Not even the wording mandatory makes it mandatory. Nothing under part 91 can force you to overhaul unless either of these criterias are met:
1. A life limit is part of the TCDS sheet.
2. Your maintaining an aircraft according to an maintenance plan where certain SB’s are referenced as part of that maintenance plan. Then they’re mandatory.
In general, it is never a good idea to design a maintenance plan to begin with. An inspection program is much better. Anyway, here’s the clarification from FAA themselves:
Thank you NCYankee. Can anyone confirm what is the situation with an EASA aircraft?
The service bulletins are not usually FAA mandatory. My McCauley C-406 recommended time between overhauls for the hub is 2000 hours or 60 months.The prop has a mandatory 10,000 hour service life. Mine was installed new in 1991 and resealed in 2007 and in 2016.Both reseals were IRAN (Inspect and Repair as Necessary). In both cases, other than the reseal and regrease, they were in perfect condition. They did need the reseal as the grease was old. My Bonanza has a SB that requires the wing bolts be removed, inspected, and retorqued every 5 years and replaced after 15 years. This is not required by an AD and there has never been a reported failure of a wing bolt in the 70+ year history of the type. My aircraft was manufactured Dec 1967 and still has the original wing bolts as they have never been removed, but they are inspected for any external corrosion annually and torque has been checked a few times.
From time to time, I have disagreed with a shop doing an annual regarding whether a service bulletin was required or not. Without an AD, they are optional. I have had shops sign off annuals as unairworthy and provide me or the owner with a discrepancy list. This satisfies the annual inspection requirement. I then have an A&P return the aircraft to service by responding to the discrepancies. If necessary, i get a ferry permit to relocate the aircraft. If a repair was necessary, it was accomplished. If the discrepancy was not mandated to be repaired, the A&P would just indicate the aircraft was returned to service. These kind of squawks don’t need to go into the logbook and even if they did, the annual record does not need to be kept more than one year or to when the next annual is accomplished.
airways wrote:
Is it normal that a maintenance organisation doesn’t want you to order parts yourself ? I’m looking at an engine remanufacture but the quote my maintenance guy got is about $ 8K more than what I got. This is excluding transport, labour, extra parts,… Ideally I’d order it myself but apparently this is not how they work.
Yes it is. They add to their parts prices, so they prefer you not to source them themselves.
Another example: needed a 3rd wheel turbine stage. If I did the replacement work at the shop he would charge me $2800 for the used part. If I just bough the part to bring to another shop, the same part increased to $4800. I can understand the principle, but if you add all of these little markups together, it can be a huge difference. So you need to weed as many of them out as possible and accept the ones you can’t easily affect.
Is it normal that a maintenance organisation doesn’t want you to order parts yourself ? I’m looking at an engine remanufacture but the quote my maintenance guy got is about $ 8K more than what I got. This is excluding transport, labour, extra parts,… Ideally I’d order it myself but apparently this is not how they work.
I always call our annuals not “owner assisted maintenace” but “owner retarded maintenance” :-)
Bobo wrote:
They invited me to help out with the next inspection, that should be good!
This is a good tip! My prop is due this fall. Based on the five years, not the hours of service. I struggle with this stuff, allthough I’m happy with my maintenance company so far. I try to keep up to speed with the regulations concerning maintenance. They invited me to help out with the next inspection, that should be good!
I am one of those owners who has a very good maintenance organisation and have never fealt overcharged on anything. However as is said above, knowledge is a very valuable asset. What is the regulation on an EASA aircraft then about prop “overhauls” and the time limits. Having read the above I am now confused. I have a McCauley constant speed.
