ICAs during Annual?

[jaylw314]

2 hours ago, bradp said:

So the service intervals for garmin are not part of the Airworthiness Limitations section.

Counter this to the dumb AD about the Trig based transpoders needing to be checked for panel orientation.  

Oh come on, there are probably a tons of planes out there with KT-74's installed on side panels ready to clobber their flight engineers, right?  

[Rwsavory]

4 hours ago, BrettKS said:

 

Everyone raves about these Mooney Service Centers being the way to go.. but maybe they aren't all of the same caliber. My annual estimate was nearly $8.5k--with no major engine work needing done. 

Not everyone raves about Mooney Service Centers. And, no, they are not all created equal in any event.  The good ones have their rightful place.  For next year, as well as general maintenance issues between annuals, find yourself an honest shop that won’t nickel and dime you.  

[EricJ]

8 hours ago, PilotCoyote said:

Appendix D to Part 43

...

(j) Each person performing an annual or 100-hour inspection shall inspect (where applicable) each installed miscellaneous item that is not otherwise covered by this listing for improper installation and improper operation.

———————

Maybe we need to define the term “where applicable” in paragraph (j)......?

I think that the question that must be answered with a straight face is: “How do you fully meet the requirement to inspect for “improper installation” and “improper operation”, without referring to the manufacturer’s approved data ?” If you don’t refer to it, then you are just drawing from whatever data you can recall from your own memory and experiences. To rely entirely upon your own memory or the basic list in Appendix D to determine the airworthiness of all components in a modified aircraft, seems unwise.

I think installation and operation are not the same thing as post-installation maintenance per an ICA.   The ICA is separate from the installation instruction and separate from the operation manual.  
 

6 hours ago, jaylw314 said:

So my beef would be with an IA telling me he needs to comply with the ICA's because they are required by regulation.  I believe that is incorrect, just like it is not required to log that you complied with any ICA.  OTOH, if he told me he will proceed with complying with the ICA's because they are consistent with assuring himself the aircraft is in airworthy condition (or in simpler language), I would probably be fine with that (and probably respect his thoroughness).

My other beef is with his statement that he needs the avionics shop to confirm compliance with ICA's.  If he said he needed to have a quick consultation with his avionics guy, that would be ok, and I might even be ok with paying for it if there was a complication.  But to say an avionic shop is somehow required to rubber stamp an annual is flat out wrong.

This is consistent with my thinking.   I still don't see anything that connects ICAs with annuals, especially operating solely under Part 91, and I don't see how anybody other than the IA (e.g., an avionics shop) is required in any way for an annual inspection.   My understanding is that the IA must perform the inspection and cannot delegate it.
 

2 hours ago, jaylw314 said:

OK, here's the article version of the presentation I was thinking of:

https://www.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2011-12_intervals.pdf

from the article:

"The general rule is that Part 91 (noncommercial) operators are never required to comply with such manufacturer specified intervals (when-to’s) simply because there is no regulation in the FARs requiring them to do so. There are two— and only two—exceptions to this general rule: If such intervals are mandated by an FAA airworthiness directive (AD) or if they are set forth in an FAA-approved airworthiness limitations section (ALS) of the manufacturer’s MM or ICA, then compliance is required by regulation. Otherwise, it isn’t. The regulatory reference that covers these two exceptions is FAR 91.403...

§ 91.403 GENERAL.

(a) The owner … of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with Part 39 of this chapter [Airworthiness Directives].
(c) No person may operate an aircraft for which a manufacturer’s maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section … have been complied with."  (my emphasis added)

In other words, the only things required by regulation are the items in the Airworthiness Limitations section of an ICA, which is not common and does not apply to the Garmin ICA above.

This has been my (limited) understanding as well, that the Limitations sections of things like the POH, ICAs, etc., etc., are the guiding sections.   The Limitations section of my POH (M20J model Manual number 1220) says "FAA Approved" on the bottom of every page, and only that section, and as kortopates showed above the Airworthiness Limitations section of the Garmin documents is the "FAA Approved" section, which also says, "There are no additional Airworthiness Limitations...that result from this modification."

I'm not seeing a strong case directly connecting ICAs and annuals, and definitely nothing connecting an outside shop to an annual or even to the instructions in the ICA (which are pretty much visual checks or simple installation checks like bonding resistance, nothing a shop would be needed for).    It sounds to me like the IA is pumping the bill up.

And, yeah, many MSCs never or rarely get mentioned on this site when people ask for recommendations.   

 

[jaylw314]

7 minutes ago, EricJ said:

This has been my (limited) understanding as well, that the Limitations sections of things like the POH, ICAs, etc., etc., are the guiding sections.   The Limitations section of my POH (M20J model Manual number 1220) says "FAA Approved" on the bottom of every page, and only that section, and as kortopates showed above the Airworthiness Limitations section of the Garmin documents is the "FAA Approved" section, which also says, "There are no additional Airworthiness Limitations...that result from this modification."

My understanding is that the AL section is usually empty because if someone wants to put something in there, it would be subject to the same rules-making process as AD's--it has to go through NPRM and be approved by the FAA before it can be added

[kortopates]

9 hours ago, jaylw314 said:

OK, here's the article version of the presentation I was thinking of:

https://www.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2011-12_intervals.pdf

from the article:

"The general rule is that Part 91 (noncommercial) operators are never required to comply with such manufacturer specified intervals (when-to’s) simply because there is no regulation in the FARs requiring them to do so. There are two— and only two—exceptions to this general rule: If such intervals are mandated by an FAA airworthiness directive (AD) or if they are set forth in an FAA-approved airworthiness limitations section (ALS) of the manufacturer’s MM or ICA, then compliance is required by regulation. Otherwise, it isn’t. The regulatory reference that covers these two exceptions is FAR 91.403...

§ 91.403 GENERAL.

(a) The owner … of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with Part 39 of this chapter [Airworthiness Directives].
(c) No person may operate an aircraft for which a manufacturer’s maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section … have been complied with."  (my emphasis added)

In other words, the only things required by regulation are the items in the Airworthiness Limitations section of an ICA, which is not common and does not apply to the Garmin ICA above.

Thanks for going to the trouble of looking up Mike's writing on this. I was with you entirely until your last line. Your quotation of 91.403 (c) is Mike saying that the Airworthiness Limitations Section are mandatory to be complied with just like AD's. 

Why do you then say "In other words, the only things required by regulation are the items in the Airworthiness Limitations section of an ICA, which is not common and does not apply to the Garmin ICA above." We are indeed only talking about items in the Airworthiness Limitations section of the Garmin (OEM) ICA - the entire section 4 I posted above is FAA approved data and mandatory to comply with.  (I don't understand why you think they are not common and don't apply to the Garmin ICA - they certainly do and very common in avionics STCs)

The rules for ICA are precisely the same as the rules for maintenance manuals. Specifically, if an ICA has a clearly identified Airworthiness Limitations section, then everything in that section (and ONLY that section) must be complied with, precisely as if it were in an AD. 

[kortopates]

On 8/7/2019 at 2:44 PM, EricJ said:

I think the key point is that the Airworthiness Limitations sections for most stuff like this says what the above linked docs say, something like "There are no additional Airworthiness Limitations...that result from this modification."   In other words, you don't need to do anything special as a result of installing that equipment.   All of the stuff I've put in recently has been this way.

I think you may be misconstruing the meaning of the boiler plate preface text "There are no additional Airworthiness Limitations...that result from this modification." This is not to contradict the remainder of the Section 4 (Airworthiness Limitations Section) but references the basis of where these came from as a requirements for  of Part 23 Appendix A that defines the required scope for "Instructions of Continued Airworthiness" - its just saying that there are no additional requirements beyond those listed in Section 4. 

Edited August 9, 2019 by kortopates

[kortopates]

6 hours ago, jaylw314 said:

My understanding is that the AL section is usually empty because if someone wants to put something in there, it would be subject to the same rules-making process as AD's--it has to go through NPRM and be approved by the FAA before it can be added

It only has to be approved by the FAA, just read the first page of section 4. AD's need to go through a NPRM, not Airworthiness Limitations.

Its true that we don't really have any but the no clutch back spring in the gear actuators in the Mooney, most are on condition, but here is a example Mooney list for the K model:

[EricJ]

7 hours ago, kortopates said:

I think you may be misconstruing the meaning of the boiler plate preface text "There are no additional Airworthiness Limitations...that result from this modification." This is not to contradict the remainder of the Section 4 (Airworthiness Limitations Section) but references the basis of where these came from as a requirements for  of Part 23 Appendix A that defines the required scope for "Instructions of Continued Airworthiness" - its just saying that the not additional requirements beyond those listed in Section 4 apply. 

Ahg!   I only just noticed something fairly important and relevant:   hypertech linked the ICA for the GTN 625-750, Garmin doc 190-01007-A1 Rev 1 , in which the Airworthiness Limitations section is Section 3 and has the boilerplate and nothing else, suggesting there are no more limitations.    You posted a page from 190-01007-A1 Rev 9, which seems to have had some significant additions, although I can only see that single page.    So, yeah, there may be some stuff...   Ahg.   Good to make sure you have the latest revision when looking at this stuff.

The link hypertech posted is on the Garmin site...now I'm confused if they have obsolete revs up.   

[kortopates]

2 hours ago, EricJ said:

Ahg!   I only just noticed something fairly important and relevant:   hypertech linked the ICA for the GTN 625-750, Garmin doc 190-01007-A1 Rev 1 , in which the Airworthiness Limitations section is Section 3 and has the boilerplate and nothing else, suggesting there are no more limitations.    You posted a page from 190-01007-A1 Rev 9, which seems to have had some significant additions, although I can only see that single page.    So, yeah, there may be some stuff...   Ahg.   Good to make sure you have the latest revision when looking at this stuff.

The link hypertech posted is on the Garmin site...now I'm confused if they have obsolete revs up.   

Ah, yes, they're upto Rev 11 now, this is the current version off the Garmin site http://static.garmin.com/pumac/190-01007-A1_11.pdf 

As you'll see, there is a lot of stuff, but almost all "on condition" except for the annual visual check and a 10 yr/2000 hr bonding check (some others for composite aircraft only which aren't applicable to us).

[EricJ]

21 minutes ago, kortopates said:

Ah, yes, they're upto Rev 11 now, this is the current version off the Garmin site http://static.garmin.com/pumac/190-01007-A1_11.pdf 

As you'll see, there is a lot of stuff, but almost all "on condition" except for the annual visual check and a 10 yr/2000 hr bonding check (some others for composite aircraft only which aren't applicable to us).

Interesting.    It looks to me like the Airworthiness Limitations section is only 4.1 under the ICA chapter and is the only section that is FAA Approved.    The maintenance intervals, inspections, tests, etc., are all later sections that are under the ICA chapter but not under Airworthiness Limitations.    The Periodic Maintenance Table is now 4.3.      The Periodic Maintenance subsection, 4.2.1, says it's all software and will produce an annunciator or system message if it needs maintenance.

And none of the items in the Periodic Maintenance Table seem to me to be anything that requires an avionics shop.   It's all visual inspection except for the bonding tests at 10 years or 2000 hours, which sounds like if you have a screwdriver and a good multimeter you should be fine.

Just finished my "Inspections" class, so it's interesting to me.

 

[kortopates]

21 minutes ago, EricJ said:

Interesting.    It looks to me like the Airworthiness Limitations section is only 4.1 under the ICA chapter and is the only section that is FAA Approved.    The maintenance intervals, inspections, tests, etc., are all later sections that are under the ICA chapter but not under Airworthiness Limitations.    The Periodic Maintenance Table is now 4.3.      The Periodic Maintenance subsection, 4.2.1, says it's all software and will produce an annunciator or system message if it needs maintenance.

And none of the items in the Periodic Maintenance Table seem to me to be anything that requires an avionics shop.   It's all visual inspection except for the bonding tests at 10 years or 2000 hours, which sounds like if you have a screwdriver and a good multimeter you should be fine.

Just finished my "Inspections" class, so it's interesting to me.

 

Wow, I did not notice that till you just pointed that out. I miss-assumed that all of Section 4 was titled Airworthiness Limitations Section - but its not. Section 4 is ICA (Instructions for Continued Airworthiness). Since only the ALS (which is only 4.1) defines mandatory requirements and there are none listed in 4.1, I believe you are correct and therefore the Section 4.3 is not mandatory. My bad for misconstruing the section titles and mistaking 4.1 for being all of 4.  Just to be sure though, I'll double check with my team, but I believe you're right.  

[jaylw314]

11 hours ago, kortopates said:

It only has to be approved by the FAA, just read the first page of section 4. AD's need to go through a NPRM, not Airworthiness Limitations.

Its true that we don't really have any but the no clutch back spring in the gear actuators in the Mooney, most are on condition, but here is a example Mooney list for the K model:

Thanks for clarifying that, I thought AL's needed to go through the rules-making process as well.

Hey wait, is the no back clutch spring an Airworthiness Limitation just for K models on?  I couldn't find any AL section in the J service manual, nor did I see it on the page you posted from the K manual?

[kortopates]

5 minutes ago, jaylw314 said:

Thanks for clarifying that, I thought AL's needed to go through the rules-making process as well.

Hey wait, is the no back clutch spring an Airworthiness Limitation just for K models on?  I couldn't find any AL section in the J service manual, nor did I see it on the page you posted from the K manual?

Negative on the No Clutch back spring - I was mixing apples and oranges into the discussion and should have clarified. What I posted was only the Maintenance Manuals Time limited components and I should have clarified - I listed it really to your point earlier when you used the word "rare", I thought you were referring to Mooney's time limited component section where we don't have any but the reference to SB's for clutch. But I should have included these are an example of non-mandatory requirements for us Part 91 operators since because they are not included in Section 4 - Airworthiness Limitations Section which I'll post below.  

These changes came about just a few years ago at the direction of the FAA to include Airworthiness Limitations Section 4 in the maintenance manual. Previous MM revisions did not include a Sect 4, just a Section 5. Also they cleaned up Section 5 and made it much more conservative. For example they use to cite the Engine manufacturers TBO limits, but now they refer to the OEM's Continued Airworthiness Data instead which is a much cleaner way of doing it and really leaving it up the OEM to define any "mandatory" requirements since they would be the only ones that could (not that they would) - but certainly  not Mooney.

Notice also that section 4 is FAA approved and it only references serial numbers starting with the Encore (2000 and up) and foremost it doesn't list any of the items we see in Section 5 - in fact its blank. That's because we have a plane that has very few certification requirements under Part 23. In contrast, Cirrus is certified entirely under part 23 and they have lots of expensive mandatory items listed.

I don't recall if the J model was similarly updated, but all the longbodys where just like this.

[PT20J]

Mike Busch covers this particularly well in his Sept 2019 column in AOPA PILOT. ICA compliance (annual or otherwise) is not required for part 91 operators of small non-turbine airplanes unless the ICA contains FAA-approved airworthiness limitations. This does not mean that some ICAs are not a good idea. But as the operator, you bear the responsibility to decide.

Skip

[jaylw314]

13 hours ago, kortopates said:

Negative on the No Clutch back spring - I was mixing apples and oranges into the discussion and should have clarified. What I posted was only the Maintenance Manuals Time limited components and I should have clarified - I listed it really to your point earlier when you used the word "rare", I thought you were referring to Mooney's time limited component section where we don't have any but the reference to SB's for clutch. But I should have included these are an example of non-mandatory requirements for us Part 91 operators since because they are not included in Section 4 - Airworthiness Limitations Section which I'll post below.  

These changes came about just a few years ago at the direction of the FAA to include Airworthiness Limitations Section 4 in the maintenance manual. Previous MM revisions did not include a Sect 4, just a Section 5. Also they cleaned up Section 5 and made it much more conservative. For example they use to cite the Engine manufacturers TBO limits, but now they refer to the OEM's Continued Airworthiness Data instead which is a much cleaner way of doing it and really leaving it up the OEM to define any "mandatory" requirements since they would be the only ones that could (not that they would) - but certainly  not Mooney.

Notice also that section 4 is FAA approved and it only references serial numbers starting with the Encore (2000 and up) and foremost it doesn't list any of the items we see in Section 5 - in fact its blank. That's because we have a plane that has very few certification requirements under Part 23. In contrast, Cirrus is certified entirely under part 23 and they have lots of expensive mandatory items listed.

I don't recall if the J model was similarly updated, but all the longbodys where just like this.

If I understand correctly, the gist of the Cessna 210 case was that even if the manufacturer got the FAA to approve an item in the ALS of the maintenance manual, that would only be mandatory for aircraft produced after the item was added to the ALS.

That means even if Mooney got an ALS item added to the J model maintenance manual, it would be mean absolutely nothing since it would only apply to J's made in the future, not the past.

[kortopates]

8 hours ago, jaylw314 said:

If I understand correctly, the gist of the Cessna 210 case was that even if the manufacturer got the FAA to approve an item in the ALS of the maintenance manual, that would only be mandatory for aircraft produced after the item was added to the ALS.

That means even if Mooney got an ALS item added to the J model maintenance manual, it would be mean absolutely nothing since it would only apply to J's made in the future, not the past.

This is true, FAA legal has stated from regulatory standpoint only the OEM maintenance manual from when the plane was manufactured applies. But reality is you won't find any shop in the country that operates as a repair station that can get away with this. As a part of doing business each repair station must write up an FAA approved operations manual that covers every aspect of how they do business from training to documentation. Of course they will all say that they will follow the latest OEM documentation for controlling their maintenance. Such repair stations have their hands tied behind their back with respect to this. But in such a situation as this, an owner can always ask for them to complete the annual inspection with a list of discrepancies and have another A&P make an appropriate entry to clear the discrepancy. 

[jaylw314]

43 minutes ago, kortopates said:

This is true, FAA legal has stated from regulatory standpoint only the OEM maintenance manual from when the plane was manufactured applies. But reality is you won't find any shop in the country that operates as a repair station that can get away with this. As a part of doing business each repair station must write up an FAA approved operations manual that covers every aspect of how they do business from training to documentation. Of course they will all say that they will follow the latest OEM documentation for controlling their maintenance. Such repair stations have their hands tied behind their back with respect to this. But in such a situation as this, an owner can always ask for them to complete the annual inspection with a list of discrepancies and have another A&P make an appropriate entry to clear the discrepancy. 

Is there any reason you couldn't get the IA who did the annual to sign off those same discrepancies or does that look too suspicious?  

[kortopates]

Is there any reason you couldn't get the IA who did the annual to sign off those same discrepancies or does that look too suspicious?  

I don't think I follow. If he couldn't sign off for the annual, how could he sign off right after?
Any A&P can sign off on discrepancies, it's not an inspection requiring an IA.


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[jetdriven]

59 minutes ago, kortopates said:

This is true, FAA legal has stated from regulatory standpoint only the OEM maintenance manual from when the plane was manufactured applies. But reality is you won't find any shop in the country that operates as a repair station that can get away with this. As a part of doing business each repair station must write up an FAA approved operations manual that covers every aspect of how they do business from training to documentation. Of course they will all say that they will follow the latest OEM documentation for controlling their maintenance. Such repair stations have their hands tied behind their back with respect to this. But in such a situation as this, an owner can always ask for them to complete the annual inspection with a list of discrepancies and have another A&P make an appropriate entry to clear the discrepancy. 

That settles it. Never take your plane to an FAA approved repair station.  It’s not needed anyways,  and the repair stations always add a bunch of unnecessary work by claiming their PMI won’t allow that.  Our FAA man says that  2100hr prop is not airworthy past TBO. 
Plus, they have a lot of folks off the street working on your stuff. It’s not an A/P or someone under direct supervision, it’s often some unskilled worker who is authorized under the repair station license. Such as Kelly Aerospace. 

[kortopates]

That settles it. Never take your plane to an FAA approved repair station.  It’s not needed anyways,  and the repair stations always add a bunch of unnecessary work by claiming their PMI won’t allow that.  Our FAA man says that  2100hr prop is not airworthy past TBO. 
Plus, they have a lot of folks off the street working on your stuff. It’s not an A/P or someone under direct supervision, it’s often some unskilled worker who is authorized under the repair station license. Such as Kelly Aerospace. 

ALL very true points, unfortunately .


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[PT20J]

1 hour ago, kortopates said:

This is true, FAA legal has stated from regulatory standpoint only the OEM maintenance manual from when the plane was manufactured applies. But reality is you won't find any shop in the country that operates as a repair station that can get away with this. As a part of doing business each repair station must write up an FAA approved operations manual that covers every aspect of how they do business from training to documentation. Of course they will all say that they will follow the latest OEM documentation for controlling their maintenance. Such repair stations have their hands tied behind their back with respect to this. But in such a situation as this, an owner can always ask for them to complete the annual inspection with a list of discrepancies and have another A&P make an appropriate entry to clear the discrepancy. 

This is precisely why Don Maxwell told me he never became a repair station. 

Skip

[jaylw314]

2 hours ago, kortopates said:

I don't think I follow. If he couldn't sign off for the annual, how could he sign off right after?
Any A&P can sign off on discrepancies, it's not an inspection requiring an IA.


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For the same reason any other A&P could sign off right after--if the IA is willing to sign off the annual with a "discrepancy" (that is not required by regulation during the annual), the "discrepancy" is resolved after the annual is completed, right?  It would just save a step of taking the plane to a different A&P, assuming the IA is also an A&P

Edited August 10, 2019 by jaylw314

[bradp]

Here’s a time-based wrinkle.  What drives the 10-year Cirrus chute repack schedule for part 91 operators?  I know nothing about Cirri so would be interested to know.  Is there an airworthiness limitation for OEM BRS chutes?  How about for the STCd versions (Cessna) - is there an AL/ICA that drives it? 

[jaylw314]

17 minutes ago, bradp said:

Here’s a time-based wrinkle.  What drives the 10-year Cirrus chute repack schedule for part 91 operators?  I know nothing about Cirri so would be interested to know.  Is there an airworthiness limitation for OEM BRS chutes?  How about for the STCd versions (Cessna) - is there an AL/ICA that drives it? 

I'm guessing it's in the Airworthiness Limitations section for the Cirrus's, I think I remember hearing that somewhere.  And I think the plural of Cirrus is, in fact Cirrus's  

Edited August 14, 2019 by jaylw314

[carusoam]

Similar to airbags...

Expect that there is some active chemistry contained in the system... that may be sensitive to oxygen, and heat of storage...

Time will change the amount of active chemistry that will be available to do the job...

They probably used some science to determine the limitations of the system in usual storage situations...

Then selected the time not to exceed...

PP thoughts only, not a packaging engineer for a pharma company... 

Best regards,

-a-