Cessna C337 SID

[skymstr02]

As an A&P IA, today's part 91 Skymaster could be tomorrows part 135 car parts hauler, and the same annual inspection is still valid in both cases.

[Ernie Martin]

No need to. The Part 135 cargo/on-demand is just an example. The Final Rule applies only to Part 121, multi-engine Part 129 and multi-engine Part 135 (with the Part 135 exclusion mentioned earlier). It does not apply to Part 91. Period.

Ernie Martin

[skymstr02]

What I'm saying is that I could perform an annual inspection on a Skymaster today, the owner sells it tomorrow, with a fresh annual, and the new owner puts the aircraft on a 135 certificate the next day.
The annual that I performed is still in effect, and not due for another 12 months.

[tropical]

Originally Posted by skymstr02

What I'm saying is that I could perform an annual inspection on a Skymaster today, the owner sells it tomorrow, with a fresh annual, and the new owner puts the aircraft on a 135 certificate the next day.
The annual that I performed is still in effect, and not due for another 12 months.

True. But in order to put the Skymaster on a Pt 135 Certificate requires a "Conformity Inspection" by the FAA. In order to comply with a conformity inspection all SB's must be complied with.

[tropical]

Originally Posted by Ernie Martin

All good points, but take a look at the specific elements I cite from the FAA's Final Rule (page, column and paragraph is listed for each citation). It's hard to believe that SIDs will be required when the FAA explicitly states that they "will not apply to" certain operations, such as Part 135 cargo-only and on-demand.

Ernie Martin

The real question here is will Cessna incorporate these inspections into the maintenance manual? If so any IA doing an annual inspection will have to think long and hard about ignoring them.

[skymstr02]

Originally Posted by tropical

True. But in order to put the Skymaster on a Pt 135 Certificate requires a "Conformity Inspection" by the FAA. In order to comply with a conformity inspection all SB's must be complied with.

But the SID is not a service bulletin.

[tropical]

Originally Posted by skymstr02

But the SID is not a service bulletin.

Not at this point. But the FAA PMI could require that SID's also be complied with for a Part 135 certificate. Right now all of this is in unknown territory.

[Skymaster337B]

Just a point of order. There was a question asked "Are inspections for continued airworthiness the same as SIDS?" The answer is not just no, but what is an "inspection for continued airworthiness?" The answer is: inspection for continued airworthiness is either listed on the aircraft's type certificate or in the maintenance manual (and is referred to by the aircraft's type certificate). For example, a new Cirrus maintenance manual may have a section called "instruction for continued airworthiness." And in that section it might say every 5,000 hours to replace the windshield. In this case, it is mandatory!!!!!

That's why I said the only required maintenance required, other than ADs or FARs, is the maintenance manual on the day the aircraft was produced...at least for part 91. So, if Cessna makes a new maintenance manual for the Skymaster with a section for continued airworthiness then you are not obligated to follow it...at least under part 91.

On a side note, if you have a Supplemental Type Certificate, such as paper oil filters then there may also be an Inspection for Continued Airworthiness listed in the STC instructions. In that case the Inspection (or instruction) for Continued Airworthiness is mandatory since the STC modified the original aircraft's type certificate.

[tropical]

Originally Posted by Skymaster337B

That's why I said the only required maintenance required, other than ADs or FARs, is the maintenance manual on the day the aircraft was produced...at least for part 91. So, if Cessna makes a new maintenance manual for the Skymaster with a section for continued airworthiness then you are not obligated to follow it...at least under part 91.

Not necessarily true. Can you provide a reference that a mechanic only has to follow a maintenance manual that was produced when the aircraft was manufactured and that revisions are not mandatory? Also, if Cessna revises the TCDS and places these inspections in the "Limitations" section they now become mandatory irregardless of the type of operation. Notice 43.13 says "current manufacturer's maintenance manual".

43.13 Performance rules (general).

(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator, except as noted in §43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

Once again it boils down to the mechanic signing off the inspection.....if the aircraft is later involved in an accident or a certificate action and the mechanic did not follow the MM his liability has now increased dramatically.

43.16 Airworthiness limitations.

Each person performing an inspection or other maintenance specified in an Airworthiness Limitations section of a manufacturer's maintenance manual or Instructions for Continued Airworthiness shall perform the inspection or other maintenance in accordance with that section, or in accordance with operations specifications approved by the Administrator under part 121 or 135, or an inspection program approved under §91.409(e).

Also, under the FAR's the owner is responsible to insure all maintenance and inspections are done and properly documented. Do you as the owner want to risk yourself by not following a maintenance manual? Ask an attorney that question.

[Skymaster337B]

At last year's IA seminar the head FAA maintenance guy told this to the group, "that the only required maintenance manual is the one at the time of production." This is very applicable to much older airplanes certified under CAR, like the Skymaster was. The key word is "required" that doesn't stop any one from using new data however. I'm sure the reference was in an FAA or NTSB ruling, but since you asked I guess I'll have to search for it.

[Roger]

Curent means "current at the time of manufacture" as pertaining to part 91. Period .

http://www.faa.gov/about/office_org/...aintenance.pdf

[Ernie Martin]

Roger, this is precisely the reference we needed. It's required reading for all Part 91 users curious about SIDs. This won't happen, but this discussion on SID applicability to Part 91 operators could end right here.

Ernie

[WebMaster]

Originally Posted by tropical

The real question here is will Cessna incorporate these inspections into the maintenance manual? If so any IA doing an annual inspection will have to think long and hard about ignoring them.

Cessna is re-writing the service/maintenance manual to include the SIDs.

It is up to the owner/operator to convince the IA that the new manual can be ignored. Personally, I think that if you take your aircraft to any shop, as opposed to an independent contractor, they will want compliance with the new manual.

[Ernie Martin]

After you show the IA or shop the FAA document referenced by Roger? I don't think so.

Read it carefully. There is zero room for interpretation, zero ambiguity: for Part 91 the Manual at time of manufacture governs. What is even more empowering is the reasoning expressed in the document.

That's not to say a greedy or dinosauric mechanic may push for doing the SIDs, but a) that should be the exception, and b) most will come around when they read the FAA paper.

Ernie

[tropical]

Originally Posted by Ernie Martin

After you show the IA or shop the FAA document referenced by Roger? I don't think so.

Read it carefully. There is zero room for interpretation, zero ambiguity: for Part 91 the Manual at time of manufacture governs. What is even more empowering is the reasoning expressed in the document.

That's not to say a greedy or dinosauric mechanic may push for doing the SIDs, but a) that should be the exception, and b) most will come around when they read the FAA paper.

Ernie

We live in a legal world of Tort Law. Any IA would have to think long and hard before signing off an inspection that does not comply with the manufacturers instructions. The liability that will follow them is staggering. And a good attorney can argue that the manufacturer placed these extra inspection measures from a safety standpoint. Just imagine how this would look in front of a jury.

I don't think it's necessarily a "greedy or dinosauric" mechanic that would push for accomplishing the SIDs but one that is using CYA.