ELT Testing and Annual Sign Off

[Glas467]

I just watched Dick Kohler's latest "Hints for Homebuilder's" about ELT installation and testing.

Does the FAR required annual testing require an A&P or FAA certified avionics shop/technician to sign off the test for a homebuilt aircraft, or can the owner (not necessarily the builder) do the test per the FAR and sign it off themselves?

Thank you and happy flying!

[WLIU]

Normally the individual doing the annual condition inspection does the test and records that work as part of the aircraft's logbook entry for the overall inspection. That is, maintenance require by FAR is documented by an FAA maintenance certificated individual.

Best of luck,

Wes

[rwanttaja]

14CFR 91.207 covers the yearly inspection of the ELT:

(d) Each emergency locator transmitter required by paragraph (a) of this section must be inspected within 12 calendar months after the last inspection for -
(1) Proper installation;
(2) Battery corrosion;
(3) Operation of the controls and crash sensor; and
(4) The presence of a sufficient signal radiated from its antenna.

Note that this is not tied to the "Annual Inspection," it just says the unit must have been tested in the past 12 months. Nor does Part 91 specify the required qualifications of the person performing the test.

My interpretation is that anyone may perform the test. It's *convenient* to do it in conjunction with the annual or condition inspection, but no qualifications to perform the test are listed.

This goes double for homebuilts, which are merely inspected to verify the plane is in a condition for safe flight.

Ron Wanttaja

[Marc Zeitlin]

I just watched Dick Kohler's latest "Hints for Homebuilder's" about ELT installation and testing.

Does the FAR required annual testing require an A&P or FAA certified avionics shop/technician to sign off the test for a homebuilt aircraft, or can the owner (not necessarily the builder) do the test per the FAR and sign it off themselves?Assuming that you're ONLY talking about EAB aircraft, then the ONLY thing that an A&P is required for is to sign off the annual Condition Inspection. Since a 91.207 ELT check is NOT a required part of the Condition Inspection (it can be done at any time, as long as the intervals between are "within the past 12 months") and there is no requirement for the ELT check to be synchronized with the CI, my interpretation, as an A&P who does about 25 - 30 CI's each year on EAB aircraft, is that anyone is legally allowed to perform and log the ELT 91.207(d) testing for an EAB aircraft.

Now, as Wes states, I normally do the ELT test when I do the CI, and sign it off in the CI signoff, but that's not REQUIRED, it's just what I do for most of my customers - they COULD do the ELT check themselves, if they wanted to, and if I see a signoff in the logs that's less than 12 months old, I don't bother checking the ELT.

[Mike M]

...Does the FAR required annual testing require an A&P or FAA certified avionics shop/technician to sign off the test for a homebuilt aircraft, or can the owner (not necessarily the builder) do the test per the FAR and sign it off themselves?

It depends. For USA and FAA start with AC91-44A. Follow the directions, go to the manufacturer for the test method. To the best of my knowledge the FAA doesn't require a certification to conduct and document the test.

Examples:
https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91-44A_CHG-1.pdf
"8.2.6 Owners of ELTs should carefully follow owner manual instructions and when possiblelimit testing to the “Self-Test” function."
"9.4.4 121.5 MHz Testing. Testing the functionality of a 121.5 MHz transmitter should beaccomplished per manufacturer’s instructions."

[martymayes]

Some interesting history on ELT's:

ELT requirements did not originate with the FAA. That device became a part of airplane equipment with signing of the 1970 Occupational Safety and Health Act. Some people are not aware of that, as the FAA is often blamed for ELT stuff when credit should go to the 91st congress.

Since the FAA was required to comply with the congressional act, they sat down in the lunchroom at lunch and in four short years wrote out some regs between bites of tuna fish sandwich which were inserted into Title 14 by 1974. They were not very specific as to who is authorized to do what and remain that way to this day (perhaps that would have taken too long). This is one of those things where you go with the flow and don't ask a lot of questions for clarification. A few things have been clarified over the years, the more recent being in 1994 amendment of 91.207(d) that requires a separate ELT inspection sign off to show compliance with the regs. No more lumping it into the annual inspection sign off as "Inspected ELT." As a matter of convenience, we usually do the ELT inspection in conjunction with the annual inspection or CI but it's not required; a separate sign off is required. Also there is new guidance about mounting or securing the ELT with hook and loop fasteners, aka "velcro" that's officially a no-no.

At the last IA training I attended there was some discussion on ELT's and the presenter indicated a 406 ELT does not transmit a data block until 50 seconds of continuous operation. I thought that was interesting so if you inadvertently hit the remote switch on the panel, hurry up and turn it off and you won't be surrounded by CAP when you land.

Maybe because I'm easily amused, I have an excerpt of the OS&H act (maybe I wrote it while in high school because I had a teacher that would assign writing congressional acts as punishment). Doesn't take a lot of imagination to see who was lobbying for what when this came to pass:

EMERGENCY LOCATOR BEACONS
SEC. 31. Section 601 of the Federal Aviation Act of 1958 is amended by inserting at the end thereof a new subsection as follows:

EMERGENCY LOCATOR BEACONS
"(d)(1 ) Except with respect to aircraft described in paragraph (2)
of this subsection, minimum standards pursuant to this section shall
include a requirement that emergency locator beacons shall be
installed—
"(A) on any fixed-wing, powdered aircraft for use in air commerce
the manufacture of which is completed, or which is
imported into the United States, after one year following the
date of enactment of this subsection; and
"(B) on any fixed-wing, powered aircraft used in air commerce
after three years following such date.
"(2) The provisions of this subsection shall not apply to jetpowered
aircraft; aircraft used in air transportation (other than air
taxis and charter aircraft) ; military aircraft; aircraft used solely for
training purposes not involving flights more than twenty miles from
its base; and aircraft used for the aerial application of chemicals."

[Bill Berson]

There should be an app to make your cellphone into an ELT.

[Dana]

Who can perform the rest of it's mode C?

[Mike M]

Who can perform the rest of it's mode C?

ELTs are Mode C?

[Marc Zeitlin]

Who can perform the rest of it's mode C?ELT, not transponder check.

[Dana]

Oops, never mind. Brain fart there...

[Frank Giger]

We all have them from time to time.