Re: new engine
It is not a legal issue. It is not a regulatory issue. Aircraft maintenance manuals are NOT regulatory unless certain airworthiness limitations sections of those manuals are list on the TC data sheet.
Sal did not tell the whole story. FAR 43.13 (a); Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propellor, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturers maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, OR OTHER METHODS, TECHNIQUES, AND PRACTICES ACCEPTABLE TO THE ADMINISTRATOR, EXCEPT AS NOTED IN 43.16.
§43.16 Airworthiness Limitations.
Each person performing an inspection or other maintenance specified in an Airworthiness Limitations section of a manufacturer's maintenance manual or Instructions for Continued Airworthiness shall perform the inspection or other maintenance in accordance with that section, or in accordance with operations specifications approved by the Administrator under Parts 121,
123, or 135, or an inspection program approved under
Very few of our general aviation aircraft usually discussed in this forum have a limitations section in the maintenance manual, and even if one did, the limitations sections do not address procedure, just limitations on time life items, and inspection intervals.
Just because a manufacturer says something is mandatory doesn't make it so. You DO NOT have to comply with manufacturers "Mandatory" service bulletins, unless your compelled to perform by an FAA regulation. An example would be if an AD referenced a service bulletin, or operators flying 121 or 135 would be required to comply with manufacturers mandatory SB's on engines , props, and appliances, and sometimes airframe SB's.
In this particular discussion, and the type engine and airframe discussed above, it is the operators decision to use the oil of choice. There are many other areas in general aviation that owners, operators, and mechanics still enjoy freedoms to use our experience and intelligence to do things better.
Technology comes first, then someone writes about it, then it gets regulated. Todays cutting edge truths will become tomorrows OWT's, and regulations sometimes, manytimes, do not get revised to reflect our new found knowledge.
FOR REFERENCE ONLY
Re: new engine
True, mandatory service bulletins are not mandatory. However, if you comply with one you must follow all the instructions of the service bulletin. You cannot as you say "use our experience and intelligence to do things better" and deviate from the instructions of the bulletin because in our opionion or experience we can improve upon the bulletin.
The same applies for maintenance manuals, they may not necessarily be approved by the FAA, but you cannot deviate from their instructions because your life experiences show that a different method will produce a better affect.
If while performing maintenance you find other methods, techniques or practices that you would like to use, then take them to your local FAA for acceptance (good luck).
The issue is not if maintenance manuals are regulatory, the issue is the rules governing maintenance which is found in FAR 43. Mechanics must use "methods, techniques, and practices prescribe in the current manufacturers maintenance manual"
The regulation here does not need to be revised. The manufacturers maintenance manual may need to be revised because of new technology or simply because old wives tales have been proven false. All the FAR does is regulate us as mechanics to use what the manufacturers give us.
Re: new engine
I cannot find a single statement in your previous post that is factual. I hope that I can provide some additional info here, that will allow you to view this subject a little differently. I'm not going to type the following FAA Order in it's entirety, just what pertains to our discussion.
DEPARTMENT OF TRANSPORTATION, FEDERAL AVIATION ADMINISTARATION, ORDER# 8620.2 (dated 11/2/78)
SUBJECT; Applicability and Enforcement of Manufacturers Data.
Paragragh 3, BACKGROUND. There exist a difference of opinion among field inspectors concerning the manner in which manufacturers maintenance manual material, including service letters and service bulletins, could be enforced by the FAA.
FAR 43.13 requires all persons to use methods, techniques, and practices acceptable to the Adminstrator while performing aircraft maintenance. The manufacturers maintenance manuals, service bulletins, and service letters have always been regarded as a source of acceptable data for complying with FAR 43.13 (a) and (b); however, such acceptability does not, in itself, impose an enforcement OR MANDATORY COMPLIANCE REQUIREMENT.
Paragragh 11, SUMMARY. To sum it up, compliance with manufacturers maintenance instructions is required when:
a. MADE MANDATORY BY AN AIRWORTHINESS DIRECTIVE
b. MADE MANDATORY BY A TYPE CERTIFICATE DATA SHEET
Sal, there is much more info in this FAA Order that applies to our discussion. General aviation aircraft maintenance and parts manuals are crude at best, to varying degrees, and should not be relied upon as the only source of information. I have a Mooney Service Manual laying on my desk (pity me), it is 1/2" thick. My tractor Service Manual is 3" thick, much more detailed and better illustrations.
If you are restricting yourself to the content of the manufacturers maintenance instructions, your customers aircraft will NEVER leave the ground again. A good mechanic can, and will have to, use other sources of information, including there knowledge and experience. Sometimes we even have to make it up as we go.
Re: new engine
"If you are restricting yourself to the content of the manufacturers maintenance instructions, your customers aircraft will NEVER leave the ground again."
How could this statement possibly be true? In fact, its the opposite. Not following the manufacturers maintenance will lead you to finding the ground in a manner that might not be desirable. Scan thru the NTSB accident/incident reports and you will find hundreds of cases where faillure to follow the maintenance manual resulted in the accident/incident. The first thing an investigation will focus on is the past maintenance and how it was performed. I have never known of a mechanic loosing their certificate because they followed the manual. But I do know of several who have had theirs suspended for not following the manual.
I agree that other sources of information are naturally required for maintenance. For example, the maintenance manual may simply state to safety-wire the bolts upon completion. If the manual does not have a standard aircraft procedures chapter, then AC43-13 could be used for safety wiring. However, if the maintenance you are performing has specific procedures called out in the manual, then those procedures must be performed.
My question to you would be, under what AUTHORITY would you deviate from the maintenance manual and perform procedures that you as a mechanic feel would be more benificial to the job you are performing. Secondly, how would you sign off that job in the maintenance records? You wouldnt be able to say you performed it IAW the maintenance manual if you deviated from the instructions.
In regard to your last paragraph, I would never have a mechanic work on my plane that deviates from the manual because he believes he has a better method. In addition, I would never want a mechanic working on my plane that "sometimes we even have to make it up as we go."
Stories of mechanics not following the manual and making it up as they go can be found on the NTSB accident/incident web site!!!
(by the way, I do value your opinions and appreciate your responses. I will passionately continue to beat this dead horse till the cows come home or their is peace in the middle east, whichever occurs first)
Re: new engine
I also respect your opinions, as I believe we can all benefit from other peoples experiences. I, myself do not intend to continue to beat a dead horse, however I do think I should clarify some of my previous statements, and answer your questions to me.
"You cannot as you say "use our experience and intelligence to do things better" and deviate from the instructions of the bulletin because in our opionion or experience we can improve upon the bulletin.
The same applies for maintenance manuals, they may not necessarily be approved by the FAA, but you cannot deviate from their instructions because your life experiences show that a different method will produce a better affect."
My response to the above statement;
My reason for my choice of words here has nothing to do with deviating from AMM methods that are known to be correct, but my experience has proven that their are many mistakes in aircraft AMM's and IPC's, and many times some maintenance items are not even addressed in the manuals. AC43.13 is generic and not specific to particular aircraft, therefore a mechanic may not be able to reference data found in these publications. If I happen across a discrepancy in a manual that throws a wrench in my ability to perform the maintenance correctly, I submit FAA Form 8010-4 Malfunction or Defect Report, and report that discrepancy to the manufacturer.
"My question to you would be, under what AUTHORITY would you deviate from the maintenance manual and perform procedures that you as a mechanic feel would be more benificial to the job you are performing. Secondly, how would you sign off that job in the maintenance records? You wouldnt be able to say you performed it IAW the maintenance manual if you deviated from the instructions."
Again, deviating from correct information is not an option. As for the authority for deviating from incorrect information, It is a mechanics responsibility to determine that the information is indeed wrong, report their findings, and then gather the necessary acceptable data to perform the task.
Pilots are given the authority to deviate from regulatory requirements of FAR 91 in emergency situations for obvious reasons; they have to get the aircraft safely on the ground. As mechanics, we are not given that same authority because there is no immediate danger; the aircraft is allready on the ground, and we have the time available to work through our situation before that aircraft is returned to service.
Examples of manufacturers maintenance manual discrepancies are provided below;
"Gates Learjet Model 55
Rudder Hinge Attachment
The following information is contained in Gates Learjet Service News Letter No. 90, dated January/February 1984:
Upon reinstallation of the rudder after completion of SB 55-27-3, an operator noticed the rudder center hinge assembly on the vertical stabilizer was rubbing the rudder hinge. Investigation of the Model 55 Illustrated Parts Catalog, 27-21-10, page O, Detail A & B, and page 1, item 11, and the Model 55 Maintenance Manual, 27-20-01, page 202 detail, found the installation is improperly illustrated. The washers (AN960-416L) should be installed one-on-top, one-on-bottom, against the bearing in the rudder hinge assembly on the vertical stabilizer."
"DO YOU BELIEVE THIS?
The original safety switch (squat switch) was defective and needed to be replaced. A new switch was installed. After installation, the manufacturer's maintenance manual was consulted to find an appropriate function test (F/T) of the safety switch, but none was found. A call to the manufacturer revealed that a proper F/T of the switch had not been developed. When further pressed, the manufacturer revealed that the only way they knew to F/T the switch was to select the gear-up position with the aircraft on the ground. If the gear did not retract, the switch was OK. They also revealed that they actually did retract the gear out from under an aircraft using their method. Obviously, a more reliabe less risky method should be developed. We suggest (and accomplished) a continuity check of the wiring with the aircraft on jacks."
"Learjet Model 25 Century
Autopilot Pitch Servo Cables
This aircraft underwent a 600-hour inspection 62.7 hours previously. The 600-hour inspection cabs for the capstan to be removed, tested, and reinstalled. Because the pilot reported that the auto pilot problem started immediately after the inspection, it is believed the capstan was improperly installed at that time.
Because there are many more holes for retaining pins than are actually used, it is very easy to make this mistake. The aircraft maintenance manual capstan removal and installation instructions do not specify where to install the retaining pins and the diagram of the capstan does not show the location of the pins."
"Beech Model C99
Rudder Balance 2720
After installation of a Whelen Flashing Beacon Kit (P/N 90033-15), supplied in Beech Kit No. 99-3035-1, it was found that the rudder could not be properly balanced.
The Whelen flashing beacon weighed 8 pounds and replaced a Grimes oscillating beacon weighing 2.25 pounds. A balance check of the rudder showed it to be over 3 inches outside of the minimum limit. Neither the Whelen kit documentation nor the maintenance manual have any provisions to add enough weight to bring the rudder into balance.
To properly balance the rudder, it was necessary to remove the Whelen unit and reinstall the Grimes unit. The submitter recommended that balance procedures be provided in the Whelen kit documentation."
"Revolution Model Mini 500
Flight Control Rigging 6200
The information for the following article was furnished by Mr. Fred Maupin, Aviation Safety Inspector (Airworthiness) FAA Flight Standards District Office located in Houston, Texas.
As the result of an accident investigation, it was determined that the flight control rigging instructions supplied by the kit manufacturer may be inadequate. Physical evidence from the accident site indicated the possibility that rigging of the rotor primary flight controls was not correct.
Section 7 (Rigging and Balancing) of the kit manufacturer's Assembly and Maintenance Manual contains instructions for rigging the primary helicopter flight controls. These instructions are ambiguous and appear to omit specific tolerances, limits, measurements, dimensions, and other critical criteria which would ensure safe operation. There are other sections of the maintenance manual, operations manual, and assembly instructions which need to be improved."
Fortunately, these mechanics used there knowledge and experience to overcome these potentially dangerous situations, with the result being better in contrast to manufacturers instructions. There are hundreds more examples, not enough space.
A persons life is more important to me than worrying about signing something off IAW manufacturers data. I think you are reading something else into my previous post that just isn't there.
"The manufacturers maintenance manuals, service bulletins, and service letters have always been regarded as a source of acceptable data for complying with FAR 43.13 (a) and (b); however, such acceptability does not, in itself, impose an enforcement OR MANDATORY COMPLIANCE REQUIREMENT."
Sorry for the long post,
Re: new engine
OK, Ill make this my last post (maybe)
I agree with your statement "deviating from correct information is not an option." But I dont believe that mechaincs should create their own procedures just because one is not available, or that it is confusing.
Whenever it is dicsovered at our facility that the manual has an incorrect procedure, no procedure or that the instructions are not completely clear, the next step is to contact the manufacturer and to receive in writing the correct procedure. Believe it or not this works extremely well. The written responce from the manufacturer is then included in the maintenance entry as a "IAW", and a copy is attached to the work order. And usually down the road the next manual revision includes this information. This process does not slow down the delivery or schedule of the aircraft. Most aircraft manufacturers send the information by the next day. The manufacturers are very happy to receive input from mechanics/facilities maintaining their aircraft, and to correct any discrepancies that could possibly show "negligence." (I hate to use that word)
Now, I dont want to take up alot of space with stories about mechanics doing what they think is best, but I will list just one. American Airlines flight 191. "American and Continental Airline mechanics were not following the McDonnell Douglas procedures for removing engine pylons for maintenance. The instructions involved removing the 13,500 pound engines from the pylons, and then removing the 2000 pound pylons. Clever mechanics in Tulsa had figured out how to do it by removing the engines and pylons all at once using a fork lift. This nonstandard procedure saved 200 man hours, but often damaged the pylons which hold the engine in place."
Mechanics thought they knew better than the manual, and it cost over 200 lives when the engine fell off the aircraft on take off. This is one example of mechanics not following the procedure and doing what they thought was best. A practice that I dont believe in!! (doing what we think is best)
OK Dell, I'll step off the soapbox now on this subject. What other FAR would you like to discuss???
Re: new engine
I really do appreciate your input. I mean that. This thread began discussing the use of oil for engine breakin, and ended with something totally different. I like that. This is what allows all of us to expand and improve our knowledge.
I did make a mistake when I said "sometimes we even have to make it up as we go", but this statement was intend to mean that there are times when the data is not there, or incorrect, and this is when a good mechanic will do just what you have said;"the next step is to contact the manufacturer and to receive in writing the correct procedure". Many times we do get the cooperation in a timely manner, many times not. Sometimes we get a D.E.R. involved. Sometimes we just call our local FSDO and explain the situation, and get a verbal blessing to proceed to do the job with data that we have presented, and agreed to be acceptable. That is entered into the maintenance entry.
There is a difference in approved data and acceptable data. The only approved data that may appear in a general aviation, Part 91 aircraft would be a limitations section of the AMM, the TCDS, or a service bulletin that is referenced in an AD. The rest is recommended, advisory, or acceptable (which ever words you choose). The engine oil chosen for breakin or normal operation falls into this catagory, and an owner may use an oil he wants, so long as there is not a specific regulation prohibiting the use of that particular oil in that particular engine.
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