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For the IAs out there. Who can do an inspection?


N201MKTurbo

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In my IA training, they often mention that an IA cannot delegate an inspection. But can two IAs work on the same annual? One does some of the inspections and the other does others? 

I can probably answer my own question by asking Who is going to sign it off? Can two sign off the same inspection? Can they both take credit for it?

Now I know IAs who will walk past an airplane after some non IA has done the inspection work and sign it off. But I'm not that guy.

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I would argue that, since the engine and airframe have separate log books, they can have separate annuals.  I would go so far as to say they don’t have to be done simultaneously.  I think I actually signed mine off that way one year.   However, I seem to recall being corrected and learning that the annual has to occur simultaneously.  I’ll have to see if I can find that reference.  Ultimately, the one signing the log book is liable, but can one person sign off on the engine and one the airframe.  Seems like a reasonable split, if there is not something specifically prohibiting that.

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8 minutes ago, takair said:

I would argue that, since the engine and airframe have separate log books, they can have separate annuals.  I would go so far as to say they don’t have to be done simultaneously.  I think I actually signed mine off that way one year.   However, I seem to recall being corrected and learning that the annual has to occur simultaneously.  I’ll have to see if I can find that reference.  Ultimately, the one signing the log book is liable, but can one person sign off on the engine and one the airframe.  Seems like a reasonable split, if there is not something specifically prohibiting that.

I was taught that there is no requirement for an engine or propellor annual. Only the airframe requires an annual. Granted the airframe annual includes inspections of the engine and propellor, but only one logbook entry is required. But if work was done on the engine such as cleaning the plugs or timing the mags, that work must be logged somewhere. I would put it in the engine log book, but you don't need to mention the annual. Most do.

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6 minutes ago, N201MKTurbo said:

I was taught that there is no requirement for an engine or propellor annual. Only the airframe requires an annual. Granted the airframe annual includes inspections of the engine and propellor, but only one logbook entry is required. But if work was done on the engine such as cleaning the plugs or timing the mags, that work must be logged somewhere. I would put it in the engine log book, but you don't need to mention the annual. Most do.

This is correct per AC43-9C

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39 minutes ago, N201MKTurbo said:

In my IA training, they often mention that an IA cannot delegate an inspection. But can two IAs work on the same annual? One does some of the inspections and the other does others? 

I can probably answer my own question by asking Who is going to sign it off? Can two sign off the same inspection? Can they both take credit for it?

Now I know IAs who will walk past an airplane after some non IA has done the inspection work and sign it off. But I'm not that guy.

I worked at a shop in Killeen, TX where there were 3 IA’s.  I know for a fact that they all worked together on the Annuals, but only one signed off the logbook. (I’ll bet the official answer if they were questioned by a Fed was that of course they did the whole inspection themselves.). They all three did more than enough Annuals for currency.

I think who signs it off is like deciding who is PIC if there are 2 pilots in an airplane- you should decide ahead of time.  For me personally, if it’s my signature I do the inspection or I inspect the repair myself.

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I've wondered about stuff like this, and I think one thing boils down to defining "inspection".   My last two annuals were heavily owner assisted, and the guys that came to my hangar for the inspection are a father/son pair that have a shop and have been doing this forever.    This year the dad suggested I make entries for 100-hour inspections for everything, and they'd follow it with an annual inspection logbook entry, which is what happened.   That indicated that I did the extent of the "non-inspection" work, and they came along and did the "inspection" part for the "annual".   At least that was the idea.

Clearly not everything in FAR 43 Appendix D is "inspection", particularly the entirety of section (a), which is just work to be done to support the task.

If somebody takes the compression readings and presents them to the "inspector" for evaluation, is that sufficient to be an "inspection" performed by the IA?   The IA is evaluating the results of a measurement, just like if somebody assisted in measuring control surface travel or looking for corrosion or cracks in a small space that a small assistant can reach but the IA can't.   Does the IA actually have to perform every measurement?  I've not found any regulatory guidance on splitting these hairs, which is probably a good thing, but it does mean that there's a fair amount of variation in practice that can be justified.

Whether multiple IAs can share the signoff of a single inspection is a bit trickier, I'd think, but is certainly an interesting question.

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2 hours ago, N201MKTurbo said:

I was taught that there is no requirement for an engine or propellor annual. Only the airframe requires an annual. Granted the airframe annual includes inspections of the engine and propellor, but only one logbook entry is required. But if work was done on the engine such as cleaning the plugs or timing the mags, that work must be logged somewhere. I would put it in the engine log book, but you don't need to mention the annual. Most do.

I figure the engine log is more complete with the inspection sign off.  In theory, that engine can move to another aircraft and would be considered airworthy.  Using that thinking, wouldn’t it be acceptable for one IA to sign off the engine and the other sign off the airframe?  I guess the argument might be that the accessories belong with the airframe, so the airframe guy would be responsible.  I suppose it just gets too complicated.  

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  • 2 weeks later...

My .02 worth is what we do and what we have seen other shops do.  Quick down and dirty summary.  A&P preps the airplane for annual inspection.  (ie removes panels interior etc. etc.)  IA does AD research on airframe while it is being prepped. A&P does 100 hr inspection and AD compliance checks on engine and prop.  A&P signs logbooks for engine and propeller as completing a 100hr inspection on each. IA performs and signs off the airframe logbook as an annual.  That way the A&P and IA can work simultaneously on the same airplane and everything gets done much more efficiently.  

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1 hour ago, Caz said:

A&P preps the airplane for annual inspection.  (ie removes panels interior etc. etc.) 

That was always my job, along with putting it back together. As I developed a relationship with the IA, more things got pushed to me:  clean, gap and tear spark plugs; grease landing gear; wash and wax belly panel; remove and remount wheels. We replaced the nose tire and tube together. 

Several years the IA and I worked together, and knocked out everything over a 3-day weekend. Then he retired.

New IA doesn't do owner-assisted anything, but he did let me watch the brake fluid level the first time we redid the brakes, so it wouldn't overflow. 

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  • 2 weeks later...
On 9/26/2023 at 9:44 PM, takair said:

I figure the engine log is more complete with the inspection sign off.  In theory, that engine can move to another aircraft and would be considered airworthy.  Using that thinking, wouldn’t it be acceptable for one IA to sign off the engine and the other sign off the airframe?  I guess the argument might be that the accessories belong with the airframe, so the airframe guy would be responsible.  I suppose it just gets too complicated.  

Accessories don’t  get a separate Annual. When you see an Annual entry for the engine or prop it’s incorrect, but nobody as in FAA for some reason doesn’t get bent out of shape over it, which surprises me as some seem to concentrate on minutia. 

The “airplane” as in the whole thing not airframe gets an annual, We have over time started calling the Airplane logbook the airframe logbook, but that’s not really the case I don’t believe. I believe technically the engine and prop logbook are a part of the Airplane records not separate records, but I’ve never seen that written down. I said records not books intentionally because I think the FAR’s cover records, not books. May seem to be a silly difference but it can be important.

There is no requirement for the engine and prop to have their own logbook I don’t think, I can find places on the internet that says they have to, but I don’t think that’s correct. It’s rare to see a separate logbook for a fixed prop for example or has been in my experience.

I can come up with several possibilities as to why separate logbooks came into use but they are just guesses. My guess is back when airlines had big round motors, they used to change motors even more frequently than we do spark plugs, it’s was surprisingly easy to do an engine change, maybe I should have said quick instead of easy but they changed motors out frequently, repaired the one removed and it went into the spares pool.

So as they were changing motors so frequently it made sense for it to have its own log, but also darn near every component in a turbine has a life limit in hours or cycles and having its own historical records separate from the airplane just makes sense.

A whole lot of Aircraft maintenance, more than most want to admit admit is done because “we have always done it this way”.

For example until recently I thought an Aircraft had to have a Logbook, but apparently not, seems a box full of scraps of paper with entries on them is all that’s required. I think that’s the gist of this discussion, records are required to be maintained, but they don’t have to be in books, books make sense of course but aren’t required.

I’m still learning.

I’m 99% sure that ONE IA has to complete the entire Annual and that you can’t have more than one doing inspections, not to say it doesn’t happen. 

However an A&P or another IA can sign off the 100 hour on the engine and or prop, because it’s not part of the Annual. I don’t think they are required either, but people thought “I have to put something in the book” so we started entering 100 hour inspections 

None of this I can back up with references, it’s all what I’ve gleaned over the years and as always it may be incorrect.

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10 hours ago, A64Pilot said:

Accessories don’t  get a separate Annual. When you see an Annual entry for the engine or prop it’s incorrect, but nobody as in FAA for some reason doesn’t get bent out of shape over it, which surprises me as some seem to concentrate on minutia. 

The “airplane” as in the whole thing not airframe gets an annual, We have over time started calling the Airplane logbook the airframe logbook, but that’s not really the case I don’t believe. I believe technically the engine and prop logbook are a part of the Airplane records not separate records, but I’ve never seen that written down. I said records not books intentionally because I think the FAR’s cover records, not books. May seem to be a silly difference but it can be important.

There is no requirement for the engine and prop to have their own logbook I don’t think, I can find places on the internet that says they have to, but I don’t think that’s correct. It’s rare to see a separate logbook for a fixed prop for example or has been in my experience.

I can come up with several possibilities as to why separate logbooks came into use but they are just guesses. My guess is back when airlines had big round motors, they used to change motors even more frequently than we do spark plugs, it’s was surprisingly easy to do an engine change, maybe I should have said quick instead of easy but they changed motors out frequently, repaired the one removed and it went into the spares pool.

So as they were changing motors so frequently it made sense for it to have its own log, but also darn near every component in a turbine has a life limit in hours or cycles and having its own historical records separate from the airplane just makes sense.

A whole lot of Aircraft maintenance, more than most want to admit admit is done because “we have always done it this way”.

For example until recently I thought an Aircraft had to have a Logbook, but apparently not, seems a box full of scraps of paper with entries on them is all that’s required. I think that’s the gist of this discussion, records are required to be maintained, but they don’t have to be in books, books make sense of course but aren’t required.

I’m still learning.

I’m 99% sure that ONE IA has to complete the entire Annual and that you can’t have more than one doing inspections, not to say it doesn’t happen. 

However an A&P or another IA can sign off the 100 hour on the engine and or prop, because it’s not part of the Annual. I don’t think they are required either, but people thought “I have to put something in the book” so we started entering 100 hour inspections 

None of this I can back up with references, it’s all what I’ve gleaned over the years and as always it may be incorrect.

Some good stuff here. https://dommagazine.com/article/documenting-annual-inspection

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I think this is one of those areas where there's such a variety of common practice that a lot of different methods are essentially acceptable.   I recently had a question regarding recording inspections for items other than "the aircraft", e.g., engines, propellers, and a couple things come to mind:

In FAR 43 Part 1 the definition of "maintenance" includes "inspections".  

FAR 43.9 requires a record of any "maintenance" and the person performing the maintenance "shall make an entry in the maintenance record of that equipment..."

I think the basics of that suggests that an inspection of an engine should be accompanied by a record in the engine logbook, if one exists.   Likewise for a propeller.   Whether the inspection record says "annual inspection" or "100 hour inspection" or "inspection" seems to be open to interpretation or personal preference.    I've also heard the "no record required" opinion beyond the "aircraft" logbook for a major inspection, even if it includes appliances or components like an engine or propeller.

So there appears to be a reasonably wide variety of practice in this area, which suggests there are options when you go to do it and not only one way to proceed.

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