They also consider Service Bulletins and Emergency Service Bulletins mandatory, and IAs don't require them for Part 91 operators.
There may be confusion at the outset, and some IAs may require them, but the inspection requirements are determined by the FAA and here the issue is clear: Part 91 and even some Part 135 operations won't be subject to them. Nor will they automatically become ADs.
I covered this in a message on the
AV Web SIDS Article 12-24-09 thread. For those of you who haven't read it, here is an excerpt with the requisite link to the FAA's Final Rule:
I have been reading various comments on this Board about the possibility of an IA requiring the SIDs, either out of an abundance of caution or if Cessna issues a revised Service Manual with SIDs. While I can’t rule out a poorly informed IA taken such a stance, I think the record is clear that Part 91 operators will not have to do the SIDs.
My basis is the FAA’s Final Rule and Notices (“FRN”) on the matter, which is essentially the mandate for the SIDs. Later I will provide you a link so you may peruse the document, but here’s a summary.
The genesys of SIDs was the 1988 in-flight failure of a high-time Aloha Airlines Boeing 737, where a section of the upper fuselage ripped away because of fatigue. Congress pushed the FAA into evaluating steps that should be taken to prevent such future failures in high-time (or “aging”) aircraft. Initially only transport aircraft were considered but that was later expanded to cover smaller aircraft.
Both the heading and the first paragraph of the FRN make it clear that only Part 121, Part 129 and Part 135 operations are covered. Moreover, on Page 5 (3rd full paragraph of the 3rd column) Part 135 cargo-only and on-demand operations are excluded.
Concerns that SIDs may become ADs also appear unfounded. On Page 2 (1st full paragraph of the 3rd column) the FAA explicitly states that ADs will be issued only to address “unsafe conditions that have already been identified.” And the Cessna 400-series SIDs supports this, because only one of the SIDs became an AD after cracks were found and a fatal in-flight failure occurred.
Given that SIDs were mandated by the FAA and the FRN’s clear intention to exclude Part 91 and some Part 135 operations, I do not believe Cessna can take actions that would essentially contravene the FAA.
All of this is small consolation to many non-commercial foreign operators who will be subject to the SIDs.
The FRN may be found at http://edocket.access.gpo.gov/2002/pdf/02-30111.pdf.
Ernie