Checkride, with Airworthiness Issues

[Dazzler]

So my student passed his Private Pilot ASEL checkride today (my first Private applicant as it happens), and I went along with him to meet the examiner, and sit in on the oral part of the test.

It went well, apart from one sticky point, which was when the examiner had asked my student to point out when any recurring AD on the aircraft was due next.

My student fumbled a little with the AD list and compliance records, during which the examiner glared over in my direction with a "I hope you covered this with him" look in his eye. I was beginning to wonder whose checkride this was!

Eventually my student found the recurring AD on the Cessna 172 which has to do with seat tracks. The AD states that it is due every 100 hours, so there was no entry of a "next due date" in the aircraft log for this particular AD. It was just covered in the 100 hour inspection, which included the phrase "Checked new and recurring ADs" in the signoff, but didn't explicitly specify the AD numbers checked. It did refer to an attached AD list which listed ADs by number however.

This was unacceptable to the examiner who proceeded to point me and my student to FAR 91.417 (a) (1) (v) which states that the maintenance records must include -
The current status of applicable ADs including, for each, the method of compliance, the AD number, and revision date. If the AD involves recurring action, the time and date when the next action is required.

He said that, because the revision date was missing, and that the AD numbers weren't listed in the log, that the airplane wasn't technically airworthy. My thought was that, if an AD is due every 100 hours, how could you possibly know the revision date? All you really could determine would be the tach time.

The examiner let the checkride continue but suggested that we talked to the mechanic at the flight school, which I did but he basically said the examiner was being overly picky and that no revision date could be stated.

I would like to use this examiner again, but don't want any future student pilots having to endure this. I am not sure what to do.

Incidentally the examiner is also a qualified Aviation Inspector with IA authority, which implies he knows what he's talking about.

[minitour]

You need to get the mechanic on board or find a new DPE. You won't win this even if the DPE is wrong and it'll be your students that pay the price.

Good luck!

-mini

[Berkut]

Originally Posted by Dazzler

He said that, because the revision date was missing, and that the AD numbers weren't listed in the log, that the airplane wasn't technically airworthy. My thought was that, if an AD is due every 100 hours, how could you possibly know the revision date? All you really could determine would be the tach time.

Are you confusing the revision date with the time the next recurring element of the AD is due?

[Dazzler]

Originally Posted by Berkut

Are you confusing the revision date with the time the next recurring element of the AD is due?

Are they not the same thing? Even if they're not, the FAR says that both need to be written in the log.

[Berkut]

Originally Posted by Dazzler

Are they not the same thing? Even if they're not, the FAR says that both need to be written in the log.

No, they aren't the same thing, and I think that led to a misunderstanding about his actual complaint.

It appears to me that there are two issues here:

1) How does one list the next time and date for a recurring AD that's specified by time in service as opposed to calendar time, and
2) The rest of your AD compliance record in general

I suspect that the issues your examiner had went deeper than just some confusion over the recurring date. Like you said, the reg states:

The current status of applicable airworthiness directives (AD) including, for each, the method of compliance, the AD number, and revision date. If the AD involves recurring action, the time and date when the next action is required.

Break that down into the elements that are required, and you get:

For each airworthiness directive:
*The current status
*The method of compliance
*The AD number
*The Revision date
*The time and date when next action is required

It would appear that the general statement of "Checked new and recurring ADs." does not satisfy the requirement. For each AD, it should be something along the lines of "Complied with AD 87-20-03 Revision 2 dated 11-24-1990 by inspection of seat track rails and holes for wear. Next inspection due at 2125.6 TT"

Yes, there is no exact date stated. You don't have one, only the TT at which it must be performed. Your examiner was complaining about the lack of any indication when it should be performed, the lack of AD numbers and revision dates, and probably the way the ADs were recorded in general.

Does that help any?

[Dazzler]

Thanks for the response.

I guess the question remains that is it legal to put a sweeping statement of "Checked the ADs" in an inspection signoff, to cover all recurring ADs to date?

I suppose there's something about it buried in FAR Part 39, "Airworthiness Directives". I would be interested in knowing what "The King of the FARs" (MidlifeFlyer - Mark) has to say on this topic.

[DE727UPS]

Why can't the AD list be considered part of the log and have that satisfly the "written in the log" mandate. What if you attached the AD list TO the log with a staple?

I can tell you that every airplane I have owned, and it's been over 10, has used an AD list attached to the log, and I've never heard any mechanic say that's not okay.

[Berkut]

Originally Posted by DE727UPS

Why can't the AD list be considered part of the log and have that satisfly the "written in the log" mandate.

I don't see any problem with that, as long as all the required information is there. Due to some apparent confusion in terminology, we would probably have to see the records in question to sort out exactly what the examiner had a problem with.

[Dazzler]

I believe his main issue wasn't with the AD list not being attached physically to the log, but the missing "Next Due" dates. Just saying "Due at Next 100 Hours" wasn't acceptable to him.

[moxiepilot]

Originally Posted by Dazzler

I believe his main issue wasn't with the AD list not being attached physically to the log, but the missing "Next Due" dates. Just saying "Due at Next 100 Hours" wasn't acceptable to him.

I would tend to agree with the "due at next 100 hr" not being specific enough.


All of the logs I have reviewed by A&P's usually have at the beginning of the entry: date and tach time then the description of actions preformed. Unless the Tach time is listed then when the inspection occurred doesn't mean a whole lot.

BTW on a side note isn't the seat track thing every 50 hours? I haven't looked at that AD in a while

[Dazzler]

Just had a telephone conversation with the mechanic at the flight school and he said that this particular examiner was being a d**khead. I told him that I didn't want to tell him how to do his job, but to go ahead and humour me and put the AD due date in the log book anyway. After discussing some more, he agreed to do it. We'll see...

[ILS37R]

Part of the concern with the "due at next 100 hours" might be that while a 100-hr can be overflown, an AD, unless explicitly specified, cannot. The seat rail AD, in particular, cannot be overflown. Ergo if someone not really familiar with the AD were doing a maintenance ferry flight in the 10-hr overflight buffer but the seat rails had not yet been inspected, the aircraft would not be airworthy.

Obviously, someone looking over the logs could just do the math from the last 100-hr tach time, but it is somewhat misleading to lump the AD and 100-hr together since they're subject to different rules. A bit nit-picky, granted, but that would be my concern.

[nosehair]

Originally Posted by Dazzler

had a telephone conversation with the mechanic at the flight school and he said that this particular examiner was being a d**khead. ...

Now the mechanic is being a d**khead back. Isn't that the way of it?
The mechanic doesn't want to have to write all dem details ever dam time. I don't blame him. I hate writing all that stuff in a student's logbook - but, HEY! It's my job! I do it with style.

[Dazzler]

Originally Posted by nosehair

Now the mechanic is being a d**khead back. Isn't that the way of it?
The mechanic doesn't want to have to write all dem details ever dam time. I don't blame him. I hate writing all that stuff in a student's logbook - but, HEY! It's my job! I do it with style.

I hear ya - you're preaching to the choir here. I was thinking the same, but kept the conversation to a diplomatic level so I could get him to agree that he should probably do something about it, and fill in the appropriate paperwork to be in accordance with the FARs.

[nosehair]

Originally Posted by Dazzler

I kept the conversation to a diplomatic level so I could get him to agree that he should probably do something about it, and fill in the appropriate paperwork to be in accordance with the FARs.

Good Job! I see you do yours with style, also.

[Berkut]

Originally Posted by Dazzler

put the AD due date in the log book anyway. After discussing some more, he agreed to do it. We'll see...

If he doesn't have a date, what is he going to put?

[Berkut]

Originally Posted by Dazzler

Just saying "Due at Next 100 Hours" wasn't acceptable to him.

I can see his point, since 100 hour inspections can be overflown but the AD cannot. Not only that, if the aircraft is taken out of for-hire service, even temporarily, that next 100 hour inspection might not come. The ADs really need to be tracked individually. It's nice if they happen to coincide with an inspection, but that can't be relied upon.

Oops, I missed that ILS37R beat me to it.

[CDVdriver]

Suggest to your A&P that he prints stickers where he only has to fill in the TT and his signature . Technically (but only that) the DPE is correct.
On my CFI checkride the FSDO inspector questioned me on a MX logbook entry, on the specific wording.
I could not give him an answer and told him so. He gave me a stern look and asked me the following question: " is this check ride for your CFI or do you wish to be an A&P?"
In a shaky tone of voice i told him CFI, please Sir.....
He smiled and told me to go get the A&P and gave him a beating right there and then.

Morale of the story... you cannot be held responsible for the exact wording of a MX entry if you are not the A&P.

[Berkut]

Originally Posted by CDVdriver

Technically (but only that) the DPE is correct.

That's an interesting statement. In what way is he incorrect?

[mhcasey]

When I'm sending a student for a checkride, I have them fill out a spreadsheet with the last performed, next due, and time till due (tach or days):

Annual
VOR
100 Hour
Altimeter/Pitot Static
Transponder
Elt (and battery expiration date)
Recurring AD's

Tab each of those in the mx records and have the spreadsheet filled out ahead of time and the examiner is not likely to ask too many questions.

[CDVdriver]

It is in my experience unusual that a DPE is this picky.
Acting in the spirit more then the letter of the law the DPE could have had a talk with the operator requesting different wording on the entries for the next check ride. He may be an IA himself but he is not there in the function of PMI but as an examiner.
The AD has been complied with and will be complied with on the next inspection.
Unnecessary burden on the student for a PPL check ride.

It's like getting a ticket for doing 47 in a 45mph zone, technically correct but not in the spirit.