Moving from a Baron to a King Air
What’s the big deal?
By Joe Hertzler
The inspection process is what keeps our aircraft safe and efficient. The rules are very specific. In order to continue operation of an aircraft, inspections must be performed periodically and the aircraft must meet the criteria of the inspection(s) without defect. If an inspection reveals no discrepancies, a logbook statement is made indicating the aircraft is "airworthy." Conversely, when the aircraft has NOT successfully passed the inspection and discrepancies were identified that need to be corrected, the statement entered into the logbook is one of an "unairworthy" nature, (See 14 CFR Part 43.11). There are only two choices following an inspection — airworthy or not.
How the process works
An inspection is conducted, all findings or discrepancies are written down, all discrepancies are corrected, the maintenance performed to correct the discrepancies is properly recorded in the logbooks, and the inspection is then signed off in the logbooks as airworthy. In the case where not all of the discrepancies are corrected (sometimes a decision of the aircraft owner), the inspection is signed off as "unairworthy" and a list of uncorrected discrepancies is provided to the owner [See CFR Part 43.11 (b)].
Moving from piston to turbine
Many times, aircraft owners suffer quite a shock when they make the move from a piston twin to a twin turbine aircraft. Although it is a natural progression, the impact of such a move is almost always underestimated when it comes to the inspection requirements for the aircraft.
This is the first of a three-part series dedicated to aircraft inspection programs. This article will discuss the separation point and draw a clear line of distinction between the basic inspection requirements for smaller, less complex aircraft, and the larger, more complex aircraft.
The regulation that makes the distinction is 14 CFR Part 91.409. This is the rule that specifies the inspection requirements for aircraft operated under Part 91. Together with the many other regulations referenced, 91.409 provides a picture of the FAA’s separation point between Basic aircraft — those requiring Annual Inspections, and Complex aircraft — those requiring inspections as specified by an inspection program.
The basic inspection for aircraft is the Annual Inspection and is required to be performed – you guessed it – every year. Specifically, the frequency of an annual inspection is every 12 calendar months. What this means, for example, is that if an annual inspection was performed on January 12, 2001, the next annual inspection is due no later than the last day of the same month of the following year.
Another option for the lighter, less complex aircraft is the Progressive Inspection. A Progressive Inspection is a program submitted to the FAA (or provided by the manufacturer) that provides for small portions of the inspection to be performed at specific intervals so that a complete aircraft inspection is accomplished each 12 months [See CFR Part 91.409 (d)].
The required "Scope and Detail" of an Annual Inspection is contained in 14 CFR Part 43 Appendix D. Appendix D contains the list of items that, as a minimum, must be included on the inspection guide used by the inspector. As stated in Part 43.15 (c), "...whenever an annual or 100-hour inspection is performed, the person performing the inspection must use a checklist."
The majority of aircraft manufacturers provide an inspection guide to be used by the mechanic. Manufacturer-provided inspection guides are usually contained within the maintenance manual for the aircraft, but sometimes are published under separate cover. Care must be taken whenever using a manufacturer’s guide to ensure that the inspection guide is complete and includes all the requirements of Part 43 Appendix D.
For rotorcraft there are a few additional specific inspection requirements (other than Appendix D) contained in CFR Part 43.15 (b).
An annual inspection must be performed by either an IA [See CFR Part 65.95 (a)(2)] or a certificated repair station rated properly for the aircraft being inspected [See CFR Part 145.51 (c)].
A progressive inspection may be performed by a mechanic without Inspection Authorization, as long as the inspection is being supervised by the holder of an Inspection Authorization. As the holder of a repair station rating, the repair station establishes (with FAA involvement) who within the station is authorized to perform inspections "Qualified Inspectors" [See CFR Part 145.43 (a)(2)].
The inspection program
Separation Point for Annual Inspections vs. Inspection Programs
For the "Complex" aircraft as shown in Table 1, the owner is required to make a selection as to which inspection program will be used. The four options are found in CFR Part 91.409 (f) and are as follows:
1. A continuous airworthiness inspection program that is part of a continuous airworthiness maintenance program currently in use by a person holding an air carrier operating certificate or an operating certificate issued under Parts 121, 127, or 135 of this chapter and operating that make and model under Part 135 of this chapter and maintaining it under 135.411 (a)(2) of this chapter.
2. An approved aircraft inspection program approved under 135.419 of this chapter and currently in use by a person holding an operating certificate issued under Part 135 of this chapter.
3. A current inspection program recommended by the manufacturer.
4. Any other inspection program established by the registered owner or operator of that airplane or turbine-powered rotorcraft and approved by the administrator under paragraph (g) of this section. However, the administrator may require revision to this inspection program in accordance with the provisions of 91.415.
1. In some cases, the owner of an aircraft with 10 or more passenger seats may know of another operator of a like aircraft who holds an air carrier certificate and has an FAA-approved continuous airworthiness maintenance program for that make and model. The Part 91 operator may elect to use the inspection portion of the maintenance program in use and maintained by the air carrier operation. When he or she makes such an election, they would choose this option (f) (1).
2. Similar to Option (f)(1), this option is also for the operator who knows of another operator of a like aircraft who holds an air carrier certificate and holds an Approved Aircraft Inspection Program (AAIP) for that make and model. The Part 91 operator may elect to use that AAIP as long as the air carrier continues to have a like aircraft on their certificate and the AAIP is maintained to the FAA standard.
3. This option is the most common one used. Option (f)(3) is simply the inspection program provided by the aircraft manufacturer for their aircraft. I particularly like this option because the manufacturer is the one burdened with keeping it current. As the requirements of the program change, those changes are implemented for the aircraft.
4. This option simply allows the owner to develop and submit for approval, their own Part 91 inspection program. This "Owner’s Program" is often confused with the AAIP used in CFR Part 135.419. Once approved, the owners program can be used.
In any case, the owner is required to make a selection and record that selection in the aircraft maintenance records, [Ref. Part 91.409 (f)] so that those maintaining the aircraft know what inspection guide(s) to use while performing the inspection. Periodically, an aircraft will be moved from one inspection program under CFR Part 91.409 (f) to another option. Whenever this occurs, the owner is to make note of it in the maintenance logbooks, and is required to ensure that all of the requirements of the program he or she is entering are current and up to speed.
Regardless of which option the owner selects, the rule is clear on what must be included in the scope and detail of the inspection program for these multi-turbine- powered aircraft. CFR Part 91.409(e) states that: "...the replacement times for life-limited parts specified in the aircraft specifications, type data sheets, or other documents approved by the Administrator are complied with and the airplane or turbine-powered rotorcraft, including the airframe, engines, propellers, rotors, appliances, survival equipment, and emergency equipment, is inspected in accordance with an inspection program selected under the provisions of paragraph (f) of this section..."
Look Phase and Special inspections
As inspections go, an inspection program will generally contain multiple Look Phase inspections — inspections that require an inspection guide with several different items to look at, as well as several Special inspections —inspection of specific parts at specific time intervals. Look Phase inspections are usually referred to as A, B, C, D checks or Phase 1, 2, 3 or 4 or 100-hr, 300-hr, etc., while special inspections are simply listed as inspection or functional check requirements to specific components or parts of the aircraft As you can imagine, the requirements of such an inspection program are more specific to the aircraft and its equipment and in some cases, much more detailed than the basic annual inspection requirements contained in Appendix D of Part 43.
So, the difference between an "Annual" type inspection and the "Inspection Program" requirements of Part 91.409 (e) really lie in the type of aircraft being inspected as shown in Table 1.
Next issue, we will get into the detail of what makes up an inspection program recommended by the manufacturer, and some of the FAA guidance material for what is mandatory and what is "on condition" with respect to manufacturer recommendations.