Inoperative Instruments & Equipment

[jjsemperfi]

For Part 91 operations.... Let's say my map light is broken for a day VFR flight. I do not operate an MEL. It's not required per 27, Equip List, 205, or AD's. Can I (PIC) placecard and annotate or does an A&P have to placecard and annotate?

[Astro]

You can.

[jjsemperfi]

If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43....

[jjsemperfi]

"Maintenance: inspection, overhaul, repair, preservation, and replacement of parts but excludes preventative maintenance." So if a non A&P can perform preventative maintenance, and the deactivation of the inop equip requires maintenance, then the non A&P cannot perform the task. Unless it does not involve maintenance. So I guess my question now becomes, does deactivating an inop peice of equip require maintenance?

[Astro]

If we're talking about an r22 here it says in the POH that the map light is on a breaker with the panel gages, (don't know if that means they're on the same one or if its next to it). If separate just pull it, If not, I would imagine that simply turning the map light switch to "off" would sufficiantly deactivate it?

[Pohi]

Wouldn't that be covered in the master MEL?

 

http://fsims.faa.gov/PICResults.aspx?mode=Publication&doctype=MMEL

Edited April 30, 2014 by Pohi

[aeroscout]

Wouldn't that be covered in the master MEL?

 

http://fsims.faa.gov/PICResults.aspx?mode=Publication&doctype=MMEL

The manufacturer publishes an MMEL. In order to be used as an MEL it must be approved by the FAA.

[avbug]

"Maintenance: inspection, overhaul, repair, preservation, and replacement of parts but excludes preventative maintenance." So if a non A&P can perform preventative maintenance, and the deactivation of the inop equip requires maintenance, then the non A&P cannot perform the task. Unless it does not involve maintenance. So I guess my question now becomes, does deactivating an inop peice of equip require maintenance?

 

 

That depends on what is done to deactivate the equipment. The list of items found in Appendix A of Part 43 is not all-inclusive. If an item doesn't require complex assembly or disassembly operations, doesn't affect the airworthiness structural or aerodynamic integrity of the aircraft, and the person performing the preventative maintenance has been trained in the operation, has done it before, and has access to the current publications, tools, or standard equipment/practices prescribed by the manufacturer, the private pilot (or higher) or operator can deactivate the item.

 

Not enough information is provided, however. If a circuit breaker is opened, it's different than removing a radio from a rack; a weight and balance amendment might be required for the latter, whereas a temporary log entry or squawk signoff suffices for the former. If one does open a circuit breaker, however, one needs to know that opening that breaker only deactivates the inoperative component; one needs to be able to determine that safety isn't compromised in other ways.

[Pohi]

The manufacturer publishes an MMEL. In order to be used as an MEL it must be approved by the FAA.

So an operator uses the MMEL to develop their own MEL? Are they allowed to add more than what's on the MMEL?

Edited April 30, 2014 by Pohi

[Velocity173]

So an operator uses the MMEL to develop their own MEL? Are they allowed to add more than what's on the MMEL?

 

Yeah, just cannot be less restrictive than the master. We've got a bunch of EMS crap on ours. Signed off by the company and the FSDO.

 

We also carry stickys so the pilot can placard something inop after the appropriate MEL inop item is written up in the log book.

Edited April 30, 2014 by Velocity173

[jjsemperfi]

So pulling a circuit breaker isn't considered maintenance? On a recent check ride an examiner wouldn't let a rated pilot pull a breaker and placard. We had to get an A&P. I think it's ridiculous. Deactivation doesn't require maintenance if you're pulling a breaker or flipping a switch.

[jjsemperfi]

This question comes from an 8 hour CFI oral. One of many.

[jjsemperfi]

Just frustrating when your school is teaching to a high standard that is good for one examiner but not for another. And saying "well don't use the other guy" doesn't work for CFI rides.

[avbug]

So pulling a circuit breaker isn't considered maintenance? On a recent check ride an examiner wouldn't let a rated pilot pull a breaker and placard. We had to get an A&P. I think it's ridiculous. Deactivation doesn't require maintenance if you're pulling a breaker or flipping a switch.

 

 

That depends on the breaker, it's use and function, the manufacturer, and other factors. One cannot say "it's just a circuit breaker," and simply because the circuit breaker is labeled for a particular item does not mean that opening the breaker will deactivate the item.

 

Some items receive power from several busses or sources, and even when the circuit breaker is open, the item may be grounded and may still be a problem. In some cases, removal of the item is necessary, which also results in a need to amend the weight and balance papwerwork.

 

A circuit breaker is not designed to be used as a switch, turning an item on or off. Some circuit breakers cannot be manually opened, requiring other means of deactivation. Where a MEL or MMEL is provided, the means of deactivation will generally also be provided. You should be aware that for certificate holders (Part 135 and 121), where the terms of the MEL are spelled out, the requirements to operate under that exclusion are divided into (M) and (O) procedures (Maintenance and Operations). Actions taken to deactivate are generally M procedures, requiring maintenance personnel

 

The opening of a circuit breaker as well as the resetting of a circuit breaker (particularly when it has opened on its own, or when the system has power applied) should be very carefully considered. Again, for most 135 and 121 operations, resetting of a circuit breaker is forbidden except where specifically called out by a procedure and checklist. There are good reasons for this, as resetting circuit breakers has lead to some tragic fatalities. Such guidance also points to a need to take the use of circuit breakers (and deactivation) seriously. You may be thinking "what's the big deal?", but there may be more to the story than you know.

 

When you undertake to open that circuit breaker, have you consulted the schematic diagram of your aircraft electrical system (not just the type in general, but your specific aircraft) to determine what else may be deriving power from that circuit breaker?

 

The following story, while not a helicopter, shows a series of mistakes and well as events and failures, culminating in the loss of a F-18, a very costly chain of errors. Among those errors was a failure to understand the relationship between the fuel probe and the fuel transfer pumps, and that little lack of systems knowledge ended up being a contributing factor to the loss of the aircraft.

 

http://www.military.com/daily-news/2014/04/12/out-of-fuel-out-of-time-and-one-chance-to-land.html?ESRC=airforce-a.nl

 

Years ago a fixed wing pilot who had been a military mechanic on Cobras was flying for an EMS operation where I not only flew, but was the Director of Maintenance. He had complained about the tire on a King Air 200. I was waiting on a part to replace the tire. On a Sunday afternoon, I drove by the hangar, and found the door open. I poked my head in, and found that he had the airplane on jacks, and had removed the offending wheel assembly. When I asked what he was doing, he told me that because I didn't seem to be able to get around to doing it, he would do it himself.

 

I asked him whether he was performing the required dye penetrant check on the wheel assembly halves, or whether he'd replaced the wheel packing between the wheel halves, and what he was using to torque the assembly bolts. He wasn't aware that he needed a packing (it's what seals the tubeless wheel assembly and prevents the tire from going flat). He knew nothing about any need to strip paint or do a dye penetrant check, and had never used zyglo or done non destructive testing. He didn't have a torque wrench, and intended to do the work by feel or "calibrated elbow."

 

I booted him out of the hangar and banned him, except for flight operations. Absolutely no touching of the tools and no performance of maintenance. Especially my tools and my liability.

 

The mechanic didn't get his certification in a box of cracker jacks any more than you got your pilot certification the same way. He has his job to do, you have yours. Yes, you can complete the actions in many cases, necessary to deactivate a component, but you need to have a thorough understanding of what is necessary to deactivate that component in that specific aircraft, as well as the potential ramifications, limitations, or unintended consequences.

 

Back to the items cited in Appendix A of Part 43: simply because it's listed there doesn't automatically mean you can do it.

[Astro]

Something similar happened to one of our guys once. During a ramp check he was told that since he took the door off (r22) he was altering the aircraft and therefore needed to make a maintenance entry and sign it in order to approve it for return to service (43.9a(1-4)). For about 6 months thereafter anytime one of us took a door off we had to make a maintenance entry. Personnaly I never understood why, since according to the RFM (p.2-6) flight with the doors off was already approved by the FAA. So why would I (the pilot) have to re-approve it?

 

When stuff like this happens just ask them to "show me where it says that".

[Nearly Retired]

Astro, it's a weight and balance thing. I know the balsa wood doors of an R-22 don't weigh more than a sheet of copy machine paper, but some helicopter doors are fairly hefty and can affect your empty weight c.g. (which would obviously affect your max gross c.g. as well).

 

Often, the weight and balance section of the RFM will have a "Form C" which has the pertinent w/b information for the ship up top, and columns for the addition/removal of items below. Using this form, a pilot can quickly calculate the change in c.g. due to configuration changes of the aircraft.

 

And yes, the removal or reinstallation of the door probably would require a simple logbook entry on the part of the pilot. In the "good old days" it didn't. You just pulled the doors on your 47 and stuck 'em in the hangar until you came back. Now the FAA treats every aircraft like it's a 777. They've really taken just about all of the fun out of flying, no?

[avbug]

Something similar happened to one of our guys once. During a ramp check he was told that since he took the door off (r22) he was altering the aircraft and therefore needed to make a maintenance entry and sign it in order to approve it for return to service (43.9a(1-4)). For about 6 months thereafter anytime one of us took a door off we had to make a maintenance entry. Personnaly I never understood why, since according to the RFM (p.2-6) flight with the doors off was already approved by the FAA. So why would I (the pilot) have to re-approve it?

 

When stuff like this happens just ask them to "show me where it says that".

 

Flight manual approval for door-off operation doesn't constitute a logbook entry. If you alter the aircraft configuration, then it needs to be noted in the aircraft records.

 

As for "show me where it says that," you can look in 14 CFR 43.5(a). Additionally, approval for operation with doors off or other aircraft configuration changes doesn't constitute authorization to do the work any more than an aircraft being approved for IFR operations means you can go fly IFR without an instrument rating. The person doing the work needs to be qualified in accordance with the regulation.

 

Removal or reattachment of a door may be a very simple affair, or in some cases it may seen simple, but may require more than what is apparent.

 

Part 43, appendix A doesn't list the operation, and also notes that it can't involve complex assembly. Additionally, when you do the work, you are still responsible for all the performance standards and requirements that are applicable to a certificated mechanic. That includes maintenance entries in the appropriate aircraft log. If you're removing doors, the maintenance record is kept until the doors are reinstalled; making repeated records entries in the permanent log is probably not a good idea; ensure you have the correct medium for recording your work, and that you make proper entries. Date, and signature, a description of the work performed is a minimum, but it's a very good idea to reference the technical standard under which you performed the work (part number for the aircraft maintenance manual, etc).

[Guest pokey]

I am beginning to run out of bug spray

[avbug]

I am beginning to run out of bug spray

 

Pokey, consistently failing to contribute in any meaningful way. Shocking.

[Guest pokey]

don't forget one thing bug... I can ground your aircraft ! hehehehehheheheeeee

[Astro]

If I'm wrong I'm wrong, but I thought the whole point of the FAA approving the r22 for operation with the doors off in the RFM was so that we wouldn't have to make an entry every time? At a flight school that's alot of entries!

 

NR, yes the RFM does include doors off w & b figures, and yes I do put them in my calculations when I fly doors off. However the RFM also includes w & b figures for removing the dual controls. So am I supposed to make a maintenance entry every time I take them off to fly solo?

[avbug]

Having weight and balance "figures" in the AFM doesn't relieve the responsibility to amend the weight and balance document for the aircraft; that's the document that lists the last weight and balance, as actually weighed, or calculated with addition or removal of equipment.

 

Some places that frequently change configuration will prepare more than one document, appropriate to the configuration, so it doesn't need to be re-done.

 

Yes, a logbook entry needs to be made if you change the aircraft configuration, to include removal or addition of cockpit flight controls. It doesn't need to be made in the permanent aircraft record; the squawk log will do, so long as that documentation is retained until the configuration is changed again. The documentation as written up should refer to the revised weight and balance.

[avbug]

don't forget one thing bug... I can ground your aircraft ! hehehehehheheheeeee

 

You'd have to know which and where it is, first. Good luck with that.

 

Anyone can ground any aircraft; doesn't need to be another pilot or mechanic.

[jjsemperfi]

It doesn't need to be made in the permanent aircraft record; the squawk log will do

 

Out of curiosity, where does it say that?

[Astro]

Having weight and balance "figures" in the AFM doesn't relieve the responsibility to amend the weight and balance document for the aircraft; that's the document that lists the last weight and balance, as actually weighed, or calculated with addition or removal of equipment.

 

Some places that frequently change configuration will prepare more than one document, appropriate to the configuration, so it doesn't need to be re-done.

 

Yes, a logbook entry needs to be made if you change the aircraft configuration, to include removal or addition of cockpit flight controls. It doesn't need to be made in the permanent aircraft record; the squawk log will do, so long as that documentation is retained until the configuration is changed again. The documentation as written up should refer to the revised weight and balance.

 

So on the same daily squawk sheet that I might write "red position light out" I'm supposed to write that I took the dual controls out and right door off and have w & b figures to show the aircraft still within limits, then when I get back I need to write that I put them both back on?