Annual condition inspection without oil change?

[Roger Lee]

An LSRM-A can not supervise. Only the A&P can. That's taught in all the schools.

[Doug Hereford]

Dggrant,

You did not specify LSRM inspection rated only. Since these certificated individuals can only perform inspections, I agree that they cannot supervise. I was also assuming you were talking about SLSA. As you properly noted, ELSA do not fall under the requirements of part 43.

 

Dggrant and Roger (and all),

A LSRM with a maintenance rating can supervise someone performing maintenance that he/she (the supervisor) is authorized to perform, and approve the aircraft for return to service afterward. Except as is noted in FAR 43.3(d) which does not allow supervising of required inspections. Again, I'm talking about SLSA airworthiness here.

 

Also, just to clearify, FAR part 43 absolutley does apply to SLSA.

 

Roger,

I'm assuming that you are a certificated Repairman with a maintenance rating. You would be legally allowed to supervise someone while they perform maintenance that you are allowed to perform (ref. 43.3 (d)). FAR 43.7(g) then allows you to approve this airplane for return to service after that maintenance. As I said before, part 65 limitations still apply.

 

 

Doug Hereford

[Roger Lee]

Hi Doug H.

 

I have talked to several in the FAA and Carol at Rainbow Aviation which is the only FAA approved LSRM class in the country with Carol sitting on a few of the LSA committees. I have been in numerous classes and they all teach LSRM's can not supervise with SLSA, only A&P's can. I'm 100% sure on this one. Call both entities and double check, but I'm sure they'll tell you the same thing.

 

(If it's an owner approved item then it wouldn't be supervising.)

[Doug Hereford]

Roger,

 

Please have any and/or all of your sources quote specific regulatory languauge. Just because they teach a class, are FAA or sit on a committee does not give them authority to supercede laws, and does not make them experts either.

 

My suspicion is that some what what these people have said has possibly been taken out of context, but maybe not.

 

As I stated above, LSRM with inspection ratings cannot supervise. LSRM with maintenance ratings can supervise maintenance (not inspections however) that they are authorized to perform.

 

Please get those regulatory references, and names of sources (on the oil change issue too).

 

Doug Hereford

[Rogerck]

Speaking of annuals, I'm getting ready to have our A&P do ours. We always do owner assist and the mechanic finds this very helpful. He's not speciafically Rotax or LSA trained. There are not such people in our local area and we prefer to keep our aifcraft on field using a mechanic we know and trust. At any rate, in addition to the FD and Rotax checklists, and all the additional things good A&P's look at, I was wondering if the mechanics on this site who have completed numerous CT inspections have or could put together a list of items that most frequently have issues? A critical list such as this would be very helpful to those of us that don't have access to highly experienced CT mechanics.

 

Thanks,

 

Roger Kuhn

 

PS Perhaps the Administrator could set up a questionairre/table where everyone could add significant items that came up during thier annuals. We would then have a running survey as the the most important recurring items.

[Doug Hereford]

Rogerck,

The only thing I would offer off-hand is that, as of the last time I checked, the FD checklist does not speak at all to inspections of the BRS. Make sure that your mechanic properly inspects this IAW something from the mfg.

 

Roger Lee,

I don't mean to be a pest, but I do expect you to get those regulatory references, and names of your sources (I already know Carol), for your stated positions on supervising maintenance by repairmen.

 

I was looking back at some previous posts, and ran across one where you stated that maintenance personnel don't approve SLSA for return to service after inspections (Only certificated aircraft). As it pertains to this discussion of condition inspections. I would ask you to expand on that as well.

 

Doug Hereford

[Roger Lee]

Hi Doug H,

 

You can talk to Carol at Rainbow or Edsel Ford or any of his assistants.

 

You can look up the inspection verbiage on almost any site like the AOPA, EAA, ask Carol or the FAA.

You do not put an LSA back in service after the annual Condition inspection.

If it was a GA aircraft and had an annual you could, but we don't get annuals, we get annual condition inspections.

 

I should be wondered something along these lines and this is published all over the net.

 

"I certify that I have inspected this aircraft within the scope and detail of the Rotax and Flight Design maintenance manuals and found it to be in a safe condition for operation."

[Doug G.]

Here is the response I got from Carol about the regs-

 

There are certain repairman who can supervise-65.103 © excludes the Light Sport Repairman

 

Sec. 65.103

 

Repairman certificate: Privileges and limitations.

 

(a) A certificated repairman may perform or supervise the maintenance, preventive maintenance, or alteration of aircraft or aircraft components appropriate to the job for which the repairman was employed and certificated, but only in connection with duties for the certificate holder by whom the repairman was employed and recommended.

( A certificated repairman may not perform or supervise duties under the repairman certificate unless the repairman understands the current instructions of the certificate holder by whom the repairman is employed and the manufacturer's instructions for continued airworthiness relating to the specific operations concerned.

[© This section does not apply to the holder of a repairman certificate (light-sport aircraft) while that repairman is performing work under that certificate.]

====

 

I take that to mean that a repairman can only supervise when they themselves are doing work under an A&P.

 

As far as the annual sign off - I learned from the FAA that the correct wording is on the airworthiness document that should be with the airworthiness certificate in every SLSA. [Not sure about ELSA]

[Doug G.]

Doesn't do parenthesis well, evidently.

[Roger Lee]

Hi Doug,

 

That's correct. I (LSRM-A) can't legally supervise a pilot to let's say remove engine components. I also can't work on a "certified" 912S Rotax engine, but I can if I'm supervised by an A&P.

[Doug G.]

OK,what does that say about the owner being included in the 100hr/annual checklist on the CTLS?

[Doug Hereford]

Dggrant, Roger,

FAR 65.103© excludes LSRM. The relevent rule is FAR 65.107. There is nothing within that rule, or part 43, that prohibits a properly qualified repairman from supervising maintenance. In fact, 65.107 actually states within it, that a repairman can supervise.

 

excerpt from 65.107(d): "If that person has not previously performed that work, the person may show the ability to do the work by performing it to the satisfaction of the FAA, or by performing it under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned."

 

Also Roger, as long as the aircraft is certificated as a SLSA/ELSA (not standard or other airworthiness), a properly qualified LSRM can perform maintenance on the engine, even if it is a certified version of the engine.

 

 

As for the owner items on FD checklists, I stand firm that an owner cannot perform any parts of any required inspection.

 

Doug Hereford

[Doug Hereford]

To all,

 

A couple of additional points related to LSRM privileges and limitations:

 

An LSRM with a maintenance rating may perform maintenance, and approve for return to service afterward, a SLSA certificated aircraft with a standard airworthiness “certified” engine (or other component part) installed. He/she may not approve for return to service after a major repair or major alteration to this certified part however. (ref. FAR 65.107© (1).

 

An example of this situation would be the Cub Crafters S2. It is SLSA (pink airworthiness) however, it has a Continental O-200A “certified” engine installed. A LSRM with a maintenance rating may perform maintenance on this engine, and approve the aircraft for return to service afterward. The LSRM would not be authorized however to approve this aircraft for return to service after a major repair, or major alteration to this engine.

 

Rogerck referred to an “owner assisted” inspection in a previous post. In my experience, this a common practice with smaller aircraft, and perfectly legal as long as the rules are followed.

Actually, thinking of this practice as owner assisted, can be misleading because, almost anyone can assist. It doesn’t have to be an owner. This would fall under the scope of supervised maintenance. As long as the assistant is doing non-inspection type maintenance, like pulling panels, cleaning parts, and repairs found necessary during the inspection, they may be supervised by an LRSM with maintenance rating, or an appropriately rated mechanic/repair station. The assistant cannot perform ANY part of the actual inspection (regardless of whether they own the aircraft or not). Technically speaking, the assistant’s name should be included in the maintenance record entry, for the specific work that he/she performed, and the inspector should follow-on with the required inspection sign-off there-by approving the aircraft for return to service. (ref. FAR 43.9)

 

An example of this entry might look like this:

 

Performed condition inspection on XYZ aircraft IAW inspection procedures dated xx/xx/xxxx. The following additional maintenance was performed by Joe Blow.

1. Changed R/H MLG tire and tube IAW XYZ aircraft procedure 123. Installed P/N: xxx tire and xxx tube.

2. Aircraft serviced and lubricated as required IAW XYZ procedures contained in ch. 12 of XYZ mx procedures manual.

3. R&R all required aircraft inspection panels to facilitate the above noted inspection.

4. Complied with XYZ aircraft Service Bulletin ABC in accordance with the accomplishment instructions provided.

 

Maintenance note: the status of applicable Airworthiness Directives, and Safety Directives related to this aircraft can be found (give location).

 

I certify that this aircraft has been inspected IAW XYZ manufacturer’s inspection procedures, and was found in a condition for safe operation. Date and aircraft TTIS

 

Signature, certificate type and number.

 

The "maintenance note" within this sample, is not required. Researching AD’s and SD’s is required however. (ref. FAR 43.15(a)(1).

 

Doug Hereford

[Roger Lee]

That's it. The LSRM can not supervise or have an owner assist like an A&P can. We (the LSRM-A) have limits.

 

"As long as the assistant is doing non-inspection type maintenance, like pulling panels, cleaning parts, and repairs found necessary during the inspection, they may be supervised by an LRSM with maintenance rating, or an appropriately rated mechanic/repair station. The assistant cannot perform ANY part of the actual inspection (regardless of whether they own the aircraft or not)."

 

Exactly what Doug G and I have been saying.

 

The SLSA with the Continental is still an SLSA. It isn't a certified engine in a regular type certificated category aircraft. As an LSRM I can not work on a type certificated motor-glider with a certified Rotax 912S without being under the supervision of an A&P. Even then the A&P is supposed to have Rotax knowledge, but he wouldn't have hired the Rotax mechanic LSRM if he had a clue to start with.

Anytime we talk about LSA and the other aircraft types it is always type certificated verses LSA. There's their world (type certificated) and then our world (LSA) and they may cross paths, but aren't always the same.

[Rogerck]

Ah, there are times that I certainly appreciate that our (with my co-owner) CTSW is classified as an Experimental Light Sport Aircraft. There is nothing about this category that precludes everything being done safely and prudently, but it sure eliminates the wrangling over technical differences that may not make practical sense. Not all of us are fortunate enough to live in an area where there are light sport repairman with maintenance ratings that know both CT and Rotax. In fact, there are very few of these people across the country. We have to rely on A&P’s that have years of experience, who get it, and can be further educated by information such as this forum. From a strictly CT perspective, I wish there were lots of Roger Lees and Doug Herefords across the country, but this isn't the case.

 

One person's opinion.

 

Roger Kuhn

[Roger Lee]

When I see an annual condition logbook entry like the one above I would give it a 4 out of ten. It lacks many essential elements of the inspection that should show trends and information the owner and next mechanic should have. No oil change info on the mag plug, oil filter or the type or amount of oil, or plug info with gap and if thermal paste was applied, no slipper clutch info for comparison next inspection, no compression test for comparison next inspection. No gascolator fuel flow test, no ELT check, no info on whether a carb sync was done, no info when the next inspection(s) are due,nothing mentioned if the air filter was cleaned and this is what I would consider a bare minimum. Since we talk about hoses here so often why isn't there at least a comment to show they were at least looked at and found in good condition. Nothing mentioned on whether the instruments like the Dynon's or GPS are up to date with current software.

 

Things not logged are then assumptions that the last person did it, but since they usually don't bother with a check list or log it you the new mechanic assume wrong. I find things all the time on my new first time clients that have had 5-6 annual inspections with a laundry list of things not done and no way to check it because the logbook labels were too skimpy in detail. You know they didn't use a check list or have a clue about a Rotax or CT. Some have no detail just state the the inspection was done and that's a sin. Might be legal, but it's still a sin.

 

If it isn't logged and or the mechanic didn't give the owner a signed off check list then how would anyone know if the mechanic used a check list and especially what he really did since he didn't log it. I find tons of things mechanics don't check and point them out to owners so they know their mechanic isn't checking things or using a check list because if he did that many things would not have been missed because they come right off the Rotax and FD check list.

The statements in the example are too broad and have no specifics so you don't know if things were done so you have to assume they were done and 60% of the time they aren't done.

 

On point #2 in the logbook list I see all the mechanics write something along this line to cover what they think the inspection should have been, but didn't really use a real Rotax or FD check list so they missed 40% of the things to check or haven't even read all through the FD or current Rotax bulletins to know what needs to be checked on an on going basis.

 

When I call and question some mechanics to see if they did something because they didn't log it they say they didn't have time to look things up or find a check list.

[Doug G.]

What Roger L. said.

Doug G.

[Roger Lee]

Sorry for the soapbox :unsure: , but this is such a poorly addressed area from too many mechanics and it's just too easy to be more complete.

 

 

I would say we as a group can absolutely influence our mechanic's and meachanic's across the country. You as an LSA owner just need to let them know what you expect and what they should use to make sure they have taken and inspected all things that will assist you in being safe and keeping your family members and friends safe when they fly with you.

 

Ask them to use the Rotax and FD check list. Print it out for them and have them sign each item and give it back to you so you and the next person know what was done and you don't have to assume. Keep these in a 3 ring binder. Make them detail a better logbook entry. If you need examples I'll be happy to send you a few. They absolutely don't need to look the same just show some detail. Certainly they did more than just change the oil and write I did and annual inspection. Good detailed documentation is the mechanics only protection in court. Make poor logbook entries and get eaten alive in court if you ever have to go and defend yourself.

You are paying their salary to do a job a certain way and many get a handsome dollar for their work. If they are too hardhead or stubborn then maybe it's time to work with another mechanic. Starting fresh is not always a bad idea. Maybe a good idea is to send your mechanic to Rotax school in consideration of the next annual. You should take a pro-active interest in your mechanic and maybe the old timer needs to be brought up to date.

[Doug Hereford]

To all,

 

The maintenance record entry example that I used in my previous post was not intended to cover technical particularities of any specific aircraft model (hence the XYZ aircraft model notation). I was trying to illustrate one way to document supervised maintenance, as that is what we have been discussing recently.

 

To Roger, and Dggrant,

Apparently I have misunderstood your postitions on whether or not a LSRM with maintenance rating is allowed to supervise someone performing maintenance. I was under the impression from reading your replys, that you have been taught in schools, that LSRM with maintenance ratings cannot supervise at all. Dggrant, I believe you cited (through Carol) FAR 65.103 and a basis for this opinion. If this is what you two have been saying, then I will continue to disagree with both of you until you can provide relevant regulatory citations to prove otherwise.

 

To restate my points another way:

1. A LSRM with a maintenance rating can supervise maintenance (just not inspections). Therefore, if done the way that I tried to describe in my previous post, an LSRM with a maintenance rating can perform an "owner assisted" Condition inspection (SLSA, or ELSA).

2. A LSRM with an maintenance rating can perform or supervise maintenance on a "certified" engine installed in SLSA (It doesn't even have to be physically installed in the aircraft).

3. FAR 65.103 is not applicable to LSRM at all, and is not a basis for any of the privileges or limitations imposed on them. The relevant reg. is FAR 65.107. All LSRM should review and completely understand this rule.

 

Doug Hereford

[Roger Lee]

Okay I finally got to talk to the FAA after the holiday and had already talked to Rotax and here is their stance on our two subjects in question.

 

First question: Is the oil change mandatory during an annual?

Rotax's stance was that they put it on the check list because some people may only fly 10 hrs a year and they want the oil change done at least once a year and not left to sit in the engine. So for that guy yes it needs to be done. But if you are on a Rotax recommended schedule and it's documented then it's not a requirement.

The FAA stance was the same. So long as you are on the Mfg's recommended schedule and have it documented then in the logbook, then document it that way on the check list and the logbook.

 

 

Second question: Can an LSRM-A supervise an owner assist 100 Hr or annual. NO, he can allow the owner/pilot to remove wheel pants or inspection ports and clean parts, but he is not allowed to do any part of the inspection. The owner can perform what is allowed to do as preventative maint. as it is described in the FAR's and this should be documented by the mechanic in the logbook as to what the owner did during the inspection. This is pretty much the way it is taught in schools all over the US.

 

The LSRM does not have the same rights in an owner assist as the A&P does.

 

 

My sources are Rotax and Edsel Ford of the FAA LSA division.

These are the standards that a mechanic will be held to so if you don't agree with either authorities stance I would call and convince yourself so as not to put yourself out there on that proverbial tree limb.

[Ed Cesnalis]

Thanks Roger,

 

Final question is what [documents as well as relevant sections] are Rotax and Edsel Ford hanging their hats on? Otherwise we are back to "it is what is taught in school" or knowledge that is passed verbally.

Doug's case is persuasive, where is he wrong?

[S3flyer]

Rotax's stance was that they put it on the check list because some people may only fly 10 hrs a year and they want the oil change done at least once a year and not left to sit in the engine. So for that guy yes it needs to be done. But if you are on a Rotax recommended schedule and it's documented then it's not a requirement.

The FAA stance was the same. So long as you are on the Mfg's recommended schedule and have it documented then in the logbook, then document it that way on the check list and the logbook.

Roger, appreciate you chasing this down. Thanks.

 

[Roger Lee]

Hi Ed,

 

I already knew the answers, but did the calls for others. If people have further questions they may be better served by directing them to the FAA as they are better equipped to quote chapter, verse and or legal precedents. Unless you hear it from them my research will always be questioned.

 

p.s.

I'm going out tomorrow and get some in flight numbers for the Sensenich prop, i.e. TAS, WOT RPM, ect... I did them once, but since it has been a while I forgot what they were.

[Doug Hereford]

To all,

I stand firm on everything a have said in past posts. I do appologize however, because I don't how anyone could be following this discussion and be anything but thoughly confused.

 

Doug Hereford

[Roger Lee]

That's why I think anyone that still has questions should call the FAA. We can all think what we want and practice what we want, but we will be judged and violated from the FAA.

 

Then the arduous task of getting out from under that rock falls right on the individual. At the least it would take time which is money out of the mechanics pocket and you'll still have those pesky bills to pay in the mean time and the worst will be spending a long suspension and throwing legal fees at it trying to get your licence back or trying to overturn the whole thing.

 

Better to make a free phone call up front. It will save time and money later.