Annual Inspections

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Built in grey area
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Annual Inspections

Can an IA sign off an Annual Inspection if that person only inspects the airframe items while an A&P performs a 100 hour inspection on the engine and prop of the same aircraft? 

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Anonymous (not verified)
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Umm, sure, an IA can sign off on anything, however he/she would be in violation of 43.15. There is no provision for delegating any portion of an inspection to another person. An annual inspection requires that the IA perform the entire inspection.

whitefaced
whitefaced's picture

Agreed,
An annual inspection is an "aircraft" inspection. If an IA signs off this inspection, he/she must have personally performed the inspection (entire aircraft) IAW scope and detail of App. D of part 43.

Anonymous (not verified)
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I hear this question from time to time, have even seen it done! I think this comes from the old argument regarding the proper sign off for the engine and prop portions of an annual inspection. Since there is no such thing as an annual inspection of an engine/prop, they get signed off as a 100 hour inspection, and the airframe on which they are installed get the annual sign off.

Folks then twist this to mean that since the engine/prop get a 100 hour inspection sign off as part of the annual, an A&P, or P can do that portion of the inspection and the IA the airframe portion.

I still see a lot of engines/props with annual sign offs, technically incorrect, but no one seems to mind much.

To answer your question you have to go to part 65.95 IA limitations allows an IA to perform the Annual inspection. Under part 65.81 mechanic limitation does not allow for an A&P rating to perform the annual inspection. The annual inspection covers the entire aircraft propeller, engine, and airframe and is signed off in the airframe records as being completed in accordance with part 43.11 and accomplished in accordance with part 91.409.(a)(1) and (d)(1).which takes us back to part 65.95. So the rule is pretty straight forward only the IA can perform the whole inspection and can NOT delegate any part of it to another.

Having said that if this were a 100-hour inspection then different A&P mechanics could perform the 100-hours and sign off the work they performed such as one mechanic with a powerplant rating performing the engine inspection, and the propeller and one mechanic with an airframe rating would sign off the airframe record indicating they accomplished the 100-hour inspection. If several mechanics help perform the 100-hour inspection each should sign off the part they completed per part 43.9. If one mechanic signs off the entire 100-hour and something happens since their name and signature are in the records they will be held accountable for the whole inspection.

The annual inspection only has to be signed off in the airframe records as being completed. However it is accepted practice by the field and FAA that IA sign off the engine and propeller in there record books with an annual. The proper way to sign off the annual is the part 43.11 entry goes in the airframe record and a 100-hours inspection in the engine and propeller logs indicting they were accomplished by the IA.

I have seen many records that indicate 100/annual inspection this is wrong as both inspection are signed off by a different rating. So for the annual inspection just write annual per part 43.11 and sign off with your IA. You could sign off the engine and propeller with a 100-hour using you’re A&P number and that would be correct.

In my IA refresher course I provide examples of this and how to perform the proper sign offs and show examples of what is not acceptable. Keep in mind part 91.417 provides what is required to be in the annual inspection entry and the owner is required to ensure we IA record the inspection correctly.

AnonymousCirrusPilot (not verified)
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Does this mean that the airframe, engine, and propeller all require separate individual annual inspections?
Is an "annual inspection" is not complete without these inspections and entries?

Anymouse (not verified)
Anonymous's picture

While it is common for misinformed mechanics to sign off an annual inspection in engine and propeller logs, this is incorrect. There is no such thing as an annual inspection of an engine, or propeller. The airframe log should contain an annual inspection entry, the engine and propeller logs should have a 100 hr inspection entry.

n14ky
n14ky's picture

91.409 is very clear, an AIRCRAFT can not be operated unless within the previous 12 months it has had an annual inspection. An annual inspection can only be performed on an aircraft. That aircraft includes the airframe, each engine, and each propeller along with all installed equipment. When you sign a maintenance record for an annual inspection, the most appropriate record for that sign off is the airframe log book or record. Since the engines were part of that annual inspection, and since the scope and detail of the annual inspection is identicle to that of a 100 hour inspection, the 43.11entry for the engines (and propellers) are then appropriatly 100 hour inspections. The airframe entry is the only one that you use your IA for as an IA is not authroized to perform 100 hour inspections (ref 65.95), you use your A&P for that.

Anymouse (not verified)
Anonymous's picture

Pretty much what I said, except 91.409 does not require all AIRCRAFT to have an Annual Inspection. Some may have Progressive Inspections and Multi Engine Turbine aircraft DO NOT GET ANNUAL inspections. They are however, inspected on an annual basis.

Bill H (not verified)
Anonymous's picture

I understand and agree with you, but if a engine only gets a 100 hr inspection and not an annual then why are they not required to have a 100 hr inspection every 100 hrs when operating under part 91?

Anymouse (not verified)
Anonymous's picture

You are still misunderstanding. An engine is not required to "get" a 100 hour inspection as part of the aircraft's required ANNUAL inspection.

The engine is merely signed off as having been inspected as per a 100 hour inspection because there is no such thing or criteria as an annual inspection of an engine.

This is simply a courtesy. If it would make you feel any better, you could not sign off the engine as getting a 100 hour, or an annual inspection and that would be perfectly legit as long as you recorded the actual maintenance you did and properly recorded the airframe annual inspection.

This is the kind of discussion that we all learn from. Per Part 91, the annual inspection is for the aircraft and the part 43.11 inspection record entry is signed off in the Airframe records. The airframe consists of all those items listed on the Type Certificate Data Sheet (TCDS) with for most General Aviation (GA) aircraft includes an engine and propeller. The proper way to inspect the engine and propeller during an annual inspection is with an inspection checklist and sign both off indication a 100-hour type inspection was completed per Part 43 Appendix D or the manufactures checklist. The Inspection Authorization (IA) is required to perform the entire inspection only. Keep in mind the annual is only an inspection and CANNOT be delegated such as having an A&P perform a 100-hour inspection on the engine or propeller. However, once the inspection is complete the A&P can perform maintenance and fix what the IA finds or it can be fixed during the annual. This brings up an important point that the items fixed must be signed off first then the IA can sign off the annual inspection as airworthy. If the annual is signed off, then there is a maintenance record entry for fixing stuff then the IA may be at fault.

Anymouse (not verified)
Anonymous's picture

I mostly agree Stache with the exception of your statement that signing off the engine and prop as having a 100 hour inspection is "proper"

Some may misunderstand that to mean that it is required. There is actually no regulatory requirement to do that, but I do agree that it is the common practice and certainly more "proper" than signing the engine/prop off as having an ANNUAL inspection.

An IA can sign off an annual inspection in the airframe record and only record the maintenance that was performed as part of that inspection in the engine/prop logs and be perfectly legal without signing them off as having an annual, or 100 hour inspection.

whitefaced
whitefaced's picture

We have established that engines and propellers do not get Annual inspections (more specifically Annual inspection sign offs). My rational for this is that neither of these products are "aircraft", and an Annual inspection is an "aircraft" inspection.

What is interesting to me is that, as I understand the relevant regs., a 100 hr. inspection is also an "aircraft" inspection as part 91.409 seems to stipulate.
Since the "aircraft" must be approved for return to service after the 100 hr. inspection IAW part 43, it would seem that a single person is actually responsible for doing this. What I mean to say is that a single set of items contained in 43.11 signature, cert type and #, etc...................

We know that this is not necessarily the case though when more than one inspector performs the scope and detail of the 100 hr. inspection on a particular aircraft's airframe or powerplant.

While I have participated in this type of process hundreds of times, I have never fully vetted it out in my mind. I have also been under strict FAA oversight with never an objection, or so much as a passing comment on the subject.

This is the only scenario I can think of where it seems possible that multiple inspectors (and signoffs) could be necessary to approve an "aircraft" for return to service.

Any thoughts are welcome. I do not mean to muddy the waters. An explanation might be in the theory that aircraft subject 100hr. inspection programs can have airframes out of phase with powerplants when considering inspection status. I have never heard of or seen this practice attempted. If it is legal, I should have been doing it years ago.

Doug Hereford

n14ky
n14ky's picture

When we get down to it, there is no requirement for separate records for the airframe, each engine, and each propeller. There have been many aircraft that I've worked on in the past with only one maintenance record (one log book) that covered all parts of the aircraft. Not that I recommend it, since it gets messy when you replace an engine or prop, but it complies with the requirements of 91.417. Having separate log books for each unit is a convenience for the aircraft owner, with no regulatory basis. Hence the signing of inspections in the separate log books is also only a convenience for the owner. That said, if you do make entries, as a mechanic, they need to meet the requirements of 43.9 and 43.11. Making a single entry in the airframe log providing you identify all the work performed per 43.9 and the inspection per 43.11 is all that is required by the regulations.

whitefaced
whitefaced's picture

n14tky,
I agree with all that. That does not address the scenario I asked about.
In the case of a 100 hr inspection where more than one inspector participates, there seems to be a need to have more than one inspection sign off. Since a 100 hr. is still a whole aircraft inspection, how is this possible?

It is as though 65 allows a mechanic to do something that 43 does not provide for.?

The other option might be that one inspector signs off the entire aircraft (even though say two persons inspected it airframe for one and powerplant for one). I don't think this would be legal, because one would have to have been supervising the other which is not allowed on inspections (43.3).

Back to inspections out of phase. Doesn't make sense to me either, but can't totally map it out.

Doug Hereford

Anymouse (not verified)
Anonymous's picture

Doug, I think you are missing Stache's earlier point that it is not possible to have more than one person perform an annual inspection. The option of delegating a portion to another person is not given to the IA. He/She must perform the inspection in its entirety.

So only one person can return to service. If a different person performs and signs off a 100 100r inspection immediately prior to the annual, the IA is still obligated to inspect the entire aircraft as if nothing previous was inspected.

whitefaced
whitefaced's picture

No I am not missing the previous point,
I understand all of that. That is not what I am talking about. Maybe my post is misplaced since the title of this thread is Annual inspections.
I am talking about 100hr. inspections for aircraft that require them, and the scenario where multiple A&Ps participate in the inspection. In the case of a piston twin aircraft for example, one could employ up to five inspectors on the same inspection (one for each engine, one for the airframe, and one for each propeller).
As I have seen and participated in the common practice here, each mechanic (inspector) signs off the relevant part (airframe, engine and propeller), and approves it for return to service Ref. 43.11.

If a 100hr. inspection is an "aircraft" inspection as I believe it to be, how can there be multiple separate approvals for return to service of parts of the aircraft?

Doug Hereford

Anymouse (not verified)
Anonymous's picture

Okay, my apologies. While it is theoretical that 5 A&Ps could perform the various parts of the inspection on a piston twin, it is highly doubtful that would occur. Maybe a shop has a plethora of mechanics and not enough work.

If it did occur, there is nothing wrong with each signing off the portion that they performed.

whitefaced
whitefaced's picture

I would ask you to think then of a 100 hr inspection like we have all determined is the concept of an Annual inspection..............a whole aircraft inspection.
If it is infact, an aircraft inspection (as I believe it to be), how can more than one inspector approve it for return to service? Why can the power plant and airframe inspections not be considered separate inspections........with different due times?

Also, it is not theoretical, I have on numerous occasions utilized more than one inspector for this inspection. It is good business, as it gets the job done quicker.

Doug Hereford

n14ky
n14ky's picture

I believe you will find the answer to your question in 14 CFR 65.85(a) & 87(a). Each of them provide for a Mechanic with either an A or a P to perform the appropriate 100 hour inspection on either the Powerplant or the airframe. Contrast the wording in 65.85 & 87 to the wording in 65.95(a)(2).

For an IA working under 65.95 he has to perform the inspection on the AIRCRAFT. For a Mechanic with an Airframe rating, he can perform the 100 hour on the AIRFRAME. and a mechanic with a Powerplant rating can perform a 100 hour inspection on the POWERPLANT and PROPELLER.

David

whitefaced
whitefaced's picture

I am aware of the part 65 A&P privileges. Maybe a better way to ask is:
Where is tha aircraft's approval for return to service sign off when more than one mechanic participates in the 100 hr. Inspection, as part 65 seems to allow.

Doug Hereford
Also, David, I noticed a chief counsel opinion on a question you had.
Maybe worth a thread?

whitefaced
whitefaced's picture

I am aware of the part 65 A&P privileges. Maybe a better way to ask is:
Where is the aircraft's approval for return to service sign off when more than one mechanic participates in the 100 hr. Inspection, as part 65 seems to allow.

Doug Hereford
Also, David, I noticed a chief counsel opinion on a question you had.
Maybe worth a thread?

n14ky
n14ky's picture

Perhaps the answer if you have multiple mechanics working the same aircraft would be to have a Repair Station. While not really part of the discussion, in a repair station, you can have as many mechanics as you want do the inspection, since the "person" doing the inspection is the Repair Station, and not the individuals.

Doug, which letter of interpretation are you referring to, I have several. The most recent was the one on Light Sport.

David

whitefaced
whitefaced's picture

n14ky,
Well, I don't see myself adding repair station capabilities just to prevent this situation. I guess it will remain one of those few instances when things are just a little fuzzy.

The opinion I was referring to is the one on LSA.

Doug Hereford

n14ky
n14ky's picture

I suppose that would be good for some comments. I don't really agree with their final observation.

Dave 1962 (not verified)
Anonymous's picture

"an IA is not authroized to perform 100 hour inspections"?
Yes they are.
I/A's can do annuals, progressive (or supervise a progressive), 100 hour.
A&P's can do 100 hr inspections.
There is NOTHING that an A&P can do that an IA can't since an IA is an AP with an additional rating.

n14ky
n14ky's picture

Under 65.95, there is no provision for an IA to perform a 100 hr inspection. I agree that all IAs also are A&Ps, but you can't sign for a 100 hr inspection with your IA, only your A&P. Yes, it is the same person, but it is using the authority of a different certificate.

n14ky
n14ky's picture

One further point, mechanics can do MAINTENANCE, which includes inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance. Persons utilizing the authority of their IA can only perform INSPECTIONS, and only those inspections authorized in 65.95.

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