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"Gene Kearns"
shared these priceless pearls of wisdom: - -No... you shouldn't sign it off at all. You, as a mechanic or owner -cannot just arbitrarily decide to "....inspect each component by -whatever approved standard I wished...." That is not true. If 43.13.1x or 65-9/12/15 or any one of a number of Advisory Circulars gives me, as a mechanic, the option of inspecting a particular part by a number of methods, then absent direct prohibition during a REPAIR, I can use any one of them. For example, there are four methods by which I am authorized to inspect a part (magnetic particle, dye penetrant, x-ray, or hydrostatic). It is MY option in MY professional opinion as to which method I am going to use on a particular part. However, if it is to be a major OVERHAUL, then I must use whatever method(s) are specified in the o/h manual. - -If one *must* do business in this manner.... go homebuilt. Please, don't talk down to me. - -Probably not. The work, if it to be signed off as a "major overhaul" must be -done in STRICT accordance with the manufacturer's overhaul procedure. - - -"major overhaul" is not a defined concept. There are overhaul -standards clearly stated in FAR 43. An overhaul may be a major -*repair* or not.... under Part 43. I'd suggest a brief discussion with your Principal Maintenance Inspector at your local FSDO. "Major overhaul" is a VERY WELL defined concept. - -1. If the manufacturer's overhaul manual specified dye penetrant inspection and -I chose the much better and more conclusive X-ray inspection of a part, it is -not a major overhaul. - - -Clearly under Part 43 you must follow the manufacturers suggestions. -That doesn't however, prevent you from having your own procedure -approved by the FAA. The onus of proving that you "chose the much -better and more conclusive X-ray inspection of a part" is on you. No sir, I do NOT have to follow the manufacturer's suggestions. Suggestions are just that, suggestions. And, if I am "repairing" instead of "overhauling" then I certainly must follow any approved repair procedures. If there is no clear repair procedure, I may proceed on my own best judgement. [snip of a whole bunch of nitpicky crap] - -Many manufacturers of engines and airframes allow break-in installed -on the airframe if the proper engine parameters can be monitored. A -GEM is usually sufficient. A GEM didn't even EXIST when a C-85 was designed, nor has the service manual given that as an approved method of testing. Ditto most engines in service today. - -STRICT accordance with the overhaul manual. - - -And service publications, which engine manufacturers consider to be -supplements and supercedures to the printed manual. Only if the magic words, "FAA Approved Data" appear on the publication, in which case it is a true supplement, not a service letter. - - -Again, if the rules contained in FAR 43 are just too intrusive and -onerous to follow..... the FAA has give you an "out" ... go homebuilt. Oh, horsefeathers. Jim Jim Weir (A&P/IA, CFI, & other good alphabet soup) VP Eng RST Pres. Cyberchapter EAA Tech. Counselor http://www.rst-engr.com |
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