AD 2007-26-12 Robinson Helicopter Company

[spencer]

Ad 2007-26-12

 

© Thereafter, if the rotor blade has been found airworthy by the inspections in paragraph (a), before each flight, visually check for any exposed (bare metal) skin-to-spar bonded area on the lower surface of each blade within the outboard 24 inches paying particular attention to the last 10 inches before the tip. An owner/ operator (pilot) holding at least a private pilot certificate may perform this visual check and must enter compliance into the aircraft maintenance records in accordance with 14 CFR 43.11 and 91.417(a)(2)(V). If a pilot finds any area of skin bare metal in the outboard 24 inches of either blade, before further flight, a qualified mechanic must comply with the requirements of paragraph (a) of this AD.

 

Would all Robinson owners/operators and pilots please read AD 2007-26-12 in full. I highly recommend that pilots and operators give their comments to the FAA and the AOPA per this section of the AD by March 3rd 2008. This is basically saying that they want us to record in the maintenance records before each flight that we have complied with this. This is going to be a major pain. I think they crossed the line to something that is not practical. Checking the rotor blades is already in the daily preflight checks and part of a 100 hour inspection and annual inspection. In the AD they also mentioned adding this check to the daily preflight checks in the POH. They want us to record this inspection before each flight. I am a flight instructor and there is times where I will have several flights a day. Let’s say for this instance I have 3-5 a day. Before each flight per this, means I have to make record in the maintenance records that I complied with this AD those 3-5 times. Let’s say I stopped for fuel. Before the next flight I have to do this visual inspection and comply with it in the records per this AD. I do not want to keep the Maintenance logbooks in the aircraft and neither does the FAA (although based of this AD it seems that they want us to) so I will have to figure out a way to keep record of it. For Flight instructors the part where it says, “An owner/operator (pilot) holding at least a private pilot certificate may perform this visual check and must enter compliance”. Let’s say I am soloing a student and for that supervised solo flight the student is PIC of the aircraft. This Student pilot who will be PIC is also responsible that the aircraft is airworthy for flight. Although they cannot do this inspection. This brings on another thought, does this mean that if my student crashes a helicopter do to blade debonding and I inspected it is it my fault(their technically PIC and also responsible that the aircraft is airworthy for flight).

I haven’t thought of an amendment to this yet but I think the “before each flight “part is unacceptable to personal owners and especially people who are trying to run a business with Robinson Helicopters. Possible ideas I had to this are making it a part of the 50 hr inspection and require complinence in the maintenance records. Also we could do this inspection every 25 hours in service. The key point that makes me mad is the before each flight we have to do this. I think this is a good example that the FAA solves a problem by throwing more paper work at it. Below is the comments section from the AD and I advise people to give their comments here and there and to the AOPA. I called the AOPA today and I was the first person to voice a complaint. I apologize to any spelling errors or to people who really don’t care.

 

AOPA -1-800-872-2672

Comments Invited

 

This AD is a final rule that involves requirements that affect flight safety and was not preceded by notice and an opportunity for public comment; however, we invite you to submit any written data, views, or arguments regarding this AD. Send your comments to an address listed under ADDRESSES. Include "Docket No. FAA-2007-0378; Directorate Identifier 2007-SW-04-AD'' at the beginning of your comments. We specifically invite comments on the overall regulatory, economic, environmental, and energy aspects of the AD. We will consider all comments received by the closing date and may amend the AD in light of those comments.

 

We will post all comments we receive, without change, to http://regulations.gov , including any personal information you provide. We will also post a report summarizing each substantive verbal contact with FAA personnel concerning this AD. Using the search function of our docket web site, you can find and read the comments to any of our dockets, including the name of the individual who sent the comment. You may review the DOT's complete Privacy Act Statement in the Federal Register published on April 11, 2000 (65 FR 19477-78).

Edited January 7, 2008 by spencer

[FUSE]

If I am reading it correctly you only have to do that the first 10 hours TIS.

 

What I don't know is what exactly 10 hours TIS means. Is that the first 10 hours after the tests are done or the first 10 hours after the blades are installed. I think it means after the blades are installed but I would really like to know for sure.

[spencer]

If I am reading it correctly you only have to do that the first 10 hours TIS.

 

What I don't know is what exactly 10 hours TIS means. Is that the first 10 hours after the tests are done or the first 10 hours after the blades are installed. I think it means after the blades are installed but I would really like to know for sure.

 

 

there·af·ter-after that in time or sequence; afterward

 

I guess based on their use of "Thereafter" i assumed it meant what i said originally. I think that after Jan 18th you have within 10 TIS before you have to bring the aircraft in to get the inspection by the mechanic.

Edited January 7, 2008 by spencer

[Mikemv]

Dear Spencer, You do not have to carry the aircraft logs/records with you. Make a paper, "Recurring AD" sign off sheet with the AD referenced paragraph for the inspection before EACH flight with the aircraft N number, date, hours, next due prior to flight, and a space for Signature and Cert. #. Carry it in the aircraft for sign offs and it does become a permanent part of the aircraft records. I have done this before on numerous aircraft with Recurring AD's. Your point about student pilots on solo's will still work if you or other Pilot makes the Inspection/Sign-off for them. Solo x-c will make the student find someone to do it. You may have to make a phone call and prior arrangements for them.

This is safety of flight and required before each flight. The factory will always want to cover themselves and protect the pilots. It is really not that difficult to do. Only takes a few seconds and you are safe to go. Be sure to train your students via a briefing that any new, sudden vibrations should be a land as soon as possible condition. We have a R-22 & R-44 here and have the paper work in place at this time!

Do not expect this to go away or change any time soon!!! None of us will have any input about changing the frequency of inspections! Be safe, Mike

[nbit]

I was about to say the same... Sounds like you can carry a sheet of paper that may later be added to the maintenance log(s). At least, that is what I intend to do for compliance until I hear different.

 

If I read it correctly, within 10 hours time in service, we have to do the tap test and take the end cap off, etc... ...Also the pilot has to check the blade visually. I do that before every flight now, cause I've been concerned over the skin de-laminations I've heard about.

So, I'll carry a sheet of paper for each Robbie product I fly and fill it out at each preflight. Does that constitute compliance??? Thoughts???

 

Sounds a little inconvenient, if that's the process, but gotta stay in business too.

[spencer]

Dear Spencer, You do not have to carry the aircraft logs/records with you. Make a paper, "Recurring AD" sign off sheet with the AD referenced paragraph for the inspection before EACH flight with the aircraft N number, date, hours, next due prior to flight, and a space for Signature and Cert. #. Carry it in the aircraft for sign offs and it does become a permanent part of the aircraft records. I have done this before on numerous aircraft with Recurring AD's. Your point about student pilots on solo's will still work if you or other Pilot makes the Inspection/Sign-off for them. Solo x-c will make the student find someone to do it. You may have to make a phone call and prior arrangements for them.

This is safety of flight and required before each flight. The factory will always want to cover themselves and protect the pilots. It is really not that difficult to do. Only takes a few seconds and you are safe to go. Be sure to train your students via a briefing that any new, sudden vibrations should be a land as soon as possible condition. We have a R-22 & R-44 here and have the paper work in place at this time!

Do not expect this to go away or change any time soon!!! None of us will have any input about changing the frequency of inspections! Be safe, Mike

 

 

I am aware of the Recurring AD sign off sheet that is referenced. The main underlying point is that if you are preflighting the aircraft and getting scheduled maintenance done as already prescribed in the POH and aircraft maintenance manuals. I feel it is unnecessary to do a Complience report before each flight. Checking the blades is apart of my walk around inspection before each flight after my beginning daily preflight check perscribed in the POH. I ask myself how much paint can erode in 2.5 hours of flight leaving enough bonding line exposed for it to debond. Safety is the primary concern in every flight, but a line has to be drawn with what is practical and what is not. Prior arrangements to get this inspected for a student on a x-c is not practical.Solo X-c country flights have gone on for years without issue and without prior arrangements to get something inspected. Bear in mind this is my opinion from the point of someone already doing enough paperwork. I hate to think that my input means nothing to the FAA for the sake that they are there to service pilots and operators.

[FUSE]

Thanks for the clarification folks...

[Goldy]

"The factory will always want to cover themselves."

 

That is what this entire AD is all about...IMHO. This allows them to make a fault of the aircraft now a pilot error, plain and simple.

 

Goldy

[mechanic]

"The factory will always want to cover themselves."

 

That is what this entire AD is all about...IMHO. This allows them to make a fault of the aircraft now a pilot error, plain and simple.

 

Goldy

 

Ya, if RHC keeps the price increases coming and not dealing with the real problems of the blade debonding, the R22 is rapidly increasing in hourly costs! Won't be the cheapest to operate much longer. I think they are nipping a warranty issue too, with this AD..

 

I said it before, I can't see why a paint change or blade tape wouldn't cure this problem with out having an AD implemented ????????

 

I read on another site that a lot of the 07 aircraft are having major corroision problems, as soon as 3 months old, due to the lack of the zinc chromate primer on fuselage and certain parts. Includes both 22 and 44's. I don't know if its a isolated case or not at this point.

 

Time will tell.

[Goldy]

Ya, if RHC keeps the price increases coming and not dealing with the real problems of the blade debonding, the R22 is rapidly increasing in hourly costs! Won't be the cheapest to operate much longer. I think they are nipping a warranty issue too, with this AD..

 

I said it before, I can't see why a paint change or blade tape wouldn't cure this problem with out having an AD implemented ????????

 

I read on another site that a lot of the 07 aircraft are having major corroision problems, as soon as 3 months old, due to the lack of the zinc chromate primer on fuselage and certain parts. Includes both 22 and 44's. I don't know if its a isolated case or not at this point.

 

Time will tell.

 

I thought they added special coatings to the fuselage on the Mariner series of ships only, didnt know they were doing all of them until now. Maybe I should pay attention ? Curious as to why, and like you said time will tell what the real impact is. Of course, it's a moot point, they wont be around much longer.

 

Goldy

[mechanic]

I thought they added special coatings to the fuselage on the Mariner series of ships only, didnt know they were doing all of them until now. Maybe I should pay attention ? Curious as to why, and like you said time will tell what the real impact is. Of course, it's a moot point, they wont be around much longer.

 

Goldy

 

I have been hearing/reading the R22 will be going out of production soon?? Anyways, the 44 and 66 still use this type of blade design. If RHC has their way and schools use the Raven I for flight training they will have paint erosion on those blades as well and at a much higher cost to replace, right?? Problem still not solved and the cost to operate will increase on those aircraft too.

 

Just my -.02cents

[Goldy]

I have been hearing/reading the R22 will be going out of production soon??

 

No basis in fact. Frank denies it. I believe it.

[aclark79]

Interesting that the FAA would specificly state in the AD that the manufactures response to blade debonding was not found to be sufficient enough to warrent termination of the AD in question...

 

So what do I do for my student who goes X/C to another airport, shuts down for fuel and wants to return... does he have to find a pilot there willing to sign his AD sheet....? What a joke...

[ChopperJ]

"So what do I do for my student who goes X/C to another airport, shuts down for fuel and wants to return... does he have to find a pilot there willing to sign his AD sheet....? What a joke..."

 

 

Yeah, what do we do about that? Do I have to fly behind the student in a chase helicopter just to sign off on the AD after they refuel on their cross country?

Edited January 8, 2008 by HeloJVB

[apiaguy]

Go Schweizer!!

 

(sorry, just made me laugh)

[67november]

Go Schweizer!!

 

(sorry, just made me laugh)

 

 

I concur

[shanesplanet]

I don't understand why RHC just doesn't recall the blades. It is just my opinion but their quality seems to be slipping lately. I am at a school with 3 brand new ships in the past year and each one has had a laundry list of problems.

[67november]

recall???? gawd forbid should Frank want to spend millions on a recall. without first finding a fix for replacement and then have a company issued AD for the fix issued!

[Superman]

I don't understand why RHC just doesn't recall the blades.

 

 

They more or less did when everyone had to switch to the “new and improved” -4 blades. Just send in your old -2 blades, a large sum of money and we'll fix you right up! I’m guessing the -6 blades will be coming soon. Hold onto your wallet.

Guess I don’t have a problem with the AD other than the student pilot issue. I don’t think I would be willing to sign my name to an AD log, on a machine and student pilot I knew absolutely nothing about.

 

Seriously, how are you planning to deal with this?

 

Clark

[spencer]

Interesting that the FAA would specificly state in the AD that the manufactures response to blade debonding was not found to be sufficient enough to warrent termination of the AD in question...

 

So what do I do for my student who goes X/C to another airport, shuts down for fuel and wants to return... does he have to find a pilot there willing to sign his AD sheet....? What a joke...

 

 

I can see the headlines now." Student pilot responsible for linemen death while hot refueling an R-22 on an Solo X-C flight"

[Goldy]

while hot refueling an R-22 on an Solo X-C flight"

 

Wow, talk about living dangerously

[67november]

there is nothing wrong with hot refueling, IF it is done properly.

[LostHeliBoy]

quote name='67november' date='Jan 9 2008, 22:28 ' post='59870']

there is nothing wrong with hot refueling, IF it is done properly.

 

I agree but It is very dangerous.

 

As a student in NZ I was able to hot re-fuel and did so with my instructor many times on long cross countries in the back and beyond.. ... I know this in NZ I'm talking about,little brother to the big outback robinson testing ground called austrialia.. but I felt that it was safe at the time and was not dangerous.. When I was working for an Ag operator(also in NZ) we hot refueled all the time.. as it was more effecient to to so.. money button on ...... money button off.. .... as far as "a student pilot chops of line mans' head." what the pilot doing inside the helicopter during a fueling op?

silly...

 

I second the opinon of aclark79 in his last post.. living the the pacific NW .. the weather is unpredictable.. and in saying that I rarely send out a student pilot in Wx that thay cannot handle. If a student is refueling at a distant airport after an unnessary long solo cross country and a blade inspection by a rated pilot how is this going to be achieved by a student?

 

FAR 61.109;C,(4)

 

(4) 10 hours of solo flight time in a helicopter, consisting of at least—

 

(i) 3 hours cross-country time;

 

(ii) One solo cross-country flight of at least 75 nautical miles total distance, with landings at a minimum of three points, and one segment of the flight being a straight-line distance of at least 25 nautical miles between the takeoff and landing locations; and

 

(iii) Three takeoffs and three landings to a full stop (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

 

SO 75nm at 75Kts with ZERO wind would be an 60 mins. althought the total distance needs to be 75nm so 25&25&25 (or whatever combo you can dream up) would work and still be in the relm for the regs.. with no fuel stop.. the real issue is the Weather.. an unforseen thunderboomer rolls in and devistates the country side you sent you student up in.. oops.. now I have to drive for four hours round trip to go look at blades and sign a piece of paper.

 

Can this AD be condensed to a once a day procedure? a rated pilot look at the blades in question wave purple people eater farey dust all over them and make them fly all day? instead of another step to get off the ground in a timely fashion.

 

have fun..

Edited January 10, 2008 by LostHeliBoy

[spencer]

I agree but It is very dangerous.

 

As a student in NZ I was able to hot re-fuel and did so with my instructor many times on long cross countries in the back and beyond.. ... I know this in NZ I'm talking about,little brother to the big outback robinson testing ground called austrialia.. but I felt that it was safe at the time and was not dangerous.. When I was working for an Ag operator(also in NZ) we hot refueled all the time.. as it was more effecient to to so.. money button on ...... money button off.. .... as far as "a student pilot chops of line mans' head." what the pilot doing inside the helicopter during a fueling op?

silly...

 

I second the opinon of aclark79 in his last post.. living the the pacific NW .. the weather is unpredictable.. and in saying that I rarely send out a student pilot in Wx that thay cannot handle. If a student is refueling at a distant airport after an unnessary long solo cross country and a blade inspection by a rated pilot how is this going to be achieved by a student?

 

FAR 61.109;C,(4)

 

(4) 10 hours of solo flight time in a helicopter, consisting of at least—

 

(i) 3 hours cross-country time;

 

(ii) One solo cross-country flight of at least 75 nautical miles total distance, with landings at a minimum of three points, and one segment of the flight being a straight-line distance of at least 25 nautical miles between the takeoff and landing locations; and

 

(iii) Three takeoffs and three landings to a full stop (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

 

SO 75nm at 75Kts with ZERO wind would be an 60 mins. althought the total distance needs to be 75nm so 25&25&25 (or whatever combo you can dream up) would work and still be in the relm for the regs.. with no fuel stop.. the real issue is the Weather.. an unforseen thunderboomer rolls in and devistates the country side you sent you student up in.. oops.. now I have to drive for four hours round trip to go look at blades and sign a piece of paper.

 

Can this AD be condensed to a once a day procedure? a rated pilot look at the blades in question wave purple people eater farey dust all over them and make them fly all day? instead of another step to get off the ground in a timely fashion.

 

have fun..

 

 

I tried to relay my sense of humor in the refueling statement, obviously I failed miserably. I was being facetious.

But back on point, obviously there are ways to deal with the AD, but the point of all of this is whether it is PRACTICAL or not. I still move to get the before each flight portion revised.

[Goldy]

there is nothing wrong with hot refueling, IF it is done properly.

 

 

No way! Re-fueling an R22 with AVGas is waaaaaay more dangerous than the hot refueling seen in turbine or military ops. I wouldnt get within 100 feet of an R22 begin hot refueled...but you do what you want !

 

 

Spencer- yeah, your statements got lost on this one !!

 

 

Goldy