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FAA, and running Items on Condition

Which to a large extent was the Mike Busch critique, in that a lot of the manufacturers life parameters, natural commercial built in redundancy, is supported by a regime that is potentially vague, or not, depending which side of the fence you sit. I also agree that because the system is mis-understood by a lot of A&P/I/A, that they naturally bend to the ultra cautious mode, leaving the owners in an awkward place.

What I have found is the biggest problem is that most mechanics may be OK in using a spanner (though clearly some are not even able to do that bit) but almost none of them can read and understand the regs. I think it is just that most of the people in question are not “bookie” types and their eyes glaze over after a few lines. You see this when trying to email with them. Mostly they are essentially illiterate. And many avoid written comms because they know they can’t do it. This is true for both FAA A&Ps and EASA66 guys, even though the latter have far less discretion on what needs to be done.

I view on comdition as meaning I do not have to follow a manufacturer’s schedule but can form my own.

Exactly. Lots of “on condition” stuff does in reality have to be replaced periodically because inspecting it isn’t viable or safe. For example an o-ring which is on-condition is hardly going to be removed out of its groove (stretching it in the process) and inspected, when a new one is €10. The €10 is perhaps 50x what it should cost but this is not worth thinking about in the context of an Annual. So a lot of stuff is simply replaced each time. On a TB20 Annual this stuff comes to about 300 quid.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

an o-ring which is on-condition is hardly going to be removed out of its groove (stretching it in the process) and inspected, when a new one is €10

That is not a periodic replacement, it just reflects the fact that o-ring condition is judged non serviceable after removal and replacement. You don’t typically disassemble parts just to replace o-rings on a periodic schedule although it might not be a bad idea to do so after decades of service sealing e.g. AVGAS, within fuel fittings etc.

On condition maintenance is just that, and I think it’s important to recognize it. Of course everybody has items they replace periodically (mags, oil, filters of all kinds) but to redefine ‘on condition’ as being an owner defined periodic maintenance schedule is incorrect, and a slippery slope towards European style maintenance regimentation on owner operated light aircraft.

P.S. IIRC my mechanic has a university degree in economics, an A&P IA, CFI, multi engine, instrument and commercial ratings, about 3000 hrs including 1500 or so commercially in 1920s biplanes, and a Class 1 truck drivers license. He owns two planes. His real job is in engineering for an engine OEM and he’s pretty capable of both writing and thinking

Last Edited by Silvaire at 11 Sep 07:22

Silvaire wrote:

On condition maintenance is just that, and I think it’s important to recognize it. Of course everybody has items they replace periodically (mags, oil, filters of all kinds) but to redefine ‘on condition’ as being an owner defined periodic maintenance schedule is incorrect, and a slippery slope towards European style maintenance regimentation on owner operated light aircraft.

I didn’t say periodic. It is a maintenance schedule or plan devised by the owner not the manufacturer.

There is equally a danger that on condition is treated as fly it till it breaks. Which is also not the case.

Last Edited by JasonC at 11 Sep 07:39
EGTK Oxford

JasonC wrote:

There is equally a danger that on condition is treated as fly it till it breaks. Which is also not the case.

It can be the case, it depends, and it is not always an issue. For example, in my service on my plane something like a DG is entirely unnecessary and typically has a gentle failure mode. I would never service or replace a DG periodically on my plane, I would do so when it needs resetting too frequently for my taste.

I have no written maintenance plan and have zero need for one. I do it based on continuous (unscheduled) assessment and frequent inspection by me, my own ‘rules’ (memorized) and my own and my IA’s occasional review of logbook entries. I ‘live with’ my planes, I don’t ‘visit’ them occasionally.

Last Edited by Silvaire at 11 Sep 12:36

boscomantico wrote:

With an N-reg there are essentially zero “musts”, except the annual inspection

I agree except for AD’s. Many have repeating cycles with requirements to be complied with. Some on a Beechcraft must be done every 100 hours, so there is no grace period for these. The good thing is that some may be performed by the owner – pilot.

KUZA, United States

Peter wrote:

Mostly they are essentially illiterate

So just received this from my intrepid A&P. I have copied and pasted

- Note Testing a vacum system is not part of an annual inspection or is raising Form 337’S
Last Edited by BeechBaby at 11 Sep 16:54
Fly safe. I want this thing to land l...
EGPF Glasgow

Yeah – standard stuff. Also it makes zero sense. Why should raising a 337 be anything to do with an annual inspection? A 337 is the cover form for a Major Alteration. An Annual is not a Major Alteration (well, it might be in some cases ) What is this guy smoking? OTOH taking the p1ss out of people who can’t write a single meaningful sentence is a losing battle these days.

Administrator
Shoreham EGKA, United Kingdom

BeechBaby wrote:

- Note Testing a vacum system is not part of an annual inspection or is raising Form 337’S

Aside from a couple of minor typos, (writing or texting on a cell phone ? ) what’s the problem ?

Both points are 100% correct:

- Testing the vacuum is generally not part of a “basic” FAA Annual Inspection, although I would point out that a full ground run IS part of the Inspection and that would at least enable the inspector to ascertain that the vacuum system is indeed operational.

- Raising 337 Forms is definantly not within the scope of an Annual Inspection although reviewing them to ascertain that any Major Mods have been correctly filed is indeed part of the Inspection process.

So once again: What’s your beef ?

FAA A&P/IA
LFPN

BeechBaby wrote:

The best laugh was that he wanted paid upfront,

It’s so easy to bash people’s writing mistakes …

FAA A&P/IA
LFPN

Raising 337 Forms is definantly not within the scope of an Annual Inspection although reviewing them to ascertain that any Major Mods have been correctly filed is indeed part of the Inspection process.

This implies that it is normal procedure for an A&P/IA to obtain a copy of the FAA record for the aircraft, at each Annual. Is there a reference for this requirement?

Administrator
Shoreham EGKA, United Kingdom
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