AD compliance question

[Guest]

For the A&P IA’s in the group. I’m trying to clarify an AD compliance question.

Suppose you have an AD which says “You must comply with manufactures S/L 1234 within the next period of hours or years.”  The plane in question has complied with the S/L as required by the AD.

The manufacturer then releases a revised S/L 1234-R1 some time later, but the AD never stated S/L 1234 or latest revision in the original version.  The AD has not been revised to include R1 of the S/L.

Is the owner or maintainer required to comply with the R1 version of the S/L?

My interpretation and experience says it’s not required.

Clarence

 

[takair]

My interpretation and experience with the FAA is that you comply with AD as written, thus, the original version of the S/L.  At work, we are often playing hopscotch with ADs, and it can be frustrating.  The problem is the long lag time for an AD to catch up...they are typically a year behind the OEM.  Of course, and I don’t doubt you did this, it is worth looking at the new SLand making a judgement call as to the intent.  It may be a correction or change that has safety benefits and the AD is just not yet caught up.

[Guest tommy123]

As a IA I would comply with the AD by complying with the SL called out in the AD. As a owner I always comply with SL required or not. Mooney issues them for a reason.

Edited August 6, 2018 by tommy123

[Andy95W]

I agree with Rob, above ( @takair ).  I would read both and comply with the one that makes the most sense from a safety perspective.  Legally speaking, I think you're covered either way.

[Jim F]

My IA is not current but here is how I would handle it.

Review the change to the new Rev of the SL. Sign off the AD with a reference to the SL new Rev and add a note that the AD was privosly complied with on X date and SL Rev old.  I don’t think there is an issue signing off an AD twice.  Or you could ask the FSDO or whatever it’s call up by you. 

Lets us know what you do. 

Jim

[Guest]

Thanks for the replies.  It actually affects our C150 fuel caps.  The reference S/L has been revised and now superseded. The original called for one vented fuel cap, the newer one under a completely different number calls for 2 vented caps.  I’m going to install the second cap even though by the letter of the AD it wouldn’t be required.

Clarence

[Shiny moose]

IMIAO you must use the SL that is stated in the AD to comply with the AD. If you comply with another SL that is a different item of compliance and a different log book entry. If and when the AD is revised  to reflect the new SL number, you would be able to reference the new SL number and date to comply with revised AD. 

Where this gets tricky is where different part numbers are installed for the different SL. But we still have to comply with that AD as written 

[Shiny moose]

Damn it took me 20 min to write that last post.

I agree with you to change both caps to vented. 1 vented Cap meets the AD requirement, your second vented cap is a SL compliance and signed of as different items is How I would sign logs books

[Sean S]

It wouldn't hurt to apply for an (AMOC) alternate method of complianace referencing R1 of the service letter. That might get the FAA to revise the AD sooner, or it wont.