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Owner Maintenance Rules and AD Compliance


DVA

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It does appear to me that replacing the lines is something th FARs allow under preventative maintenance. What I can't find is anything it the FARs that says an owner can perform an inspection. Since the AD calls for an inspection, I don't feel this falls under preventative maintenance as the reg is written. 

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I think the AD requirement is separate from the preventive maintenance requirement.

All the allowance for owner to work, inspect and return to service occur under the preventative maintenance section. Therefore the AD compliance is not allowed under that section of the regulations. Therefore, the owner is no longer authorized since this work is outside the preventative maintenance section.

I do agree that the actual WORK is one in the same, but the AUTHORIZATION to do the WORK comes from two separate sources.

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On 1/15/2017 at 1:44 PM, RobertGary1 said:

From a practical point the 100 hour gear lube and inspection AD coincides with the 100 hour fuel injection line AD. Few a&ps will charge for the line inspection when doing the gear  

 

-Robert 

What? There are plenty of Mooney ADs that are required to be done every 100 hrs. Just because they happen to be required at the same time does not mean a mechanic won't charge you to comply with one of them. If they are then they are losing money. They are separate items on separate components. 

An AD cannot be complied with by a private pilot unless the AD specifically states that, and I can't think of any that do. An Airworthiness Directive/inspection is not on the 'preventative maintenance' per FAR 43 Appendix A par, C. It is not on the list so it is not preventive maintenance, therefore a private pilot cannot comply with it. You guys that are not mechanics and are trying to argue the point otherwise crack me up. 

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6 minutes ago, N6758N said:

An AD cannot be complied with by a private pilot unless the AD specifically states that, and I can't think of any that do. An Airworthiness Directive/inspection is not on the 'preventative maintenance' per FAR 43 Appendix A par, C. It is not on the list so it is not preventive maintenance, therefore a private pilot cannot comply with it. You guys that are not mechanics and are trying to argue the point otherwise crack me up. 

Here’s one: 97-14-15 ... so your first theory is blown; there are others.

Next, there are many “mechanics” here and some are participating in this thread.

Finally, no need to be cynical, this is not as simple as you make it sound.

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1 hour ago, DVA said:

Here’s one: 97-14-15 ... so your first theory is blown; there are others.

Next, there are many “mechanics” here and some are participating in this thread.

Finally, no need to be cynical, this is not as simple as you make it sound.

As I said, I did not know of any, not that they didn't exist. The AD you cited is a perfect example of what I said. If the AD in question (2015-19-07) was allowed to be complied with by a pilot, it would say so! In general if the regs do not state that something is allowed then you can probably assume it is not. Not trying to be cynical, and you can include me as one of those 'mechanics' that are participating in this thread. You're absolutely correct that nothing is as simple as it sounds and nothing could be more true when it comes to the FARs. This forum is great for gathering info on various topics, just saying that those of us who do this stuff for a living tend to have a better idea when it comes to some of the legal stuff. I hope you're able to find you answer here. 

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2 hours ago, N6758N said:

What? There are plenty of Mooney ADs that are required to be done every 100 hrs. Just because they happen to be required at the same time does not mean a mechanic won't charge you to comply with one of them. If they are then they are losing money. They are separate items on separate components. 

 

Have you read the AD? It's literally just looks and notice if there are kinks. I've never had a Mooney Service Center charge for this 10 seconds of inspection and 30 seconds of writing when part of other work  

-Robert

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42 minutes ago, RobertGary1 said:

Have you read the AD? It's literally just looks and notice if there are kinks. I've never had a Mooney Service Center charge for this 10 seconds of inspection and 30 seconds of writing when part of other work  

-Robert

Yes , because mechanics should work on your plane for free........ Its what they live for..... By the way if that line fails in the year after they sign it off , the feds will climb up their ass with a microscope......  But its cool , their time and training , expertise , and liability are of no value to anybody....

 

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48 minutes ago, RobertGary1 said:

Have you read the AD? It's literally just looks and notice if there are kinks. I've never had a Mooney Service Center charge for this 10 seconds of inspection and 30 seconds of writing when part of other work  

-Robert

As a matter of fact I have read the AD, many, many more times than you have. If the FAA says it should take an hour to do the inspection, than I should think it should take me at least half that time to complete it. 

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How about this.

1. It appears that we agree that these are pre-fabricated fuel lines.

2.  if there is an issue the pilot can replace the line and return the aircraft to service under preventative maintenance

3. therefore resetting the 100 hour clock on that line or lines

4. if a owner / pilot really wants to get around an inspection do this: buy 4 new lines replace them and 100 hours later swap the lines out with the ones he has in his spare parts bin that are serviceable again resetting the 100 hour clock and so on......

There are many regulations we can only read what the regulation states we cannot give it more we cannot take away from it.  There maybe contradictions between the regulations as to what you can and can't do.  However, if you do what the regulations allow you to do you cannot be penalized.  If someone does try to penalize you you have the regulations to fall back on.

 

Not to derail the thread but food for thought another item allowed under PM is replace the light lens and reflector for navigation lights.  Since LED lights are a single unit of light lens and reflector can the pilot replace them?  I do not want to open this discussion here but it is there for us all to ponder in our own minds what the regs say and what is available.  There are black and white issues in the regs but there also exists some gray areas that can be interpreted in different ways while not adding or subtracting from what is written in the regs. JMHO

 

 

 

 

 

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56 minutes ago, Alan Fox said:

Yes , because mechanics should work on your plane for free........ Its what they live for..... By the way if that line fails in the year after they sign it off , the feds will climb up their ass with a microscope......  But its cool , their time and training , expertise , and liability are of no value to anybody....

 

It seems like your beef is with how the Mooney factory service centers bill and not me.  

-Robert

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11 hours ago, DVA said:

Dave - replies below.  Good topic.

D - You write: “Although the message back to your client should reiterate that owner maintenance is a good thing, this particular owner-performed maintenance item isn’t one of them."  I’d like to know why you feel this “isn’t one of them?” - Please consider that absent the AD in this case the owner is allowed to do everything surrounding removal and replacement of the fuel line.

S - Correct, and I should have clarified that.  The owner can still perform the work and reap the learning benefit of same...only the presence of the AD changes WHO can actually sign off, citing the regs above.  I do the large majority of my annual tasks every year under my mechanic's guidance, so I recognize and embrace the value of the owner-assisted annual/maintenance tasks where appropriate and legal, according to the FAA.

D - In the end this about owner maintenance and promoting it - we as a shop want to do that - and I think that helps make a Good Shop. I have seen in 35 years of flying that when owners get involved in the maintenance of their aircraft they are safer in the air.

S - Couldn't agree more.  I wish more shops would allow owners the opportunity to participate in their annuals and maintenance.

D - In this case there is absolutely no reason why (IMO) that if an owner can replace a fuel line under the FARs, then the owner has had to inspect it, too. This particular AD calls only for a visual inspection for compliance, the owner can do that - as an option, and as such I see no need to add time and cost of a A&P wandering over just to take a look.

S - Again I agree, but in this example of this being an AD item, my point was not who does the work, but who inspects and signs it off.  It does seem silly to require an A&P wander over, do a visual inspection, and sign off an AD item, but the regs say it's required.  My mechanic and I have had this conversation a couple of years back during an annual (can't remember the specific AD, as there are very few on the Ovation to begin with).  Although I benefited from the learning experience at the time by being allowed to do the work, he was most-insistent that he sign off and be that "final checkpoint" to ensure we're complying with the regs to the letter.  As far as I'm concerned, any nominal/additional costs I have to pay an A&P for to have him sign off (although mine are included in the core annual price), is what I consider part of the responsibility of ownership...until such time as the FAA changes the rule(s).

Regards, Steve

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It's so interesting how many people are so confident they know the answer to this question yet we've seen in one post the fsdo says the answer is not so simple. Goes to show just how committed people can become in their understanding of how they think it should be ignoring the importance of the actual whims of the FAA. 

Edited by RobertGary1
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But Robert, we shouldn't be subject to "the whims of the FAA." That's why the regulations are thoroughly cussed and discussed before being issued. They should be clear, but as you know, they often are not. That ain't our fault!

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Re the time to carry out the fuel line AD there are two different scenarios.

An owner who taxis to the shop for compliance will encounter more labour than an owner who's plane is already in the shop for an Annual inspection.  I presume the FAA suggested labour relates to the former.

Clarence

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9 hours ago, RobertGary1 said:

It's so interesting how many people are so confident they know the answer to this question yet we've seen in one post the fsdo says the answer is not so simple. Goes to show just how committed people can become in their understanding of how they think it should be ignoring the importance of the actual whims of the FAA. 

As I mentioned earlier, I'm not a mechanic, but was able to use business leadership and legal experience to articulate a reply at Dave's (OP) request.  We're all learning here, regardless of our professional/vocational/academic training.  My reply was simply intended to serve 2 purposes...provide feedback at another member's request based on what I've learned from my own A&P/IA, and learn something in the process - not to create, case-build, and then support my own interpretation of the FARs.

Back to Dave's original post...What is your take?

Regards, Steve

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