Today's Message Index:
----------------------
1. 06:19 AM - Re: Re: First Conditional (David Saylor)
2. 07:15 AM - Re: Re: First Condition Inspection (Kelly McMullen)
3. 07:48 AM - Passenger warning placard (Lenny Iszak)
4. 09:19 AM - Definition of Airworthy; was: First Conditional Inspection (David Saylor)
5. 06:57 PM - Re: Definition of Airworthy (Kelly McMullen)
Message 1
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| Subject: | Re: First Conditional |
I agree. I've seen a lot of EABs with annuals signed off in the logs.
Same fit, form, and function, but an annual is not a condition inspection.
My concern would be, like Bob encountered, when a fed says we can't use the
word "airworthy", like it's reserved for a higher class of aircraft or
something. Not the case.
--Dave
On Sun, May 27, 2018 at 5:52 PM Jesse Saint <jesse@saintaviation.com> wrote
:
> The operating limitations, iirc, give the wording then say =9Cor si
milarly
> worded statement=9D. The passenger warning says it does not meet th
e federal
> safety regulations for standard aircraft, but does not say anything about
> airworthiness. The special airworthiness certificate is still and
> airworthiness certificate. All that aside, the easiest way to handle it i
s
> to use the wording in the operating limitations. I see many experimentals
> that have past sign offs with the certified plane wording.
>
> Jesse Saint
> Saint Aviation, Inc.
> 352-427-0285
> jesse@saintaviation.com
>
> Sent from my iPad
>
> On May 27, 2018, at 8:14 PM, Kelly McMullen <apilot2@gmail.com> wrote:
>
> You are debating with the FAA themselves. The definition says it has to
> have a type certificate. They then insert circular wording to say conditi
on
> for safe operation means airworthy, which it does not. Experimental
> aircraft have a "special airworthiness certificate" because they don't me
et
> the requirements for a "Standard" airworthiness certificate. Look at the
> required passenger warning on your instrument panel that states the
> aircraft does not meet all FA A airworthiness requirements. Your operati
ng
> limitations state the very specific language to be used for sign-off of a
> condition inspection. Use other language at your own peril. The language
is
> there to protect you more than anything else. Type certificated aircraft
> have very specific language for sign off of their annual inspection, and
> any inspector that values his certificates will use that language.
>
> Sent from my IBM-360 main frame
>
>
> On Sun, May 27, 2018 at 9:53 AM, David Saylor <saylor.dave@gmail.com>
> wrote:
>
>> Maintained correctly, our airplanes are airworthy. They have
>> airworthiness certificates. They fit the FAA's definition, which
>> acknowledges that they needn't conform to a type design. 91.7 says we'r
e
>> not allowed to take off unless the plane is airworthy.
>>
>> If you want to substitute "airworthy" for "in a condition for safe
>> operation" in your signoff, go ahead. That's about as similarly worded
as
>> you can get!
>>
>> 8130.2J
>> Appendix I
>> Definitions:
>> Airworthy. An aircraft with a type certificate (TC) is airworthy when it
>> conforms to its U.S. TC and is in a condition for safe operation. For th
e
>> purpose of this order, a non-type-certificated aircraft is airworthy whe
n
>> it is in a condition for safe operation.
>>
>> --Dave
>>
>> On Sat, May 26, 2018 at 3:50 PM Bob Turner <bobturner@alum.rpi.edu>
>> wrote:
>>
>>>
>>> I think you will find suggested wording in your operating limitations
>>> document. These days the faa recommends you do not use the word
>>> =9Cairworthy=9D, as that specifically means =9CIs in
conformance with its type
>>> certificate=9D. Of course EAB aircraft don=99t have a type
certificate.
>>>
>>> --------
>>> Bob Turner
>>> RV-10 QB
>>>
>>>
>>>
>>>
>>> Read this topic online here:
>>>
>>> http://forums.matronics.com/viewtopic.php?p=480425#480425
>>>
>>>
>>>
>>>
>>>
>>>
>>> ==========
>>> -List" rel="noreferrer" target="_blank">
>>> http://www.matronics.com/Navigator?RV10-List
>>> ==========
>>> FORUMS -
>>> eferrer" target="_blank">http://forums.matronics.com
>>> ==========
>>> WIKI -
>>> errer" target="_blank">http://wiki.matronics.com
>>> ==========
>>> b Site -
>>> -Matt Dralle, List Admin.
>>> rel="noreferrer" target="_blank">http://www.matronics.com/contribut
ion
>>> ==========
>>>
>>>
>>>
>>>
>
Message 2
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| Subject: | Re: First Condition Inspection |
Dave,
It is a definitional thing. You use the same Part 43 Appendix D guidance
to do a 100 hour inspection, an annual inspection, and a condition
inspection. You inspect the same things and for the most part standards
are the same. However, an annual requires an IA, 100 hour an A&P, and a
condition inspection can be a repairman or A&P.
The FAA engages in a lot of circular definitions and arguments. They
choose to define "airworthy" as an aircraft, airframe, engine, etc. that
"conforms to its original or properly modified type certificate".
No amateur built aircraft has a type certificate. So it can't meet the
above definition. You can go off and find all kinds of links back to
safety, safe for flight, certificates, etc. which still don't get you to
conforming to a type certificate.
I've seen plenty of type certificated aircraft that have only been
signed off for 100 hour inspections for several years. By paperwork,
they are not airworthy, regardless of how pristine the aircraft is.
I see plenty of amateur built aircraft signed off for annuals...says
nothing about the safety of the aircraft, but their paperwork is
inadequate. Why not do it right, just as you would do the physical work
right? No different than aircraft that go years without jam nuts
properly tightened, cables not properly routed, etc. They haven't fallen
out of the sky yet, but the potential is there. I saw a Cessna that had
the flap and aileron cables crossed in the door posts
for over 20 years. Would you want to hop in and fly that aircraft?
Do you want to buy an amateur aircraft that the records show a history
of improper inspection records?
Your airplane blows a tire on landing, takes out a runway light or two.
Do you want to be answering the investigating FSDO inspector's question
about how you determined that the aircraft is "airworthy". Why put
yourself in that situation?
On 5/28/2018 6:17 AM, David Saylor wrote:
> I agree. I've seen a lot of EABs with annuals signed off in the logs.
> Same fit, form, and function, but an annual is not a condition inspection.
>
> My concern would be, like Bob encountered, when a fed says we can't use
> the word "airworthy", like it's reserved for a higher class of aircraft
> or something. Not the case.
>
> --Dave
>
> On Sun, May 27, 2018 at 5:52 PM Jesse Saint <jesse@saintaviation.com
> <mailto:jesse@saintaviation.com>> wrote:
>
> The operating limitations, iirc, give the wording then say or
> similarly worded statement. The passenger warning says it does not
> meet the federal safety regulations for standard aircraft, but does
> not say anything about airworthiness. The special airworthiness
> certificate is still and airworthiness certificate. All that aside,
> the easiest way to handle it is to use the wording in the operating
> limitations. I see many experimentals that have past sign offs with
> the certified plane wording.
>
> Jesse Saint
> Saint Aviation, Inc.
> 352-427-0285
> jesse@saintaviation.com <mailto:jesse@saintaviation.com>
>
> Sent from my iPad
>
> On May 27, 2018, at 8:14 PM, Kelly McMullen <apilot2@gmail.com
> <mailto:apilot2@gmail.com>> wrote:
>
>> You are debating with the FAA themselves. The definition says it
>> has to have a type certificate. They then insert circular wording
>> to say condition for safe operation means airworthy, which it does
>> not. Experimental aircraft have a "special airworthiness
>> certificate" because they don't meet the requirements for a
>> "Standard" airworthiness certificate. Look at the required
>> passenger warning on your instrument panel that states the
>> aircraft does not meet all FA A airworthiness requirements. Your
>> operating limitations state the very specific language to be used
>> for sign-off of a condition inspection. Use other language at your
>> own peril. The language is there to protect you more than anything
>> else. Type certificated aircraft have very specific language for
>> sign off of their annual inspection, and any inspector that values
>> his certificates will use that language.
>>
>> Sent from my IBM-360 main frame
>>
>> On Sun, May 27, 2018 at 9:53 AM, David Saylor
>> <saylor.dave@gmail.com <mailto:saylor.dave@gmail.com>> wrote:
>>
>> Maintained correctly, our airplanes are airworthy. They have
>> airworthiness certificates. They fit the FAA's definition,
>> which acknowledges that they needn't conform to a type
>> design. 91.7 says we're not allowed to take off unless the
>> plane is airworthy.
>>
>> If you want to substitute "airworthy" for "in a condition for
>> safe operation" in your signoff, go ahead. That's about as
>> similarly worded as you can get!
>>
>> 8130.2J
>> Appendix I
>> Definitions:
>> Airworthy. An aircraft with a type certificate (TC) is
>> airworthy when it conforms to its U.S. TC and is in a
>> condition for safe operation. For the purpose of this order, a
>> non-type-certificated aircraft is airworthy when it is in a
>> condition for safe operation.
>>
>> --Dave
>>
>> On Sat, May 26, 2018 at 3:50 PM Bob Turner
>> <bobturner@alum.rpi.edu <mailto:bobturner@alum.rpi.edu>> wrote:
>>
>> <bobturner@alum.rpi.edu <mailto:bobturner@alum.rpi.edu>>
>>
>> I think you will find suggested wording in your operating
>> limitations document. These days the faa recommends you do
>> not use the word airworthy, as that specifically means
>> Is in conformance with its type certificate. Of course
>> EAB aircraft dont have a type certificate.
>>
>> --------
>> Bob Turner
>> RV-10 QB
>>
>>
>>
>>
>> Read this topic online here:
>>
>> http://forums.matronics.com/viewtopic.php?p=480425#480425
>>
>>
>>
>>
>>
>>
>> ==========
>> -List" rel="noreferrer"
>> target="_blank">http://www.matronics.com/Navigator?RV10-List
>> ==========
>> FORUMS -
>> eferrer" target="_blank">http://forums.matronics.com
>> ==========
>> WIKI -
>> errer" target="_blank">http://wiki.matronics.com
>> ==========
>> b Site -
>> -Matt Dralle, List Admin.
>> rel="noreferrer"
>> target="_blank">http://www.matronics.com/contribution
>> ==========
>>
>>
>>
>>
Message 3
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| Subject: | Passenger warning placard |
I'm updating my panel, and looked up the exact wording for the passenger warning
placard. Turns out the wording had recently changed.
https://www.eaa.org/en/eaa/eaa-news-and-aviation-news/news/10-12-2017-changes-to-passenger-warning-placards-in-new-faa-order
--------
Lenny Iszak
Palm City, FL
2014 RV-10, N311LZ - 400 hrs
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=480479#480479
Message 4
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| Subject: | Definition of Airworthy; was: First Conditional Inspection |
Vernon, I'm sorry you're being subjected to so much hot air. But the
statement you were presented is incorrect and you deserve better. Airworthy
is not a crime!
On Sun, May 27, 2018 at 5:19 PM Kelly McMullen <apilot2@gmail.com> wrote:
> You are debating with the FAA themselves. The definition says it has to
> have a type certificate. They then insert circular wording to say condition
> for safe operation means airworthy, which it does not. Experimental
> aircraft have a "special airworthiness certificate" because they don't meet
> the requirements for a "Standard" airworthiness certificate. Look at the
> required passenger warning on your instrument panel that states the
> aircraft does not meet all FA A airworthiness requirements. Your operating
> limitations state the very specific language to be used for sign-off of a
> condition inspection. Use other language at your own peril. The language is
> there to protect you more than anything else. Type certificated aircraft
> have very specific language for sign off of their annual inspection, and
> any inspector that values his certificates will use that language.
>
You are debating with the FAA themselves.
*I'm not arguing with what the FAA has written down. I'm trying to explain
the FAA's definition of "Airworthy: An aircraft with a type certificate
(TC) is airworthy when it conforms to its U.S. TC and is in a condition for
safe operation. For the purpose of this order, a non-type-certificated
aircraft is airworthy when it is in a condition for safe operation".*
The definition says it has to have a type certificate.
*No, the definition says an aircraft either has a TC or it doesn't. They
pretty well covered all cases.*
They then insert circular wording to say condition for safe operation means
airworthy, which it does not.
*There's nothing circular about it. TC'd or not, they defined "airworthy"
to mean "in a condition for safe operation", so in this context, that's
what it means.*
Experimental aircraft have a "special airworthiness certificate" because
they don't meet the requirements for a "Standard" airworthiness certificate.
*That's what makes them special! But it doesn't mean they're not
airworthy. In fact, if an aircraft has ANY kind of FAA airworthiness
certificate, that pretty well certifies it to be, you know, airworthy.*
Look at the required passenger warning on your instrument panel that states
the aircraft does not meet all FA A airworthiness requirements.
*I'm not sure what that means. My placard mentions federal safety
regulations, but it doesn't say anything about airworthiness requirements.
Does yours?*
Your operating limitations state the very specific language to be used for
sign-off of a condition inspection. Use other language at your own peril.
*If you're afraid of the word, don't use it. I find it useful.*
The language is there to protect you more than anything else.
*Protect me from what? The need to easily explain my choice of words? I've
always found that my actions protect me better than words.*
Type certificated aircraft have very specific language for sign off of
their annual inspection, and any inspector that values his certificates
will use that language.
*I thought we were discussing non-type-certificated aircraft and their
condition inspections. What do type certificated annuals have to do with
it?*
*--Dave*
Message 5
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| Subject: | Re: Definition of Airworthy |
It depends on where you look. In the interest of finding more clarity I
researched the matter once I had time. I thought perhaps the FAA had
changed its position and guidance. That does not appear to be the case.
FAA Order 8900.1 Flight Standards Information Management System, which
is the definitive guidance for FAA Standards offices and inspectors,
says on its current version:
"1/8/18 8900.1 CHG 568
VOLUME 1 GENERAL INSPECTOR GUIDANCE AND INFORMATION
Indicates new/changed information.
CHAPTER 1 ORDER ORGANIZATION, USE, AND REVISION
Section 2 Definitions
1-26 DEFINITIONS. The following definitions are from Title 14 of the
Code of Federal Regulations (14 CFR) part 1, 1.1 or other appropriate
sources.
C. Airworthy. Two conditions must be met before an aircraft can be
considered Airworthy:
1) The aircraft must conform to its type certificate (TC); that is,
when the aircraft configuration and the components installed are
consistent with the drawing, specifications, and other data that are
part of the TC, and include any supplemental TC and field-approved
alterations incorporated into the aircraft.
2) The aircraft must be in condition for safe operation; this refers
to the condition of the aircraft relative to wear and deterioration."
Notice that it says NOTHING about aircraft that lack a type certificate.
So the FAA as of this date does not have consistency between its various
Orders, advisory circulars, etc. What else is new? The order you cite is
policy for issuing certificates, and states its definition is for the
purposes of that order ONLY. The FSIMS definitions page is 6 months
newer and is broader in purpose and scope.
I recall not so long ago the FAA had no definition of airworthy.
So you are free to do what you think is right. The conservative position
to advise new repairmen is to use the exact language contained in their
operating limitations. A DAR has to use the language that FAA national
dictates at the time the special airworthiness certificate is issued.
The statement I gave Vernon is not incorrect, it is the current FAA FSDO
guidance.
Calling information presented by myself and others hot air or incorrect
is simply not the case. It is an unsettled area of FAA policy. To assert
that your position is more correct simply has no basis.
The FAA has asserted for a very long time that amateur built aircraft
cannot meet the definition of airworthy. For one office to insert a
different position in one order last summer is simply inconsistent with
that position. Note the previous version of that same order issued two
years earlier did not contain any definition of airworthy.
On 5/28/2018 9:09 AM, David Saylor wrote:
> Vernon, I'm sorry you're being subjected to so much hot air. But the
> statement you were presented is incorrect and you deserve better.
> Airworthy is not a crime!
>
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