R22 MR Temp Light Inoperative - LEGAL to fly?

[Jay Bunning]

Hi and thank you all for any feedback.

 

I know the practical answer to this - "I wouldn't fly with a MR Temp light inoperative", but what is the position regarding regulations?

 

Firstly I would check the day VFR required equipment (91.205) - and the MR Temp Light is not on that list. So now I go to inoperative equipment 91.213(d) and this is where it gets a bit less clear to me. It seems to say that as long as the instrument/equipment is not required for day VFR (91.205), not "Indicated as required on the aircraft's equipment list" (the R22 POH?) and the aircraft doesn't have a MEL then it is OK to fly without the equipment being operational - as long as the pilot removes/placards (remove the bulb?) and doesn't consider it a hazard to safe flight (which is subjective).

 

I would conclude that legally, if it was a short flight maybe to a repair facility, you could legally fly with the MR Temp Light pulled (that is my version of removed/placarded). What do you guys think - legally?

 

I want to know because I want to make sure I tell my students the correct thing. And this issue doesn't just apply to the MR Temp light, what about other equipment/instruments not on the day VFR or POH lists of required equipment? (Heater, Carbon Monoxide light, VSI, etc).

 

Like I said the practical advice for this example would be "call the mechanics/don't fly etc" but I would appreciate some clarification on the legal issue.

 

Many thanks

 

Jay

[eagle5]

There may be something about this in FAR Part 27?,...or you can just wait to see if iChris chimes in!

[kodoz]

It isn't in the limitations as required equipment, and the MMEL doesn't specifically address warning lights. The POH also states that you may disable a warning light at night (EPs, section 3-8). Barring a requirement in Part 27, seems like the proper procedure is to disable and placard.

[amphibpilot]

The following was posted by RHC's Pat Cox (ts1@robinsonheli.com) over on the pprune.org website in response to a similar query:

 

"The subject MR TEMP warning indication system must be operative.

 

Refer to 14 CFR § 91.213 Inoperative instruments and equipment.

...(d) Except for operations conducted in accordance with paragraph (a) or © of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided—

...(2) The inoperative instruments and equipment are not—

(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;

....

 

14 CFR 27 is the Certification Basis of the R22 (ref page 6 of Type Certification Data Sheet No. H10WE), and includes:

§ 27.1305 Powerplant instruments.

The following are the required powerplant instruments:

...(f) An oil temperature warning device to indicate when the temperature exceeds a safe value in each main rotor drive gearbox (including any gearboxes essential to rotor phasing) having an oil system independent of the engine oil system.

 

Also refer to Advisory Circular 91-67, Minimum Equipment Requirements For General Aviation Operations Under FAR Part 91 > Chapter 2. Conducting Operations Without An MEL."

Edited March 22, 2013 by amphibpilot

[Counterrotate]

The MR TEMP warning system is required by 14 CFR 27.1305 (f).

 

Damn, beat me to it.

[eagle5]

(f) An oil temperature warning device to indicate when the temperature exceeds a safe value in each main rotor drive gearbox (including any gearboxes essential to rotor phasing) having an oil system independent of the engine oil system.

 

There's some other sh*t there too!,...ain't the internet just grand!

[rick1128]

It isn't in the limitations as required equipment, and the MMEL doesn't specifically address warning lights. The POH also states that you may disable a warning light at night (EPs, section 3-8). Barring a requirement in Part 27, seems like the proper procedure is to disable and placard.

 

Generally if a component or item is not listed in the MMEL it is required.

[Goldy]

Generally if a component or item is not listed in the MMEL it is required.

 

Exactly, with little exception, especially with Robbies that don't have an MEL, if it was on the aircraft and working when it was certified, it better be on and working or your AC is not airworthy.

[Astro]

The last R-22 I flew had a few things I would guess I could be airworthy without?

 

GPS

Heading Indicator

Turn Coordinator

Attitude Indicator

VOR

Marker Beacons

Clock

Transponder (I'm guessing that if I'm in airspace that doesn't require it, it doesn't have to work?)

Heater

Map Light

Radio (again, if its not required, does it have to be working?)

[Goldy]

The last R-22 I flew had a few things I would guess I could be airworthy without?

 

GPS

Heading Indicator

Turn Coordinator

Attitude Indicator

VOR

Marker Beacons

Clock

Transponder (I'm guessing that if I'm in airspace that doesn't require it, it doesn't have to work?)

Heater

Map Light

Radio (again, if its not required, does it have to be working?)

 

Those are what we refer to as "options". If you have all of them in an R22 then you're probably a bit nose heavy!

[rjl2001]

I'm not sure I'm fully understanding the significance of Part 27, as I'm in my CFI training and this is the first I've seen of it. Right now after typing a lengthy question, I'm hoping I just realized what I was overlooking. Does 14 CFR Part 27.1305 fall under this reference in 91.213(d):

"(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated" ?

 

Up to this point I've always used the flow chart of:

Is the equipment/instrument required under 91.205?

Is the equipment/instrument required by the aircraft's equipment list?

Is the equipment/instrument required by an Airworthiness Directive?

Is the equipment/instrument necessary for safe flight as determined by the pilot?

 

If I had asked those questions of an inoperative MR Temp light, I would have answered no to all four checks, and then thought the aircraft was still airworthy as long as the light was secured, placarded inoperative, and appropriately documented. Am I totally missing something or was my hunch correct about the reference in 91.213(d)?

 

Also, does the MMEL have any significance or impact on an aircraft operating without an MEL under Part 91? Or does the MMEL only become an operating factor when electing to operate with an MEL?

 

I've been looking over AC 91-67 and the R-22/R-44 MMEL but that still left me with questions. For whatever reasons I've never had a good understanding of an MMEL, MEL, LOA, and STC's.

[pilot#476398]

Does 14 CFR Part 27.1305 fall under this reference in 91.213(d):

"(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated" ?

 

Yes, because Robbies were certified under part 27, its mentioned in the POH.

 

Up to this point I've always used the flow chart of:

Is the equipment/instrument required under 91.205?

Is the equipment/instrument required by the aircraft's equipment list?

Is the equipment/instrument required by an Airworthiness Directive?

Is the equipment/instrument necessary for safe flight as determined by the pilot?

 

If I had asked those questions of an inoperative MR Temp light, I would have answered no to all four checks

 

Without the MR Temp light how would you know if the MR transmission is getting too hot? I would say yes to check #4!

Edited March 22, 2013 by pilot#476398

[amphibpilot]

(moved to earlier post)

Edited March 22, 2013 by amphibpilot