Inoperative Instruments & Equipment

[jjsemperfi]

There is no “maintenance W&B”. In the RFM, it’s the W&B. And, the W&B which is provides the particular aircrafts current W&B information which is maintained by the maintenance folks. Over time and when equipment changes are made, each previous W&B is superseded and a new recalculated W&B is provided so the pilot has the most up-to-date information. After that, you as a pilot must compute the W&B for each flight per 91……

 

I ask a student.... How do you know if your W&B is up to date? Well, I have to check Maint records, STC's, and Equip List to see if anything has been added or removed. Yes I get this part. But maybe where I am confused is I think the W&B that Maint keeps up to date for us is a different item than the the W&B found as an actual section in the POH. Out of the factory does an aircraft have a W&B sheet signed off by mechanics? That may be what I'm hung up on.

 

[Spike]

I ask a student.... How do you know if your W&B is up to date? Well, I have to check Maint records, STC's, and Equip List to see if anything has been added or removed. Yes I get this part. But maybe where I am confused is I think the W&B that Maint keeps up to date for us is a different item than the the W&B found as an actual section in the POH. Out of the factory does an aircraft have a W&B sheet signed off by mechanics? That may be what I'm hung up on.

 

 

 

How do you know if your W&B is up to date?

 

I’ll check the aircrafts RFM and refer to the W&B section to include the Equipment List contained within…

 

To wit, when equipment changes are made that affects W&B, the W&B sheet in the RFM is updated. Entries are made in the Aircraft Maintenance Logbook that reflect those changes i.e. “installed item ‘A’ per ACME Aeronautics STC 6969 and W&B recalculated and found within limits. RFM W&B updated and the aircraft is returned to service” (maintenance entries will vary)….. That is, for maintenance purposes, there is no other W&B form, list, log or whatever. It’s all located in the RFM and must be current if the machine is considered to be “in service” by the owner/operator.... If it’s not up to date, then the machine is unairworthy….

Edited May 3, 2014 by Spike

[jjsemperfi]

Ah ha! The 300C W&B is different than the Robby. I see now where the Robby says that the section is updated and inserted at the end of the section (Chapter 6). The 300C isn't like this. The W&B updated by Mechs is a different form than the W&B section in POH. I think that is where my disconnect is coming from. Alright, now that I've pissed you off enough Spike and iChris, I thank you for your help.

[Spike]

Ah ha! The 300C W&B is different than the Robby. I see now where the Robby says that the section is updated and inserted at the end of the section (Chapter 6). The 300C isn't like this. The W&B updated by Mechs is a different form than the W&B section in POH. I think that is where my disconnect is coming from. Alright, now that I've pissed you off enough Spike and iChris, I thank you for your help.

 

If I may be so bold to say, you didn't piss-off either of us off. We're just trying to help......

Edited May 4, 2014 by Spike

[Spike]

Ah ha! The 300C W&B is different than the Robby. I see now where the Robby says that the section is updated and inserted at the end of the section (Chapter 6). The 300C isn't like this. The W&B updated by Mechs is a different form than the W&B section in POH. I think that is where my disconnect is coming from. Alright, now that I've pissed you off enough Spike and iChris, I thank you for your help.

 

I’ll add by saying, not all operators put the W&B update sheet/equipment list in the W&B section of the RFM. I’ve seen it stuffed in the back of the RFM and, in the front, and of course in the W&B section…….

[iChris]

 

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).

 

Please note the fact that the appendix A list is not all inclusive, it's a general list. It's a misunderstanding the FAA needs to clear up.

 

“Even though the introductory text of subparagraph [c] states that "preventive maintenance” is limited to the following work, in view of the broader definition of preventive maintenance in section 1.1, we believe that such limitation is not controlling.”

 

“As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed, as examples of the tasks in each category, they cannot be considered all inclusive.”

 

“It is our understanding that Flight Standards' Aircraft Maintenance

Division is planning to clarify this issue in a future revision to the AC.”

 

Chief Counsel to Mr. Coleal Feb 26, 2009

[iChris]

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

 

 

FAA Fort Worth-Aircraft Evaluation Group (FTW-AEG)

MMEL Preamble

A Master Minimum Equipment List (MMEL) is developed by the FAA, with participation by the aviation industry, to improve aircraft utilization and thereby provide more convenient and economic air transportation for the public. The FAA approved MMEL includes those items of equipment related to airworthiness and operating regulations and other items of equipment which the Administrator finds may be inoperative and yet maintain an acceptable level of safety by appropriate conditions and limitations….

 

Ref: Policy Letter #34

Edited May 6, 2014 by iChris

[iChris]

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".

 

As far as removing doors on light helicopters, in most cases there is no appreciably affect on weight or balance and if the removal can be accomplished without tools according to accepted practices listed in the RFM, it can be done by the pilot on a temporary flight-by-flight basis without documentation entry each time.

 

Under conditions of airworthiness, if the aircraft was type certificated for flight with doors off and the conditions for such flight are provided to the pilot in the RFM, with the limitations for such optional flight configuration, the aircraft is considered airworthy when so configured by the pilot. In other words, the aircraft’s condition of airworthiness has not been altered.

 

To be airworthy:

 

(1) The aircraft must conform to its Type Certificate (TC). Conformity to type design is considered attained when the aircraft configuration and the components installed are consistent with the drawings, specifications, and other data that are part of the TC and would include any Supplemental Type Certificate (STC) and field approved alterations incorporated into the aircraft.

 

(2) The aircraft must be in a condition for safe operation. The condition of the aircraft relative to wear and deterioration (e.g., skin corrosion, window delamination/crazing, fluid leaks, tire wear, etc.) must be acceptable.

 

Definition Airworthy: FAA Order 8120.2G; pg 2-1 ; also 14 CFR §3.5[a]

 

EXAMPLE: MD 500E:

 

Edited May 6, 2014 by iChris

[Jaybee]

Generally speaking, I was taught if it doesn't require tools then it doesn't require logging.

 

A&P two cents worth... as I was taught it by an A&P...

 

EDIT - sorry but no official reference for that "rule of thumb"

[avbug]

Changes in airworthiness are not the only times that logbook entries are required; any time maintenance has been performed (and that does not necessarily require the use of tools; a change in aircraft configuration may or may not require tools, but will certainly require documentation in the aircraft log).

 

Don't listen to me. As an A&P and inspector, former director of maintenance (twice), and nearly three decades of maintenance experience, it's all just conjecture. Disregard the regulatory references; they're purely for entertainment. Carry on.

 

I'll try to reference what "an A&P told me" to better establish the fact, another time.

Edited May 6, 2014 by avbug

[aeroscout]

 

 

FAA Fort Worth-Aircraft Evaluation Group (FTW-AEG)

MMEL Preamble

A Master Minimum Equipment List (MMEL) is developed by the FAA, with participation by the aviation industry, to improve aircraft utilization and thereby provide more convenient and economic air transportation for the public. The FAA approved MMEL includes those items of equipment related to airworthiness and operating regulations and other items of equipment which the Administrator finds may be inoperative and yet maintain an acceptable level of safety by appropriate conditions and limitations….

 

Ref: Policy Letter #34

We may be considering two sides of the same coin...

 

VOLUME 4 AIRCRAFT EQUIPMENT AND OPERATIONAL AUTHORIZATIONS CHAPTER 4 MINIMUM EQUIPMENT LISTS (MEL) AND CONFIGURATION DEVIATION LISTS (CDL) Section 6 Master Minimum Equipment List Development and Approval Process for 14 CFR Parts 121, 135, and 129 Operators

 

4-776 GENERAL. This section contains information for aviation safety inspectors (ASI) concerning the development, approval, and revision process of Master Minimum Equipment Lists (MMEL).

4-777 PROPOSED MASTER MINIMUM EQUIPMENT LIST (PMMEL). The first requirement for producing an initial MMEL is the development of a PMMEL that reflects the manufacturer’s concepts of which items can be inoperative. The Federal Aviation Administration (FAA) encourages the aircraft manufacturer to develop a PMMEL during the aircraft certification process. The aircraft manufacturer coordinates with the Aircraft Evaluation Group (AEG) and the aircraft operators throughout the PMMEL development process. Manufacturers and operators seeking consideration for relief for operating with certain items of equipment inoperative must provide supporting documentation that sufficiently substantiates their requests. In addition to including an evaluation of the potential outcome of operating with items that are inoperative, this documentation should consider the subsequent failure of the next critical component, the interrelationships between items that are inoperative, the impact on Approved Flight Manual (AFM) procedures, and the increase in crew workload. The PMMEL must not conflict with the AFM limitations, Configuration Maintenance Procedures (CMP), or Airworthiness Directives (AD). The PMMEL should specify suitable limitations in the form of placards, maintenance procedures, crew operating procedures, and other restrictions as necessary to ensure an acceptable level of safety. To substantiate these considerations, the manufacturer must provide demonstrations that include evaluation flights as necessary. Schedule AEG participation or observation in participation flights, if needed, in conjunction with the certification test program or the Flight Standardization Board’s (FSB) operational evaluation, whenever possible. The manufacturer develops the PMMEL in a format acceptable to the Administrator and submits it to the AEG for review.

4-778 INITIAL MMEL APPROVAL PROCESS. To initiate the MMEL approval process, the AEG schedules Flight Operations Evaluation Board (FOEB) meetings to review and evaluate the PMMEL for technical accuracy and acceptability. The AEG invites interested parties, such as the manufacturer, operators, and interested aviation community representatives, to participate in these meetings. The FOEB discusses each PMMEL item with the interested participants and recommends approval, modification, or disapproval for each item. If they cannot reach a consensus, they may hold an item open for further consideration or until they gather more information. The manufacturer or operator must resubmit, with additional justification, items not acceptable or held open by the FOEB. The PMMEL is the initial manufacturer and the operators use the AEG working document to develop the draft MMEL and establish the working relationship between the initial operators and the FOEB chairman. The FOEB chairman arranges to have the draft MMEL posted on the MMEL Web site,www.opspecs.com for operator and industry review and receives comments within the indicated time period. (For access to this Web site, contact the Technical Programs Branch, AFS–260, at (202) 267–8166.) The FOEB will review and discuss the recommendations and comments and revise the draft MMEL as necessary. After the FOEB properly completes the coordination of the draft MMEL with field and industry, the Air Transportation Division, AFS–200, Washington Headquarters, will post the approved MMEL on the MMEL Web site for access by industry for preparing individual operator MELs.

I am paying particular attention to the sentence...

 

 

"The first requirement for producing an initial MMEL is the development of a PMMEL that reflects the manufacturer’s concepts of which items can be inoperative. "

The manufacturer and the FAA usually work closely during the designing and building of new aircraft so it may be a chicken or the egg.

 

I say chicken, but I appreciate your reference.

 

 

edit sp and format

Edited May 6, 2014 by aeroscout

[Jaybee]

Changes in airworthiness are not the only times that logbook entries are required; any time maintenance has been performed (and that does not necessarily require the use of tools; a change in aircraft configuration may or may not require tools, but will certainly require documentation in the aircraft log).

 

Don't listen to me. As an A&P and inspector, former director of maintenance (twice), and nearly three decades of maintenance experience, it's all just conjecture. Disregard the regulatory references; they're purely for entertainment. Carry on.

 

I'll try to reference what "an A&P told me" to better establish the fact, another time.

 

Avbug was identified on another pilot chat forum as Douglas Ames Bader. A search of the FAA airman database shows that Douglas Ames Bader has no mechanic certificate, nor a rotorcraft certificate. So unless there are multitudes of Avbugs running around talking condescendingly on chat forums that all work as fire pilots....

[Guest pokey]

 

So unless there are multitudes of Avbugs running around talking condescendingly on chat forums that all work as fire pilots....

 

You mean to tell me that there is a whole SWARM of avbugs?! SHEEEESH !! I had better run out and stock up on more bugspray

[avbug]

 

Avbug was identified on another pilot chat forum as Douglas Ames Bader. A search of the FAA airman database shows that Douglas Ames Bader has no mechanic certificate, nor a rotorcraft certificate. So unless there are multitudes of Avbugs running around talking condescendingly on chat forums that all work as fire pilots....

 

I'm sure you'll find the terms of service of "outing" people prohibitive, but the stupidity of one who "outs" the wrong person, or identifies the poster as the wrong person as you've done, is laughable.

 

If your'e going to do it, get it right, mate, rather than passing on misinformation from someone else who thought they had it right. Don't be a bloody idiot.

[Guest pokey]

did anyone really believe he would admit who he was/wasn't?? come on bug, inquiring mimes wanna know,, (and not mime was NOT a typo)

[avbug]

Douglas Bader was a British WWII fixed wing pilot. He's dead. The pilot the poster above referenced is apparently a name someone pulled off the FAA database, when trying to determine who "Douglas Bader" is. The same folks on the other web board thought that Douglas Bader was an "American," and a French ace. Rocket scientists, all.

 

Jaybee apparently isn't intelligent enough to think for himself or herself, and simply parrots what other rocket scientists got wrong. What does that make Jaybee?

[rotormatic1]

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

 

Under part 91, 133, and 137, you don’t need a MEL approved by the FAA for certain aircraft, see (1)(ii) listed below.

 

 

 

§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—

(1) The flight operation is conducted in a—

(i) Rotorcraft, non-turbine-powered airplane, glider, lighter-than-air aircraft, powered parachute, or weight-shift-control aircraft, for which a master minimum equipment list has not been developed; or

(ii) Small rotorcraft, nonturbine-powered small airplane, glider, or lighter-than-air aircraft for which a Master Minimum Equipment List has been developed; and

(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;

(ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;

(iii) Required by §91.205 or any other rule of this part for the specific kind of flight operation being conducted; or

(iv) Required to be operational by an airworthiness directive; and

(3) The inoperative instruments and equipment are—

(i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with §43.9 of this chapter; or

(ii) Deactivated and placarded “Inoperative.” If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and

(4) A determination is made by a pilot, who is certificated and appropriately rated under part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft.

An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator.

For the application of 43.9, here is the definition of maintenance from FAR 1:

Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

Preventive maintenance means simple or minor preservation operations and the replacement of small standard parts not involving complex assembly operations.

[avbug]

You aren't authorized to use a MMEL off the shelf; you need aircraft-specific approval. That is, where a master MEL exists for your aircraft, you need approval for your serial number. You can gain approval for the MMEL verbatim, or you can develop your own based off the master list. Simply because a list exists, you aren't authorized to use it until approval has been granted for your specific aircraft.

[aeroscout]

You aren't authorized to use a MMEL off the shelf; you need aircraft-specific approval. That is, where a master MEL exists for your aircraft, you need approval for your serial number. You can gain approval for the MMEL verbatim, or you can develop your own based off the master list. Simply because a list exists, you aren't authorized to use it until approval has been granted for your specific aircraft.

That is my understanding also. Thanks for posting.