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Formerly TC'd Products and ADs on Experimentals

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IflyPlanez

New Member
Joined
May 31, 2022
Messages
3
Greetings all,

A&P Mechanic here who has been asked to perform a condition inspection on an experimental aircraft with a Lycoming O-320 that has no data plate. My issue is that the owner is not the original builder, and has no records of AD status. On a TC aircraft/product this would of course be something that I would have to squawk under 14 CFR 43.11, but am not entirely sure if I am required to follow 43.11 for this aircraft. The parameters of the condition inspection (as I'm sure most of you know), are that the inspection be performed within the scope and detail of Part 43 Appendix D, which does not itself reference ADs at all. HOWEVER, Part 43.11 does essentially require AD research, and it states that it applies to all inspection conducted in accordance with Part 91 (not sure if "scope and detail" equates to "in accordance with"), so its a bit of a conundrum.

I have informed him that he absolutely should get the ADs complied with on the engine to the best of his ability, and that he is primarily responsible for compliance with them, but as the person performing the inspection (if it is indeed conducted under 43.11) I also hold secondary responsibility for them (if they do in fact apply) in determining if the aircraft is in a condition for safe operation. It is very difficult to say that it is in a condition for safe operation, regardless of regulatory requirements, if there are known unsafe conditions that have not fully been accounted for in the records. On the other hand, I am essentially telling him that the engine is a paperweight until it is taken apart (for ADs where external inspection isn't possible).

Anyone have any commentary on applicability of ADs on formerly TCd products?
 
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