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Re: flight school annual report

Posted: Thu Jan 01, 2015 6:07 pm
by drseti
That's a very inciteful question, Helen. My Evektor airframe and engine are now 8 years and 1700 hours old. I'll have to check my AMT logbook for total mx hours, next time I'm on the airport - and will post the ratio once I've calculated it.

Re: flight school annual report

Posted: Thu Jan 08, 2015 2:06 am
by rezaf_2000
Thanks Paul for posting all these reports. I guess I represent Illinois in your 2014 report! :D

By the way, in the other thread I mentioned what I would have liked the LSRM-inspection course to be like. Now we know that's impossible since the curriculum is mandated by FAA. But, where there is an unanswered customer need, there is an opportunity, right?! How about you develop a 2-day hands-on annual inspection course? You could perhaps schedule it when your own airplane needs one of its 100-hour inspections and a couple of students can come over and watch you do the actual inspection? The shops typically mention 10-16 hours of shop time for the annual/100 hour inspection, so a weekend should be enough? You can decide to make the LSRM 16-hour course a prerequisite and this one as a companion course, although I think it could just run on its own merit.

Re: flight school annual report

Posted: Thu Jan 08, 2015 8:52 am
by drseti
Actually, Reza, I do something along those lines, though on a very informal basis. Any of my registered students is welcome to observe, or assist, when 100 hour inspection time rolls around. All very non-commercial. I don't charge them for the experience, and they don't charge me for their labor!

Re: flight school annual report

Posted: Thu Jan 08, 2015 10:26 am
by comperini
drseti wrote:Any of my registered students is welcome to observe, or assist...
Be careful. Under Part 65, you don't have supervisory privileges.

Re: flight school annual report

Posted: Thu Jan 08, 2015 10:48 am
by drseti
True. But if I'm doing the work, and the inspection, and the assistance being rendered is to hand me tools, hold things, and clean things, then I'm not exactly exercising supervisory privileges, am I?

Re: flight school annual report

Posted: Thu Jan 08, 2015 12:24 pm
by comperini
drseti wrote:True. But if I'm doing the work, and the inspection, and the assistance being rendered is to hand me tools, hold things, and clean things, then I'm not exactly exercising supervisory privileges, am I?
I personally don't think so either... and I'd do the same. I think that line in the sand isn't clear (at least it's not to me). Sure, we can't allow someone to do something in our absence and then "sign off their work", but I do think there is wiggle room for someone doing something standing right next to you.

Re: flight school annual report

Posted: Thu Jan 08, 2015 12:45 pm
by drseti
When it's an owner assisted annual (or, more properly, an owner hindered annual), the line is clear - it's drawn at the end of the list of owner-authorized preventive maintenance items. In the case of the student assisting with the 100 hour inspection of my aircraft, I tend to be a bit more restrictive.

Re: flight school annual report

Posted: Thu Jan 08, 2015 1:26 pm
by 3Dreaming
drseti wrote:When it's an owner assisted annual (or, more properly, an owner hindered annual), the line is clear - it's drawn at the end of the list of owner-authorized preventive maintenance items. In the case of the student assisting with the 100 hour inspection of my aircraft, I tend to be a bit more restrictive.
Paul, maintenance and inspections are 2 entirely different things. As you pointed out the owner can do preventive maintenance items. Any other maintenance items must be performed by someone rated to do those items. For the inspection, only the person performing the inspection may do the inspection items.

Re: flight school annual report

Posted: Thu Jan 08, 2015 1:32 pm
by drseti
Understood, Tom. In the case of a condition inspection, non-structural inspection covers must first be removed. This as an owner-authorized PM item. I see no reason the owner can't do that (and similar owner-approved items) when I do the inspection.

Re: flight school annual report

Posted: Thu Jan 08, 2015 3:17 pm
by 3Dreaming
drseti wrote:Understood, Tom. In the case of a condition inspection, non-structural inspection covers must first be removed. This as an owner-authorized PM item. I see no reason the owner can't do that (and similar owner-approved items) when I do the inspection.
I know this is a bit of a grey area, but CFR 43 Appendix D says the person performing the inspection must remove the inspection plates, along with other items.

Re: flight school annual report

Posted: Thu Jan 08, 2015 3:37 pm
by drseti
Not only a gray area, Tom, but also not common practice. For the 30 years that I did owner-assisted annuals with an IA on my old Beechcraft, I did the open-up and button-up tasks, and so did everyone else I know who did owner-assisted annuals.

So, my question is, if somebody brought you a plane to annual, and the inspection plates had already been removed, would you advocate reinstalling and re-removing them before starting?

The annual inspection checklist also says to wash the plane. If the plane were freshly washed when delivered to you, would you dirty it and then wash it again?

My point is, the guidelines are just that.

Re: flight school annual report

Posted: Thu Jan 08, 2015 6:20 pm
by 3Dreaming
drseti wrote:Not only a gray area, Tom, but also not common practice. For the 30 years that I did owner-assisted annuals with an IA on my old Beechcraft, I did the open-up and button-up tasks, and so did everyone else I know who did owner-assisted annuals.

So, my question is, if somebody brought you a plane to annual, and the inspection plates had already been removed, would you advocate reinstalling and re-removing them before starting?

The annual inspection checklist also says to wash the plane. If the plane were freshly washed when delivered to you, would you dirty it and then wash it again?

My point is, the guidelines are just that.
Are you saying CFR 43 Appendix D is just a guideline and not regulatory?

Re: flight school annual report

Posted: Thu Jan 08, 2015 6:39 pm
by drseti
3Dreaming wrote:Are you saying CFR 43 Appendix D is just a guideline and not regulatory?
No, not exactly. But, consider:
Appendix D to Part 43 - Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections
"Scope and Detail" is not a checklist. "As applicable" confirms that you are allowed to use the aircradt manufacturer's checklist in lieu of Appendix D.

And:
(a) Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling
.

The key word here is necessary. If the owner has already removed the plates, access doors, fairings, and cowling (all permitted under PM rules), then this step is not necessary.

Re: flight school annual report

Posted: Thu Jan 08, 2015 7:21 pm
by 3Dreaming
drseti wrote:
3Dreaming wrote:Are you saying CFR 43 Appendix D is just a guideline and not regulatory?
No, not exactly. But, consider:
Appendix D to Part 43 - Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections
"Scope and Detail" is not a checklist. "As applicable" confirms that you are allowed to use the aircradt manufacturer's checklist in lieu of Appendix D.

And:
(a) Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling
.

The key word here is necessary. If the owner has already removed the plates, access doors, fairings, and cowling (all permitted under PM rules), then this step is not necessary.
You can only use the manufactures checklist if it covers all the items listed in appendix D as they apply to the aircraft.

It is completely allowable per the regulations for the owner to remove panels for maintenance, but an inspection is not maintenance. The regulations are very clear that maintenance and inspections are two separate actions.

Re: flight school annual report

Posted: Fri Jan 01, 2016 2:00 pm
by drseti
Happy New Year! AvSport's 2015 Annual Report is now available for download from:
http://avsport.org/reports/report2015.pdf