" reinspection due at tach XXXX.X."   In other words, state WHAT you did, HOW you did it, and what further action is due, if any.  A simple "complied with AD XXXX-XX-XX doesn't mean a damn thing if the AD listed several varying courses of action. Complied with what?  The inspection portion?  The terminating action?  Required parts changes? Para A & B, but not C?  Take, for example, the Aileron Link AD on many Mooney aircraft.  If an IA signs it off simply as "Complied with AD 98-24-11", what was accomplished? Were the links inspected and no cracks found, necessitating a reinspection per M20-264 within 100 hours, or were they replaced with the reinforced links constituting terminating action?   

[Sabremech]

I understand your point. I don't write a book with my entries and keep it detailed and short. If the AD is an inspection and simple, I will sign it off as complied with AD XXXX-XX-XX as nothing else is needed to be known other than the AD is complied with. If it is a recurring AD, I note the next due in my signoff. If parts were changed, they are written in my parts changed portion of my logbook entry.

 For me, all I want to know, has the AD been complied with and is it terminated or recurrent. The key is that any recurrent AD is noted and the next due date or time is in my entry.

 David