Avidflyer2
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Answer:
The opinion in this office is that the AD does not state to simply C/W the SB verbatim, The previous EC will not count as AD compliance. Many of the failures are after many landing so even if the wing may have or may have been in Flight School use, the failure may not appear until more usage is utilized. I would have to look at the ACTT and when the inspection was performed, to consider requesting an AMOC. For instance, and aircraft that had the EC performed at 4400 hours., I feel that would be an easier request than an aircraft that had 2200 hours and was approaching the 5000 mark…(if that makes since.) But as in your email mentions, the test results would need to be provided for an AMOC request as well.
Aviation Safety Inspector
FAA FSDO EA39
Greensboro, NC
336-369-3947
________________________________________
Question:
Thank you for looking into AD2020-26-16 for me regards to the logbook entry for the records review. I have another issue with the AD regarding the eddy current inspection being performed prior to the requisite number of Factored Service Hours. It is being discussed whether an EC inspection done on a wing before the wing spar meets or exceeds the threshold of 5000 FSH complies with the one-time requirement. For example, An EC inspection is done on a wing at 2500 FSH, well before the initial inspection threshold of 5000 FSH. The compliance paragraph (f) indicates credit may be given for actions "unless already done". "Does this early EC inspection comply with the AD?", I think not. I'm of the opinion that the wing spar has to be inspected (again) upon accumulating 5000 FSH. A lot of owners are getting the wing bolt inspection done early simply for peace of mind, but they may be surprised to learn the AD will become due once the wings reach 5000 FSH.
AD POC Dan McCulley of Atlanta ACO has in part said, "Thanks for your question, it is one we are getting frequently since many owners like yourself have conducted an inspection prior to the publication of the AD. In short, such an inspection would require an AMOC if the AD is applicable to your aircraft. Keep in mind that Piper SB 1345 and the AD 2020-26-16 use different approaches to determine hour usage and applicability. It is possible that the Piper SB is applicable to your aircraft but the AD is not. We are working on a template that will make requesting an AMOC for cases like this fairly easy. One would need to provide all of the information that is requested on the Appendix 1 Inspection Results Form along with the requestor’s name and full address. I have attached a flow chart that many people are finding useful for this complicated AD. If I haven’t answered your questions feel free to email me back."
The flowchart does not address whether the early EC inspection will be accepted in lieu of the EC inspection due at 5000 FSH. Additionally, Dan's mention of the Appendix 1 Inspection Results requirement for the AMOC may no longer be available to us mechanics as it is normally given to the owner/operator at the time of the inspection, there isn't a requirement for this info to be entered in the maintenance records. End result is that I cannot use the AMOC unless I have the inspection results. I'm tempted to request a legal interpretation regarding the AD paragraph (f) compliance "unless already done".
_________________________________________
I have posted this conversation with my Aircraft Safety Inspector after reading other points of view here on Piper Forum. It is important enough for this thread to have its own post. I have redacted names to protect the guilty (me) as everyone, including the FAA are entitled to their own opinions.
The thought that if an early EC inspection doesn't count, also means that a failure indication on a early EC inspection isn't a grounding issue per the AD. Yes, it would be foolhardy to continue to fly the airplane and it would not be airworthy per its Airworthiness Certificate but it would not be grounded by the AD per se.
The opinion in this office is that the AD does not state to simply C/W the SB verbatim, The previous EC will not count as AD compliance. Many of the failures are after many landing so even if the wing may have or may have been in Flight School use, the failure may not appear until more usage is utilized. I would have to look at the ACTT and when the inspection was performed, to consider requesting an AMOC. For instance, and aircraft that had the EC performed at 4400 hours., I feel that would be an easier request than an aircraft that had 2200 hours and was approaching the 5000 mark…(if that makes since.) But as in your email mentions, the test results would need to be provided for an AMOC request as well.
Aviation Safety Inspector
FAA FSDO EA39
Greensboro, NC
336-369-3947
________________________________________
Question:
Thank you for looking into AD2020-26-16 for me regards to the logbook entry for the records review. I have another issue with the AD regarding the eddy current inspection being performed prior to the requisite number of Factored Service Hours. It is being discussed whether an EC inspection done on a wing before the wing spar meets or exceeds the threshold of 5000 FSH complies with the one-time requirement. For example, An EC inspection is done on a wing at 2500 FSH, well before the initial inspection threshold of 5000 FSH. The compliance paragraph (f) indicates credit may be given for actions "unless already done". "Does this early EC inspection comply with the AD?", I think not. I'm of the opinion that the wing spar has to be inspected (again) upon accumulating 5000 FSH. A lot of owners are getting the wing bolt inspection done early simply for peace of mind, but they may be surprised to learn the AD will become due once the wings reach 5000 FSH.
AD POC Dan McCulley of Atlanta ACO has in part said, "Thanks for your question, it is one we are getting frequently since many owners like yourself have conducted an inspection prior to the publication of the AD. In short, such an inspection would require an AMOC if the AD is applicable to your aircraft. Keep in mind that Piper SB 1345 and the AD 2020-26-16 use different approaches to determine hour usage and applicability. It is possible that the Piper SB is applicable to your aircraft but the AD is not. We are working on a template that will make requesting an AMOC for cases like this fairly easy. One would need to provide all of the information that is requested on the Appendix 1 Inspection Results Form along with the requestor’s name and full address. I have attached a flow chart that many people are finding useful for this complicated AD. If I haven’t answered your questions feel free to email me back."
The flowchart does not address whether the early EC inspection will be accepted in lieu of the EC inspection due at 5000 FSH. Additionally, Dan's mention of the Appendix 1 Inspection Results requirement for the AMOC may no longer be available to us mechanics as it is normally given to the owner/operator at the time of the inspection, there isn't a requirement for this info to be entered in the maintenance records. End result is that I cannot use the AMOC unless I have the inspection results. I'm tempted to request a legal interpretation regarding the AD paragraph (f) compliance "unless already done".
_________________________________________
I have posted this conversation with my Aircraft Safety Inspector after reading other points of view here on Piper Forum. It is important enough for this thread to have its own post. I have redacted names to protect the guilty (me) as everyone, including the FAA are entitled to their own opinions.
The thought that if an early EC inspection doesn't count, also means that a failure indication on a early EC inspection isn't a grounding issue per the AD. Yes, it would be foolhardy to continue to fly the airplane and it would not be airworthy per its Airworthiness Certificate but it would not be grounded by the AD per se.
