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danielfindling
11-21-2011, 04:59 PM
My ELT battery is due for replacement in December. Is this an approved maintenance item for a private pilot or must I employ an A & P?

dusterpilot
11-21-2011, 06:25 PM
You can do it yourself and make the logbook entry: "Removed ELT Battery and replaced with new battery # xxxxx. Next ELT Battery due Nov. 2013. ELT ops checked OK. Name, Owner, Pilot Cert #"

Tom Downey
11-21-2011, 09:48 PM
You can do it yourself and make the logbook entry: "Removed ELT Battery and replaced with new battery # xxxxx. Next ELT Battery due Nov. 2013. ELT ops checked OK. Name, Owner, Pilot Cert #"

That's good so far,, but if you are complying with 91.207 it requires a A&P to sign off the inspection. Inspections are never owner maintenance, Battery replacements are :)

Mike Busch
11-22-2011, 12:24 AM
I agree with both dusterpilot and Tom. The battery replacement is preventive maintenance per Part 43 Appendix A(c) and may be owner-performed (and must be logged). The annual functional check per 91.207 requires an A&P and is normally performed at the same time as the annual inspection and normally documented in the annual inspection logbook entry, although it's not actually part of an annual inspection per Part 43 Appendix D.

teknosmurf
11-22-2011, 08:01 AM
This doesn't really apply to me, but I am curious. I have heard that some ELT's are "rechargable". Is this true? Do these rechargeables simply use off-the shelf rechargable batteries that can be replaced when their lives are finished? Do they require special recharging equipment? Does this move them into the non-owner maintenance category?

Also, are there any ELT's that require dissassembly to replace/recharge the battery?

Tom Downey
11-22-2011, 11:14 AM
This doesn't really apply to me, but I am curious. I have heard that some ELT's are "rechargable". Is this true? Do these rechargeables simply use off-the shelf rechargable batteries that can be replaced when their lives are finished? Do they require special recharging equipment? Does this move them into the non-owner maintenance category?

Also, are there any ELT's that require dissassembly to replace/recharge the battery?

READ FAR 91,207 it gives the useful life of rechargeable battery powered ELTs.

Tom Downey
11-22-2011, 11:16 AM
I agree with both dusterpilot and Tom. The battery replacement is preventive maintenance per Part 43 Appendix A(c) and may be owner-performed (and must be logged). The annual functional check per 91.207 requires an A&P and is normally performed at the same time as the annual inspection and normally documented in the annual inspection logbook entry, although it's not actually part of an annual inspection per Part 43 Appendix D.

I like to marry up the annual and the 91.207 required inspection also. it saves time and costs for the owner. As you say, there is no requirement to do that.

danielfindling
11-23-2011, 06:56 AM
Thanks to all. The replacement was simple and I made the logbook entry as described.

Bill Greenwood
11-23-2011, 10:47 AM
Do You have the new style 406 ELT or the old small yellow type?
If it is the 406 how much did it cost?
Thanks

danielfindling
11-23-2011, 08:38 PM
do you have the new style 406 elt or the old small yellow type?if it is the 406 how much did it cost?thanks 121.5 mhz

FlyingRon
11-24-2011, 07:09 AM
Close duster... Close but on a certificated aircraft you need specifically a SIGNATURE and the type of pilot certificate. The word OWNER is spurious.

dusterpilot
11-25-2011, 06:45 AM
You're correct....I assumed everyone would know a signature is required and that's what I meant by "NAME." (Bad when you assume anything.) On the other hand, during a recent safety seminar it was stated that "Owner" should also be entered since it's "owner-performed" maintenance and just any pilot's signature wouldn't work. A little discussion followed and the key word was "should" since the regs don't specify it and a little checking can verify whether the pilot signing is really the owner. In any case, maintaining the logbooks should be just as meticulously done as maintaining the aircraft.

FlyingRon
11-25-2011, 07:12 AM
I don't know who this discussion is with, but it was wrong. OWNER is spurious. It's also not limited to the OWNER. The reg says "owned or operated." BOTH the name and the signature are required by regulation. You can argue that those can be the same thing, frankly given most people's signatures, I'd make sure the name is listed legibly.

I am meticulously doing the log books. I am following the prescribed REGULATION for making the entry rather than relying on what a bunch of good ol' boys hanging around after an seminar think ought to be in there.

Tom Downey
11-25-2011, 10:18 AM
The FAA's preferred method of making maintenance record entries is given in AC 43-9C. It's all there, read it. it is online at FAA.GOV.

FlyingRon
11-25-2011, 06:49 PM
Thank you, Tom.

flyingriki
11-25-2011, 07:39 PM
I have tried, without luck, to interpret how the FAA treats the use of batteries that have expiration dates. My ELT system uses various sizes of Duracells that all have dates on them. The first couple times I replaced them all and used those removed for years in other devices. The last time I had saved, unused, the previous year's batteries and put them in so I 'changed' the batteries with some that were within voltage and date life spec. Seems a silly way to meet the requirement but I have heard there is an allowed way to do this given the lack of use, full charge and dating provided by these manufacturers. Anybody know the facts or am I dreaming again........?
Thanks!

Tom Downey
11-25-2011, 08:06 PM
I have tried, without luck, to interpret how the FAA treats the use of batteries that have expiration dates. My ELT system uses various sizes of Duracells that all have dates on them. The first couple times I replaced them all and used those removed for years in other devices. The last time I had saved, unused, the previous year's batteries and put them in so I 'changed' the batteries with some that were within voltage and date life spec. Seems a silly way to meet the requirement but I have heard there is an allowed way to do this given the lack of use, full charge and dating provided by these manufacturers. Anybody know the facts or am I dreaming again........?
Thanks!

91.207 says
(c) Batteries used in the emergency locator transmitters required by paragraphs (a) and (b) of this section must be replaced (or recharged, if the batteries are rechargeable)—
(1) When the transmitter has been in use for more than 1 cumulative hour; or
(2) When 50 percent of their useful life (or, for rechargeable batteries, 50 percent of their useful life of charge) has expired, as established by the transmitter manufacturer under its approval.

how difficult is that to understand ?

when your ELT uses D cell batteries that have a date of 2015 on them and you placed them in service today when are they due for replacement?

Bill Berson
11-25-2011, 08:49 PM
Most rechargeable batteries (ni/cad or ni/mh) will self discharge in a few weeks. A lithium rechargeable might not self discharge as fast.
I would not use anything but the usual alkaline D cells normally used.


Does anyone use rechargeable?
Bill

flyingriki
11-25-2011, 09:37 PM
....as established by the transmitter manufacturer under its approval.

Since I don't read 'governmentese' what does this mean? How does it affect or modify the first part of the sentence on 50% of useful life?
I don't know what was established by my manufacturer under it's approval.........

Tom Downey
11-25-2011, 11:14 PM
Since I don't read 'governmentese' what does this mean? How does it affect or modify the first part of the sentence on 50% of useful life?
I don't know what was established by my manufacturer under it's approval.........

many manufacturers make their own batteries and date them, you change them at that date. those who use the "D" cells you use their date on the batteries.

So to answer my question above, you would change the batteries on or before the date on the batteries. and do the 91.207 inspection each year.

Frank Giger
11-26-2011, 12:18 AM
when your ELT uses D cell batteries that have a date of 2015 on them and you placed them in service today when are they due for replacement?

December 2013.

And then again whenever my annual is done to keep everything in synch, so that every other annual I'd change the batteries. D cells are cheap for the price.

Bill Berson
11-26-2011, 10:07 AM
The "useful life" from FAR 91 is not explained and open to interpretation.
The term "useful life" has at least three definitions that I can think of:

1) useful life with the ELT in operation drawing current
2) useful life in the airplane fully charged but self discharging while in standby mode (rechargeable only)
3) useful life uncharged but on the shelf waiting for installation (rechargeable only)

I would go with the ELT manufacturer instructions.
Bill

flyingriki
11-26-2011, 10:10 AM
So to answer my question above, you would change the batteries on or before the date on the batteries. and do the 91.207 inspection each year.

The date on the batteries does not correspond to the 50% rule. It would be correct to change them at 1/2 way to that date.
Maybe now you see why this isn't so simple to interpret..........

Bill Berson
11-26-2011, 12:07 PM
I agree, this part of FAR 91.207 is not as simple as it should be.

After reading 91.207 again, I think the FAA was confused when 91.207 was written.
The FAA is confused over the difference between "useful life" and "shelf life".

Useful life is the quantity of energy remaining in the battery. FAR 91.207 (c)(1) requires replacement if the quantity of energy has been depleted by ELT use of one hour or more. (from this I infer the FAA's definition of "useful life", since the FAA does not define the words in FAR 1.1)

On the other hand, the date on the Duracell D-cell is a shelf life date. This date has nothing to do with useful life while in operation.
I think this date is a manufacturers suggested date after which an unused battery may not have 100 percent of the new batteries total energy, but that is my opinion. I just checked a Duracell from my shelf dated MAY 2010, it still checked at full voltage. But voltage is not an accurate measure of remaining energy, and I have no means to check the quantity of energy left in this battery. Eveready and other brands have no shelf life dates. And that is why Duracell is usually specified by the ELT manufacturer, I think.

I don't think there is any suitable method to determine 50 percent of useful life by inspection, so FAR 91.207 is flawed in my opinion.

To summarize my thoughts, follow the ELT manufacture approval, or if this information is not available, use the the date on the Duracell battery as an expiration date.
Bill

Tom Downey
11-26-2011, 01:06 PM
To summarize my thoughts, follow the ELT manufacture approval, or if this information is not available, use the the date on the Duracell battery as an expiration date.
Bill

The instructions that came with my ELT that uses "D" cells says to use the date on the batteries.

I would suggest that you check the ELT manufacturers instructions that came with your unit.

The orange 406 ELT instructions say

SECTION 11 E-04.0 LITHIUM BATTERY REPLACEMENT
THE LITHIUM BATTERY (P/N E-04.0) MUST BE REPLACED ON OR BEFORE THE BATTERYEXPIRATION DATE MARKED ON THE BATTERY. IT IS NO LONGER AIRWORTHY AFTERTHIS DATE. SEE FAR 91.207 FOR OTHER ELT REQUIREMENTS.


ACK tech yellow box (121.5)

BATTERY REQUIREMENTS:
TRANSMITTER EIGHT DURACELL D CELLS
REMOTE CONTROL ONE DURACELL PX28L OR EQUAL


BATTERY REPLACEMENT INTERVAL:
TRANSMITTER UP TO FIVE YEARS
REMOTE CONTROL UP TO 8 YEARS

flyingriki
11-26-2011, 02:37 PM
BATTERY REPLACEMENT INTERVAL:

TRANSMITTER UP TO FIVE YEARS
REMOTE CONTROL UP TO 8 YEARS









crystal clear......

I don't know who this guy is but he suggests he knows what he's talking about (always scary?):

This expiration date IS the half‐life of the battery, aka when 50% of thebattery’ useful life has expired. Look for the maintenance logbook entry when the ELT batterywas last replaced and you will find an indication of the half‐life of the new batteries.

http://www.aerotechservices.com/resources/e-training/The_ELT_Conundrum.pdf


At the end of this video Dick (as an A&P, IA and Tech Advisor) suggests the logbook entry wording he uses:
http://www.eaavideo.org/video.aspx?v=77829561001

flyingriki
11-26-2011, 04:36 PM
My ELT battery is due for replacement in December. Is this an approved maintenance item for a private pilot or must I employ an A & P?

I think the video I quoted above will answer your original question with authority in addition to Mike's.

Tom Downey
11-26-2011, 05:24 PM
crystal clear......

I don't know who this guy is but he suggests he knows what he's talking about (always scary?):

That came as a copy and paste from the ACK installations for my unit which is on line. @ http://www.ackavionics.com/products.htm


This expiration date IS the half‐life of the battery, aka when 50% of thebattery’ useful life has expired. Look for the maintenance logbook entry when the ELT batterywas last replaced and you will find an indication of the half‐life of the new batteries.
When we talk about ELT batteries there are two types the manufacturers battery which come with an expiration date stamped on them, and the common "D" cell which have a date stamped on each one. Please show me an authority reference as to what that date is, "expiration or shelf life".

http://www.aerotechservices.com/resources/e-training/The_ELT_Conundrum.pdf


At the end of this video Dick (as an A&P, IA and Tech Advisor) suggests the logbook entry wording he uses:
http://www.eaavideo.org/video.aspx?v=77829561001


Dick is simply an A&P-IA just like I am, using the same rule 91.207, He says nothing that contradicts what I have been saying, but the unit he is talking about and using as a demo, is an old Narco Shark 7 which is no longer authorized to be used in the US airspace. See the FCC rules for that. If you really want to know the proper sign off for any return to service see FAR 43. it's all in there. My return to service statement is simple, and came directly from my PMI at FSDO.

" I have inspected this __(ELT make and model)__ system in this aircraft according to applicable aircraft and ELT manufacturers instruction and applicable FAA guidance and found that it meets requirements of section 91.207 para 1 thru 4"

FAR 91.207 requires that you have an ELT installed that is in operable condition but does not call out which type that is.

Tom Downey
11-26-2011, 05:29 PM
I think the video I quoted above will answer your original question with authority in addition to Mike's.

Dick does a nice presentation, but never talks to the "D' cell battery type of ELT. or mentions the "D" cell battery life. Using his demo as a reference where he says the battery should be changed before the date stamped on it, could carry over to the "D" cell.

Tom Downey
11-26-2011, 05:51 PM
My humble opinion of the rule 91.207.

As written it is out dated and incomplete at giving the pilot and passengers the best equipment available. This rule should be rewritten to say that the pilot is responsible for carrying an impact activated PLB. in FAR 91.7. That would place the responsibility on the pilot and remove the junk that causes all the false indicators that we have and the over burdening of the inspection rules.

flyingriki
11-26-2011, 08:09 PM
http://eaaforums.org/images/misc/quote_icon.png Originally Posted by flyingriki http://eaaforums.org/images/buttons/viewpost-right.png (http://eaaforums.org/showthread.php?p=6688#post6688)
I think the video I quoted above will answer your original question with authority in addition to Mike's.


Dick does a nice presentation, but never talks to the "D' cell battery type of ELT. or mentions the "D" cell battery life. Using his demo as a reference where he says the battery should be changed before the date stamped on it, could carry over to the "D" cell.

NOT the original question ...

Mike Busch
11-27-2011, 01:43 AM
Although this does not answer the regulatory question, there's an interesting Technical Bulletin about Duracell alkaline batteries at http://www.duracell.com/media/en-US/pdf/gtcl/Technical_Bulletins/Alkaline%20Technical%20Bulletin.pdf

Among other interesting facts, the Bulletin indicates that at 70F the batteries lose only 3.5% of their capacity per year. They retain 85% after four years and better than 70% after eight years. Shelf life is worse at higher temperatures and better at lower temperatures.

To directly address the question of battery replacement for the ubiquitous yellow ACK E-01 that uses standard drug-store-variety Duracell MN-1300 D-cell alkaline batteries, the manufacturer's guidance appears at http://www.ackavionics.com/pdf/E-01%20M%2009.04.20071.pdf and staties in pertinent part:

"The battery replacement date is found on each Duracell MN1300 cell. It reads as follows: 'Best if installed by (date)'. The (date) indicated is the date by which the batteries must be replaced. All cells must have the same date."

Other than the ACK E-01, every ELT I've ever seen use special battery packs that are clearly placarded with a replacement date. I personally have never encountered a situation where the replacement date needs to be calculated on the basis of the 50% rule of 91.207(c)(2). My theory is that the FAA lawyer who wrote that regulation inadvertently omitted the word "OR" from the sentence, and that it should actually read:

"(2) When 50 percent of their useful life (or, for rechargeable batteries, 50 percent of their useful life of charge) has expired, OR as established by the transmitter manufacturer under its approval."

But what do I know?

Frank Giger
11-27-2011, 06:05 AM
Yet another reason I'm glad I'm building a single seat aircraft - no ELT required!

So what's the "rule of thumb" consensus?

Assuming that the batteries aren't terribly expensive, is "every two years whether they need it or not" okay, assuming the darned thing hasn't gone off?

Tom Downey
11-27-2011, 10:03 AM
Although this does not answer the regulatory question, there's an interesting Technical Bulletin about Duracell alkaline batteries at http://www.duracell.com/media/en-US/pdf/gtcl/Technical_Bulletins/Alkaline%20Technical%20Bulletin.pdf

Among other interesting facts, the Bulletin indicates that at 70F the batteries lose only 3.5% of their capacity per year. They retain 85% after four years and better than 70% after eight years. Shelf life is worse at higher temperatures and better at lower temperatures.

To directly address the question of battery replacement for the ubiquitous yellow ACK E-01 that uses standard drug-store-variety Duracell MN-1300 D-cell alkaline batteries, the manufacturer's guidance appears at http://www.ackavionics.com/pdf/E-01%20M%2009.04.20071.pdf and staties in pertinent part:

"The battery replacement date is found on each Duracell MN1300 cell. It reads as follows: 'Best if installed by (date)'. The (date) indicated is the date by which the batteries must be replaced. All cells must have the same date."

Other than the ACK E-01, every ELT I've ever seen use special battery packs that are clearly placarded with a replacement date. I personally have never encountered a situation where the replacement date needs to be calculated on the basis of the 50% rule of 91.207(c)(2). My theory is that the FAA lawyer who wrote that regulation inadvertently omitted the word "OR" from the sentence, and that it should actually read:

"(2) When 50 percent of their useful life (or, for rechargeable batteries, 50 percent of their useful life of charge) has expired, OR as established by the transmitter manufacturer under its approval."

But what do I know?

You knew where the reference was. Thanks for that. The reference is the ICAs for the ELT. and must be followed

Tom Downey
11-27-2011, 10:09 AM
Yet another reason I'm glad I'm building a single seat aircraft - no ELT required!

So what's the "rule of thumb" consensus?

Assuming that the batteries aren't terribly expensive, is "every two years whether they need it or not" okay, assuming the darned thing hasn't gone off?

The installation instructions for your ELT are the Instructions for continued airworthiness, the FAA has deferred to the manufacturer for what's legally airworthy.

FlyingRon
11-27-2011, 10:12 AM
The information on your D cell ELT is contained in the documentation that came with it that you should have before attempting to do any servicing of it.
According to the AK-450 docs the DURACELL (only legal battery) expiration date is the expiration date. They give you a place on the case where you are to write the new expiration date when you change it.

I had a bit of an argument with my mechanic over this one who said it was only half the interval between now and the battery date. I pointed out that that interpretation was first a GROSS misapplication of the ELT battery rules and second TRUMPED by the manufacturers specific approved instructions for continued airworthiness.

flyingriki
11-27-2011, 10:33 AM
Thank you Mike, best information yet and answers all my questions! That "or" makes a poorly written sentence actually make sense.....! Will go by the mfg. and, thanks to you, I have a copy of the missing manual.
Between that and Dick's video on inspection and log entry I think I'm all set.
Thanks again.

Mike Busch
11-28-2011, 02:18 AM
You knew where the reference was. Thanks for that. The reference is the ICAs for the ELT. and must be followed
At risk of serious thread creep -- and I know I'm going to hate myself in the morning for pointing this out -- it is NOT true that ICAs must be followed, at least for a Part 91 operator. Manufacturer-specified maintenance intervals (including inspection, overhaul and replacement intervals) never need to be complied with by a Part 91 operator UNLESS:

-- Compliance is mandated by Airworthiness Directive

-- The interval appears in a clearly identified "Airworthiness Limitations" section of the manufacturer's maintenance manual or instructions for continued airworthiness

The ACK E-01 ICA do not contain an Airworthiness Limitations section. Therefore, compliance with the battery replacement intervals specified therein is not required by regulation. Those intervals are "acceptable to the Administrator" but they are not required.

Of course, if you don't comply with the manufacturer-specified interval, then you need to comply with some other acceptable guidance to comply with 91.207. The only other acceptable guidance available would appear to be the "50% rule" of 91.207(c)(2). Since that rule is (a) ambiguous and inscrutible, and (b) less generous than what the manufacturer specifies, nobody in his right mind would do anything OTHER than comply with the manufacturer's guidance.

But you don't HAVE to comply with it. It's not an Airworthiness Limitation and it's not mandated by AD. ;)

flyingriki
11-28-2011, 05:18 PM
Thanks again Mike. Seems a lot like the tax code, gotta have real pros to interpret!
And I was asked what was so hard to understand....
Had me feeling kinda dumb - briefly.

Tom Downey
11-28-2011, 09:31 PM
At risk of serious thread creep -- and I know I'm going to hate myself in the morning for pointing this out -- it is NOT true that ICAs must be followed, at least for a Part 91 operator. Manufacturer-specified maintenance intervals (including inspection, overhaul and replacement intervals) never need to be complied with by a Part 91 operator UNLESS:

-- Compliance is mandated by Airworthiness Directive

-- The interval appears in a clearly identified "Airworthiness Limitations" section of the manufacturer's maintenance manual or instructions for continued airworthiness

The ACK E-01 ICA do not contain an Airworthiness Limitations section. Therefore, compliance with the battery replacement intervals specified therein is not required by regulation. Those intervals are "acceptable to the Administrator" but they are not required.

Of course, if you don't comply with the manufacturer-specified interval, then you need to comply with some other acceptable guidance to comply with 91.207. The only other acceptable guidance available would appear to be the "50% rule" of 91.207(c)(2). Since that rule is (a) ambiguous and inscrutible, and (b) less generous than what the manufacturer specifies, nobody in his right mind would do anything OTHER than comply with the manufacturer's guidance.

But you don't HAVE to comply with it. It's not an Airworthiness Limitation and it's not mandated by AD. ;)

If we believe the installation instructions are not mandatory ICAs, and we are not required to comply with them, why would we believe the date code requirement in the same instruction is required?

I can't imagine any A&P-IA, Owner, or operator defending them selves in a NTSB hearing, or civil court by telling the Judge we are not required to comply with the maintenance instructions written by the manufacturer, when the FAA requires the manufacturer to write them prior to certifications of all components that are not on the type certificate.

Tom Downey
11-28-2011, 09:43 PM
Thanks again Mike. Seems a lot like the tax code, gotta have real pros to interpret!

If you want the real Pros they are in OKC. you can pose question directly on the FAA home page.

And I was asked what was so hard to understand....

Were you not the one that stated he could not read government legalese ?

Had me feeling kinda dumb - briefly.

we all feel that way from time to time, but we will help when asked.

Frank Giger
11-28-2011, 11:43 PM
Tom, you missed the best part of Mike's statement:


Of course, if you don't comply with the manufacturer-specified interval, then you need to comply with some other acceptable guidance to comply with 91.207. The only other acceptable guidance available would appear to be the "50% rule" of 91.207(c)(2). Since that rule is (a) ambiguous and inscrutible, and (b) less generous than what the manufacturer specifies, nobody in his right mind would do anything OTHER than comply with the manufacturer's guidance.

I can very well see someone defending themselves in an NTSB hearing or civil court using the FAA's language, and I'm sure it's been done.

Legal and Prudent are mutually exclusive concepts, after all.

Tom Downey
11-29-2011, 12:56 AM
Tom, you missed the best part of Mike's statement:

NO simply re-enforcing the point

I can very well see someone defending themselves in an NTSB hearing or civil court using the FAA's language, and I'm sure it's been done.

Legal and Prudent are mutually exclusive concepts, after all.

Agreed, what is safe isn't always legal, and what is legal isn't always safe, but ELT batteries ? Well its a moot point IMHO anyway, the old ACK yellow box can't be used IAW the FCC, but it does meet the 91.207 rule as written, So it's legal but safe?

Mike Busch
11-29-2011, 04:22 AM
If we believe the installation instructions are not mandatory ICAs, and we are not required to comply with them, why would we believe the date code requirement in the same instruction is required?I can't imagine any A&P-IA, Owner, or operator defending them selves in a NTSB hearing, or civil court by telling the Judge we are not required to comply with the maintenance instructions written by the manufacturer, when the FAA requires the manufacturer to write them prior to certifications of all components that are not on the type certificate.
Installation instructions are mandatory because they are "how-to's" rather than "when-to's." Battery replacement in not mandatory because it's a "when-to" and not a "how-to."

"How-to's" (or in regspeak "methods, techniques and practices" are the mechanic's responsibility and governed by Part 43. Specifically, 43.13 requires that we use methods, techniques and practices prescribed by the manufacturer's maintenance manual or ICA.

When-to's (or in regspeak "inspection, overhaul and replacement intervals") are the owner's responsibility and governed by Part 91 Subpart E. Compliance with manufacturer-prescribed inspection, overhaul and replacement intervals is required ONLY under two conditions: if mandated by AD, or if set forth in a clearly identified Airworthiness Limitations section of the manufacturer's maintenance manual or ICA.

Everyone knows that engine and prop TBOs are not compulsory for a Part 91 operator. The exact same thing applies to ALL manufacturer-prescribed inspection, overhaul and replacement intervals (even ELT batteries) for exactly the same reason.

This would be an absolute and effective defense in an NTSB hearing where the issue is whether or not a certificate holder complied with or violated the FARs.

Civil court is a whole different kettle of fish, because the standard for civil negligence is not regulatory compliance but rather the elusive and ill-defined "reasonable and prudent" standard that is pretty much in the eye of the beholder (juror). You can be in total compliance with all applicable regulations and still be found negligent in civil court. Jurors are totally unpredictable. That's why we have CGL insurance.

rosiejerryrosie
11-29-2011, 09:37 AM
I can't believe that a question about changing batteries has gone to five pages! Hope no body asks about changing oil!! or light bulbs!!:D

Tom Downey
11-29-2011, 10:55 AM
Installation instructions are mandatory because they are "how-to's" rather than "when-to's." Battery replacement in not mandatory because it's a "when-to" and not a "how-to."

"How-to's" (or in regspeak "methods, techniques and practices" are the mechanic's responsibility and governed by Part 43. Specifically, 43.13 requires that we use methods, techniques and practices prescribed by the manufacturer's maintenance manual or ICA.

When-to's (or in regspeak "inspection, overhaul and replacement intervals") are the owner's responsibility and governed by Part 91 Subpart E. Compliance with manufacturer-prescribed inspection, overhaul and replacement intervals is required ONLY under two conditions: if mandated by AD, or if set forth in a clearly identified Airworthiness Limitations section of the manufacturer's maintenance manual or ICA.

Everyone knows that engine and prop TBOs are not compulsory for a Part 91 operator. The exact same thing applies to ALL manufacturer-prescribed inspection, overhaul and replacement intervals (even ELT batteries) for exactly the same reason.

This would be an absolute and effective defense in an NTSB hearing where the issue is whether or not a certificate holder complied with or violated the FARs.

Civil court is a whole different kettle of fish, because the standard for civil negligence is not regulatory compliance but rather the elusive and ill-defined "reasonable and prudent" standard that is pretty much in the eye of the beholder (juror). You can be in total compliance with all applicable regulations and still be found negligent in civil court. Jurors are totally unpredictable. That's why we have CGL insurance.

Mike brings up a very valid point, that this whole issues revolves around FAR 43.13/15/16 And if the inspector believes the maintenance instructions provided are mandatory or not. If we believe they are not, that would make the battery replacement date a non binding issue and we would never be required to replace it. Because 91.207 D 1-4 has no requirements for voltage or life date.

seeing as the FAA placed this statement in the approval letter for production of the Amer-King 451 (see the first para o the second page) http://www.ameri-king.com/pdf/FAA TSO C91a, C126, FCC, AND COSPAS-SARSAT TYPE APPROVAL CERTIFICATE APPROVED DOCUMENTS FOR MODEL.PDF we would have a very difficult time convincing any NTSB judge that the manufacturers instructions are not required maintenance.

My contention is simply this, to uphold our obligation to FAR 43.16 we must use the practices acceptable to the administrator and the manufacturers instructions are all we have. so in giving the instructions say the battery has a life limit dated on it, or a voltage limit, that is as close as we can get to a time life item, in as much as we are required to record and track the time or voltage.

As Mike pointed out, we use manufacturers instruction manuals to maintain every thing else why would we deviate here.

Tom Downey
11-29-2011, 10:58 AM
I can't believe that a question about changing batteries has gone to five pages! Hope no body asks about changing oil!! or light bulbs!!:D

Isn't that what these forums are for? the discussion and education of the members.

Bill Berson
11-29-2011, 12:09 PM
Mikes excellent article (Sport Aviation Dec 2011) says: " you may ignore ICA (instructions for continued airworthiness) with regard to time intervals but not if the ICA contains a clearly identified FAA-approved ALS (airworthiness limitations section). (or mandated through an FAA airworthiness directive.

I scanned through this ELT ICA and could not find any ALS:http://www.ameri-king.com/pdf/03c%20ICA-451%20Rev%20NC-1%20Operations%20and%20ICA.pdf

I would follow the manufacturer time recommendations in this case, even if no ALS.
This is an interesting learning experience, perhaps the first or only case where a typical Cessna owner will encounter these issues of ICA and ALS, since most personal airplanes do not have time life parts (Cirrus is one that does have an ALS). Helicopters certainly have life-limited parts usually listed in the overhaul manual and TCDS (type certificate data sheets).
We need to consider the possible ICA for any part or addition to the airplane, as this example shows.
Bill

Frank Giger
11-30-2011, 03:17 AM
That December article brought a long discussion at the airport in regards to engine TBO's.

It was pretty spirited until the A&P showed up.

He's a good'un and agreed that overhauls aren't tied to numbers of hours so much as the state of the engine. Just because an engine has less than X hours doesn't mean it doesn't need to be torn down; the same is true for those past X hours.

He related a story of a guy who was incredulous that he needed an overhaul because the Hobbs said it wasn't time for it!

Since we all agreed that at the TBO milestone the engine should be inspected, we all parted with handshakes.

The thread creep is appropriate, IMHO, as it speaks to the larger issue of scheduled maintenance. We all want our planes to be safe and functional; we also would like them to meet the letter of the rules whenever possible.

rosiejerryrosie
11-30-2011, 11:08 AM
Isn't that what these forums are for? the discussion and education of the members.
Meant as a joke, Tom, just a bit of laughter for an otherwise dreary day.:cool:

Bill Greenwood
11-30-2011, 12:11 PM
Just to add another element to the discussion on TBO, there was a famous research scientist or engineer in England over the war that found in bombers, that the planes that were inspected more often were LESS reliable and less ready for duty. Thus, LESS NOT MORE, maintenance was better; sort of it it is running good it is better to let well enough alone.
I don't have his name now, nor more details. but I'd guess that one aspect of this was that if an engine was likely to have trouble it may do it early in its life, and once past a certain hours it is more likely to last longer if not disturbed.
This is not just theory, at least in the case I am reffuring to, the research was accepted by the RAF.

Tom Downey
11-30-2011, 01:15 PM
Just to add another element to the discussion on TBO, there was a famous research scientist or engineer in England over the war that found in bombers, that the planes that were inspected more often were LESS reliable and less ready for duty. Thus, LESS NOT MORE, maintenance was better; sort of it it is running good it is better to let well enough alone.
I don't have his name now, nor more details. but I'd guess that one aspect of this was that if an engine was likely to have trouble it may do it early in its life, and once past a certain hours it is more likely to last longer if not disturbed.
This is not just theory, at least in the case I am reffuring to, the research was accepted by the RAF.

There is an old rule. " If it ain't broke, don't fix it until it is."

Mike Busch
12-01-2011, 01:45 AM
Just to add another element to the discussion on TBO, there was a famous research scientist or engineer in England over the war that found in bombers, that the planes that were inspected more often were LESS reliable and less ready for duty. Thus, LESS NOT MORE, maintenance was better; sort of it it is running good it is better to let well enough alone.
I don't have his name now, nor more details. but I'd guess that one aspect of this was that if an engine was likely to have trouble it may do it early in its life, and once past a certain hours it is more likely to last longer if not disturbed.
This is not just theory, at least in the case I am reffuring to, the research was accepted by the RAF.
The scientist was named Conrad Hal (C. H.) Waddington, and the reason you know about him is that I wrote a column on the subject (titled "The Waddington Effect") in EAA Sport Aviation last year. Waddington's work was virtually unknown because it was classified until after his death in 1975. At that time, his diary was published in England, but it never sold many copies and has been out of print for a long, long time. There are still a handful of copies in stores that specialize in rare old books.

What Waddington discovered in 1941 was independently rediscovered in the late 1960s by aeronautical engineer Stanley Nowlan and statistician Howard Heap at United Airlines. Their work was the foundation of what has become "Reliability-Centered Maintenance." Nowlan and Heap almost certainly were unaware of Waddington's work, because it remained classified until 1975.

jack hogan
06-15-2012, 03:09 PM
OK. The battery part I get. Does my "Repairman Certificate" allow me to sign off the functional check? I assumed it did, but .... I've been wrong before.
Follow on discussion item. My ELT is 10yrs old (121.5/243.0) type. Any one have thoughts about replacing it w/the 406? If so which brand name?