Seven month annual....

[47U]

AC 43-9C is a good review on maintaining required records.  Para 11. d., in particular.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-9C_CHG_2.pdf

11. DISCREPANCY LISTS.
a. Before October 15, 1982, issuance of discrepancy lists (or lists of defects) to owners or operators was appropriate only in connection with annual inspections under part 91, inspections under § 135.411(a)(1), inspection programs under part 125, and inspections under § 91.217. Now, § 43.11 requires that a discrepancy list be prepared by a person performing any inspection required by parts 91, 125, or § 135.411(a)(1).
b. When a discrepancy list is provided to an owner or operator, it says in effect, except for these discrepancies, the item inspected is airworthy. It is imperative, therefore, that inspections be complete and that all discrepancies appear in the list. When circumstances dictate that an inspection be terminated before it is completed, the maintenance record should clearly indicate that the inspection was discontinued. The entry should meet all the other requirements of § 43.11.
c. It is no longer a requirement that copies of discrepancy lists be forwarded to the local Flight Standards District Office (FSDO).
d. Discrepancy lists (or lists of defects) are part of the maintenance record and the owner/operator is responsible to maintain that record in accordance with § 91.417(b)(3). The entry made by maintenance personnel in the maintenance record should reference the discrepancy list when a list is issued.

[thinwing]

On 10/22/2020 at 5:04 AM, Unit74 said:

This is absolutely incorrect. While logging the compressions has become a tradition, there is absolutely no mandate to do so. In fact, many log entries are wrong, but well intended in this respect. What is does is allow owners a way to follow dropping compressions and it is a convenient place to do so. But the same could be said about thing like tire tread wear or oil consumption or plethora of other things pilots might want to track. Use an MX spreadsheet or catalog the work orders otherwise.  But the only log entry required is wether or not the IA found the plane airworthy or not. End of story. If not, it is followed by the entry of “a discrepancy list was provided to the owner” and the entry is done. 
 

As the the erroneous entries, For instance, “inspected left brake caliper and rotor and found unserviceable. Replaced left caliper with PNxxxxx and left brake rotor with PNxxxxx.”  Or how about “ bore scoped number 3 cylinder and found cylinders wall scored and exhaust valve burned. Removed cylinder number 3 and replaced with overhauled cylinder from ABC Engines, part number xxxxxxx-xx. Ground run check completed, aircraft returned to service”

 

Both of the above anecdotal entries are ridiculous.  The only thing that should be logged is the “Removed cylinder number three and replaced with overhauled cylinder form ABC Engines, part number xxxxxxx-xx. Ground run check completed, aircraft returned to service”. But for some reason, APs tend to like logging their trade craft vs what is actually required, which is logging the repair made. What was wrong with the item does not matter to anyone but the owner. And once the work is done, it is irrelevant! So why is it even in the forever log? 
 

That’s my 50 cents worth. And the cash value of my opinion is worth exactly what you paid for it. 

its listed under 14 CFR appendix D to part 43 item D #3..this is basic guide to scope of annual and 100 hr inspections.Further manufactors items to be followed at annual inspections take precedent.both specify compression testing at annual (with the differential method being most common )So with out these being recorded at annual ,it is not co0mplete.

[EricJ]

6 minutes ago, thinwing said:

its listed under 14 CFR appendix D to part 43 item D #3..this is basic guide to scope of annual and 100 hr inspections.Further manufactors items to be followed at annual inspections take precedent.both specify compression testing at annual (with the differential method being most common )So with out these being recorded at annual ,it is not co0mplete.

The compression test must be performed, like the rest of the items in Appendix D, but there is no requirement to record the results.   It is used to determine the outcome of the inspection, and it is very typical to record them so that people can track their compression history for future diagnostic purposes, but there is no requirement to do so.

The manufacturer's list is just a list and is not a requirement, either.   Only the items in Appendix D are required.   

[thinwing]

that interesting Eric....ive never worked with an IA that didnt record them and insisted on doing the test him self or directly observing them.After studing part 43 appendix d ,you are correct ,apparently there is no spelled out rule about recording anything!The giude to mechanics does advise rather strongly a checklist is used (typically from the mfd)Any mfd ICA are manditory however and are frequently included as part of an annual.So i wonder what ICA lycoming has??

[Yooper Rocketman]

18 hours ago, thinwing said:

that interesting Eric....ive never worked with an IA that didnt record them and insisted on doing the test him self or directly observing them.After studing part 43 appendix d ,you are correct ,apparently there is no spelled out rule about recording anything!The giude to mechanics does advise rather strongly a checklist is used (typically from the mfd)Any mfd ICA are manditory however and are frequently included as part of an annual.So i wonder what ICA lycoming has??

Can you post the actual FAA regulation that says ICA's are mandatory for Part 91?  I had that question before as Maintenance Committee Chair for our mercy flight org and we were supplied with a quote dug up from Mike Busch by a Beech Talk poster showing otherwise.  When I further discussed the issue with the IA that was doing our maintenance he admitted Part 91 wasn't required to comply with ICA's (after he had already "implied" we were) "but we really should".

Tom

[thinwing]

hi tom...my IA is my source as well as a couple repair man who state ICA are manditory unlike recomendations for TBO time and calendar limits for part 91.let me see what i can find k

[thinwing]

the closest i could find was for and stc holder (mooney rocket /missile )must provide ICA for all maintance.Typically under airworthyness limitation,part 91 .409 inspection program for their aircraft.thus this becomes part of manditory maintance record under section 43.9.this is also why every 337 must have a ICA attached and becomes a requirement for future maintance.it is required under FAA field approval policy ,the owner /operator under part 91 is reponsible the above is done.

[Yooper Rocketman]

Hmm.  I would like to hear what Mike Busch has to say about this.  He seems to find a lot of "supposed required maintenance" that is not truly required.  Wonder if Paul,@kortopates could share Mike's thoughts on this?

These ICA's can be very expensive and not very well thought through.  TKS requires the fluid filter to be changed on a calendar clock, not usage.  I ran one for 16 years on my Rocket and never changed it until close to selling time.  Cut the old filter apart and it was spotless.  I've had two IA's state ICA's were not mandatory for Part 91.  Seems to be some inconsistency here.

Tom

 

[kortopates]

On 11/2/2020 at 5:57 AM, Yooper Rocketman said:

Hmm.  I would like to hear what Mike Busch has to say about this.  He seems to find a lot of "supposed required maintenance" that is not truly required.  Wonder if Paul,@kortopates could share Mike's thoughts on this?

These ICA's can be very expensive and not very well thought through.  TKS requires the fluid filter to be changed on a calendar clock, not usage.  I ran one for 16 years on my Rocket and never changed it until close to selling time.  Cut the old filter apart and it was spotless.  I've had two IA's state ICA's were not mandatory for Part 91.  Seems to be some inconsistency here.

Tom

 

Yes - there is much confusion on this topic because only the FAA Approved section listed under "Airworthiness Limitations Section" also referred to as the ALS  specifies maintenance required under 14 CFR § 43.16 and § 91.403 unless an alternate program has been FAA approved. So I'll try to boil it down so that its clear what part of an ICA is mandatory and what isn't since their is a lot of confusion on this.

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" (ALS)  then everything in that section (and ONLY that section) must be complied with, precisely as if it were in an AD. Such a section will also show "FAA Approved".

For example, most of the Mooney Maintenance Manuals were updated a few years ago to include the FAA Approved ALS. Here is an example of the M20K Maintenance Manual update for this section:

Notice there isn't a single required FAA Approved Airworthiness Limitation on any of the K's and FAA requirements for incorporating this section didn't even start till the Encores. Longbody's are similar.

More commonly, to day we see lots of ICA's associated with STC'd appliances such as Avionics. But the only section of an ICA that is mandatory is the FAA approved ALS. With respect to anything in any other section of ICA, there is no requirement for a Part 91 operator to perform any of the inspection or maintenance items prescribed therein. But if the operator elects to do any of those items, then they must be performed using the methods, techniques and practices prescribed in the ICA. 

In general, a Part 91 operator of a small piston or single-engine turbine airplane is never required to comply with either the manufacturer’s inspection program or the manufacturer’s maintenance program. Such an operator is required only to perform a generic (Appendix D) annual inspection, and is not required to comply with any particular maintenance program (other than Airworthiness Limitations and ADs). 

A Part 91 operator of a multiengine turbine or a large airplane >12,500 lbs. must comply with the manufacturer’s inspection program (or AAIP) but not with any particular maintenance program (other than Airworthiness Limitations and ADs).

A Part 135 or 121 operator is required to comply with both the mfr’s inspection and maintenance programs. 

Edited November 3, 2020 by kortopates