What's DUE DATE for the 5 year hose replacement?

[NC Bill]

Is it the date of engine manufacture or the date of installation?

 

And how much over 5 years can you legally extend it (if any)?

[Doug Hereford]

NC BILL,

 

Legally speaking, the hose replacement is only a MANUFACTURER recommendation (or requirement)unless required by Safety Directive, Airworthiness Directive, or FAA approved Airworthiness Limitation. Otherwise, replacement would only be legally required if an unsafe condition was discovered during an inspection. Airworthiness Directives and Airworthiness Limitations will only be found when dealing with FAA approved articles, so in the case of the non-certified Flight Design CT, Safety Directives would apply. As for which date to use, legally speaking it would be spelled out in one of the three documents listed above. If none of these documents exist that require hose replacement, then the date is irrelevant.

 

You will probably get a bunch of disagreement with my reply. As I have discovered, this (manufacturer's authority) is a hotly debated topic in the SLSA world. What I have told you is the legal answer (as you requested). It is also the safe answer. Some may refer to "the new FAA interpretation". It is not new, it is just that a few in the FAA and many in the field have been grossly mis-interpreting the rules, and the FAA has recently corrected this.

 

While not directly related to this reply, my personal opinion is that somewhere in the five year life of a hose (especially flamable liquid carring hose) is a good time to replace them for preventive (thanks Jim) reasons.

 

Doug Hereford

[BMcCand - N248CT]

I performed the 5 year work based upon the interpretation prior to the FAA clarification. I based the time upon 5 years after installation.

When doing the work , the only deterioration was the inside of two coolant hoses at tight bends, where the springs are.

The oil hoses and fuel hoses were flexible and intact. The fire sleeves didn't have the ends dipped, so I replaced the sleeve

and dipped it.

The airframe fuel hoses showed no problems. The two hoses at the wing root are very difficult to replace. I went to an FD

service center, Rainbow aviation, for help with that. It takes 3 people, following an LOA to do this. And the willingness to drill

a hole in your composite structure! However, the wing pull also satisfied the wing inspection requirement.

The engine mount replacement takes and FD service center, too. I wouldn't have been able to do that on my own.

 

So, the 5 year work is now 'required' by Rotax, but interpreted as non-required by the FAA. I think it is a good idea - given the

discovery of coolant hose issues.

[Safety Officer]

Hi Bill,

 

This is a tangled web for sure and you did the right thing for sure and some of the comments below are not directed at any one specifically, but just general FYI.

 

The hose change technically would be due 5 years after the aircraft's initial certification date. Bill, you are absolutely right that hoses need to be done regardless of some of the legal maneuvering and you did the right thing. Squeezing a hose can not determine if it is any good. If it is hard then you are so far in the late stages of a hose hardening it isn't funny and no one has the x-ray vision to see on the inside. There is too much money and legal issues for an owner at stake at this time. There are too many players that can cause you grief. First you have the FAA and until they come out with explicit detail in writing then it may be costly to back that up. On one hand you have the aircraft Mfg. saying to follow the Rotax manual which clearly states to do the hose change. Then if you choose not to do it and have some type of failure the insurance company has grounds to not pay saying you didn't follow the recommended instructions from the aircraft Mfg and the engine Mfg again regardless of what the FAA says because you would need that in writing to over ride the others, so that is another costly argument with the insurance people. It's kind of like the IRS, you can claim anything and you can dispute anything, but how much are you willing to risk and pay for your argument. Sometimes the final outcome is ten times more expensive than the original issue in legal cost and wrangling for months to years.

 

Here is another example where the FAA has no say.

If you have an issue after warranty on a Rotax engine and you choose the option not to due the hose change, mounts or some other items that the FAA said you don't have to do. Now the engine has a major failure. Rotax has many times stepped up to the plate and helped the customers that have kept good records and done all the Rotax required maint. If people choose to save a buck and not do this then instead of Rotax offering them a new engine, called "good faith" help, you may be on the hook for an $18,300 on your own. A case in point. An owner just had a exhaust lifter failure at 833 hrs. The engine was a total loss. The paperwork was complete with all the check list, the logbooks inspection sign offs were long and not 2 sentences, oil analysis where done and all maint done on time with 75 hr. plug changes and 50 hr oil changes. Rotax offered a new engine for $7200 and prorated the engine for that 833 hrs. after 5 years. Not a bad deal. The big but here is choose to skip maint. in the Rotax manual or let a mechanic get away with poor documentation (this is more rampant than I care to admit) and Rotax and or the insurance company will have good grounds to not help regardless of what the FAA has said that wasn't in any explicit writing.

 

It all comes down to how much do you want to risk. We read and hear about these people all the time with legal, financial or busted aircraft issues. The FAA isn't going to jump in and help you, you will be on your own to get things straightened out. Most people don't know it, but GA aircraft has hose requirements too.

 

Why make yourself one of these people when it's just as easy and less costly and usually safer in the long run to do the right thing.

 

 

A couple of other comments.

It should not take an LOA to do the hose in the wing. There is a service letter or LOA with instructions on how to do this and it has been out for years (Feb. 2009). You legally don't need an FD service center either to do the engine isolator change out. Most people are getting these done with the mechanic at the hose change shop.

Here is a copy of the wing hose replacement document. I am posting another picture and document for when people do a hose change to re-route the fuel lines lower and down through the engine frame to be out of the way of the airbox. These documents and all LOA's are under our thread called "Flight Design Letter's of Approval". I would take a few minutes and just read down through those so everyone may get acquainted with what's included and approved for our LOA's.

09 02 10 FD Manufacturer Approval CT2kCTSW hole in root rib.pdf

08 06 04 FD Manufacturer Approval for all CTSW re-routing of fuel lines.pdf

[Safety Officer]

Our forum is a great place for information that pertains to CT's and LSA in general. Before I would let a mechanic that isn't on this site, doesn't have all the current Rotax and FD or other aircraft manuals , service documents or first hand training I would come here and look around or ask some questions because many times someone else has already been through the process that you may need done. This can save you a lot of time and money. Our community here is just for that purpose, to foster friendships beyond our municiple boundaries and a good maint. knowledge base, bare none.

 

You know what the three pontificaters say:

 

All for One and One for All!

[BMcCand - N248CT]

Hi Roger,I used the wrong term about the wing pull. We used the 09 02 10 directive that you cited, not getting another LOA.The manual said 3 people for a wing pull, but I see how it could be done with one person,and two stepladders.I guess I did the 5yr hoses a little early, based upon manufacture date rather than spec. airworthiness. Oh well.The engine pull is something that needed specific training. Would not have wanted to do that alone the first time.I might have opened up a lot more wires and pipes than was actually needed with pivoting the engineto the right, instead.Always more to learn from the Rainbow folks.

 

[Roger Lee]

Hi Bill,

 

I never hurts to do things early because something always comes up if you wait to the last minute. It has been a parts issue for some so I always advise to buy your 5 year hose change parts early. I usually buy 4 sets at a time. I would advise owners to do the parachute inspection a little early too.

[Doug Hereford]

To all,

I agree whole-heartedly with following manufacturer's recommendations 9 times out of 10. In the case of hose changes, as I posted eariler, I do also recommend changing them in and around the five year point. Technically speaking, hoses manufacturered to any recognized industry standard or TSO will have a date code somewhere on the assembly, or indelibly marked on them. That would be a good starting point when making a decision to replace based on calendar. Just because an aircraft was certificated on a certain date, does not mean the the hoses installed did not sit around on a shelf in a built-up state for months or even years before installation. Flight Design is better than most to be sure, but it is not uncommon to find a brand new aircraft with manufacturer required time change items that have a bunch of calendar run off of them simply due to manufacturing logistics. Hoses are a prime example of this. If aged hoses were installed as in the example I mapped out, following the manufacturer's recommendation to change at five years from certification could actually lead to older hoses in service.

 

The original question asked about legal hose change requirements. My answer stands in legal and safety respects.

 

I am going to comment on the example given on the hoses that were changinged by N248CT. "The only deterioration was the inside of two coolant hoses at tight bends." This is a VERY good find. N248CT may have prevented an unscheduled maintenance event by uncovering this unsafe condition. You have to admit however, that the unsafe condition did not exist due to the age of the hoses, but because they were improperly routed / supported. Any type of conduit has a minimum bend radius that must be respected. Obviously in your example, the coolant hoses were routed in a way that exceeded this recommended minimum bend radius. This is what caused the unsafe condition. I wonder how many condition inspections had been performed without uncovering this. Or maybe the improper routing/supporting is a manufacturing defect that FD should become aware of so that a Safety Directive could be issued to mandate by law, the changing of these subject hoses, and correction of improper routing. Maybe FD's condition inspection check list is not of the scope and detail necessary to allow for proper inspection of these hoses, in which case a Safety Directive must be issued to mandate additional inspection/hose change. Maybe there was an unauthorized alteration to the aircraft that re-routed the hoses outside of ASTM standards (which should hopefully have been uncovered on condition inspection). I don't know the answer, but suffice to say, there is a legal system in place to discover and correct unsafe conditions. It must be followed. My recommendation (if not already done) would be for N248CT to investigate the circumstances that may have lead to the partially kinked hoses, and report it to FD ASAP so that a proper resolution can be made.

 

As for "Legal Maneuvering". Safety Officer, I realize that you said that you were not directing your comments toward anyone specifically, however just to be clear. There is absolutely no "Legal Maneuvering" on my part. What is legal is safe. What is safe is legal. That is why the system works. I recognize that my views may be in stark contrast with most others on this forum, but I assure you that my statements about what is required, are based strickly on regulation, and that my goals are the same as yours.

 

One more thing for NC Bill. Because 5 year hose change is not required by law (unless Safety Directive, Airworthiness Directive, or Airworthiness Limitation require it) there is no reason to change them "early" unless an inspection of them reveils an unsafe condition (like a kink for example)that can only be corrected by changing one or more.

 

Doug Hereford

[Safety Officer]

Hi Doug,

When I referred to legal maneuvering I meant between the FAA, Rotax, the aircraft Mfg's which puts the owners in the middle and possibly at odds with the insurance companies over a claim.

[NC Bill]

Thanks to all for your time answering the question.

 

It's a privilege to have access to your knowledge and experience.

[BMcCand - N248CT]

I agree the hose routing might be a design issue. N248CT is maintained by the book. FD worried about the bend radii , as evidenced by

putting springs inside the hoses. The inside bends had cracking if I bent the hoses the other way. I didn't find fragments of

rubber in any drained coolant. Don't know if others have seen coolant hose degradation, but I think i heard it somewhere.

 

Roger, I'll be following your earlier advice to call BSR and reserve a slot for parachute repack. Due this year for me.

 

Other (NC) Bill - I find this dialog very valuable too !

[Doug Hereford]

NC Bill,

 

I will give another reply on the subject of hose changes (you can substitute any manufacturer requirement/recommendation that is not attached to an AD, Safety Directive, or Airworthiness Limitation).

 

Here is one practical example: Your airplane goes into maintenance for condition inspection. During the inspection, the inspector informs you that the hoses are going to be due for five year manufacturer required replacement in two months. The condition inspection is completed, and the aircraft is approved for return to service. Your initial thought was probably that you should change the hoses early to avoid a second maintenance event in two months. You don't have to do this unless you just want to. It would be perfectly legal and advisable to defer the hose changes until the next scheduled inspection or other maintenance. If the same hose changes were driven by Airworthiness Directive, Safety Directive or Airworthiness Limitation, you could NOT defer them, and if the aircraft were operated past the two month calendar without complying with the AD, SD, or AWL, then the operator would be in violation of the law each time he/she operated the aircraft.

 

If I were inspecting your aircraft as in the example above and found a hose kinked beyond standard radius allowance, I would squawk that hose (and that hose only) regardless of its age. The aircraft would not be approved for return to service by me until that hose was changed and the routing/supporting issue corrected.

 

Doug Hereford