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  #21  
Old 12-07-2014, 08:03 AM
WingedFrog's Avatar
WingedFrog WingedFrog is offline
 
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Quote:
Originally Posted by rvbuilder2002 View Post
Not correct.
Have a look at THIS domument I linked to in post #8 of this thread.
Page 3 and 4 are particularly relevant.

The FAA issues AD
The manufacturers issue Safety Directives
Scott, is there somewhere on VANs web site a clear way to identify "Safety Directives" applying to the RV-12? What I see is "Safety Alerts" and "Safety Bulletins". May I suggest that VANs use the same terminology as FAA to avoid any confusion? While I am at it, listing the FAA's ADs applying to the RV-12 would not hurt either.
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  #22  
Old 12-07-2014, 08:19 AM
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My Rotax mechanic checked my float bowls from my 912 ULS. There's a serial number check (believe it's actually the serial numbers on the carbs), and the visual inspection of the floats. Probably most helpful is weighing the floats on a very accurate small scale.

Last edited by designrs : 12-07-2014 at 08:24 AM.
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  #23  
Old 12-07-2014, 03:42 PM
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rvbuilder2002 rvbuilder2002 is offline
 
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Quote:
Originally Posted by WingedFrog View Post
Scott, is there somewhere on VANs web site a clear way to identify "Safety Directives" applying to the RV-12? What I see is "Safety Alerts" and "Safety Bulletins". May I suggest that VANs use the same terminology as FAA to avoid any confusion? While I am at it, listing the FAA's ADs applying to the RV-12 would not hurt either.
This is where it gets a bit complicated...

As I mentioned previously, all of the primary requirements pertinent to S-LSA certification and continued airworthiness are ddeveloped under a consensus standard through an ASTM process.
The FAA writes rules in the FAR's requiring compliance with the consensus standard, but they don't actually write the standard (at least not exclusively... they do have input as members of the committee).

I am pretty sure (I will check to confirm) that the names used on the Van's web site are what the ASTM requires them to be called, and the FAA chooses to refer to them by another name (I think they are actually just using a generic term to cover all the different levels of notifications).

There is a requirement for a manufacturer to cross publish any notification for any product manufactured by someone else, but used on their aircraft.
That is why on the Van's web site you see SB 14-10-14, which is just a document that refers owners to the one issued by Rotax regarding the carb. floats.

The reason you don't see any FAA A.D.'s listed is because as far as I am aware, there has not been one issued by the FAA that would apply to the RV-12.
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  #24  
Old 12-07-2014, 04:28 PM
aerofurb aerofurb is offline
 
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I stand to be corrected but FAA ADs are for certified aircraft and equipment only.

That equipment might be avionics, engine or propeller.

As an example, there are some 912 FAA ADs but not for the uncertified 'ULS' variant, only the 'S'. Listed under Bombardier-Rotax GmbH.
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  #25  
Old 12-08-2014, 09:03 AM
Ex Bonanza Bucko Ex Bonanza Bucko is offline
 
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In all the comments and opinions about the carb floats I have not seen any data about what percentage of carb floats in 912 UL(S) engines have failed.....nor have I seen any numbers.

I would think that those data would be important to Rotax and to us.

EBB
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  #26  
Old 12-08-2014, 03:38 PM
aerofurb aerofurb is offline
 
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Nope, you've got me again, EBB.

There's a problem and we know Rotax (Bing, etc) are well aware of it and working out a fix.

The actual numbers of failure are, quite honestly, immaterial. Given that Rotax have issued affected engine serial numbers (and they'll know of spares sold from that batch of floats), I would hazard a guess that they have a pretty good idea of the number of possibly duff floats.

Maybe that's not ideal for you or many others but life's like that sometime.

Could be worse, you could have a ruck of ECi cylinders attached to your TCM heritage engine....
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  #27  
Old 12-10-2014, 05:10 PM
Loki Loki is offline
 
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Quote:
Originally Posted by rvbuilder2002 View Post
Not correct.
Have a look at THIS domument I linked to in post #8 of this thread.
Page 3 and 4 are particularly relevant.

And as Mel already mentioned, one of the standard issue operating limitations says....

No person may operate this aircraft in the light-sport category unless it is
continuously maintained in compliance with 14 CFR § 91.327(b).


The pertinent part of 91.327 says.....

(b) No person may operate an aircraft
that has a special airworthiness certificate
in the light-sport category unless—

(3) The owner or operator complies
with all applicable airworthiness directives;

(4) The owner or operator complies
with each safety directive applicable to
the aircraft that corrects an existing
unsafe condition. In lieu of complying
with a safety directive an owner or operator
may—


The FAA issues AD
The manufacturers issue Safety Directives
This is true up to a point. Several SLSA MFG have tried to add more than the FAR regulates and have tried to give away some of the FAR regulations. The MFG must publish their requirements so they fit into and within the FAR limitations. If you as an MFG fall outside of this then it isn't enforcable. The owner is only required to follow the FAR regulations and not just whatever an MFG wants to write. Unfortunately too many rules published have and do fall outside of the FARs and that is why FAA legal has enterd the foray on several occasions. Then owners try to apply certified aircraft terminology and or certified regulations to LSA. This has what has made the last ten years hard for many.
If this wasn't true then it wouldn't be clear as mud and we wouldn't have had to get the FAA legal involved.
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  #28  
Old 12-10-2014, 06:19 PM
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rvbuilder2002 rvbuilder2002 is offline
 
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Quote:
Originally Posted by Loki View Post
The MFG must publish their requirements so they fit into and within the FAR limitations. If you as an MFG fall outside of this then it isn't enforcable.
I am not entirely clear on what you mean by this, when in 91.327 of the FAR's
it says

(b) No person may operate an aircraft
that has a special airworthiness certificate
in the light-sport category unless?

(3) The owner or operator complies
with all applicable airworthiness directives;

(4) The owner or operator complies
with each safety directive applicable to
the aircraft that corrects an existing
unsafe condition.


Seems to imply (to me anyway) that if a mfr issues a safety directive indicating that it was done for a safety of flight issue, it has to be complied with.

Can you cite any examples where the FAA ruled against a manufacturer issued notification?
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Opinions, information and comments are my own unless stated otherwise. They do not necessarily represent the direction/opinions of my employer.

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Van's Aircraft Engineering Prototype Shop Manager
Hubbard, Oregon
RV-6A (aka "Junkyard Special ")
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  #29  
Old 12-13-2014, 06:46 PM
Loki Loki is offline
 
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Safety Directives and or and AD (certified aircraft) if one ever got published is mandatory, but Service Bulletins according to FAA legal department are not. Even if an MFG says mandatory and publishes it as only a SB then it isn't mandatory in the FAA's eyes. Only Service Directives are because they are supposed to be a flight Safety issue. If an SLSA MFG believes they have a flight safety issue then it should be published under an SD.
When the US supplier for Rotax found out about this legal ruling from the FAA they went straight to Rotax in Austria to try and get SD's, but Rotax believes their languge is strong enough and didn't want to comply with publishing SD's.
FAA believes that all should comply with a Rotax SB that says mandatory, but can't enforce it. This was an issue years back and I talked to the top people in the FAA for LSA and Rainbow Aviation also got the same ruling.
This has all been hashed out on several forums and many calls to the FAA have resulted all with the same outcome.
All that said I believe anyone who doesn't comply with an SB that says mandatory may be in the foolish camp one day.
Mandatory stated SB's are published for a good reason.
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  #30  
Old 12-22-2014, 10:24 AM
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rvbuilder2002 rvbuilder2002 is offline
 
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Default Closing the loop.....

I provide the following info in an attempt to answer some of the questions regarding seeming contradictions within the FAA regs, advisory circulars, manufacturers documentation, etc.

There is currently a disconnect between the requirements within the ASTM's and all of the FAA's documents.
Particularly in the case of Safety Directives / Alerts.
As it stands at the moment, there is no regulatory basis to require an S-LSA owner to comply with a safety alert (which is what the ASTM's currently require them to be called) as discussed previously in this thread. It technically is not legal for a manufacturer to call something a Safety Directive. The ASTM's require them to be call Safety Notifications.
The reason for that is an error in the ASTM's
The ASTM advisory committee has been working on this since OSH 2014 and will likely vote on a final version early in 2015. It will become active about 6 months later (so late summer 2015)
A major change will be renaming what is currently called a Safety Alert, to Safety Directive (what the FAA originally wanted it to be, and what all of their regulatory documents refer to them as).
Once this takes place, anything labeled as a Safety Directive will be binding and regulatory controlled (about the same as an A.D.).
Until that time, I suppose you are technically legal to ignore them (though you may find your self in a difficult situation of an incident or accident happened that could be linked to the issue in question). Even if you ignore it, once the new ASTM becomes active, you would have to go back and comply with any you hadn't.

So, the Van's Aircraft web site current posting of Safety Alerts, Service Bulletins, and Notifications, is in compliance with the currently active ASTM requirements.
After the release of the updated ASTM document, Service Alerts will be referred to as Service Directives, and will be mandatory (in the FAA's eyes) for an S-LSA RV-12

Hope this clears up some of the questions.
__________________
Opinions, information and comments are my own unless stated otherwise. They do not necessarily represent the direction/opinions of my employer.

Scott McDaniels
Van's Aircraft Engineering Prototype Shop Manager
Hubbard, Oregon
RV-6A (aka "Junkyard Special ")

Last edited by rvbuilder2002 : 12-22-2014 at 10:28 AM.
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