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What Can I Do?

Inhot

Well Known Member
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I'm an owner NOT a builder of an RV6. My local A&P tells me that I cannot sign off my installation of an Anti-Splat oil shutter or a new Vetterman exhaust. He's a good guy, a bud and I respect his experience and judgment when it comes to anything related to general aviation aircraft maintenance. But this is contrary to what I have read. Now, it may be that given his assessment of my capabilities he thinks it wise to inspect and sign off on my work - but that aside - am I authorized as an owner of an experimental aircraft to perform ANY maintenance (aside from a condition inspection) on my aircraft and sign off the required logbook entries? I'm going to have him do it, but I am curious whether it's actually required.
 
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Edit: appearantly I misunderstood the rules too, so I edited this to delete my wrong info.
 
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Anyone, (qualified or not) can do anything/everything EXCEPT the annual condition inspection.
 
Your mechanic friend is mistaken.

You may do anything you want to the aircraft OR have your neighbor's 7 year old perform the installation and/or maintenance. That is one of the huge advantages of EX-AB, even as a buyer, not a builder. Anyone can do work on an EX-AB.

The ONLY thing you cannot do (without either the Repairman's certificate or an A&P license) is the Condition (annual) inspection of the airplane. An A&P or the person with the Repairman's certificate for that particular aircraft needs to perform that inspection.
 
Anyone, (qualified or not) can do anything/everything EXCEPT the annual condition inspection.

Perhaps splitting hairs, but I think the A&P (or AI) needs to make/sign the logbook entry. (for the annual condition inspection)

I've been doing the heavy lifting on all my condition inspections, with an A&P supervising. i.e. open all the panels, lube, change the oil, open the filter, etc. I use a comprehensive checklist. He is also my tech advisor, and has signed a recommendation letter towards my A&P, so he is very comfortable with my work.
 
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Perhaps splitting hairs, but I think the A&P (or AI) needs to make/sign the logbook entry.

Although it is a very good idea to do do, no logbook or records are required to be kept at all for EAB, except for the annual condition inspection. So if you do keep records, anyone (or no one) may sign them.
 
Nope...........

Perhaps splitting hairs, but I think the A&P (or AI) needs to make/sign the logbook entry.

You are mistaken! A&P or Repairman for that aircraft is required to sign off the annual condition inspection. IA has nothing to do with Experimental Amateur-Built aircraft. As stated before, anyone, qualified or not, may conduct maintenance, modifications, or anything else.
 
Although it is a very good idea to do do, no logbook or records are required to be kept at all for EAB, except for the annual condition inspection. So if you do keep records, anyone (or no one) may sign them.

corrected my statement to add "annual condition inspection"
 
Perhaps splitting hairs, but I think the A&P (or AI) needs to make/sign the logbook entry. (for the annual condition inspection)

I've been doing the heavy lifting on all my condition inspections, with an A&P supervising. i.e. open all the panels, lube, change the oil, open the filter, etc. I use a comprehensive checklist. He is also my tech advisor, and has signed a recommendation letter towards my A&P, so he is very comfortable with my work.
If I may, let me add some conditioner to your split hairs. An owner may assist me by opening the airplane up, and doing Part 43 app A preventive maintenance, by if they want me to sign off an inspection, then I am the one doing the inspecting. Supervised maintenance functions are allowed, supervised inspections are not, at least as I am concerned.
Thanks
 
If I may, let me add some conditioner to your split hairs. An owner may assist me by opening the airplane up, and doing Part 43 app A preventive maintenance, by if they want me to sign off an inspection, then I am the one doing the inspecting. Supervised maintenance functions are allowed, supervised inspections are not, at least as I am concerned.
Thanks

I think we are saying the same thing. A&P does the inspection.

To the OP question, yes, he can install his oil shutter.
 
I do not see an exclusion for experimental aircraft for FAR 91.147?

https://www.law.cornell.edu/cfr/text/14/91.417

The relevant CFAR is 43.1
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-C/part-43

In particular 43.1(B)

For clarity purposes.... One of the purposes of FAR 43 is to regulate what level of certification is required for a person to do what types of Maint. and Inspection work on Type Certificated aircraft.

43.1)B) states that the entire Part (43) does not apply to an aircraft with an experimental airworthiness certificate.

This is why the operating limitations that are issued to an Experimental Amateur Built aircraft have line items stating what inspection has to be done, and when; and who can do that inspection. Because all of rules in FAR 43 that would have applied regarding these requirements, don't, because of 43.1(B).
 
EAA Sport Aviation Magazine, September 2021. Page 30.

There is a table that breaks out who can do what according to what type of plane.

If you have digital access to their archive that’s the easiest way to find it.

Patrick
 
The relevant CFAR is 43.1

Yep - got that - see post #6

Not talking about who can do the maintenance anymore - talking about the requirement for maintenance records.

A statement was made that "no logbook or records are required to be kept at all for EAB except for the annual condition

inspection." My question was where does it say that FAR 91.417 doesn't apply to experimental aircraft?

Inquiring minds want to know. :)
 
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So here’s the thing. We all believe we are super mechanics and can do anything, yet we don’t make our living working on and inspecting aircraft. There is something to be said for experience being important when it comes to certain things. I urge all of us to have an A&P do our condition inspections every so often. Having a fresh, experienced set of eyes looking things over can be… eye opening.
 
So here’s the thing. We all believe we are super mechanics and can do anything, yet we don’t make our living working on and inspecting aircraft. There is something to be said for experience being important when it comes to certain things. I urge all of us to have an A&P do our condition inspections every so often. Having a fresh, experienced set of eyes looking things over can be… eye opening.

Even though I am an A&P, and have been for almost 50 years, I still have a different mechanic do my inspection every few years. Different eyes see different things.

I've been proposing to the FAA for several years that a "Repairman" for an amateur-built aircraft should be required to have an experienced mechanic walk him through his first Condition Inspection. Knowing how to build an airplane does not mean that you know how to inspect one.

Just my opinion! Obviously not a real popular one.
 
Even though I am an A&P, and have been for almost 50 years, I still have a different mechanic do my inspection every few years. Different eyes see different things.

I've been proposing to the FAA for several years that a "Repairman" for an amateur-built aircraft should be required to have an experienced mechanic walk him through his first Condition Inspection. Knowing how to build an airplane does not mean that you know how to inspect one.

Just my opinion! Obviously not a real popular one.

It is a great idea. For the first several years (and occasionally since then), I had one of the local IA's give the FWF on my airplane the once-over after I finished the inspection. Nothing out of sorts has turned up yet, but I consider it good insurance.

I don't worry as much about missing something on the airfame portion. Its fairly simple with a couple of dozen important points to examine - largely attachment points and control systems.
 
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Even though I am an A&P, and have been for almost 50 years, I still have a different mechanic do my inspection every few years. Different eyes see different things.

I've been proposing to the FAA for several years that a "Repairman" for an amateur-built aircraft should be required to have an experienced mechanic walk him through his first Condition Inspection. Knowing how to build an airplane does not mean that you know how to inspect one.

Just my opinion! Obviously not a real popular one.

I agree with you Mel. But rather than the FAA getting involved and making a rule I would prefer that people just did that on their own. I promote it to any builder with a newly completed airplane.
 
Yep - got that - see post #6

Not talking about who can do the maintenance anymore - talking about the requirement for maintenance records.

A statement was made that "no logbook or records are required to be kept at all for EAB except for the annual condition

inspection." My question was where does it say that FAR 91.417 doesn't apply to experimental aircraft?

Inquiring minds want to know. :)
It is important to note that this is a part 91 requirement not part 43 and therefore 43.1 does not relieve one from the 91.417 requirements. Unless there is something else exempting EAB from record keeping, I would agree that the owner/ operator has to keep these records.
 
Even though I am an A&P, and have been for almost 50 years, I still have a different mechanic do my inspection every few years. Different eyes see different things.

Just my opinion! Obviously not a real popular one.

I'll go one step further and say that the builder is actually the worst person to do the first condition inspection, they will assume things are good because that's the way they built it. Can't even remember how many sump screens I've pulled that still had the original Lyc safety wire installed after years of inspections.
 
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I always have my A&P review any significant work that I do on my airplane, but I don’t ask him to sign off the logbook…he signs only if he actually does the work. I don’t do any work forward of the firewall. I even have him do the oil changes because it’s worth it to me. As to the annual inspection…I pull the interior and the flooring, luggage bulkhead, and inspection panels as a means of saving some money and learning about the airplane, although the time spent doing that is such that I’m on the fence as to whether or not it’s worth it any more.
 
Put me in the bin with Scott. I absolutely agree that quite a few builders do a poor first condition inspection...but no, we don't need a new rule mandating A&P involvement.

Let's not kid ourselves. I have seen some really dumb stuff in one year old airframes from very experienced builders. I had a lot of personal experience correcting outright dangerous things in an airframe signed off by a highly qualified DAR, and I'm pretty sure that DAR signed off the entire production series. And I once found a torque tube/aileron pushrod bolt with no nut, no indication it had ever had one...and I was the builder.

Point is, mandating some particular class of mechanic is no solution. Inspection isn't about qualifications. It's about actually looking closely, and almost anyone can fill that role.
 
As a current & previous owner of several experimental aircraft, and a buyer looking for an RV-8, I like to see clear documentation of all maintenance and repairs performed. I prefer to see occasional IA or A&P entries in the logbooks showing that multiple sets of capable eyes have looked at the plane and found it airworthy and contributed to it’s maintenance.
 
Yep - got that - see post #6

Not talking about who can do the maintenance anymore - talking about the requirement for maintenance records.

A statement was made that "no logbook or records are required to be kept at all for EAB except for the annual condition

inspection." My question was where does it say that FAR 91.417 doesn't apply to experimental aircraft?

Inquiring minds want to know. :)

My mistake.

I thought I clicked quote on a different persons post on page 1.

I agree that anything written in Part 91 applies to Experimental Amateur Built aircraft.

Including a lot of others that owner inspectors often miss. One of those that is often overlooked is FAR 91.207 (which within the part specifically mentions an entry in the aircraft maint. records is required.
 
I agree that anything written in Part 91 applies to Experimental Amateur Built aircraft.
.

Just to be a contrarian, I note that 91.409 (c)(1) specifically excludes EAB aircraft from a small subset of the rules. More generally, a lot of the 91.4xx rules reference Part 43 - which specifically excludes EAB. How are we to interpret these?
 
Just to be a contrarian, I note that 91.409 (c)(1) specifically excludes EAB aircraft from a small subset of the rules. More generally, a lot of the 91.4xx rules reference Part 43 - which specifically excludes EAB. How are we to interpret these?

Even though I interface with the FAA on a pretty regular basis, I am still far from having any expertise at interpreting the FAR's, but I think this one is pretty self explanatory.

91.409(C) says "Paragraphs (a) and (b) of this section do not apply to..."

So it is saying that only 91.409 doesn't apply to an experimental. Just because one Section (section is the portion of the "Part" being identified with the numerals after the period) doesn't apply, doesn't mean that all of Part 91 doesn't apply, or that any Section in Part 91 related to inspections don't apply. Only that Section 409 doesn't apply. I believe this would be the case for any other section in Part 91 as well.

91 is the Part, 409 is the Section, A & B are the paragraphs within that Section.

Part 43 is different. Its exclusion statement says " This Part does not apply to -". That means Part 43, in its entirety, does not apply to an experimental.
 
Wow, just Wow! Says the OP

Interesting discussion guys and very informative AND revealing. I say "revealing" as it comes as a pointed reminder as to how convoluted the CFR are. But it's what we have to deal with.

So what did I do? I installed the oil cooler shutter and the new Vetterman exhaust soliciting advice along the way from my A&P/IA. When complete I made the logbook entry and had my A&P/IA sign it off. We did discuss the issue as to whether or not his signature was required (without opening the CFR). He has his opinion and I have mine, but I like having access to his experience/knowledge and that second set of eyes.

With regard to maintaining logbooks. Regardless what the regs says COMMON SENSE should prevail. Just do it.
 
So what did I do? I installed the oil cooler shutter and the new Vetterman exhaust soliciting advice along the way from my A&P/IA. When complete I made the logbook entry and had my A&P/IA sign it off. We did discuss the issue as to whether or not his signature was required (without opening the CFR). He has his opinion and I have mine, but I like having access to his experience/knowledge and that second set of eyes.

And his opinion is WRONG. As numerous A&Ps and DARs have pointed out on this thread, anyone can do anything to an EAB aircraft. The only thing that requires either an A&P (not IA) or Repairman (for that airplane) to sign off is the annual Condition Inspection. Period.

It's a shame that he is spreading misinformation to you (and probably others) instead of educating himself on the facts.
 
It’s been my experience that most professional IAs and APs are mostly ignorant of the rules applying to experimental planes and LSAs. Probably because they don’t see them that often, I guess. Anyway I have seen where mechanics have signed of the condition inspection stating they did an AD search and didn’t find any but ignored doing a SB search, which is required for SLSAs. In one case there were over a dozen SBs ignored over several years which makes you wonder what the insurance co would do in the case of an accident.
With EABs, since there are no real systems standards, typically no wiring diagrams or maintenance manuals or an inspection checklist will likely do a poor inspection. It pays to find someone familiar with your type plane for a good inspection and continued safety.
 
It’s been my experience that most professional IAs and APs are mostly ignorant of the rules applying to experimental planes and LSAs.

It's one thing to be ignorant of something. That's okay, there are plenty of things of which we are all ignorant. It's another thing entirely to puff up and insist that you *do* know and that you are right about something, spread misinformation, and refuse to become educated on what is true. EABs have been around long enough now, and there are certainly scads of RVs all over, that A&Ps should at least know the basics of the rules by now (like who can work on them and the minimal sign-off regs).

Not knowing the bare minimum rules, and when told they're wrong, insisting they're right, is the mindset of an A&P I *don't* want looking at my plane.
 
Not knowing the bare minimum rules, and when told they're wrong, insisting they're right, is the mindset of an A&P I *don't* want looking at my plane.

Ran into one a year or two back. I always ask about documents before I make a trip to inspect. Seller's A&P was like the Mexican bandit in Blazing Saddles...we don't need no stinkin' operating limitations.
 
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