Peter wrote:
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?
Of course not.
The Inspector should review ALL the PERTINENT aircraft documents when performing a Annual Inspection. One such document is an AD Compliance List. There is no FAR requirement to have a separate list, but the Inspector needs to ascertain to a reasonable dgree that the previously required ADs have indeed been carried out.
If the Inspector cannot determine if the relevant 337s and ADs have been carried out then he has every right to sign off the Annual “UN-Airworthy” then list the absence of the before mentioned document(s) as discrepancies.
Michael wrote:
If the Inspector cannot determine if the relevant 337s and ADs have been carried out then he has every right to sign off the Annual “UN-Airworthy” then list the absence of the before mentioned document(s) as discrepancies.
Michael,
I agree, and adding to your response to Peter:
Here in the US, the first annual conducted by an IA is usually three or four hours longer because a good IA will review the maintenance records to substantiate the equipment list and and that all applicable AD’s have been complied with. Once the IA knows the airplane, this should not have to be repeated in subsequent annual inspections. Remember he is certifying that ALL AD’s have been complied and that the aircraft complies with “other approved data upon which its airworthiness depends” when he signs off the annual. How can he do that without a review of the existing record of modifications? I have quoted part 43.11(b) below. This review should also include any AFMS that are required, for example by the 337 for the IFR GPS approval.
43.11 (b) Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or Sec. 135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under Sec. 91.213(d)(2) of this chapter, that person shall place a placard, that meets the aircraft’s airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it “Inoperative,” and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.
NCYankee wrote:
Once the IA knows the airplane, this should not have to be repeated in subsequent annual inspections. Remember he is certifying that ALL AD’s have been complied and tha
Very valid point, but as an owner, I have never seen that in practice. If that were so then the £2200.00 Annual Charge, would not be added to every yearly invoice. Not seen that.
The first annual should be seen as an investment in the customer. I would not pay for the initial paperwork exercise. I’d pay a reasonable standard fee for an annual and additional work extra at a reasonable rate.
Imagine you arrive at a hotel and get asked “have you stayed with us before?” and you answer no and then get “we’ll have to charge a £2200 initial setup fee to create a customer record in our database”.
What and how an IA charges for their time is between the IA and the customer. I am only a customer, although I have managed a company that employees IA’s and mechanics. I know that I charge for all my time as an instructor by my watch. I let pilots know how I am going to charge before providing services. When I was operating an FBO, before we would do any work, we would get agreement from the customer. Digital cameras became a must use device when reporting defects.
achimha wrote:
The first annual should be seen as an investment in the customer. I would not pay for the initial paperwork exercise. I’d pay a reasonable standard fee for an annual and additional work extra at a reasonable rate.Imagine you arrive at a hotel and get asked “have you stayed with us before?” and you answer no and then get “we’ll have to charge a £2200 initial setup fee to create a customer record in our database”.
Right Achimha, it takes all of 2 minutes to set-up a new account – oh yeah, I have to do that TOO for new customers and believe me, there’s far more data to deal with customer info + aircraft data then your hotel example.
Do you have ANY IDEA how long it takes to verify all of the ADs (on the plane as well as on the paper) on a 50 year old Legacy plane ? Figure 2 to 8 hours.
That said, a “clued in” Owner Operator can PREPARE the AD list and gather supporting evidence that will expedite the IAs work and should save some money.
NCYankee wrote:
Digital cameras became a must use device when reporting defects.
And compliance !
The first annual should be seen as an investment in the customer. I would not pay for the initial paperwork exercise. I’d pay a reasonable standard fee for an annual and additional work extra at a reasonable rate.
Imagine you arrive at a hotel and get asked “have you stayed with us before?” and you answer no and then get “we’ll have to charge a £2200 initial setup fee to create a customer record in our database”.
Exactly.
A lot of aircraft owners get ripped off all over the place. I’ve been N-reg since 2005 and seen a lot of it.
However I suspect there is an element here of (a) showing total FAR compliance for the benefit of FAA inspectors reading the site and (b) frustration venting with some aircraft owners who have for years skipped required maintenance (or more likely bought a plane with that history) and went looking for an IA who signs it off… An IA who does that is going to get busted even here in Europe and I personally know some who – after getting caught more than once – got banned for life (still remain an A&P and EASA66 however). An EASA66 engineer who does bad work rarely gets done by the CAA; especially as he has the protection of the “company umbrella”.
Do you have ANY IDEA how long it takes to verify all of the ADs (on the plane as well as on the paper) on a 50 year old Legacy plane ? Figure 2 to 8 hours.
Of course; this is similar in principle to an initial CAMO setup in the EASA system, except that IMHO people get ripped off much more by CAMOs than by A&P/IAs doing the initial setup – example.
Michael wrote:
Do you have ANY IDEA how long it takes to verify all of the ADs (on the plane as well as on the paper) on a 50 year old Legacy plane ? Figure 2 to 8 hours.
CAMOs around here have software systems that determine all applicable ADs at a fingertip and track change intervals of all components. If they are correctly signed off, there is no need to open up the plane and check that the rivet was really replaced. Better computer systems — probably an advantage of the “organization” system in EASA versus the predominant freelance system of FAA.
There is an initial investment in acquiring a new customer. That is normal business practise. There is also a risk when changing shops or IAs so if I’m happy, I’ll stay of course.
Peter wrote:
Of course; this is similar in principle to an initial CAMO setup in the EASA system, except that IMHO people get ripped off much more by CAMOs than by A&P/IAs doing the initial setup
I didn’t pay a cent for the first year extra work. They want my business, they better show that. Not been to their disadvantage so far.
Any A&P has the same access to the computer programmes. The cost is trivial.
If they are correctly signed off, there is no need to open up the plane and check that the rivet was really replaced.
This is a point often missed. The engineer (FAA or EASA) is entitled to trust the logbooks. To argue the contrary is to argue that every time you get a plane which has been maintained by anybody but you since it left the factory, you have to 100% inspect everything, which is self evidently nonsense BUT a lot of people in the maintenance business (especially EASA) DO exactly that, either out of fear/suspicion that there is dodgy stuff there or to just make money.
If logbooks could not be (legally) trusted then why have them? An engineer may take a different view if he thinks something is being hidden (which may then get blamed on him) but he needs to be pretty good at justifying it to his customer. I suspect that a lot of the time the engineer (or the company, in the EASA system) is not willing to say openly they think there is something dodgy there.
