Can an A&P sign off a D check (3000 hr/ 5 year) on a Bell 412?

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sandeep.pillay
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Can an A&P sign off a D check (3000 hr/ 5 year) on a Bell 412?

 Hi folks

Can an A&P sign off a D check (3000 hr/ 5 year) on a Bell 412? Is an IA required for the D check and subsequent export C of A? The aircraft in question was in a container for over a year, duly preserved, and has never flown under an N registration.

The owner wants the D check done, and transfer the aircraft to another country's registration before she starts flying.

Really appreciate the insights available in this forum.

Regards

Sandeep

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bob.pasch
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Wow! Good question Sandeep. In my opinion, an A&P may sign off a D check on a Bell 412 if he/she meets the requirements of 14CFR Parts §65.83 Recent experience requirements and §65.81 General privileges and limitations. An IA is not required as it does not fall within the purview of §65.95 Inspection authorization: Privileges and limitations.

As for the Certificate of Airworthiness for Export, you'll need a DAR (or the FAA if your FSDO will comply) to comply with that portion of your question. If the aircraft is green and has never been registered, the transfer can be accomplished. However, if the aircraft currently has a registration of a country other than the U.S. it will require the DAR to coordinate thru that country and IAW their regulations.

If it is currently foreign registered and not cost prohibited, my suggestion would be to have it shipped (you said it was already in a container) to the currently registered country and proceed from there. I base this response on my experience working with Socata USA in the mid-90s and moving many aircraft between different countries. Again, it's my opinion and I welcome any comment or corrections...

sandeep.pillay
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Thank you, Bob. You've covered just about all the doubts I had. There's a DAR coming in to issue the Export C of A. The aircraft is presently N registered.

My second related query is regarding seat belts. Is there an FAA requirement to replace/ repair seat belts that are over ten years old?

Another query, this time non technical; why does an update to each post made come 3 times in my Inbox?

Am new to this excellent forum, hence do correct me if I am supposed to pursue these queries in a separate discussion.

Thanks and regards

Sandeep

bob.pasch
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Originally, you said "The aircraft in question was in a container for over a year, duly preserved, and has never flown under an N registration." now you say it's N registered but that's neither here nor there...

Re: Seat belts. Some seat belts have ADs on them however I would ASS/U/ME that most of them are NLA by attrition. The FAA has recognized SAE AS 8403 as the standard for which TSO C22g must meet in manufacture. TSOs 114 & C167 do the same for shoulder harnesses and restraints. AC 21-34 gives guidance on installations. The FARs cover airworthiness Standards in §23.785 (or §27.785 in your case - or §25.785 or §29.785 as applicable).

Am-safe & Pacific Scientific are probably the most popular manufacturers for restraint systems and their web sites are treasure chests of information.

Simply put, an inspection should insure that an appropriately rated TSO tag is firmly attached to each seat belt, the material is free from fraying or cuts and tears and all metal clasps or connectors are in proper condition and functioning properly.

As for why you receive three notifications for each response, I can't answer that as I've Asked Bob that same question but don't recall his response! Hope this helps...

sandeep.pillay
sandeep.pillay's picture

You're replies smack of sheer awesomeness, Bob!

About the aircraft, the aircraft got an N registration AND was packed into a box.... Now the owner wants to put her together, and get it flying again.

Sorry about the confusion, it was not intentional.

Cheers

Sandeep

AskBob
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I wish I had a answer for the 3 emails on a post. The site uses a off the shelf program and I have had the developers look into it and so far they can not tell me what is causing this issue.

Anonymous (not verified)
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Yes, an A&P may sign off the D check if the Aircraft is FAA registered. Seat belt requirements may vary depending on the CAA of the country you are exporting to, Many CAA have a 10 year life limit for safety belts on all aircraft regardless of the type of operation.

You need to consult with the DAR who will be issuing the Export Cof A. Remember, the aircraft will have to conform to the requirements of the country of export, and import.

sandeep.pillay
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Thank you, Bob.

bob.pasch
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A likely story! It's always someone else... :)

sandeep.pillay
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Thank you, Anonymous.

n14ky
n14ky's picture

Something to consider here, in order to qualify for an Export C of A from the US, the aircraft in question must meet the requirements of Part 21 Subpart H (domestic state of design, domestic state of manfacture). I am assuming that since it has never flown in the US, it doesn't have a US airworthiness Certificate now. First question, did it ever have a US Airworthiness Certificate? If not, did it have a US Export CofA when it was originally exported? If either of those is yes, it makes it easier. If both are no, then you have a bigger problem.

In any case, the issuance of an Export CofA will require doing all those things that would be required if the aircraft were going to get a certificate here, plus a little more. The first is that any USED aircraft is required to have an inspection of the scope and detail of Part 43 Appendix D. This is not a maintenance inspection, but a certification inspection. You will need to verify that the D Check you are proposing to do will in fact meet the Scope and Detail of Appendix D.

THe other things that need to be done for an Export certificate involve verification that it complies with any special import requirements of the country it is going to, and verification of that the parties purchasing it are not "prohibited persons".

This should give you an idea of what is required. Talk with your DAR as he will be able to fill you in on all the requirements.

David Schober
A&P IA DAR

bob.pasch
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Dave, he changed his statement. The aircraft is currently N registered but is still in a box & hasn't flown.

n14ky
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Saw that Bob. He didn't say if it had a US airworthiness or not. Lots of aircraft operate outside the US still on the N# and US airworthiness, on the other hand it may have been operated on a foreign airworthiness and only recently registered here. He hasn't given the full story.

bob.pasch
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Educate me Dave. How does he get an N# without an Airworthiness Certificate???

n14ky
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Bob, registration is the first step in the process. I can't issue an airworthiness certificate unless the aircraft is already registered and has the N# on it. Registration is covered under Part 47, and certification is under Part 21. In fact 21.173 says that the aircraft must be registered before an owner can make application for an airworthiness certificate.

Sandeep (not verified)
Anonymous's picture

Thanks for that insight n14ky. My aircraft definitely fits the bill. It was N registered, but Airworthiness was not obtained since she was kept in a box. Now that she is being put together again, the owner wants an Export C of A.

Regards

Sandeep

Anonymous (not verified)
Anonymous's picture

correct, lots of aircraft are flying with an N number and without an airworthiness certificate. Public aircraft for example. They may, or may not have airworthiness certificates but all are required to have N numbers and valid registrations.

n14ky
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Sandeep, you are luck that you have a 412 and that the 412 is a domestic (U.S.) manufactured helicopter. Since it is U.S. State of design and manufacture, you only need to meet the requirements for a Standard US Airworthiness Certificate to be eligable for an Export CofA. If it was a Canadian Bell, you would have to actually get a US Standard Airworthiness Certificate and then apply for the Export CofA. The rules are different depending on where the aircraft was manufactured. Go figure!

sandeep.pillay
sandeep.pillay's picture

True.. But the FAA's system is far simpler than other certification and licencing system, and i feel this is the most effective too. EASA, for instance, has one of the most meticulous system in place, but I know of firms and individuals who work their way around these rules.

It's quite easy to be bogged down by regulations and forget the final aim, that of safer skies!

Stacheair1
Stacheair1's picture

It would good to know what country the aircraft is to be exported to since each country has a different bi-lateral agreement with the U.S. In most cases to export an aircraft, the requirement is to have 100 hour type inspection completed before an export C of A can be issued. In this case if a D-check is completed that would most likely meet the intent of a 100-hour inspection and would acceptable to the FAA for export, however the country to which the helicopter is being exported may have additional requirements before an export C of A can be issued. The inspection details must be clarified before the export C of A is issued as being acceptable.

It would not matter if the aircraft in question has an airworthiness certificate. What matters is it is properly registered. When the aircraft arrives, it will have to be assembled and the U.S. registration canceled.

A request to cancel an aircraft's registration due to its export from the United States must be made by the last registered owner, the last owner of record, the foreign purchaser when supported by evidence of ownership, or by the authorized party under an Irrevocable De-Registration and Export Request Authorization.

All exports rules and procedure can be found in FAA Order 8130-2, Airworthiness Certification of Aircraft and Related Products.

To determine what the requirements for import of countries is you can find it in FAA Advisory Circular 21-2, Export Airworthiness Approval Procedures.

David points out some good questions that will need to be answered. I have seen several aircraft exported only to be impounded when they arrive because the DAR or FAA did not follow the import requirement for the host country. I just assisted an owner here in Japan with an import that started 5-years ago and the aircraft articles were impounded for lack of history where the parts came from.

Just because an export C of A is issued does not mean the country of import will accept it if it does not meet the import requirements or does not have all the documents required. In some cases the aircraft are shipped back to the U.S. or destroyed at an impound yard since they could not meet the import requirements.

I would recommend any A&P mechanic that is performing an inspection for export to really follow the inspection completely and not cut and corners, which does happen at times. A mechanic certainly does not want their name and certificate number in the aircraft records if the aircraft is not accepted, but still passed an 100-hour type inspection.

n14ky
n14ky's picture

Denny, some good points. Bi-Lateral requirements, special conditions, and a whole host of other things could crop up. I did an export on a Navajo several years ago to a country in South America. That airplane is coming back to the U.S as they couldn't get an airworthiness certificate down there. The aircraft has been out of service now for about 5 years because they couldn't get the paperwork correct. For this particular country we don't have a bi-lateral, and there were no special conditions listed in AC21-2 appendix. The requirement for a 100 hour on an export was removed from the regulations a couple years ago since each country requires an inspection once it arrives for the issuance of an airworthiness certificate. In the Bi-laterals, some countries will accept the inspection from the exporting country and some will not. Best advice is to work closely with your DAR at the front end rather than be blind sided at the back end.

Anonymous (not verified)
Anonymous's picture

Umm back to the first question....an A&P cannot sign off a D-check which is a progressive inspection without an IA or a repair station per the limitation in FAR PARt 65.

Sandeep (not verified)
Anonymous's picture

Hello Anonymous

The D check is being undertaken as a hard time check, and not as a progressive inspection (3000 hrs/ 5 years limit). Will your point still be valid?

bob.pasch
bob.pasch's picture

Umm... Sorry Joe Blow but both §65.81 (a) and §65.85 (a) say he can! §65.85 (a) sez, in part, "...a certificated mechanic with an airframe rating may approve and return to service an airframe, or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations)." A "D" check is neither a major repair nor a major alteration, it's an inspection. And by definition, FAR §1.1 sez "Maintenance means inspection..."

There is no regulatory verbiage that prohibits an A&P from signing off that inspection except for aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter. That is not the case here.

P.S.
Bob, you gotta do something about this format! Why can't the responses be the same width and attached to the to the blog it answers? If we keep going, we'll have one letter per line... :(

Sandeep (not verified)
Anonymous's picture

...and a 'Like' button ala Facebook will be cool. Bob Pasch's replies definitely deserve a Superlike button. Thanks again, Bob.

AskBob
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I agree Bob P, the constantly narrower reply rows get ridicules. I changed the configuration and I think the display is better now. Appreciate the feedback

Bob

bob.pasch
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Uda man!

Just to clarify the answer to the question. A 3,000 hour inspection is NOT a progressive inspection program, but part of a manufacture inspection program. A progressive inspection program is something that the owner/operator would take to the FAA to be approved for the aircraft or if it is a Part 135 or 121 operator the inspection progressive program would be added to their OpsSpec by make, model, and N-number what inspection program the aircraft is on.

Since a 3,000 hour inspection is NOT a progressive inspection an A&P mechanic can sign it off in accordance with their limitation under Part 65.

This has been a good discussion and this subject comes up every now and them.

n14ky
n14ky's picture

And to clarify further, what the owner wants (a D check) isn't material to the situation at hand. To process the certification, an A&P will have to certify that an inspection of the scope and detail of Part 43 appendix D has been completed. This is not a maintenance inspection, but a certification inspection. If the D check meets the scope and detail, then he is good, but he will need to match the inspection items to appendix D, and sign it off as either a 100 hour, or a condition inspection, and a separate entry for the D check.

Yes that is all true and in addition for 43 Appendix D CFR 43 section §43.15 Additional performance rules for inspections must also be included to the list contained in Appendix D.

Many A&P forget that §43.15 also applies as an example Appendix D does not say anything about swing the landing gear so it should be added for retractale gear aircraft.

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