Public Penance

Every now and then, a mechanic drops me a letter. Many of these letters make great safety suggestions and others rag on me about the FAA in general, or a particular ugly regulation, or both.


Every now and then, a mechanic drops me a letter. Many of these letters make great safety suggestions and others rag on me about the FAA in general, or a particular ugly regulation, or both.

I promise you that I read and answer every mechanic's letter sent to me, because these kinds of letters number so few. I suspect the reason I have a near empty in-box is how mentally uncomfortable a mechanic feels about "waking up" a bureaucrat in Washington . Many mechanics have this unnatural fear that their name will go on a black list – entered into a big computer buried deep somewhere in the bowels of FAA's Washington headquarters. Once a name is entered, it remains forever listed with others who have fallen from bureaucratic grace, in a encrypted file titled: People we get next!

So, to avoid unwanted grief, most mechanics are content to put up with the FAR fleas, just to let bureaucratic sleeping dogs lie. But there are always exceptions to this rule. One such exception is a mechanic by the name of August Blake, an IA from Louisiana . About once or twice a year, August writes me a letter, and despite my earlier statement that I read every letter from a mechanic, I must admit that I am a bit reluctant to pick up and read August's letters. Why? Because 99 percent of the time he chews me out, and 99 percent of the time, he is right.

Last week, August sent me another letter. Like the true southern gentleman he is, August first complimented me on my maintenance presentation about ELT inspections at the Gulf South seminar. But, August then pointed out that I did not properly cover all of the ELT inspection requirements in part 91, section 91.209, Emergency Locator Transmitters. Okay, August, you are right – again – so, in public penance for my mistake, what follows is a complete description of the ELT rule and inspection requirements.

Background

Emergency Locator Transmitters (ELTs) became part of our aviation environment with the signing of the 1970 Occupational Safety and Health Act. Not many people are aware of the fact that the original requirement for ELT installations was a congressionally driven law, not an FAA inspired regulation.

As required by the new act, the FAA followed up with an implementation regulation that required ELTs to be installed in a majority of the general aviation fleet by June 30, 1974 . Some early exceptions were that ELTs were not required for aircraft on local training flights, ag aircraft, R&D aircraft, single-seat aircraft, rotorcraft, and turbo jets. Later ELT exemptions pertained to aircraft showing compliance with the regulations, crew training, exhibition air racing, and market surveys. The early ELTs manufactured under TSO C91 were less than 100 percent successful. Models with lithium/sulfur-dioxide batteries vented corrosive, and sometimes explosive gases. Other ELTs had hair-trigger "g" (crash sensor) switches that fired off the ELT if an overweight gnat landed on the propeller tip of an aircraft tied to the ramp. Improper installation of the ELT, hard landings, antenna/wiring faults, or just plain internal failure of the transmitter's innards, caused other ELT false alarms. Despite the millions of dollars wasted annually on false alarms, the early ELTs did save a number of lives. But, the continuing failure rate of an aviation product caught the attention of the National Transportation Safety Board (NTSB), who in 1988, issued NTSB Safety Recommendation A-87-104 which suggested existing ELTs be replaced with those that complied with TSO-C921a by 1989. In October 1990, (NASA) National Aeronautics and Space Administration and the FAA completed a report entitled Current Emergency Locator Transmitter Deficiencies and Potential Improvements Utilizing TSO-C91a ELT. This report was the driving force for the June 21, 1994 FAA rule change to part 91, section 91.207, which mandated all new ELT installations to meet TSO-C92a. The new rule did three things: 1. terminated the manufacture of ELTs under the old TSO-C91; 2. required that as of June 21, 1995, all new installations and replacement ELTs must meet TSO-C91a; 3. made mandatory inspection and recording requirements specific to ELT installation.

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