Avise needed

Hi, seeking for clarification concerning Part 91 operation I found this forum and the very interesting threads discussed here.
Crucial issue that brought me here is: I am exercising my privileges of IA for the first time. An owner operating his N registered Baron 58 asked me to perform an annual inspection. The FAA issued a clarification notice stating that this type of operators are not required to comply with overhaul times of controlled items. But in this case engines and propeller have largely exceeded their calendar life (about twenty years) even wing bolts have never passed NDT having been installed for 15 years. Cheched log book and found that many annual inspections were signed off all these years. My concern is: Would it be wise perform all the items listed, just give the owner a list of discrepancias and sign off the inspection? Thanks in avance for you time

Ariel Romero

Uruguay

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Originally Posted by Ariel Romero

Hi, seeking for clarification concerning Part 91 operation I found this forum and the very interesting threads discussed here.
Crucial issue that brought me here is: I am exercising my privileges of IA for the first time. An owner operating his N registered Baron 58 asked me to perform an annual inspection. The FAA issued a clarification notice stating that this type of operators are not required to comply with overhaul times of controlled items. But in this case engines and propeller have largely exceeded their calendar life (about twenty years) even wing bolts have never passed NDT having been installed for 15 years. Cheched log book and found that many annual inspections were signed off all these years. My concern is: Would it be wise perform all the items listed, just give the owner a list of discrepancias and sign off the inspection? Thanks in avance for you time

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Better source of information might be some of the A&Ps and IAs on this forum. But let me take a crack at it. Me getting it wrong is likely to generate some illuminating discussion. :-)

The way I see it, your job as an IA during the annual inspection is to verify that the aircraft and all its components are in compliance with the original Type Certificate (TC). Part of that original type certificate is the modifications directed by the FAA, in the form of Airworthiness Directives.

As an IA, you examine the aircraft to establish that it is still in compliance with the TC. You are also responsible for verifying that all ADs have been complied with, or have been determined to be not applicable.

So if your research on the Baron shows that a particular AD applies to the aircraft in question, you must verify that it has been performed. Ideally, there will be a log entry by an A&P, noting that the work required by AD #-XXXXXX was performed as of such-and-such date. On the next Annual, the AI should have noted the AD, and determined if the entry by the A&P is adequate.

So... if your research shows a log entry that AD #XXXXX was executed, and an IA signed off on the next annual, you are off the hook.

An IA signoff, WITHOUT documentation of the AD compliance, is worthless from your point of view. You do not KNOW if the AD was complied with. So if you cannot find anything in the logbook about the AD being performed, you are on the hook for it. You will need to perform the AD, and document it in the logs, before you sign off the Annual.

Several years ago, I had an A&P doing the yearly conditional inspection of my Experimental Amateur-Built Fly Baby. It has a Continental engine with Eisemann magnetos. The A&P found an Airworthiness Directive on my magnetos from 1969.

Now, the plane had been flying since 1980. ~20 times since, an A&P had signed off the condition inspection as being successfully completed. But this A&P refused to do so until AD compliance had been logged.

Now, there's plenty of discussion was to whether AD compliance is required in an E-A/B airplane like mine. But the point is, my A&P refused to sign off on the airplane due to the completion of the AD not being logged. DESPITE dozens of successful condition inspections since.

So I think your situation would be similar.

However, the issue is murkier when it comes down the Service Bulletins and life-limited parts. If I understand the rules correctly, compliance with these is not mandatory, FOR PART 91 OPERATIONS. If the aircraft is being operated as a private aircraft, service bulletins and life limitations are advisory, not required. Private owners routinely exceed the TBOs of their engines, for instance.

Your problem, of course, is that you don't necessarily know the use the airplane is going to be put to. The owner may swear it's just his personal flying carpet...but that doesn't stop him from selling the plane to a commercial operator with a "current annual."

This is where some input from the A&Ps on the forum would be useful. But for me, if I were doing the annual, I'd list the service bulletins and part-life limitation issues in the log, sign off the annual, and note in the entry that the aircraft is legal for Part 91 operations only.

How about it, brainy guys? Did I get it right?

Ron Wanttaja

I suggest you ask this question on the BeechTalk Forum. https://www.beechtalk.com/forums/

Ariel,

The annual must be performed per FAR 43 Appendix D, comply with ADs, and the FAA approved sections of the manufacturer's current maintenance manual.

CAR 3 airplanes do not have FAA approved sections of the maintenance manual. SBs, even mandatory SBs, and TBOs aren't required under part 91. You should have a discussion with the owner (maybe even write it down but not in the log books) about SBs and TBOs. If the airplane, engines, and propellers comply with the type design and are found by you to be in safe condition for operation, then sign off the annual.

Thanks folks for your immediate answers they are very clear. I knew compliance with o/h times is not required for this operation. My main concern is engines calendar time (they have not reached 2000 hours in service but they've have been installed for 20 years). Concerning wing bolts, AMM does not say "overhaul", but "replace" after 15 years. Thanks again

The calendar time does not matter either. The wing bolts are not required to be replaced either. Some people follow the advice to replace them. Some people want to leave them alone. The American Bonanza society can give you more information on Baron/Bonanza wing bolts.

Note that while the engines may not be a problem, check the ADs on the props. Some of these have ADs that move the overhaul times from recommendations to requirements.