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Bing Float Bowl Inspection


Runtoeat

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The following is an excerpt from a legal interpretation issued by Mr. Paul Greer, Office of the Chief Counsel, FAA, which pertains to "manufacture's recommendations" pertaining specifically to Rotax.  Note in particular the part of footnote 1 which deals with the lack of an Airworthiness Limitations Section which normally is found in an aircraft's Airworthyness Operating Instructions.  LSA aircraft do not contain Airworthiness Limitations sections.  So, the mechanic is allowed to "...use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator  (Underlining and bold done by me).  The full text of Mr. Greer's letter is attached.

 

Mr. Charles Willette
President
Dodge Center Aviation, LLC
802 South Airport Road
Dodge Center, Minnesota 55927
Dear Mr. Willette:

 

This responds to your e-mail dated March 14,2013 in which you requested a determination
as to whether information contained in the maintenance manuals for aircraft issued special
airworthiness certificates in the light-sport category (S-LSA) is mandatory. You specifically
question whether component replacement and engine overhaul times specified by
manufacturers as being mandatory must be complied with.  The rules applicable to the

performance of maintenance, preventive maintenance, rebuilding, and alteration of S-LSA

are contained in part 43 of Title 14, Code of Federal Regulations (14 CFR). Section 43.13

sets forth the performance rules applicable to persons performing work on these aircraft.

Paragraph (a) of that section specifically states that:

Each person performing maintenance, alteration, or preventive maintenance on
an aircraft, engine, propeller, or appliance shall use the methods, techniques,
and practices prescribed in the current manufacturer's 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.
Part 43 does not mandate that a person specifically perform

maintenance, alteration, or preventive maintenance solely in accordance with those instructions

specified in a manufacturer's maintenance manual. It also permits a person to perform such

work in accordance with other methods, techniques, and practices acceptable to the
Administrator.

 

I Section 43.16 refers to Airworthiness Limitations. A person performing an inspection or other maintenance
specified in the Airworthiness Limitations section ofa manufacturer's maintenance manual must perform that
work in accordance with that section or as otherwise specifically approved by the Administrator. Maintenance
manuals for S-LSA do not have an Airworthiness Limitations section to which the provisions of this section
would apply.

 

greer legal interpretation-2013.pdf

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Also if you read some of Rotax's service bulletins it says or equivalent.  So you have to read all the service letters, service bulletins, service instructions because some of those supercede what's in a book. Rotax usually only updates books once a year.

 

Is it tough to be 100%, yes, but most of us do a fine job without any hitches.

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That stands for reference.

That "reference" term means a source document with authority.

 

Right, but authority in terms of technique, or legally binding to the owner/operator?

 

Not trying to be obtuse, I'm genuinely curious.  Sourcing acceptable methods and conferring a legal duty to use those methods are different things.

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This is typical thread creep caused by someone who wants to nit pick, give it a rest guys. You are both right and you both know it. We were talking about float bowls.

 

You can call it nit picking if you want. As someone who has been working in the aviation maintenance sector for almost 35 years I feel it important to speak up when someone who is respected within the light sport community offers advice that goes against the manufacture's recommendations and standard practice within the aviation community.

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