Formerly TC'd Products and ADs on Experimentals

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Marc W

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Mar 31, 2017
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Colorado
No doubt that the O-320 helped, but I must ask: was there a mountain wave involved?
No waves. Not much wind yesterday. I have ridden in that airplane, albeit in cool weather and low altitude. However, it acts like a real airplane!
 
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skydawg

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Jul 26, 2016
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Denver, Colorado
I don’t think the original issue is as complicated as this post makes it.
Part 43 pertains only to essentially certified and previously ”certified” aircraft….nothing about engines or any other stuff. However, most EXP operating limits regardless of category will list requirements for time limited parts if any equipment on board has such (normally this info is found in orig cert docs such as TCDS)…. Reference Faa order 8130.2J for specific limits for specific exp categorie. As far as AD’s go, unless the AD is specific to your engine P/N and/or associated with airframe type (usually such exp ADs are associated with kits), it’s not applicable to EXP or other SA certificates.

So, if your airframe was never ever certified, you can hang any engine, certified or not. But I expect your ops limits will include one a few possible limitations for tracking and complying with time or life limited components published by the manufacturer. But if the data plate is missing, who‘s to say exact engine it is?
 

jhmcglynn

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Jul 26, 2015
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Florida
I belonged to a glider club in North Florida that owned 2 Czech Blanik L-13 gliders. We acquired them in the 90s and ours were registered as experimental although others had registered them as certified gliders. They were great gliders used as primary trainers by the Soviet Bloc countries. A spar failure occurred in June 2010 in Austria which resulted in an AD grounding the fleet worldwide. We complied and eventually sold them to a member. There was much discussion around the contention our L-13s were not impacted because they were “experimental “. BTW - the Wikipedia page refers to the AD as a Service Bulletin.
 

IflyPlanez

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May 31, 2022
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OP Here,

So after much discussion with a PMI and the FSDO, we agreed that it would be ACCEPTABLE for me to perform the condition inspection without signing for the ADs. I verified most of the the big ones (Crank snout, carb venturi, mags) but the bottom line is that, without at least a partial teardown, I could not account for every AD that COULD apply to a Lycoming 0-320 (A1A as far as I can tell). I gave the owner a status list and informed him that the biggest one I was still worried about was the oil impeller which potentially could still be sintered iron or aluminum. The owner was not willing to do a teardown of this kind, so I informed him that the ADs are his responsibility and the onus is on him from a regulatory standpoint. An A&P/IA checking ADs is a requirement of 43.11 for an annual or 100 hour inspection, which does not apply to a condition inspection.

As a matter of CYA, I proposed the minor alteration to the OL required condition inspection statement, which they accepted:

Complied with a condition inspection IAW the scope and detail of Part 43 Appendix D.
So far as the work performed is concerned, the aircraft is in a condition for safe operation.

This is taken from 135 Airworthiness Release regulations, and since experimental OLs say "or similarly worded statement", it clarifies that I am speaking to safe operation ONLY with respect to the scope and detail of Part 43 Appendix D, which says nothing about ADs at all.
 

pfarber

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Feb 21, 2019
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Location
Dollywood
As A&P's we have a wide latitude to determine "safe for operation".
A&Ps are NOT THE SAFETY POLICE. You really need to read and understand FAR 43.9 and 43.11

Unless you have a valid reason (ie out of spec, AD) you cannot just walk up to an AC and wave your pencil and make anything unairworthy.

Even if I hire you to do a specific task and you find an unairworthy condition, I can tell you to stop work and I will pay the bill and come get my AC never giving you the legal authority to make a 43.9 entry as you never completed the work.

At most an A&P can call the FSDO... and that would result in what?

And the bigger issue is not of the FAA, but of civil liability if you play safety police. Sure, you can follow the FARs to the letter, but that does not protect you from a civil action where the standards are completely different.

I would never touch an E/AB unless it was in my role as a paid A&P, that way insurance would cover me.

Its a minefiled out there for A&Ps. Sad, but true.
 

D Hillberg

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Joined
Nov 23, 2010
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1,753
Location
very low low low earth orbit
A&Ps are NOT THE SAFETY POLICE. You really need to read and understand FAR 43.9 and 43.11

Unless you have a valid reason (ie out of spec, AD) you cannot just walk up to an AC and wave your pencil and make anything unairworthy.

Even if I hire you to do a specific task and you find an unairworthy condition, I can tell you to stop work and I will pay the bill and come get my AC never giving you the legal authority to make a 43.9 entry as you never completed the work.

At most an A&P can call the FSDO... and that would result in what?

And the bigger issue is not of the FAA, but of civil liability if you play safety police. Sure, you can follow the FARs to the letter, but that does not protect you from a civil action where the standards are completely different.

I would never touch an E/AB unless it was in my role as a paid A&P, that way insurance would cover me.

Its a minefiled out there for A&Ps. Sad, but true.
A&Ps do work with approved data and sign off their work, That all their authorized to do.
The ADs have limits outlined in the body of the Directive
Limits are supplied by the manufacture with approval of the 'Administrator'
FARs have their limits and practices listed
Your signing on the dotted line only states the Aircraft has met the minimum standards for airworthiness
At the time of signing. After delivery the owner does what they do.

Some mechanics just pencil whip it as do some owners and pilots...

Had a few 'employers' who wanted to "overhaul" = recycle time life parts past published limits...
I removed their data plates and drilled the "dead' parts
They didn't like it. It cut into their profits, Helicopter don't work well with catastrophic failures of critical parts

As a mechanic I can and have done was place a call the local FSDO put articles under surveillance so the owner will NOT put an Airframe, Power plant, Appliance or TSOed part that is junk from being installed on anything .

Part #
Serial #
Manufacture
Person holding said item of un airworthiness.
 
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