Special Inspection Document (SID) Mandatory?

SID is "Special Inspection Document" which details certain inspection requirements that are outside the regular scheduled maintenance inspection intervals. Cessna published SIDs for its 100/200 series aircraft. They are not included in the airworthiness limitations sections of the Cessna Instructions for Continuing Airworthiness (ICA), and are not subject to any Airworthiness Directives. Therefore, Cessna SIDs for 100/200 series are not mandatory inspections from a regulatory point of view, even though they may be designated "mandatory" by Cessna. What this means is compliance with SIDs for Cessna series aircraft is recommended at the current time by the U.S. FAA. However, if you are maintaining your Cessna aircraft under the Cessna manufactures program the SID inspection may be part of that program and now it is mandatory. Remember if you are under a manufacture maintenance program in accordance with CFR 91 part 91.409 you CANNOT pick and choose, which parts of the inspection program you do and which parts you do not comply with. Background: With most Cessna aircraft now operating well beyond their original design life, Cessna, Piper and many other manufactures have published SID inspection requirements additional to the aircraft maintenance manual requirements. Most Civil Aviation Bureau (CAB) in the Pacific Rim require SID to be complied on aircraft in their countries such as New Zealand, Australia, and Japan. However, not all countries have made it mandatory yet, but a few have for good reason. In the United Kingdom, the CAA has released Information Document Number: IN–2013/138 that explains the SID is not mandatory in the UK and why. You can find the document at: https://www.caa.co.uk/docs/33/InformationNotice2013138.pdf EASA is also evaluating whether any mandatory action on some of the content of the Cessna SIDs may be necessary. Pending the outcome of this evaluation, this SIB provides guidance as to how owners and operators can evaluate the Cessna SIDs in the context of their existing maintenance programs and applicable regulations. At this time in the EASA world, the safety concern described in this SIB is not considered to be an unsafe condition that would warrant Airworthiness Directive (AD) action under Commission Regulation (EU) 748/2012, Part 21.A.3B. In addition, a number of SID inspections are already subject to an AD, either in the United States or in Australia, as specified in Appendix 2 of this SIB. The relevant FAA ADs are adopted by EASA, under Commission Regulation (EU) No 748/2012 article 3, paragraph (1)(a)(iii). Owners/operators implementing the Cessna Continued Airworthiness Program (CAP) will find that some of the CAP Manual structural inspections have been superseded and replaced by SID inspections. Relevant information can be found in Cessna SEL-05-01. The SID inspections have been incorporated into the affected Cessna Maintenance/Service Manuals and are considered to be revised ICA in the context of Commission Regulation (EC) 2042/2003, Annex I Part M, M.A.302, paragraphs (d) and (g). It is this change to the Instruction for Continued Airworthiness (ICA) that has caused a lot of discussion as being mandatory or not without going through the FAA review board. It should not be inferred from Commission Regulation (EC) 2042/2003, Part M.A.302, paragraphs (d) and (g), that all ICAs included in the Cessna 100/200 SIDs are ‘required’ to be incorporated into the approved aircraft maintenance program. However, owners and operators should ‘take into account’ the SID to determine the need for revising their AMP. So as you can see even EASA is having a difficult time with manufactures changing the ICAs to force owners to comply with SID inspection with no regulatory basic. Any decision not to incorporate the applicable Cessna SID should be properly substantiated, to the satisfaction of the competent authority depending where the aircraft is registered to satisfy the CAA, EASA, or the U.S. FAA requirements. However, here in the Pacific Rim many countries look at it differently like the Japanese Civil Aviation Bureau (JCAB) rules requires an operator to ensure an aircraft is maintained in an airworthy condition. To achieve an airworthy condition follow the applicable definitions in Part 1 – • Instructions for continued airworthiness (ICA’s) means current airworthiness data provided by the manufacturer of an aeronautical product, a product, or a component, and include any related airworthiness limitations mandated by the airworthiness authority of the State of Design. • Airworthiness data means any information necessary to ensure an aeronautical product or a product or a component can be maintained in an airworthy condition. • Airworthy condition means the condition of an aircraft, including its components, fuel, and other materials and substances essential to the manufacture and operation of the aircraft that complies with all the requirements prescribed by the Civil Aviation Rules relating to design, manufacture, maintenance, modification, repair and safety. Therefore, for an operator to maintain an aircraft in an airworthy condition, they must comply with all available Cessna ICA’s including SIDs; the information assessed for applicability, actioned accordingly and actions recorded in the maintenance logbook. The SID addresses primary and secondary airframe components only. These are described as PSE's or principal structural elements. PSE's are defined as components that carry significant flight and ground loads, and if they fail, cause catastrophic destruction of the airframe. Monitoring of these PSE's is the reason for the SIDs. Compliance expectation: While inspection requirements are essentially the same for same aircraft models (for example CE-172) there can be a wide variation of inspection requirements between different aircraft models within the same series. Considerations to be taken in to account are aircraft time in service, calendar time since new, any major repairs or rebuilds carried out on the aircraft or previous application of corrosion prevention products. Note The aircraft series SID inspection publication is an extensive document requiring in-depth research to extract applicable individual SID inspections for each aircraft. Once the individual SID inspections are identified, logbooks are to be researched for service information compliance, total time in service and calendar time in service for applicability to individual aircraft. Note If a specific airframe component has been replaced, the component is to be inspected, based on total component hours or calendar time requirements. However, any attachment structure that was not replaced when the component was replaced must be inspected, based on the total airframe hours or calendar time requirements. Inspections are due at the lessor of specified flight hours or calendar time. (Reference Cessna Model 100 series 2A-13-00 page 5 paragraph 7.C) Where it has been determined a SID inspection is not required as a result of component replacement this must be fully documented in the work records. In determining SID inspections required as result of total time in service or calendar time in service for each aircraft, all applicable Service Bulletins are to be available. Recording of inspection results: It is important results of SID inspections are recorded in an objective manner. One method is to photograph the areas where the inspection is being performed. This should be done regardless of whether the area is free (or not) of corrosion or cracking. If the area is corroded or cracked this is to be photographed and again after approved repairs or replacement has been carried out. It is recommended photographs are digital (if possible; picture identification number, date/time stamped, specific associated SID inspection and referenced to the work record/sheet) and recorded to a data stick or CD for future reference and kept as part of the aircraft work records. NDT requirements are to be carried out strictly in accordance with the SID requirement by a person with appropriately approved NDT qualification. Cessna Discrepancy Reports are to be completed and forwarded to Cessna in accordance with the SID publication. Transition periods: Cessna 200 series aircraft: all required SID inspections must be completed by 31 Dec 2013 (2A-14-00 page 1). Cessna 100 series aircraft: all required SID inspections must be completed by 30 June 2014 (2A-13-00 page 5). Note: 2A-14-31 Engine Mount inspection by 30 June 2015 or next engine overhaul. The JCAB as stated in their requirement for Japan ONLY…the below: The additional SID inspection requirements are incorporated into the specific aircraft Instructions for Continued Airworthiness (ICAs). Operators must ensure compliance with the SID inspection prior to the dates above or the aircraft is deemed to be unairworthy and should not be flown. (refer ‘Background’ above).

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Comments

The first task it says in the SID listing is

"Inspect aircraft records to verify that all applicable
Cessna Service information Letters, Cessna Service
Bulletins and Supplier Service Bulletins are complied
with".

That would mean to be in compliance you would need to carry out every SB SIL ever issued, so it is greater than simply the SID's.
I have yet to see a Cessna 152 in the UK that has had SEB 92-26 embodied which is to add about 8 extra water drains to the 152 fuel tanks.

Doesn't SID stand for "supplemental inspection document"? These inspections might seem special but....