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Safety Seminar. Flagstaff Arizona October 17, 2015. Instructor: Nelson Hochberg 928-699-8350 nelson@thenelson.name ATP, ASMELS, A&P, IA, AGI, IGI, past CFII Available at www.flgslugs.org: This presentation All links in this presentation. www.flgslugs.org. Topics.
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Safety Seminar Flagstaff Arizona October 17, 2015
Instructor: • Nelson Hochberg • 928-699-8350 • nelson@thenelson.name • ATP, ASMELS, A&P, IA, AGI, IGI, past CFII • Available at www.flgslugs.org: • This presentation • All links in this presentation
Topics • My annual was 11 months ago The plane is good to go – Right? • When and why to declare an emergency.
Required Aircraft Maintenance My annual was 11 months ago The plane is good to go – Right? ··· Maybe
Caveats • This talk addresses owner/operators under FAR Part 91 • Does not cover operations under FAR Parts 121, 125, 129 or 135 • Aircraft maintenance regulations are convoluted, outdated and confusing • I am not an attorney • On the plus side: I am not an attorney
What makes a plane fly? • $$$ MONEY! $$$ • What does it take to fly higher and faster? • $$$$$$$ MORE MONEY! $$$$$$$
The FAA has lots of rules Part 1 - DEFINITIONS AND ABBREVIATIONS Part 3 - GENERAL REQUIREMENTS Part 11 - GENERAL RULEMAKING PROCEDURES Part 13 - INVESTIGATIVE AND ENFORCEMENT PROCEDURES Part 14 - RULES IMPLEMENTING THE EQUAL ACCESS TO JUSTICE Part 15 - ADMINISTRATIVE CLAIMS UNDER FEDERAL TORT CLAIMS Part 16 - RULES OF PRACTICE FOR FEDERALLY-ASSISTED AIRPORT Part 17 - PROCEDURES FOR PROTESTS AND CONTRACTS DISPUTES Part 21 - CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS Part 23 - AIRWORTHINESS STANDARDS: NORMAL, UTILITY, ACROBATIC Part 25 - AIRWORTHINESS STANDARDS: TRANSPORT CATEGORY AIRPLANES Part 26 - CONTINUED AIRWORTHINESS AND SAFETY IMPROVEMENTS FOR Part 27 - AIRWORTHINESS STANDARDS: NORMAL CATEGORY ROTORCRAFT Part 29 - AIRWORTHINESS STANDARDS: TRANSPORT CATEGORY ROTORCRAFT Part 31 - AIRWORTHINESS STANDARDS: MANNED FREE BALLOONS Part 33 - AIRWORTHINESS STANDARDS: AIRCRAFT ENGINES Part 34 - FUEL VENTING AND EXHAUST EMISSION REQUIREMENTS FOR Part 35 - AIRWORTHINESS STANDARDS: PROPELLERS Part 36 - NOISE STANDARDS: AIRCRAFT TYPE AND AIRWORTHINESS Part 39 - AIRWORTHINESS DIRECTIVES Part 43 - MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND Part 45 - IDENTIFICATION AND REGISTRATION MARKING Part 47 - AIRCRAFT REGISTRATION Part 49 - RECORDING OF AIRCRAFT TITLES AND SECURITY DOCUMENTS Part 60 - Flight Simulation Training Device Initial and Continuing Qualification and Use Part 61 - CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND Part 63 - CERTIFICATION: FLIGHT CREWMEMBERS OTHER THAN PILOTS Part 65 - CERTIFICATION: AIRMEN OTHER THAN FLIGHT CREWMEMBERS Part 67 - MEDICAL STANDARDS AND CERTIFICATION Part 71 - DESIGNATION OF CLASS A, B, C, D, AND E AIRSPACE AREAS; AIR TRAFFIC Part 73 - SPECIAL USE AIRSPACE Part 77 - OBJECTS AFFECTING NAVIGABLE AIRSPACE Part 91 - GENERAL OPERATING AND FLIGHT RULES Part 93 - SPECIAL AIR TRAFFIC RULES Part 95 - IFR ALTITUDES Part 97 - STANDARD INSTRUMENT APPROACH PROCEDURES Part 99 - SECURITY CONTROL OF AIR TRAFFIC Part 101 - MOORED BALLOONS, KITES, UNMANNED ROCKETS AND UNMANNED Part 103 - ULTRALIGHT VEHICLES Part 105 - PARACHUTE OPERATIONS Part 119 - CERTIFICATION: AIR CARRIERS AND COMMERCIAL Part 120 - DRUG AND ALCOHOL TESTING PROGRAM Part 121 - OPERATING REQUIREMENTS: DOMESTIC, FLAG, AND Part 125 - CERTIFICATION AND OPERATIONS: AIRPLANES HAVING A Part 129 - OPERATIONS: FOREIGN AIR CARRIERS AND FOREIGN.- Part 133 - ROTORCRAFT EXTERNAL-LOAD OPERATIONS Part 135 - OPERATING REQUIREMENTS: COMMUTER AND Part 136 - COMMERCIAL AIR TOURS AND NATIONAL PARKS AIR TOUR Part 137 - AGRICULTURAL AIRCRAFT OPERATIONS Part 139 - CERTIFICATION OF AIRPORTS Part 141 - PILOT SCHOOLS Part 142 - TRAINING CENTERS Part 145 - REPAIR STATIONS Part 147 - AVIATION MAINTENANCE TECHNICIAN SCHOOLS Part 150 - AIRPORT NOISE COMPATIBILITY PLANNING Part 151 - FEDERAL AID TO AIRPORTS Part 152 - AIRPORT AID PROGRAM Part 153 - AIRPORT OPERATIONS Part 155 - RELEASE OF AIRPORT PROPERTY FROM SURPLUS PROPERTY Part 156 - STATE BLOCK GRANT PILOT PROGRAM Part 157 - NOTICE OF CONSTRUCTION, ALTERATION, ACTIVATION, Part 158 - PASSENGER FACILITY CHARGES (PFC'S) Part 161 - NOTICE AND APPROVAL OF AIRPORT NOISE AND ACCESS Part 169 - EXPENDITURE OF FEDERAL FUNDS FOR NONMILITARY Part 170 - ESTABLISHMENT AND DISCONTINUANCE CRITERIA FOR AIR Part 171 - NON-FEDERAL NAVIGATION FACILITIES Part 183 - REPRESENTATIVES OF THE ADMINISTRATOR Part 185 - TESTIMONY BY EMPLOYEES AND PRODUCTION OF Part 187 - FEES Part 189 - USE OF FEDERAL AVIATION ADMINISTRATION Part 193 - PROTECTION OF VOLUNTARILY SUBMITTED INFORMATION Part 198 - AVIATION INSURANCE
The FAA has even more rules Aeronautical Information Manual (AIM) Advisory Circulars (AC) (AC 43.13) Manufacturer’s documentation Pilot’s operations handbook (POH) Service manuals FAA orders Typically applies to FAA employees Many impact you The NTSB and courts have determined that all of these comprise regulatory requirements.
Navigating to the FARs, AIM, ADs & ACs www.faa.gov Searchable FARs: www.risingup.com/fars
Advisory Advisory Circulars are regulatory??? • Example: • There are no FARs covering hand propping. • 1983: Owner hand propped a Variezy • A nonpilot companion was instructed to reach inside the cockpit and pull the throttle back • it “got away” and ran into a parked aircraft • NTSB law judge and full NTSB board agreed with the FAA for a 40-day suspension • Based on FAR 91.13 (reckless operation) and • Airplane Flying Handbook (AC FAA-H-8083-3A)
Airworthiness • FAR Part 3 §3.5 (a) • Airworthy means the aircraft conforms to its type design and is in a condition for safe operation. • FAA Order 8130.2H • The aircraft must conform to its type design. • The aircraft must be in a condition for safe operation.
What is “Type Design” • Manufacturers receive a Type Certificate • Documents supporting the Type Certificate: • Type Certificate Data Sheet (TCDS) • http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/Frameset?OpenPage • Pilot’s Operating Handbook (POH) • Service manual • Aircraft modification • Supplemental Type Certificate (STC)
Experimental Category • Does not have a type certificate or does not conform with the type certificate • Is issued a special airworthiness certificate • Obviously cannot conform to a type design • Airworthiness can only meet a condition for safe operation • Therefore it gets a condition inspection each year instead of an annual inspection • Since annual inspections includes checking for conformity to type design
FAR § 91.7 Civil aircraft airworthiness (a) No person may operate a civil aircraft unless it is in an airworthy condition. (b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.
Operator definition • Operate.…use, cause to use or authorize to use aircraft, for the purpose of air navigation including the piloting of aircraft, with or without the right of legal control (as owner, lessee, or otherwise). • If you own, rent, borrow or steal an aircraft, you are still responsible that the aircraft is airworthy.
FAR § 91.417 Maintenance records. • each registered owner or operator shall keep the following records for the periods specified • shall make all maintenance records required available for inspection by the [FAA and NTSB] • You are required to keep the records. • It doesn’t say where or how you keep them. • You are required to provide only the required records. • You do not need to provide all records. registered owner or operator periods required
FAR § 91.417Records to maintain (1) • maintenance, preventive maintenance, alteration and records of the 100-hour, annual, progressive, and other required or approved inspections • for the aircraft and everything installed on the aircraft • retained until the work is repeated or superseded or for 1 year
FAR § 91.417Records to maintain (2) • total time of the airframe, each engine, propeller, and rotor • current status of life-limited parts • time since last overhaul of all items required to be overhauled at a specified time • current status of applicable ADs including the method of compliance and when next due • forms for each major modification (337, STC, etc) • no time limit – must be passed on to next owner applicable ADs
FAR § 43.3 Persons authorized to perform maintenance • Certified mechanic, repairman or repair station • Persons under the supervision of a mechanic or repairman • A private pilot or higher may do preventative maintenance and return the aircraft to service • Combined with FAR § 43.7 (f) • Sport pilot may work on a sport aircraft • FAR Part 43 Appendix A (c) lists preventative maintenance
FAR Part 43 Appendix A (c) (1) Removal, installation, and repair of landing gear tires. (2) Replacing elastic shock absorber cords on landing gear. (3) Servicing landing gear shock struts by adding oil, air, or both. (4) Servicing landing gear wheel bearings, such as cleaning and greasing. (5) Replacing defective safety wiring or cotter keys. (6) Lubrication not requiring disassembly other than removal of nonstructural items. (7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. (8) Replenishing hydraulic fluid in the hydraulic reservoir. (9) Refinishing decorative coating (excluding balanced control surfaces). (10) Applying preservative or protective material to components. (11) Repairing upholstery and decorative furnishings of the cabin, cockpit. (12) Making small simple repairs to fairings, nonstructural cover plates, cowlings. (13) Replacing side windows where that work does not interfere with the structure or any operating system. (14) Replacing safety belts. (15) Replacing seats or seat parts with replacement parts approved for the aircraft. (16) Trouble shooting and repairing broken circuits in landing light wiring circuits. (17) Replacing bulbs, reflectors, and lenses of position and landing lights. (18) Replacing wheels and skis where no weight and balance computation is involved. (19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls. (20) Replacing or cleaning spark plugs and setting of spark plug gap clearance. (21) Replacing any hose connection except hydraulic connections. (22) Replacing prefabricated fuel lines. (23) Cleaning or replacing fuel and oil strainers or filter elements. (24) Replacing and servicing batteries. (26) Replacement or adjustment of nonstructural standard fasteners incidental to operations. (29) Removing, checking, and replacing magnetic chip detectors.
FAR § 43.9 Content, Form of Maintenance Records Required: • A description of work performed • The date of completion • The name of any others performing the work • The signature, certificate number, and kind of certificate held by the person approving the work.
FAE § 91.405 Maintenance required The owner or operator is required to: • have period inspections and repair discrepancies between inspections • ensure that appropriate entries are made in logbook and aircraft has been returned to service • have any inoperative equipment, permitted to be inoperative by §91.213(d)(2), repaired, replaced, removed, or inspected at the next required inspection
(d)(2) FAR § 91.213 Inoperative Equipment • You can take off with inoperative equipment if: • The equipment is listed on an approved Minimum Equipment List (MEL) for that aircraft or • The airplane is nonturbine and the equipment was not: • required for VFR day when the airplane was built and • required on the aircraft equipment list and • required for the type of flight and • required by FAR 91.205 or any other Part 91 regulation and • required by an AD and • determined by a pilot or mechanic that removal will not constitute a hazard to the aircraft and • is removed and logged or is deactivated and placarded Inoperative.
FAR § 91.205 Required Equipment • Day: • Airspeed indicator, Altimeter, Compass • Tachometer, oil pressure, temperature, manifold pressure* gages • Fuel gage • Landing gear position indicator* • Anticollision light – aircraft built after 3/11/96 • Safety belt for everyone over 2 years old • Shoulder harness: front seats – aircraft built after 7/18/78 • Shoulder harness: all seats – aircraft built after 12/12/86 • Night, add: • Position lights • Anticollision light system • Electrical system to power equipment • Three spare fuses of each type* *If installed
FAR § 91.205 Required Equipment 2 • IFR, add: • Communication and navigation radios suitable for route • Gyroscopic rate-of-turn indicator (turn coordinator) • Slip-slid indicator (ball) • Adjustable sensitive altimeter • Clock displaying hours, minutes, and seconds • Generator or alternator of adequate capacity • Attitude indicator • Heading indicator
Airworthiness Directives (ADs) • Corrects an unsafe condition in an aircraft, engine, propeller, or appliance. • Usually are created from manufacturers service bulletins or accident/incident reports. • You are responsible for ADs that are created between inspections. • Sign up for email delivery of new ADs at faa.org • You are responsible for recurring ADs that come due between inspections.
Emergency Locator Transmitter (ELT) FAR § 91-207 • Batteries must be replaced: • When they expire • When 50% is used • When used for 1 hour total • Inspected every 12 calendar months • Can ferry to where it can be repaired or installed • Not needed on single seat aircraft • May be removed for <=90 days if logged and placarded
Transponder altimeter check FARs § 91.217, 91.413, 91.411 • Transponder and altitude encoder must be checked every 24 calendar months • Static system and altimeter must be checked every 24 calendar months for IFR • Required: • In Class A, B, C airspace & 30 Km around Class B • Above 10,000 MSL except within 2,500 AGL
Oil changes • Lycoming and Continental service manuals require oil changes every: • 25 hours if there is no oil filter • 50 hours if there is an oil filter • The oil filter must be changed and inspected
Aircraft required maintenancereview • Annual inspection 12 calendar months • Transponder check 24 calendar months • ELT battery when it expires • Airworthiness Directives when due • Oil change 25 or 50 hours • Inoperative equipment when it occurs and next inspection
15 minute break 0 15 1 14 2 13 3 12 4 11 5 10 6 9 7 8
Declaring an emergency When and why
SHORT SURVEY • Who has had a hazardous, uncertain, worrisome or unsafe flying situation? • Leave your hand up if you did not declare an emergency. • Leave your hand up if you did not survive the incident.
Why in the world would I ever declare an emergency?????????? • I’m going to have to fill out forms and write letters! • It will direct FAA’s attention to me! • I am Mr/Ms super pilot – I can handle the problem myself! • I screwed up – I’m not going to tell everyone! • I don’t want to have to handle a bad situation and screaming passengers at the same time. • I wasn’t talking to anyone at the time.
So to ask the question again: • Why declare an emergency?
Responsibility and authority of the pilot in command FAR § 91.3 (b) In an in-flight emergency requiring immediate action, the pilot in command may deviate from any rule of this part to the extent required to meet that emergency. I can do this without declaring But everyone else can deviate from the rules if they know there is an emergency the pilot in command may deviate from any rule of this part
What is an emergency?(Pilot/Controller glossary) • An emergency can be either a distress or urgency condition. • Distress examples: • fire, mechanical failure, or structural damage • Urgency: • the moment the pilot becomes doubtful • It’s best to declare an emergency calmly, early with lot’s of options available.
Did you know that ATC and FSS can declare an emergency for you? • They don’t have to tell you. • Who is pilot in command in this situation?
Have to complete paperwork? FAR § 91.3: (c) Each pilot in command who deviates from a rule [in an emergency] shall, upon the request of the [FAA], send a written report of that deviation to the [FAA]. FAR § 91.123: (d) Each pilot in command who is given priority by ATC in an emergency, shall submit a detailed report of that emergency within 48 hours to the manager of that ATC facility, if requested by ATC. deviates from a rule upon the request given priority if requested Most emergencies are handled without deviating from FAR part 91
Have to complete paperwork?2 FAA order jo7210.632: (2011) Air Traffic Organization Occurrence Reporting Requires ATC and FSS personal to report all “occurrences” that may affect safety or require priority Has a long list defining “occurrences” This may happen in the background “Possible pilot deviation, advise you contact (facility) at (telephone number).” It has nothing to do with declaring an emergency Some of these reports make it to an FAA inspector who looks into the occurrence further
Have to complete paperwork?3 • Contrary to what many pilots think, • Filling out paper work is not a fate worse than death. • If you find yourself in a hole • The first thing to do is • STOP DIGGING! • Will Rogers
AOPA pilot protection services • http://pilot-protection-services.aopa.org/ • Unlimited consultation with legal experts • Limited legal representation • Help with medical certification • Basic: $39/yr, Plus: $99/yr • Separate program available for mechanics • Through PAMA or Yodice Associates: 301-695-2300
Mr/Ms super pilot • Super pilots use every resource available to fly safely • Six Blue Angle pilots • have about 120 support personnel • Six Thunderbird pilots • have about 125 support personnel • When you declare an emergency, you will probably have at least two experienced people working you
Don’t confess I screwed up Forgive and forget? No! Forgive and Correct!
Aviation Safety Reporting System • Operated by NASA - confidential • May provide immunity from disciplinary actions provided: • Reported within 10 days of knowledge of incident • Inadvertent and not deliberate • Not criminal offense or accident • Not due to failure of re-examination • http://asrs.arc.nasa.gov/report/electronic.html • Or Google “Nasa form”
The kinder, friendlier FAA • Order 8000.373 (06/26/15) • …deviations arising from factors such as flawed procedures, simple mistakes, lack of understanding, or diminished skills … can most effectively be corrected through root cause analysis and training, education…. • Signed 06/26/15 by Michael Huerta, Administrator, FAA
Declaring an emergencysummary • Allows ATC, FSS to deviate from the rules to help you • Does not increase paperwork or FAA enforcement risk for you