Cessna C337 SID

[Ernie Martin]

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

[tropical]

Originally Posted by Ernie Martin

They also consider Service Bulletins and Emergency Service Bulletins mandatory, and IAs don't require them for Part 91 operators.

Ernie

But there is FAA guidance that specifically states SB's are not mandatory for Part 91 operators.

Use of the Approved Aircraft Maintenance Manual is recommended by the FAA. Cessna will incorporate these SB's into their Maintenance Manual. Now the person holding the Inspection Authorization has to make the determination of how far to stick his neck out.

[skymstr02]

This is the primary reg that all mechanics perform to:

§ 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.

It is up to the individual as to what or how that is accomplished. Keep in mind, that should anything go awry, he will be answering to the attornies and the local FAA airworthiness inspectors on his actions for that inspection.

Are inspections for continued airworthiness the same as SIDS? That will have to be determined by a judge eventually. Whether its a NTSB or civil court at law remains to be seen. This is a question that begs for resolution.

[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

[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 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.

[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