Current Rates for Condition Inspections on NON-Builder EAB Aircraft (in the US)

[TFF]

Looking in the logbooks is not giving them away. I wouldn’t do one without reading through the logbooks. I have been burned with doctored logs before, that took a lot to fix. The owner had no clue.

If you send your plane to a big shop, the only thing they care about is business. They will hold books for a check, because that’s the agreement of business. That they sign is irrelevant; both sides have made an agreement. Work done for money. Not signature. No money, what is the shop going to do?You still have to pay even if the outcome is not what you want. Your not a fool sending a Cub to someone doing King Airs? Do people have to pretend to be in a militia during their annuals?

Truth from what most A&Ps have learned the hard way is airplane owners pull some of the dirtiest tricks not to pay. Not their fault your hobby requires things to be official. That is why most A&Ps like airlines, only one person screwing you. I would also say 50% of people who have an A&P, quit because owners and airlines are asses, they can make more working on road vehicles without being personally insulted. The A&Ps that stay are the ones who love aviation and put up with it.

 

[Kyle Boatright]

They will hold books for a check, because that’s the agreement of business.

The FAA is very clear that you cannot do that. Yeah, I know, it is done, but it is a great way for a shop to get the wrong kind of attention from the FAA.

If a customer doesn't pay a shop, a mechanic's lien and/or other legal remedies are available.

 

[BBerson]

There is no requirement for logbooks at all for TC'd aircraft. The requirement is records. 91.417 requires the inspection records be kept just 12 months. So a loose leaf binder could be used to discard the inspection records after a year.
Now the EA-B operating limitation 23 requires a condition inspection entry in both the logbook and record. What does that mean?
“23. Condition inspections must be recorded in the aircraft logbook and maintenance records showing the following, or a similarly worded, statement…”

It should say “or“ not and. Or just record to be precise. Who writes this stuff at the FAA?

 

[Marc Zeitlin]

I know they don’t require it. But I also don’t see any evidence that it would be prohibited.

So if you mean that it's not prohibited to provide a list of issues to address, of course it's not prohibited. But as others have pointed out, _IF_ any of the issues prevent the aircraft from being "in a condition for safe operation", then the CI doesn't get signed off. Either the owner, someone else, or I have to fix the issue before I'll sign off the CI. So what _I_ provide to my customers is a list of all issues that don't prevent me from signing the CI, and I provide it in a separate email, NOT in the logbook.

It should be possible for an owner to pay for a single inspection sign off with defects listed, and then do the repairs himself and not return for another inspection. A second inspection puts the repair liability back on the inspector.

See above - if the defects prevent a CI signoff, then no signoff occurs prior to the defect mitigation.

Sometimes, if I know and trust the customer, I'll let them complete the fix, send me some pics or description of what they did, and then send them the signoff for the logbook (which is almost always, but not always, the "maintenance record" as well).

As others have pointed out, there is no such thing as a signoff that says "in a condition for safe operation except for <x>, which you can fix later".

With respect to logbooks/maintenance records, I will not sign off a CI for a customer that doesn't let me review the logbooks - there's no way for me to know WTF is going on with the plane with respect to calendar items or time items without that info. If I don't see logbooks, I make the assumption that EVERYTHING is out of date or past TBO (which is not regulatory, but still ends up with me recommending an awful lot of part replacements).

 

[BBerson]

See above - if the defects prevent a CI signoff, then no signoff occurs prior to the defect mitigation.

No sign off is the direct opposite of 43.11(b) that a mechanic who normally inspects TC'd aircraft only would use to comply with FAR43.11(a)(5).
Where is this contrary guidance for condition inspections found in documents?

 

[BBerson]

Guidance for maintenance records is in AC 43-9C change 2. https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_43-9C_CHG_2.pdf

Yes, this is for Standard aircraft. But the operating limitations include parts of 43. So, lacking EA-B maintenance guidance, I think this AC applies unless other guidance is offered.

start with this, page 2 par 5.
5. MAINTENANCE RECORD REQUIREMENTS.
a. Responsibilities. Part 91, § 91.417 states that an aircraft owner/operator shall keep and maintain aircraft maintenance records. However, part 43, § 43.9 states that each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment. Section 43.11 states that the person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, 135, § 135.411(a)(1), or § 135.419 shall make an entry in the maintenance record of that equipment. The persons that are authorized to perform maintenance can be found in §§ 43.3 and 43.7.

 

[Marc Zeitlin]

No sign off is the direct opposite of 43.11(b) that a mechanic who normally inspects TC'd aircraft only would use to comply with FAR43.11(a)(5).
Where is this contrary guidance for condition inspections found in documents?

There is none. The OL's are the only guidance for CI's on E-AB aircraft. After that, it's up to the person with the RC or the A&P to decide how to deal with it - there's no such thing as an official "disapproval". There is no requirement to do anything if the person decides not to sign off the CI because of a discrepancy - there's just no signoff in the logbook, until someone decides that the plane is "in a condition for safe operation", and that's a fairly subjective decision.

While you list an AC and references to Part 43, AC's are not regulatory and any reference to Part 43 doesn't apply, because (as we discussed) Part 43 doesn't apply to Experimental aircraft. Now, the OL's will usually state, as you saw in paragraph 23 of the website you referenced earlier, that the wording for the CI signoff should be something like:

“I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of FAR 43 Appendix D, and was found to be in a condition for safe operation.”​

This implies that Part 43 Appendix D should be referenced for determining whether the aircraft is "in a condition for safe operation", but if you read Appendix D, it's pretty **** vague - about the only thing that's required is a <relatively useless, if you read Mike Busch> compression check - everything else is just "look at this thing and make sure it's OK", for the most part.

So if it doesn't say it in the OL's and if it isn't in 14 CFR Part 91.417 with respect to maintenance, it doesn't apply to E-AB aircraft. The RC holder or the A&P has a LOT of discretion here. And most of the time, that's a good thing.

 

[crusty old aviator]

Like Dana’s A&P/IA, I travel as needed, and I do only owner-assisted inspections. If the owner isn’t interested in his/her aircraft, why should I? I charge $50/hr for the inspection and $25/hr for travel. The FAA doesn’t like traveling IA’s because the “industry” protects those with big shops and high overheads; but for EABs, they don’t get involved unless there’s an issue.
I‘ve been involved with EAA and homebuilts constructed of all materials for four and a half decades and haven’t found an “airworthy” one yet! (airworthy is a legal term, but you’d be surprised how many IAs sign off EAB aircraft as “airworthy”)
I insist on seeing the logs and the documents required to be carried in the aircraft before performing the inspection. I don’t take them with me: they belong with the aircraft. If the owner ”forgets“ to bring them, I don’t perform the inspection, but still charge for my travel time. I’ve had a few owners not pay me: it’s rare, and they were ostracized off their airports.
My overhead is low, so I don’t have to charge much. Most of my customers wouldn’t be able to afford to keep their aircraft if they had to rely on a big box maintenance facility, and that’s what keeps me going. The Book says we’re placed here to serve others...
Finding a mechanic like me isn’t easy, so I’m told, which is a shame, but most A&Ps don‘t want anything to do with homebuilts: EABs are outside their comfort zones, mostly due to their own ignorance.
Good luck figuring out what you’ll be flying!

 

[BBerson]

So if it doesn't say it in the OL's and if it isn't in 14 CFR Part 91.417 with respect to maintenance, it doesn't apply to E-AB aircraft. The RC holder or the A&P has a LOT of discretion here. And most of the time, that's a good thing

It is in 14CFR 91.417 where it says records of inspections shall be kept for the period specified. It doesn’t say only inspections found airworthy, it just says inspections. The AC fills in the details for clarification.
The incomplete operating limitations could be clarified by the FAA, I suppose.

Reading 91.417 carefully again, I see the owner shall keep records of inspections.
If I contact a mechanic for inspections, I will require a record of that inspection to comply. Or seek another.
I don’t expect many mechanics will understand my request. It may take some instruction.

 

[BBerson]

Finding a mechanic like me isn’t easy, so I’m told, which is a shame, but most A&Ps don‘t want anything to do with homebuilts: EABs are outside their comfort zones, mostly due to their own ignorance.
Good luck figuring out what you’ll be flying!

Yes, like you, for a short time I was a traveling mechanic that only did owner assisted annuals (never any condition inspection requested) after selling my higher overhead shop. It was difficult to find owners with so many other inspectors in the state, so I gave it up and made far more building houses with less liability.

 

[Marc Zeitlin]

It is in 14CFR 91.417 where it says records of inspections shall be kept for the period specified. It doesn’t say only inspections found airworthy, it just says inspections. The AC fills in the details for clarification.

Agreed - 91.417 states that all maintenance and inspection shall be kept for either 1 year, when they're superseded, or forever, as described.

A couple of points:

First, as @crusty old aviator pointed out, an E-AB aircraft CANNOT be "airworthy", so lets not use that term - there is no TC, and to be "airworthy", an aircraft must be in compliance with its TC. Since there is none, "airworthy" cannot be achieved - just the 2nd part of the TC'd aircraft's annual inspection which is to be found "in a condition for safe operations", which is what the OL's for E-AB aircraft require.

Second, the only required (or available, for that matter) "inspection" of an E-AB aircraft is the annual "Condition Inspection". There are no 100 hour inspections, 50 hour inspections, Maintenance Program inspections, or anything else. So the only "inspection" that needs to be logged is the CI, and the OL's point that out and state what it needs to say.

And again, the AC43.9C is not mandatory nor regulatory, as it says in its first paragraph.

Reading 91.417 carefully again, I see the owner shall keep records of inspections.
If I contact a mechanic for inspections, I will require a record of that inspection to comply. Or seek another.
I don’t expect many mechanics will understand my request. It may take some instruction.

So the "record" of the inspection is just the signoff in the logbook. The "record" does not, and does not have to, list all and every thing that I saw during the CI - just the signoff, if I did so. If I didn't sign it off because I found something to prevent it, then as stated before, it'll get fixed and then I'll sign it off.

I don't mind having this discussion, but I have to say that I'm having a hard time figuring out what point you're trying to make or to what understanding you're trying to come. What's bothering you about all this? The relative undefined nature of what a CI is? The leeway that the RC holder/A&P has? I might be able to help more if I had a better understanding about where you're trying to go...

 

[BBerson]

I don't mind having this discussion, but I have to say that I'm having a hard time figuring out what point you're trying to make or to what understanding you're trying to come. What's bothering you about all this? The relative undefined nature of what a CI is? The leeway that the RC holder/A&P has? I might be able to help more if I had a better understanding about where you're trying to go...

Glad to know you don’t mind having the discussion. I think you have extensive experience with condition inspections. I don’t know if you do annuals.
I have not yet done a condition inspection, only annual inspections. So I may do a condition inspection in the future and want to learn more about condition inspection procedure from both an owner and a mechanics perspective. Which is the topic asked in post one.

Here is a sample discrepancy list from an annual inspection I would use as template, but I would change “unairworthy“ to something else, perhaps, “found the following discrepancies“. Since I can’t think of a single word like “uncondition”.

 

[Dana]

The difference is that when an IA signs off an annual with a list of discrepancies, the annual is "good" once the discrepancies have been addressed, and the IA doesn't have to see it again. The required condition inspection for experimentals doesn't allow that; at the conclusion of the inspection the aircraft is either "in a condition for safe operation" and it gets signed off as such or it isn't. If there are discrepancies the person doing the condition inspection can only sign off the CI after the discrepancies are fixed.

 

[Toobuilder]

And to further Dana's point, in the TC world, a "discrepancy" is defined by engineering documentation. The A&P/IA has very little latitude to decide if the condition is "safe" or not... And that's not their job anyway. Their job is to inspect the airplane and determine if the airplane CONFORMS to the TC and other engineering data. That's what an "Annual Inspection" is - verifying conformance to engineering data.

The E-AB world has little to zero "engineering data" to conform to, so the determination of "safe" is up to the inspector. One A&P may decide one condition is a deathtrap, and the next guy might be just fine with it. Who is right? Could be both or none... The only thing that matters is the ink in the book and the character of the inspector who penned it.

 

[BBerson]

Several commenters have said that Dana, please show the FAA document that says that, other than the operating limitation which doesn’t say that and repeating opinions.
The operating limitation is worded suspiciously similar to the airworthy sign off. Even to the point of the phrase “the following or similar worded statement”.
When I was doing owner assisted annuals I changed the wording of the sign off to suit owner/maintainers.
Where it says ”list of discrepancies and unairworthy items” I deleted unairworthy because owners don’t like that word in the log. The FAA approved it, because discrepancies and unairworthy items is redundant.

An IA is required to follow specific procedures and entries if an aircraft is not approved for return to service.
I won’t accept that a “condition inspection“ procedure would allow inspectors to neglect discrepancy documention.

 

[Turd Ferguson]

The term "airworthy" for FAA purposes is two-part. It's when "an aircraft or one of its component parts meets its type design (engineering standards) and is in a condition for safe operation.” (mostly non specific).

The "condition for safe operation" part is quite often a judgement call on the part of the inspector. For example, you won't find any criteria for how much slack in control hinges is acceptable on most light planes. How much brake lining must remain, or how much corrosion is acceptable. Those are all judgement calls. No measurements where once can show on a calibrated scale why the amount of wear and tear present is unacceptable. It's just tacit knowledge of the situation and the mechanic declaring "I'm not okay with that"
That is kinda one of the reasons why the FAA wants a person with at least an A&P doing condition inspections on homebuilts. They are trained on what condition for safe operation means even where there is no specific criteria.

 

[BBerson]

I did a search of Code of Federal Regulations for ”condition inspection”. Nothing listed.

 

[Marc Zeitlin]

I think you have extensive experience with condition inspections. I don’t know if you do annuals.

Well, as of today, I've done about 171 (about) CI's, and zero "annuals". I don't work on TC'd aircraft - only E-AB and E-R&D.

I have not yet done a condition inspection, only annual inspections. So I may do a condition inspection in the future and want to learn more about condition inspection procedure from both an owner and a mechanics perspective. Which is the topic asked in post one.

Gotcha.

So @Dana has stated that:

The difference is that when an IA signs off an annual with a list of discrepancies, the annual is "good" once the discrepancies have been addressed, and the IA doesn't have to see it again. The required condition inspection for experimentals doesn't allow that; at the conclusion of the inspection the aircraft is either "in a condition for safe operation" and it gets signed off as such or it isn't. If there are discrepancies the person doing the condition inspection can only sign off the CI after the discrepancies are fixed.

And you've asked for FAA references for the inability of the A&P to do that. I assume, but don't know, that if discrepancies are listed as being required to be fixed prior to the Annual being in effect, that someone legally allowed to perform the fixing must sign the logbooks prior to the next flight, saying that the discrepancies have been fixed. That person might be an IA, an A&P, or the owner, if the discrepancy is of a low enough level that it's legal for the owner to do the work.

My position is that whether there is FAA documentation (which there isn't) that addresses this specific question or not, it's a logical impossibility to state, in the logbook, that the aircraft "is in a condition for safe operation", if there's any discrepancy/issue that prevent that statement from being true. I suppose that in theory, an A&P could provide a signoff in the logs as well as a list of things to fix prior to the next flight, and that the plane wouldn't be legal unless the discrepancies were signed off. But since it's legal for your grandmother's dog to work on E-AB aircraft (although an A&P is required for E-R&D), it's unlikely that any A&P (me included) would be willing to leave themselves open to that sort of situation - not requiring proof of remediation prior to providing the signoff.

As I said earlier, if there are safety discrepancies, I just won't provide a signoff until their fixed, and I don't know why anyone would. The fix can be demonstrated in a number of ways or performed by any number of folks (whom I'd need to trust). @Toobuilder 's comments about latitude and subjectivity is spot on. I've seen signoffs of things that I assumed would have killed the pilot almost immediately, and I've seen A&P's reject stuff that I know to be perfectly safe and acceptable over a million hours of canard composite flight time.

I did a search of Code of Federal Regulations for ”condition inspection”. Nothing listed.

That's because the only place it's referenced is in the aircraft's Operating Limitations. Read Paragraph 23 again, or look through Order 8130.2J for the relevant OL paragraphs for E-AB aircraft.

If you're asked to perform a CI and agree to do so (and if you've been an A&P for a long time and know the build technology of the aircraft you're being asked to inspect, there's exactly zero reason for you not to do it), you'll have all the rope you want to hang yourself and your customer . YOU will get to decide whether you like something or not; whether you want to make the owner fix a thing or not; and whether you're willing to let someone else fix a thing either before or after you put your signature in their logbook or not. Now, hopefully, you'll review as much information and documentation about the plane in question as is available so that you're going in with SOME amount of education and what to look for. Rattling around in my head is pretty much every modification and fix that's been done to canard composite aircraft; why, and whether or not they're "mandatory". I DON'T have that info for RV's, but all the RV plans changes are on-line, so I review them all and include them all in my inspection checklist, so I know what I'm looking for. I'd hope that all A&P's do the same...

I don't think there's as much definition of what to do and how, and what not to do and how, as you're expecting or looking for . Maybe that's a good thing, and maybe that's a bad thing, but I think that's what we're all saying here.

Hope this helps.

 

[BBerson]

Thanks Marc, it comes down to I don’t want to ever end up in court where the question put to me is: “did you in fact sign that the aircraft was in a condition for safe operation?” That's all the jury will hear.
I likely won’t participate in assuming such risk.

 

[Toobuilder]

Well, the fact is that the "condition for safe operation" only lasts as long as it takes the ink to dry. The reason is that unlike TC'd aircraft, ANYBODY can perform work on the E-AB during the next 12 months, trained or not. And there is no requirement to document that work. The owner can get your CI signature on monday, and on Tuesday drill a bunch of holes in the spar web and then pull the wings off in flight on Wednesday... It WAS safe when you saw it and yours is the last entry in the book, but that is not evidence that the airplane was not altered after the fact.