Who can sign off an non-appicable SB?

H. Paul Shuch is a Light Sport Repairman with Maintenance ratings for airplanes, gliders, weight shift control, and powered parachutes, as well as an independent Rotax Maintenance Technician at the Heavy Maintenance level. He holds a PhD in Air Transportation Engineering from the University of California, and serves as Director of Maintenance for AvSport of Lock Haven.

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jnmeade
Posts: 536
Joined: Tue Nov 30, 2010 8:58 am
Location: Iowa

Who can sign off an non-appicable SB?

Post by jnmeade »

Rotax has a new Alert Service Bulletin for various 912 engines. It appears the affected engines have recent serial numbers. The SB says in 3.3 the execution must be entered in the log book and refers one to 1.5. 1.5 says it has to be done by the people in paragraph 3. 3 says it has to be done by two categories of ROTAX people or by people approved by the aviation authority. I assume that for the U.S. that is the FAA.

FAR 43.3 says (in part): (g) The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

FAR 1.1 says: Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.

That begs the question of whether reading an engine serial number on the engine or in the engine log book constitutes a simple operation. I would think it does but I have no experience in this matter.

Rotax requires the execution of the SB be included in the logbook. Execution may involve determining that the SB does not require action for your serial number. In that case, can the pilot/owner sign off the engine logbook saying the SB does not apply?

I'd think yes. If you disagree, please include your references.

Obviously, if the owner finds his SN is included in the SB than a certified and approved mechanic must take it from there and the owner/pilot could not sign off under 43(g). It's no longer preventive. That's not my question. My question is when the mandatory SB is found by inspection to not apply.
roger lee
Posts: 807
Joined: Tue Dec 08, 2009 11:47 am
Location: Tucson, Az. Ryan Airfield (KRYN)

Sign off

Post by roger lee »

Hi Jim,

If you have an aircraft SB and the serial number of that aircraft is not within your serial number, but you need to address it in the logbook the answer is yes the owner can document it. It is not work that needs any authority it is only documentation which you as the owner can do. There is nothing wrong with keeping good documentation and you can document all you want. There is no reg against you documenting things in your own logbook. You may not be able to do the work or sign a particular pieces of work off (i.e. and annual or 100 hr. inspection), but you can document or make notes.
Roger Lee
Tucson, Az.
LSRM-A, Rotax Instructor & Rotax IRC
(520) 574-1080 (Home) Try Home First.
(520) 349-7056 (Cell)
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