Annuals after TBO

[RobertGary1]

2 hours ago, Shadrach said:

 

Not necessarily disagreeing with you but I think that is the type of response many IAs may give you. Personally I would only feel comfortable going more than 200 over tbo under specific circumstance. I'd want the last overhaul to have been recent (last 10 years) and maybe some type of service like a 135 operator who's doing a lot of cruising in the year. Of course good oil analysis and compression. Maybe even at that I'd end up opening it up and having it looked at. To each his own but that would be my thinking with my family in the plane. 

 

-Robert

[kellym]

14 hours ago, RobertGary1 said:

That's a discussion you'll need to have with each IA you work with so far beyond TBO.

-Robert

An IA is representing the FAA in performing the regulatory annual INSPECTION.  They do NOT need to follow the factory checklist, although it can be helpful. The requirement is to have a checklist that includes items in Part 43 Appendix D as a MINIMUM.

It is not annual MAINTENANCE.  Factories often forget that, combining recommended maintenance with an inspection. Some items like checking bearings and oil screens you cannot do without doing the associated maintenance.

The only standard for an annual is whether the aircraft, including airframe and engine and prop are airworthy. Airworthiness is not tied to TBO. Compression, borescope inspection, leakage of cylinders, debris in screens and/or filter are. Tests like the valve wobble test are not requirements because they are service bulletins. If I don't know an engine or it has squawks indicating possible valve issues, it might be worthwhile, although I would be inclined to do borescope first. They take about the same time, but borescope will show if there is any discoloration hot spots or issues with the valve seat.

Just one IA's opinion based on regs.  Ask for more IA opinions and you will get at least two other opinions if one answers. ;^)

[kellym]

10 hours ago, RobertGary1 said:

Not necessarily disagreeing with you but I think that is the type of response many IAs may give you. Personally I would only feel comfortable going more than 200 over tbo under specific circumstance. I'd want the last overhaul to have been recent (last 10 years) and maybe some type of service like a 135 operator who's doing a lot of cruising in the year. Of course good oil analysis and compression. Maybe even at that I'd end up opening it up and having it looked at. To each his own but that would be my thinking with my family in the plane. 

 

-Robert

What is basis of your 10 year timeframe? Factory guidance is 12 years, which is based on hose and gasket condition as well as corrosion under worst conditions. I would wager that 80 percent of aircraft exceed the 12 yr recommendation by more than double.

[Yetti]

If I had a dollar for everything that was signed off as Airworthy by the prior IA (that is on the Mooney check list mind you)  that we found and fixed later

[Shadrach]

15 minutes ago, kellym said:

What is basis of your 10 year timeframe? Factory guidance is 12 years, which is based on hose and gasket condition as well as corrosion under worst conditions. I would wager that 80 percent of aircraft exceed the 12 yr recommendation by more than double.

Kelly,

Your knowledge and experience is always appreciated.

thanks!

[RobertGary1]

1 hour ago, kellym said:

What is basis of your 10 year timeframe? Factory guidance is 12 years, which is based on hose and gasket condition as well as corrosion under worst conditions. I would wager that 80 percent of aircraft exceed the 12 yr recommendation by more than double.

I wouldn't have any problem with a 1000 hour engine over 10 years old. But more than 200 beyond TBO I would really only consider if ran very often.  That's just my comfort level.

-Robert

[Shadrach]

1 hour ago, RobertGary1 said:

I wouldn't have any problem with a 1000 hour engine over 10 years old. But more than 200 beyond TBO I would really only consider if ran very often.  That's just my comfort level.

-Robert

It's not about comfort level. It's about the inspection. Airworthiness is determined a number of ways depending on the component in question. Time in service is not one of them unless the component has a mandatory life limit. An IA can refuse to inspect an aircraft based on his opinions about doing business with the owner, the aircraft or both.  However, there is no legitimate log book entry for "I'm not comfortable with the engines time in service". Since you've got your theoretical "IA hat" on, how would your log book entry look?

What's prudent and what's airworthy are not always the same thing. It's prudent to replace a dry vacuum pump every 500hrs, but an operating pump with 1500hrs on it is still airworthy if the components are within limits.

[RobertGary1]

Again, I'm not suggesting what criteria any IA should use. That's kind of pointless since each IA will have his own opinion not influenced by us. I was just stating that, as an owner, I wouldn't feel comfortable flying around behind an engine more than 200 past TBO that hasn't been opened in a long time. I've also sat behind an IO-360 as it disassembled itself in flight.

An IA can "fail" an annual in the same way a CFI fails a BFR. You don't put anything in the log book. Let the guy find someone else to sign it, it doesn't bother me.

Practically your challenge will be to find a willing IA. SMOH is also on the insurance questionnaire but I'm not sure at what point it becomes a problem.

-Robert

Edited April 4, 2016 by RobertGary1

[jetdriven]

44 minutes ago, RobertGary1 said:

Again, I'm not suggesting what criteria any IA should use. That's kind of pointless since each IA will have his own opinion not influenced by us. I was just stating that, as an owner, I wouldn't feel comfortable flying around behind an engine more than 200 past TBO that hasn't been opened in a long time. I've also sat behind an IO-360 as it disassembled itself in flight.

An IA can "fail" an annual in the same way a CFI fails a BFR. You don't put anything in the log book. Let the guy find someone else to sign it, it doesn't bother me.

Practically your challenge will be to find a willing IA. SMOH is also on the insurance questionnaire but I'm not sure at what point it becomes a problem.

-Robert

Technically if the IA inspects the aircraft he must enter it into the maintenance records, that he inspected it and gave a list of discrepancies to the owner.  

I can't recall seeing SMOH on the insurance application, but I'd guess that TA to establish valuation for hull insurance rather than determining airworthiness.  Frequently on these message boards someone will make some statement  to the effect that insurance won't pay a claim because an engine is past TBO or it has a non-TSO landing light installed, but no proof is ever given. 

[Guest]

2 hours ago, RobertGary1 said:

Again, I'm not suggesting what criteria any IA should use. That's kind of pointless since each IA will have his own opinion not influenced by us. I was just stating that, as an owner, I wouldn't feel comfortable flying around behind an engine more than 200 past TBO that hasn't been opened in a long time. I've also sat behind an IO-360 as it disassembled itself in flight.

An IA can "fail" an annual in the same way a CFI fails a BFR. You don't put anything in the log book. Let the guy find someone else to sign it, it doesn't bother me.

Practically your challenge will be to find a willing IA. SMOH is also on the insurance questionnaire but I'm not sure at what point it becomes a problem.

-Robert

I'm not sure that I'm following this.  IA finds something which is unairworthy, like say oil filter full of metal.  He refuses to sign the Annual inspection, so he does not make an entry in the log book.  The owner goes shopping for a new IA who now signs out the airplane as airworthy not knowing what happened with the first IA.  How is this fair to the second guy or perhaps the next buyer?

Personally I'd write it in the log book and make the owner sign acknowledging the deficiency.

Clarence

[RobertGary1]

Just now, M20Doc said:

I'm not sure that I'm following this.  IA finds something which is unairworthy, like say oil filter full of metal.  He refuses to sign the Annual inspection, so he does not make an entry in the log book.  The owner goes shopping for a new IA who now signs out the airplane as airworthy not knowing what happened with the first IA.  How is this fair to the second guy or perhaps the next buyer?

Personally I'd write it in the log book and make the owner sign acknowledging the deficiency.

Clarence

 

I was referring to the situation in which the IA starts looking through the logs and decides he's not comfortable continuing the inspection based on the engine time/etc (for whatever valid/invalid reason he has). 

 

-Robert

[Shadrach]

[Yetti]

"Standard of care" in medicine is a crock.  I have had to fix several things with my wife that the doctors were just ordering more tests and not looking at the whole picture.  systems are systems, Computer, Planes, people.  Start with what changed.

[Cardinal767]

Here is my approach to owners who want to go past TBO either hourly or calendar as an IA.

1. Per the CFR's, the owner/operator is 100% responsible for making sure that the required maintainence is performed and documented. I have no problem doing any inspection on equipment that is past TBO, if it is operated under Part 91 and is airworthy per the maintenance manual.

2. I don't like new customers who bring me aircraft in rough shape, chances are they've been run off from other shops for any number of reasons and I will call the last shop. I've learned to usually turn them away unless they are new to the aircraft, then I'm welling to help, at least once.

3. If they have owned the aircraft for some time and are showing do diligence by performing oil testing since going over TBO, they will be a repeat customers.

4. Argue with me over what's legal and what's allowed based on your interpretation of what is in the books or from what you read online, your case better be strong and correct, or chances are you'll need to find another IA. Sorry 

[MB65E]

7 hours ago, M20Doc said:

I'm not sure that I'm following this.  IA finds something which is unairworthy, like say oil filter full of metal.  He refuses to sign the Annual inspection, so he does not make an entry in the log book.  The owner goes shopping for a new IA who now signs out the airplane as airworthy not knowing what happened with the first IA.  How is this fair to the second guy or perhaps the next buyer?

Personally I'd write it in the log book and make the owner sign acknowledging the deficiency.

Clarence

Good thoughts! There is nothing legal to stand on if you write in the logs "advised owner that his engine is over TBO " and still sign it as Airworthy the IA now owns it for a year. I don't see the point, as if they think it's going to help something. I had an MSC (in the Midwest) Write in our logs prior to ownership, "stall warning horn system inoperative, owner elects to not repair"  no repairs preformed. Then the shop signs the Annual!!! What!!!! Yes the next annual was a little expensive to say the least!

I needed to provide a list to the owner once. I got involved with a Super D at a contest that the throttle cable broke. I thought I help te guy out. Ended up finding too many things for me to fix that weekend. I made the owner sign my descrepency sheet. Luckily the airplane was based there at the airport.

Falcon does ask for SMOH on our insurance renewals.

You are trusting your IA for his opinion. I have seen some 1000hr engines I didn't want to fly let alone sign the annual on.  Work with your IA to find a solution and make the airplane safer!

 However,  please don't expect a smooth annual when you roll up to the hangar with 900hrs on the mags, 1800hrs on the fuel servo, 30year old hoses, oil burning anything more than 1qt in 5 hours, original oil cooler, fowled plugs, original generator, a bendix starter, and tell me you jumped it this morning to being it to me for annual...

Sorry, did I say all that?

Best,

-Matt

[kellym]

20 minutes ago, MB65E said:

Good thoughts! There is nothing legal to stand on if you write in the logs "advised owner that his engine is over TBO " and still sign it as Airworthy the IA now owns it for a year. I don't see the point, as if they think it's going to help something. I had an MSC (in the Midwest) Write in our logs prior to ownership, "stall warning horn system inoperative, owner elects to not repair"  no repairs preformed. Then the shop signs the Annual!!! What!!!! Yes the next annual was a little expensive to say the least!

I needed to provide a list to the owner once. I got involved with a Super D at a contest that the throttle cable broke. I thought I help te guy out. Ended up finding too many things for me to fix that weekend. I made the owner sign my descrepency sheet. Luckily the airplane was based there at the airport.

Falcon does ask for SMOH on our insurance renewals.

You are trusting your IA for his opinion. I have seen some 1000hr engines I didn't want to fly let alone sign the annual on.  Work with your IA to find a solution and make the airplane safer!

 However,  please don't expect a smooth annual when you roll up to the hangar with 900hrs on the mags, 1800hrs on the fuel servo, 30year old hoses, oil burning anything more than 1qt in 5 hours, original oil cooler, fowled plugs, original generator, a bendix starter, and tell me you jumped it this morning to being it to me for annual...

Sorry, did I say all that?

Best,

-Matt

Lets clarify a few things. The logbooks belong to the owner, and if the owner is smart, they will never leave his hands. The record entries can be made on a label sticker. Copies can be provided to IA for review. Do you really trust your IA to safeguard your logbooks like Bershire Hathaway stock certificates, in a fireproof safe? The owner is responsible for those records and how they are kept, not the mechanic. Would you really let your IA hold your credit card from aircraft entering the shop until you signed the final invoice? How often have we heard of shop losing logbooks, or a fire in the shop or shop holding logs hostage for something?

I see way too many entries made by A&P's and IAs that are incorrect. A discrepancy has no business in a logbook. If IA made such an entry in log of plane I owned, that page would immediately be cut out of the logbook.  It can be on work order or other documentation if it is not corrected. The logbook is to record what work was done and what inspections were done. Only that the inspection was done and the aircraft either was airworthy or it was not and a list of discrepancies were provided to the owner.  I see condition inspections on homebuilts entered as annuals. I see annuals entered as 100 hours. Of course any maintenance done before the inspection was complete would be entered before the inspection results.  Oil consumption is not something an IA is going to be able to determine in an inspection, and the engine manufacturers have an airworthiness standard that is WAY below 1 qt per 5 hours. More like 1 qt per 1.5 hrs. A fuel servo is supposed to go to full TBO without service, and most will easily go 12 yrs and 2000 hours. Hoses are on condition, which has more to do with environment they live in, like outdoors or in hangar, high ozone and humidity or indoors. Oil cooler is another service at overhaul. Generator is a service on condition, usually not needing more than brushes and maybe bearings. Spark plugs foul for many reasons, like running LOP, not flying on the step, flying at Cessna speeds.............not flying at wide open throttle.

 

 

[kellym]

13 hours ago, RobertGary1 said:

I wouldn't have any problem with a 1000 hour engine over 10 years old. But more than 200 beyond TBO I would really only consider if ran very often.  That's just my comfort level.

-Robert

Huge difference between what meets the definition of airworthy and what you may decide to purchase or fly. IA charge is to determine if aircraft is airworthy at the moment he signs document saying that it is airworthy. No guarantee it is airworthy more than a minute beyond when the plane taxis away from the mechanics shop. Certainly no implication that it will remain airworthy for X hundred hours or next annual. Say all 4 cylinders are at 61/80 and the only leakage heard is from crankcase breather? Engine is at 2100 hours. Airworthy? If it makes static rpm, it is airworthy, assuming no other issues. Do you want to fly it IFR at night in the mountains with some wind and snow?

[MB65E]

Hi Kelly! Thanks for the clarification. I understand. I was just making an example of an aircraft I would have a hard time justifying putting my signature on. All items could be airworthy, but would I put my kids in it? What would it look like in a court room?

I would like/hope to think that an aircraft I put my signature on would remain airworthy for the next 100hrs. I'd rather not see the thing except for oil changes and other routine items. 

I think we are actually on the same page. The legalities, judgment, interpretation, hunches, and the actual condition all need to be factored in during the decision to run past TBO. 

Cheers,

-Matt

 

[Guest]

4 hours ago, kellym said:

Lets clarify a few things. The logbooks belong to the owner, and if the owner is smart, they will never leave his hands. The record entries can be made on a label sticker. Copies can be provided to IA for review. Do you really trust your IA to safeguard your logbooks like Bershire Hathaway stock certificates, in a fireproof safe? The owner is responsible for those records and how they are kept, not the mechanic. Would you really let your IA hold your credit card from aircraft entering the shop until you signed the final invoice? How often have we heard of shop losing logbooks, or a fire in the shop or shop holding logs hostage for something?

I see way too many entries made by A&P's and IAs that are incorrect. A discrepancy has no business in a logbook. If IA made such an entry in log of plane I owned, that page would immediately be cut out of the logbook.  It can be on work order or other documentation if it is not corrected. The logbook is to record what work was done and what inspections were done. Only that the inspection was done and the aircraft either was airworthy or it was not and a list of discrepancies were provided to the owner.  I see condition inspections on homebuilts entered as annuals. I see annuals entered as 100 hours. Of course any maintenance done before the inspection was complete would be entered before the inspection results.  Oil consumption is not something an IA is going to be able to determine in an inspection, and the engine manufacturers have an airworthiness standard that is WAY below 1 qt per 5 hours. More like 1 qt per 1.5 hrs. A fuel servo is supposed to go to full TBO without service, and most will easily go 12 yrs and 2000 hours. Hoses are on condition, which has more to do with environment they live in, like outdoors or in hangar, high ozone and humidity or indoors. Oil cooler is another service at overhaul. Generator is a service on condition, usually not needing more than brushes and maybe bearings. Spark plugs foul for many reasons, like running LOP, not flying on the step, flying at Cessna speeds.............not flying at wide open throttle.

 

 

Personally I would not be giving an owner the maintenance entry for him to add to his logs at a later date.  I've imported far too many planes from the U.S. Which were a disaster in the paperwork department.  If the owner insists on this course he can at very least bring the logs for me to apply the entry and he can have them back.  Supporting a legit shop versus a mobil mechanic is quite different.

In my shop we keep around 100 completed sets of logs, in two fire proof locked filing cabinets, never lost one yet in 30 plus years.  If you're afraid to let him hold your credit card, you're already letting him hold your life in his hands, where's the big issue.

Clarence

[Mooneymite]

The original logbook for my aircraft was lost by a shop.  Since I've owned the plane, I've  kept them in my possession and none have been subsequently lost.  Once bitten....

[kellym]

16 hours ago, M20Doc said:

I'm not sure that I'm following this.  IA finds something which is unairworthy, like say oil filter full of metal.  He refuses to sign the Annual inspection, so he does not make an entry in the log book.  The owner goes shopping for a new IA who now signs out the airplane as airworthy not knowing what happened with the first IA.  How is this fair to the second guy or perhaps the next buyer?

Personally I'd write it in the log book and make the owner sign acknowledging the deficiency.

Clarence

Several false presumptions in your post. An IA who conducts an inspection has several responsibilities. If the aircraft is not airworthy, as you assume, and the owner does not want it fixed, he is to sign the maintenance record (which may or may not be in the form of a logbook) that the inspection was done and the aircraft was found to be unairworthy and that he provided the owner with a list of discrepancies. There is no refusing to sign, only refusing to call it airworthy. Must also record any maintenance performed. A new IA has to perform all the same inspection checklist items, and unless he wants to lose his certificates, is not going to state doing something that was not performed. When he checks the oil, filter and screens and finds brand new oil, there will be a lot of questions.  First will be who did oil change? 2nd would be if it was an annual and where is the list of discrepancies? The owner should be not seeking a new annual, that has already been done. He needs to be getting the deficiencies and unairworthy items corrected, which only requires an A&P, not an IA.

You do NOT put deficiencies in the logbook. Part 43.11 tells you exactly how to sign and what to do about deficiencies (i.e. provide owner a list). I would keep a copy of that list and any other work order documentation. It is up to the owner to subsequently record whatever maintenance was done to correct items on that list before flying the plane, unless a ferry permit is obtained.  Our job as IAs is to follow the regs, not make up things as we go.

[Shadrach]

8 hours ago, MB65E said:

Good thoughts! There is nothing legal to stand on if you write in the logs "advised owner that his engine is over TBO " and still sign it as Airworthy the IA now owns it for a year. I don't see the point, as if they think it's going to help something. I had an MSC (in the Midwest) Write in our logs prior to ownership, "stall warning horn system inoperative, owner elects to not repair"  no repairs preformed. Then the shop signs the Annual!!! What!!!! Yes the next annual was a little expensive to say the least!

I needed to provide a list to the owner once. I got involved with a Super D at a contest that the throttle cable broke. I thought I help te guy out. Ended up finding too many things for me to fix that weekend. I made the owner sign my descrepency sheet. Luckily the airplane was based there at the airport.

Falcon does ask for SMOH on our insurance renewals.

You are trusting your IA for his opinion. I have seen some 1000hr engines I didn't want to fly let alone sign the annual on.  Work with your IA to find a solution and make the airplane safer!

 However,  please don't expect a smooth annual when you roll up to the hangar with 900hrs on the mags, 1800hrs on the fuel servo, 30year old hoses, oil burning anything more than 1qt in 5 hours, original oil cooler, fowled plugs, original generator, a bendix starter, and tell me you jumped it this morning to being it to me for annual...

Sorry, did I say all that?

Best,

-Matt

Are you an IA? Do you not expect a fuel servo to last the life of the engine? It should. I have seen a number of Bendix mags run beautifully for 1000s of hour without overhaul. They need to be inspected for sure, but that hardly changes the TSOH. Also, help me understand how a properly mounted oil cooler wears out? Same with a generator? They are infinitely maintainable, why do you feel they're an issue?

mooneys have their issues like any other bird. If your of the attitude that an oil cooler that's in service must be replaced based on its age and not its condition, then you're limiting your customer base to a very specific kind of customer.

[Shadrach]

Just now, kellym said:

Several false presumptions in your post. An IA who conducts an inspection has several responsibilities. If the aircraft is not airworthy, as you assume, and the owner does not want it fixed, he is to sign the maintenance record (which may or may not be in the form of a logbook) that the inspection was done and the aircraft was found to be unairworthy and that he provided the owner with a list of discrepancies. There is no refusing to sign, only refusing to call it airworthy. Must also record any maintenance performed. A new IA has to perform all the same inspection checklist items, and unless he wants to lose his certificates, is not going to state doing something that was not performed. When he checks the oil, filter and screens and finds brand new oil, there will be a lot of questions.  First will be who did oil change? 2nd would be if it was an annual and where is the list of discrepancies? The owner should be not seeking a new annual, that has already been done. He needs to be getting the deficiencies and unairworthy items corrected, which only requires an A&P, not an IA.

You do NOT put deficiencies in the logbook. Part 43.11 tells you exactly how to sign and what to do about deficiencies (i.e. provide owner a list). I would keep a copy of that list and any other work order documentation. It is up to the owner to subsequently record whatever maintenance was done to correct items on that list before flying the plane, unless a ferry permit is obtained.  Our job as IAs is to follow the regs, not make up things as we go.

Kelly, 

Clarence was being facetious to make a point. He owns and operates a MSC in Canada. I think he most certainly understands the regs. He was trying to help Robert understand. 

[DonMuncy]

5 hours ago, M20Doc said:

Personally I would not be giving an owner the maintenance entry for him to add to his logs at a later date.  I've imported far too many planes from the U.S. Which were a disaster in the paperwork department.  If the owner insists on this course he can at very least bring the logs for me to apply the entry and he can have them back.  Supporting a legit shop versus a mobil mechanic is quite different.

In my shop we keep around 100 completed sets of logs, in two fire proof locked filing cabinets, never lost one yet in 30 plus years.  If you're afraid to let him hold your credit card, you're already letting him hold your life in his hands, where's the big issue.

Clarence

Clarence,

Since the US does not have any regulations specifying what form logs must be in, it would be perfectly legal for an owner to have a loose leaf notebook and put each entry on a separate removable page. Thus, if the owner provides that notebook to you and you write your entry on the next blank page, you have done your duty. It would appear to me you achieve the same thing by handing the owner a sticky entry to put in the logs. It is the responsibility of the IA to "make an entry" and the responsibility of the owner to "maintain the logs". I would think that the protection to the IA would be to carefully document what entries "he made", probably by keeping a copy.

Incidentally, I am no expert and this is my impression of the regulations from what I have seen and heard..

Don 

[MB65E]

1 hour ago, Shadrach said:

Are you an IA? Do you not expect a fuel servo to last the life of the engine? It should. I have seen a number of Bendix mags run beautifully for 1000s of hour without overhaul. They need to be inspected for sure, but that hardly changes the TSOH. Also, help me understand how a properly mounted oil cooler wears out? Same with a generator? They are infinitely maintainable, why do you feel they're an issue?

mooneys have their issues like any other bird. If your of the attitude that an oil cooler that's in service must be replaced based on its age and not its condition, then you're limiting your customer base to a very specific kind of customer.

Good morning, yes I am an IA. In my experience,  I do not expect a fuel servo to last till TBO. I have pulled one at 500, 800, and 1200 hrs that I know of. Age is also a factor. Some make it to TBO, some don't. 

Some of my points were vague. I should have been more clear with my point. If an owner is running on condition and replacing things that need it along the way that's the best way to go. If it needs to be fixed fix it. Oil coolers tend to collect sediment. But if the oil cooler is overhauled and its original that's great! Most of the time the tabs will develop cracks and need to be repaired. The vernotherm will be checked or replaced as needed too. As for the generator, I wouldn't replace it just to replace it. However, if a guy is complaining  about lack of voltage, the belt is super loose or tight, the front pulley is worn, can't keep a battery charged, and everything dims when the landing light comes on then I'd look at the generator. As for the mags keep up on the 500hr inspections, and the mags should last a long time. But if a guy flys 150hrs a year, and he has 450 on the mags I would pull the mags for the inspection during the annual. At least it would be open for discussion with the owner. However,  you are providing a service. Educating the owner can help everyone. 

I agree that a lot of techs now days are parts changers. I try to see what the issues are before I remove parts. 

All im saying, is I use more than just the airframe checklist and 43.13 when I sign the annual. I think this should be encouraged to prevent failures and improve reliability to the owner.  

Thanks,

-Matt