 Welcome to the FAA Production Studios and the FAA Safety Center, the National Resource Center located in the Sun and Fun Complex in beautiful Lakeland, Florida. I'm your host, Walt Shammel, and our next presenter has been an aircraft maintenance technician for over 20 years. He's been with the FAA over four years, and he's currently the FAA Safety Program Manager for the Minneapolis FISDO. His topic today, and a very appropriate one for today's environment, is owner-operator responsibilities in aircraft maintenance. Let's welcome James Niehoff. Thank you, sir. Good morning. How are you guys doing today? This presentation is one that I put together a while ago. It is my favorite presentation. It's got a lot of good information in it, in my opinion. I always get a lot of good feedback from it. We're not going to be talking about what you can and cannot do maintenance-wise on your aircraft as a owner-operator. We're going to be talking about your responsibilities for the maintenance of your aircraft. My name is Jim Niehoff, and I like to tell everybody a little bit about myself before I get started to make sure you know where I came from and how I came to be talking to you today. I actually started my career down here in Florida. Anybody from Florida? You're from elsewhere? South Central, Florida, Palm Beach County Glades Airport, 1982. I came to work down here as an ANP mechanic. I worked on single-engine light twin for six years. I went back to Minnesota, my home state, in 1988. I went to work for a company called Whip Air Incorporated. Anybody here have heard of Whip Air before? World's largest manufacturer of floats for aircraft. Exciting place to work. Worked on a lot of nice stuff, new stuff, different stuff, stuff that other folks in the industry weren't working on very much. It was very challenging and very exciting. Last five years there I was the Chief Inspector of the Repair Station. I guess I can tell you that the day I took the Chief Inspector job at Whip Air was the day the clock started ticking. It was a very high-paced, high-stress environment. I averaged anywhere from 100 to 120, 337s a year. That is a major repair and major alteration form, giving ideas of the volume of work that was going through the shop at the time. After five years in that position I had reached a state of burnout and was looking for someplace else to go. So in May of 2003 I crossed over to the dark side and went to work for the FAA. I was the Principal Maintenance Inspector and the GA Unit at the Minneapolis FISDO for four years. Then a year ago, December, went to work for the FAA safety team. That gives me an opportunity to put presentations like this together and talk to you folks about important issues. Today I'm going to be talking about owner-operator responsibilities and aircraft maintenance and time permitting. I'm going to spend a brief period of time on TSOs and PMAs, which are FAA-approved parts that get installed on your aircraft. I'm going to tell you what they are and how you get them put on your aircraft. At the very end, when I initially put this presentation together, my supervisor wanted an outline. So I put an outline together for her. At the very last note, the very last bullet point on my outline was a personal note from me to the audience. When she read that, she singled me, come on in here, I want to talk to you about this. And I told her what I was going to talk about and she gave me the thumbs up and I've been doing it ever since. So to start, your responsibilities start at the Airworthiness Certificate. Have you ever read one? Have you ever read one, really? This is one of those typical things where the large print giveth and the small print taketh away. Your responsibilities for maintaining and operating your aircraft are contained on its Airworthiness Certificate. Before I go any farther, I want to talk about the word Airworthy. We use this term every day in this business. Anybody here not use the word Airworthy? Do we know what it means? And they tell me what is the definition of Airworthy? When your mechanic performs the annual inspection on your aircraft and signs it off at the bottom stating, I certify this aircraft has been inspected in accordance with an annual inspection and determined to be Airworthy. What is your mechanic stating? First part of that definition, when your aircraft conforms to its type design or properly altered condition, and those are my words, and this is out of 14 CFR part 3, section 3.5, and the aircraft is in a condition for safe operation. No subjectivity in the first half, lots of subjectivity in the last half. What I mean when or properly altered condition, what do those words mean? A lot of times aircraft are altered at some point during the course of their life. In my industry career, I altered a lot of aircraft. I put a lot of floats on, I did a lot of alterations, right hand doors, larger engines, Robertson stall kits, Flint tip tanks, the list goes on and on and on. Every time a major alteration is performed on an aircraft, it must be tied back to the type design with approved data. And that is either some sort of approved data, either a type certificate or engineering order or something like that. So the aircraft can actually be altered from its original design the way it was like when it left the factory and still conformed to its type design through approved data. So this is the definition. And again, even though I worked in the industry for 20 years, and this is a favorite question for me to ask when I do maintenance presentations because I like to see how many of the mechanics out in the audience know the definition to airworthy. I was working to this definition for 20 years even though I couldn't tell you what that definition was. So it's always an interesting thing to note. So here's your airworthiness certificate. And there's a lot of information contained on here. Up here in the upper left hand corner, you see the nationality and registration marks. What is the nationality mark on an aircraft registered in the United States of America? Ann, very good. Thank you. Ann, how about Canada? What do you see on Canadian airplanes? What's the registration mark? C. All right. Does anybody know what the registration mark for an aircraft is in the Maldives? Every nation in the world that has a CAA or a Civil Aviation Authority where you can register an aircraft has their own nationality mark. And I have actually a list back at the office. It's quite interesting. So that's the nationality mark and what follows is the registration numbers and letters in some combination thereof. You'll find the manufacturer and model number on your airworthiness certificate as well as the serial number. This is the information that ties this document to your aircraft. You'll also find the category. I would wager to guess anybody flying experimental amateur built here? You're not going to see one of these in there. That's yours? Yeah. Anybody know where you go to find the category? If you wanted to know what the category of your aircraft was, where would you go to find that information? It's on the Type Certificate Data Sheet. If you haven't read the Type Certificate Data Sheet for your aircraft, I would suggest that you do that. It's very interesting. It's got a lot of information, at least from a mechanic's point of view. It's very interesting. It basically tells everything that's supposed to be on your aircraft. It'll give you the engine that you can put on it, the prop combinations. All that information is contained. It tells you the category. It tells you the certification basis and a lot of other information. Then we have the authority and basis for issuance block. If there are any exceptions to this, that's where they will be typed. My guess is that most, if not probably 99% of everybody has a none, the word none, typed in this particular box. You do find exceptions to this rule from time to time. If you get into the business jet category of aircraft, that's a lot of times you'll find it there or larger. A lot of times there are exceptions to the rules. That's where they will be. The date of issuance of the Air Within Certificate, the representative who's issuing that certificate, whether it be FAA or a DAR or whoever, and their designation number. Now that we've flipped past that and you've had a chance to look at it, did anybody notice what three rules are referenced on the Air Within Certificate? There's three rules that are spelled out. We're going to talk about that here in a little bit. But for now we're going to go through, line by line, the authority and basis for issuance section of the Air Within Certificate. I'm going to explain a little bit of this as we go. It states the following. This Air Within Certificate is issued pursuant to the Federal Aviation Act of 1958. This is the legislation that was passed by Congress and signed by the President of the United States that created the FAA. Prior to that we were the CAA. The FAA officially came into existence in 1958 and certifies that, as of the date of issuance, the aircraft to which issued has been inspected and found to conform to the type certificate therefore to be in condition for safe operation. What is that? Anybody make the connection here? That is the definition of... Airworthy. Airworthy, thank you. So the aircraft must be determined to be airworthy prior to the issuance of an Air Within Certificate. And we'll continue on. And has been shown to meet the requirements of the applicable comprehensive and detailed airworthiness code as provided in annex 8 of the Convention of International Civil Aviation except as noted here in and again if there's any exceptions to this you would find them here. So every time an initial issuance of this certificate is made, the aircraft must be determined to be in an airworthy condition. Subsequent issuance or reissuances of this certificate can be done based on the issuance of this initially. When I would issue replacement certificates and if you would ever get in a position where you would need one, whether you changed the N number on your airplane or the old certificate got deteriorated to the point where you couldn't read it or it was torn and you wanted a replacement. That's something that routinely happens at the FISDO. Probably a couple of times a week I was issuing a replacement Air Within Certificate for one reason or another. I do not need to make a determination of airworthy to reissue but a determination of airworthy must be made for an initial issuance of this certificate. Terms and conditions. Another section on the Air Within Certificate that contains lots of words and we're going to go through these and there are the three rules that are referenced. Anybody want to make a guess again as to what three rules are referenced in this particular section? One of them I would, it rarely is guessed, it's part 21 but the other two, anybody know the rule for maintenance? As a mechanic, what rule do I follow to do the maintenance on the aircraft? It's part 43. What's the rule that you need to know to operate your aircraft? Where do you find the minimum safe altitude rules and that sort of thing, anybody want to make a guess? It's 91. So let's go through this line by line. I'll explain a little bit of this as we go and it starts like this, unless sooner surrendered, suspended, revoked or a termination date is otherwise established by the administrator and there was a day when every Air Within Certificate that was issued had an expiration date on it. It was only good for one year. At the end of that year an annual inspection needed to be accomplished on the aircraft, a new determination of airworthy needed to be made and at that point in time a new Air Within Certificate was issued good for one year. That changed in the mid-50s, 1955 when as you can imagine with the number of aircraft escalating over time it got to be a huge burden to be issuing a new one of these for every single aircraft. So at that point in time no termination date was placed on the certificate however from time to time old aircraft that did have an expiration date on the Air Within Certificate come to the FISDO to get a replacement and a determination since it's never had one since 1955 because it expired at that point in time a new determination of airworthy needed to be made at that point in time before I could issue a new one. And we'll continue this Air Within Certificate is effective as long as the maintenance, preventive maintenance and alterations are performed in accordance with Part 21, 43 and 91 those are the three rules referenced and right here it all if you can imagine we live under a representative democracy or at least that's what I will call it today and we have a congress and a that passed legislation creating the FAA a president that signed that legislation giving us the authority to write and to regulate these particular rules we who elect to get involved in aviation voluntarily submit ourselves to these rules so at this point in time this is our connection to those rules this is what is telling us the FAA, the authority we have to issue the certificate and you how you as an owner operator are going to maintain and operate your aircraft all come from this particular point and let's continue there's another really important point that a lot of people aren't aware of so we're going to maintain our aircraft in accordance with Part 40 21, 43 and 91 of the FAARs as appropriate and the aircraft is registered in the United States that needs to be all capitals on that and the aircraft must have a valid registration the status of the airworthiness certificate is the same as the status of the registration if the status of your registration goes from valid to anything other than valid your airworthiness certificate has that same status are you all owners in here? are you owning your aircraft? so every three years you get a postcard from Oklahoma City remember seeing that? and this goes out to every aircraft owner every three years if the information, first of all if the card reaches you and all the information is correct you take that card and you can throw it away nothing changes if you have moved your information with registration in Oklahoma City and this card is mailed to you doesn't find you and is returned to Oklahoma City the status of your registration will be changed from valid to undeliverable triennial at that point in time you do not have a valid registration and you do not have a valid airworthiness certificate in your aircraft there are other reasons it could be terminated I'm not sure exactly how long it can stay in the undeliverable triennial status before it changes to terminated but there are a number of a variety of reasons why your registration can be changed from valid to something else if you want to check if you're curious, google your N number go to the FAA.gov website and check the status do an N number search for your aircraft it's all public information and your name and your address will be on there and the status of your registration will be there so if you're curious I would urge you to have a look and see what your status is if I were, if you were to come to me at the FISDO requesting a replacement airworthiness certificate for whatever reason lost it, new N number, what have you the first thing I would do is check the status of your registration if the status is anything other than valid I can't help you until that is fixed let me tell you one other thing and you may want to take notes on this or at least store it away back in the gray matter there is a way, if there is a problem if the status of your registration is anything other than valid and you want to go flying that day it's still possible call Oklahoma City up see what they need to fix this you may be able to do it on the phone right there you may not if you can't do it on the phone right there and they need additional information on the phone that they give you what's called a fly by wire a fly by wire and don't, if they don't know what you're talking about just work your way up the food chain until you find somebody that does that is a fax form that they can send you in about 20 or 30 minutes and it's a temporary registration good for 90 days throw that in your airplane you're good to go, you can fly on that and if you get ramp checked you won't have a problem yes sure, absolutely good point they're right around the corner out here you can check it with them and if anybody that has access to the internet go to fa.gov, you'll find that information there thank you, I appreciate that so very important, very important to understand that the registration must be valid and that the status of your airplane certificate is the same as the status of your registration I want to talk a little bit about part 21 I'm not going to go into very much detail here but I want you to know what's there I'm going to cover a couple of titles in different sections so you have an idea of what is what is in this particular section sub part B and part 21 is titled certification procedures for products and parts sub part B covers type certificates I mentioned that earlier where every aircraft, every aircraft that's owned by you has a type certificate if it's a type-certificated aircraft if it's a light sport it doesn't have one of these if it's an experimental amateur built but if it's a standard normal type-certificated aircraft it will have a type certificate and what you would do, let's say you're a manufacturer and you design and build an airplane and you demonstrate to the FAA that that aircraft meets all of the certification rules contained in the FAARs the FAA has the authority based on part 21 sub part B to issue that type certificate so you now as a manufacturer have a type certificate for that aircraft sub part E covers supplemental type certificates that's something I dealt a lot with at Whip Air they have lots and lots of STCs and that is the section that authorizes the FAA to issue supplemental type certificates approved data for an alteration production certificates let's say you are a manufacturer and you design and build an airplane and you demonstrate to the FAA that it meets all of the certification rules you get a type certificate can you start making that airplane at that point in time? you need to establish production and demonstrate that every airplane coming out the end of that production line meets the type design of the aircraft when you do that you get a production certificate and you can start making that aircraft sub part G gives the FAA the authority to issue production certificates and now sub part H air within the certificates this is the section that grants the FAA the authority to issue that air within the certificate and there's a lot of different kinds and varieties standard normal and experimental etc etc sub part O technical standard order authorizations and time permitting towards the end of this presentation I'm going to run through that tell you what a TSO is where it came from how it came to be and a little bit about that but there's a lot more to this rule and a lot of it that really you're not going to be interested in but just to give you an idea again the legislation that created the FAA gave us the authority to write these rules this is the rules that grant us the authority to do these things and we're going to go on now to part 43 this is the rule that I worked under for over 20 years in industry as a mechanic and there's three parts of this rule that you need to know about it's a very short rule it's about a dozen rules and six appendices it doesn't take very long to read if you're suffering from insomnia one night you can pull this out and it will put you right to sleep but there's three parts of this rule that you really need to know about we referenced in part 91 that we're going to be talking about here in just a minute section 43.5 and I only have the title here approval for return to service after maintenance, preventive maintenance rebuilding or alteration what you need to know about this rule is anytime a maintenance function is performed on your aircraft it must be approved for return to service it doesn't matter if your mechanic just completed the annual inspection or you just changed the oil anytime a maintenance function is performed it must be approved for return to service so what does an approval for return to service look like? section 43.9 covers content, form and disposition of maintenance, preventive maintenance rebuilding and alteration records there's four things that make up a valid approval for return to service following a maintenance function anybody tell me what they are there's going to be the date description of the work performed signature of the person performing the work and their number if it was an annual inspection it's going to be the ANPIA or the repair station and their number if it's an oil change something that you just did it's going to be your name and your number your pilot certificate number that you have under part 61 it must be approved for return to service there's one thing that was missing from that list anybody know what that was? times, thank you that's not required by the rule under maintenance functions it is required under inspections are you going to put it in? absolutely, always, I always did I did thousands of maintenance record entries as chief inspector and I always referenced the times under section section 43.11 you're going to see these referenced in 91 here again in a little bit this is content, form and disposition of records for inspections and this is where all of the time life items aircraft total time, engine total time prop total time, time since major overhaul those times if there's any life limited parts if you have an aircraft with a turbine engine in it or a helicopter there's lots of life limited parts that go into these aircraft parts and pieces these must be tracked and must be current and up to date at the time an inspection is performed going to go into part 91 now general operating and flight rules is the title of part 91 we are going to be talking about sub part E or what I call the 400 series of the rule and this is title maintenance, preventive maintenance and alterations first one we're going to talk about is 14 CFR part 91 section 91.403 and paragraph A states the owner or operator and that would be you anytime you see owner or operator that is the pilot of the aircraft or owner, operator of the aircraft and that's you is primarily responsible for maintaining that aircraft in an airworthy condition including compliance with part 39 of this chapter what's part 39 any guesses anybody know 39 is ADs airworthiness directives part 39 is not referenced on the airworthiness certificate but it is incorporated by reference in part 91 section 403A so this is a great indication of the tentacles as I describe them running through the rules where even though the source which is the airworthiness certificate doesn't tell you you need to comply with ADs you do because it's in reference in accordance with part 91 next rule we're going to talk about is 91.405 each owner or operator and that's you of an aircraft shall have that aircraft inspected as prescribed in sub part E of this part etc and shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating that the aircraft has been approved for return to service did you just see what the rule just did who's responsible to make sure that I make a maintenance record entry for your aircraft the work I just did on your airplane you are how many of you knew that there was a we had completed a float install which we did routinely constantly and delivered the aircraft it was completed we went through all our final checks it was a proof return to service we did everything that we normally do for an install on an aircraft owner comes up jumps in the airplane flies home he was local Minneapolis area two days later showed back up with his log book in his hand and said I don't see a maintenance record entry in here for my float install and it was a little late at that point in time but it was there it was one of those log books and you may have one like this it's got different sections in it it's got an avionics section in it it's got an alteration section in it it's got a number of you know it's in a book that's only that thick it's got five or six different sections in it and he didn't look in the right section I opened it up and showed it to him and it was there but he was he's on the hook for that you're on the hook for that the owner operator is responsible to make sure that your mechanic or repair station gets that work done and it's a proof return to service before you get in it and go anywhere next one 91.407 a no person may operate any aircraft that has undergone maintenance preventive maintenance rebuilding or alteration unless it has been approved for return to service by a person authorized etc etc and the maintenance record entry required by 43.9 or 43.11 as applicable of this chapter has been made and we drilled this one into the dirt into the dirt yet why is this so important why is the FAA so adamant about this anybody have any idea the answer to this question is one word nope he said safety and thank you for that because that's the first answer I always get it plays into it but really I'm thinking about the actual nuts and bolts of why this is so important and before I answer this let me ask you another question I love asking this question because it's going to show me who's got animosity towards the FAA what is the primary responsibility of the FAA this is going to give you some insight into my thinking and how I think and it's not job security and it's not to complicate and make your life miserable the number one responsibility of the FAA is to find and fix unsafe conditions in the aviation industry that's my definition that's what I think we do so the answer to this question is traceability how can we fix something if we can't find it I've got a scenario for you and this is going to illustrate why this is so important let's say hypothetical situation you are an instrument rated pilot and you have a beautiful airplane that's instrument equipped got all the bells and whistles all of a sudden one day your artificial horizon goes bad and you need a new one so you go to your mechanic and they order one and they install the new one unbeknownst to the manufacturer unbeknownst to the mechanic and unbeknownst to you there is a flaw that has been built into this part two weeks later you're up flying along and it's been functioning flawlessly up to this point in time it's running great, airplane's running great you're in the soup, you've done everything the way you're supposed to do it you're a competent IFR pilot engine is pulling like it's supposed to be when all of a sudden that flaw comes to light and it fails and before you know it the autopilot throws you into a violent upset maneuver that you can't recover from you break out of the clouds at 300 feet in a 70 degree nose down attitude going 200 miles an hour 1.03 seconds later you dig a hole in a cornfield and kill everybody on board the aircraft how are we now charged with sifting through this smoking hole going to figure out what happened to you there's more of these out there we need to find them if there's no maintenance record entry if there's no way for us to find this flaw and find out why this thing failed it's a ticking time bomb for somebody else maintenance records are vital vital in accident investigations and finding causes to accidents the real cause we don't want to blame the pilot if it's not the pilot's responsibility we want to find the part we want to know why this happened we investigate accidents to prevent future accidents that's what it's all about and that's why you see this over and over and over again not only am I charged as a mechanic to approve this work for return to service but you are responsible to make sure I do my work you can't fly it again until it's done and so there's a record of it so we can come back to it and find it if we need to very important stuff 91.409 accept is provided in paragraph C don't you love rules that start like this accept is provided now you gotta go figure out what's in paragraph C before you can understand the whole picture the whole scope of this accept is provided in paragraph C of this section no person may operate in aircraft unless within the preceding 12 months it has had an annual inspection in accordance with part 43 of this chapter or an inspection for the issuance of an airworth in certificate in accordance with part 21 of this chapter what do both of these things have in common what do we need to do before we can issue an airworth in certificate to make it sure it's airworthy what do we do if we're going to do an annual inspection we're making a determination of airworthy so every 12 calendar months a determination of airworthy must be made on your aircraft and there's a bunch of additional rules part 91 to run through some of these if you're wondering where they are and really what's in them I would urge you to spend some time in there and to read them how many of you get your altimeter and altitude reporting equipment tested every 24 calendar months this is where that comes from 411 and 413 413 is transponder test and inspections I always refer to these as the IFR certs any time an aircraft came in for an annual inspection as chief inspector I would pour through the books I do the research I would look for these and if these were overdue or coming due soon that's one of the things that I would make sure was done I'd get with our avionics shop and get that scored away 91 415 is changes to aircraft inspection programs I would have wagered to guess that everyone here really is under an annual inspection that's not an inspection program this would be like a phase card inspection or some sort of program established by the manufacturer if you're going to change from that to something else this tells you how to do that 417 is maintenance records retention tells you how long you need to keep your records and how many of you knew that it's in the rule that when you sell your airplane the records must go with it that's in 91 419 421 rebuilt engine maintenance records tells you how to deal with these and what you need for those so that's essentially part 91 and the sections that apply to you maintenance wise I would urge you to go in there if you're interested to read up on some of this stuff again it's pretty dry but worth your while I think I want to talk about 39 for a second because I mentioned it earlier and it is incorporated by reference and you must comply with ADs and I wanted to cover just one section in here it's section 39.7 and when they rewrote this rule several years ago and maybe it's getting to be longer than that I don't know it's I've earned every single one of these gray hairs on my head so I'm sort of loose track of time they started each section with a question and this is how it goes what is the legal effect of failing to comply with an error in this directive answer anyone who operates a product that does not meet the requirements of an applicable AD is in violation of this section strong language but that's one of the things that also happens during the course of an annual inspection you should have a complete list of all the ADs that are applicable applicable to your aircraft and their status a lot of times I would see and I'm probably guilty of this at some point till I figured out I wasn't supposed to be doing it a lot of times what you'll find in the maintenance record entry is the mechanical right in there checked all ADs or all ADs up to date there's a lot of ADs out there that don't apply to your airplane so we just need to know what the status applicable ADs are on your aircraft any questions on that section there's a number of ways you can deal with that and the question is what do you do when you can't get your annual inspection done in that 12 calendar month time frame and it happens a lot and that was one of the things that I did a lot as a principle in the FISDO was issue a what's called a ferry permit and a ferry permit is a temporary flight authorization that allows you to relocate the aircraft where it is to where it needs to go to get that annual inspection done so and that's a very easy thing to do again as long as your registration is valid I issued these routinely from several a week many times and that again you need that as much as I hate to admit it the FAA's teeth are rather dull unless you're a professional pilot earning a living with your certificate or a professional mechanic earning a living with your certificate and a violation or a suspension or a revocation would ruin your career there really isn't much that I'm going to be able to do to you however who does put the teeth in our rules it's the insurance companies and the lawyers you need to have an airworthy aircraft or at least something that says you have authorization to fly your aircraft when it's not airworthy because if something happens from point A to point B and you're out of annual and you didn't call for that ferry permit and something happens what's your insurance company going to do okay there we got it let's say I own an airplane and I'm in the military and I'm overseas for a year or 8 months Air Force reserve whatever I got a nice airplane at the home airport sitting in the hangar but that 12 months rolls through and I'm still overseas and so when I come back I get it inspected but I've done this outside of the 12 month window once you complete your annual inspection you're good to go the aircraft has been determined to be airworthy and you can fly it okay if you you can arrange for it to be done while you're gone if it can be done right there at the field yeah if I'm going to be gone pay for an inspection then I'm not going to use the airplane for another 6 months you can there's nothing that says if you cannot operate the aircraft out of annual if you go past that 12 months and you're going to be gone for another 8 and you just want to leave it set you can do that there's going to be some things that you probably want to take care of like your battery might be an issue the fuel is going to get old other issues like that that you're going to want to take care of before you go flying again but it can sit there there's nothing that says it can't sit there okay thank you appreciate that any other questions on this particular segment we're going to proceed then I've got time by the looks of it into TSOs and PMAs and there's a lot of confusion I think at least that was my experience and I had questions about TSOs and PMAs and what they were, where they came from and how do you get them put on your aircraft first of all a TSO is a technical standard order it is data only this came about after World War II late 40s early 50s when the aviation industry was really starting to spool up everybody was getting involved in aviation lots of people building airplanes everybody that built an airplane was building an airplane had their own idea of what a seat belt should look like everybody had their own idea of what an artificial horizon should look like everybody had their own idea of what a turn coordinator should look like etc etc etc and every single time an aircraft came up for certification for each and every single one of these issues so the technical standard order came about at that point in time and it created a set criteria for many different components that were going into aircraft I'm not sure exactly of the number right now I looked up the TSOs before I came here this was last week and the highest number I saw was TSO 198 now I know there's some that have expired and have gone away so there's not 198 of them but there's a lot ELTs seat belts, seats sump drains life rafts, life vests the list goes on and on and on of all of these particular components for example a TSO is data only and if you were to look at the TSO for the ELT for example you would find it's only about 3 or 4 pages long it's not very long but it references a lot of other documents and one of the paragraphs in there would tell you something like this this ELT needs to have a G switch that actuates between 4.8 and 5.2Gs it must transmit for a period of 48 hours once activated while transmitting 80% of its energy must be transmitted between this bandwidth and this bandwidth et cetera et cetera et cetera very technical stuff if you were a manufacturer that wanted to design an ELT you would pull this TSO out and say this is what I need to do this is how this ELT needs to work it needs to be able to meet all of these criteria you would design your ELT and if it met all of these things the FAA would issue you a TSO and allow you to start producing that ELT there is no installation authority that comes with a TSO it is just an FAA approved part I'm going to talk a little more about that in just a second then you have PMAs PMAs stands for a part parts manufacturing approval normally what you would find these on are direct replacement parts any Cessna owners here or any Cessna the example that I like to use here is the seat rails there is an AD that applies to the seat rails on your Cessna it is due every 12 calendar months every annual inspection or a certain number of hours depending on how many hours you fly you have to perform this AD it is an inspection of the seat rails on the seats of your aircraft and if you find any cracks anything that is worn beyond limits that seat rail must be replaced there are TSO holders out there I'm sorry PMA holders out there you can buy a part from them you can go to Cessna and pay $500 for a seat rail or you can go to this PMA over here and spend $200 for a seat rail what are you going to do it is a good part it is an FAA approved part what you are going to find is that that replacement part is specific to your aircraft by make and model and will be accompanied by what is called an AML or an approved model listing it will be a piece of paper that comes with that part that tells you what you can put it on if you have a 172N and you look at this AML and it has got every single 172 ever made since the dawn of time but the 172N can you put it on your airplane it must be your aircraft by model number and letter specific has to be identified on the AML for you to put it on that is your installation approval the installation of that seat rail is still a major repair and must be dealt with in a you have to file a 337 for that repair but you can put that PMA part in under that AML that AML is your installation approval for a PMA part installation of a TSO part if the installation of a TSO part is a major alteration it will require approved data to get it put on your aircraft if the installation of that TSO part is a minor alteration you can install it with a log book how do you tell the difference talk to your mechanic there are very specific well I've talked on this subject for maintenance folks there's a number of tools we have to determine if a repair or alteration to your aircraft is major or minor not an exact science but it's all the help we have and they can apply these tools to what you want to do and to the part you have and if the TSO if installation of that TSO part is a major alteration you need to get some form of approved data a number of ways you can do that get a field approval and I know there was a question in here to form the other day about the field approval process and why it had gone away I can tell you from personal experience I did a lot of them in industry and in the early 2000's I think it was 2001 or 2002 the guidance changed big time I was still a chief inspector at that time for all practical purposes as far as I was concerned field approvals went away they weren't worth my time and the public cried out as justifiably so and it changed the guidance changed and I will tell you now as a former principal and somebody that did field approvals that there is no such thing as a dead end field approvals are doable you can do anything to your aircraft all it takes is time and money but field approvals will never go away because you won't let them go away and there is always a way to get it installed on your aircraft however there is going to be times when a straight up field approval is not possible you can then go to what is called a DER designated engineering representative they work on behalf of the FAA on the engineering side they can provide what is called an 8110 that is an engineering authorization they can justify the part that you are trying to install provide you with all of the data and a form that says here install it in accordance with this and that can get it installed on your aircraft so there is a number of ways to get a TSOD part that requires that it is a major alteration installed on your aircraft but you need approved data to be able to do that so that is the gist of those two things and I will give you an example one of the examples that I use in the maintenance side of it I was talking at the Great Lakes International Aviation Conference in Novi, Michigan in January I believe it was and I talked about this and there was a particular case and we worked a lot on caravans caravan was a big aircraft and something that we worked on a lot we did a lot of alterations to it we had a lot of exclusive supply and tell that didn't like the factory seating they wanted to have the factory seating removed and they wanted to have the big captain's chairs put in the Urda captain's chairs or something on that line for installation in the caravan was a TSOD seat but the installation of that seat was a major alteration we had to get approved data to get that seat into that aircraft we hired the services of a DER who crunched the numbers for us and I'm not sure it's something that the engineers do and they come up with all of the data and the numbers to support this and provided us with an 8110-3 for the installation of these seats so there's always a way don't ever feel there's a dead end there's always a way to get a part installed especially if it's a good part a TSOD part any questions on that section anything on approved parts PMA parts or TSOD parts I think we're running good on time last section and I'm glad you guys are here this is the section I alluded to earlier where it's a personal note for me to the audience the supervisor wanted to have explained to her before she'd let me do it as you know I spent over 20 years in industry working hard every day just trying to do it right reading the rules interpreting the rules trying to work within the confines of those rules same thing you're doing I don't think there's anybody out there that wants to fly unsafe and are just looking for that information to make their lives better and safer and then when I crossed over to the dark side and went to work for the FAA my roles changed I went from working under these rules to trying to explain these rules phone would ring somebody had a question can you tell me about this rule how do we do this what does it mean and for a period of time I was in a big learning curve with the rules that I was expected to enforce and one day it dawned on me what the rules were it was an epiphany if you will and I want to share this with you by asking you two questions first question why do we have the FARs and if you think back to the other questions I've asked you about what is the number one responsibility of the FAA this is from me again why do we have the FARs you can throw out an answer if you'd like I get lots of answers safety is one of them job security for the FAA is one of them other issues like that but I'm serious why do we have the FARs why do they exist my answer to this question the FARs exist to protect you from yourself okay so if that's what they are then what are they what are the FARs and usually I have you can hear a pin drop at this point I've heard the answer to the first one I figured it's hopeless, guessing for the second one but this was my epiphany not the first question but the second question this one right here one day it dawned on me it's like the light bulb went on what are they the FARs are lessons learned exception from the CAA to the FAA we have been a reactionary entity we investigate accidents we investigate things that break we investigate things that go wrong and if enough people die a rule changes this is a hundred years of lessons learned is what you find in the rules I would ask all of you to please look at them in this light and learn from the mistakes of others you will not live long enough to learn them all yourself I went to a rotorcraft action investigation class a couple of years ago best class I've ever been to hosted by bell helicopters down in Fort Worth, Texas virtually every rotorcraft manufacturer was there and all of the instructors were outstanding they were industry action investigators from those companies all of them had anywhere from 20 to 40 years of experience outstanding instructor core there were two things that came out of this that really struck me and a couple of days before the class ended we had a big meeting at our hotel and this was a who's who in rotorcraft action investigation all of the students were there bell helicopters was there Eurocopter was there Sikorsky was there NTSB was there Frank Del Gandio, Office of Action Investigation Washington DC FAA was there anybody at an official level that investigated rotorcraft actions was there and before this was over I raised my hand I wanted to get my two cents worth in and I wanted to to ask this group there was no better opportunity than right now raised my hand and I brought up these two things that came up during the course of this class number one was a slide that was put up by Roy Fox engineer at bell been there 40 years heads up their flight safety department one of the slides that he put up during his presentation was a pie chart and we've all seen these we've all seen pie charts depicting this that of the other thing and this one depicted the causal factors for rotorcraft accidents 63% of the pie was pilot error 15% was parts etc etc the interesting thing to note is that he put this chart together 15 years ago and it's still true today the numbers haven't changed the numbers total numbers go up and go down and have been steadily trending down lately but the percentages haven't changed and the other slide that came up that was really the quintessential slide for me and the one that got me started off on this line of thought that I brought into the national landing gear failure powerpoint project that I was involved with and some educational products I have since developed for the maintenance side of the house but the title of the slide was there are no new accidents which is very true every time an airplane crashes and kills someone they've just killed themselves the same way someone else before them has and someone else before them has and someone else before them has so the question I have for you is the same question that I put out at this big meeting why is our industry not learning from their mistakes what are we doing wrong what aren't we doing right what can we do different to change this food for thought again I don't think there's anybody out there that wants to fly unsafe everybody wants to fly safe in this business nobody wants to hurt anyone nobody wants to hurt themselves an interesting statistic and again about the rules all focuses on the rules and what they are and the lessons we've learned from them if you are involved in an accident with your aircraft and if you are in violation of a rule at the time of that accident you are four times more likely to die or to kill someone the lessons the rules are there to protect you and even though regardless of what you think of them regardless of how they're interpreted regardless of your intimate dealings or your face to face dealings with the FAA these are what the rules are take this information and you know put it to heart and that the rules are there really for a reason there's minimum safe altitudes for a reason you need to have a medical certificate as a pilot for a reason I need to have certain training for an A&P for a reason all of the rules are there because we've learned a lesson along the way that tells us we needed to do this so that's my special note to you I am the Airworthiness Fast Team Program Manager for Minnesota this is my contact information if you have any questions and you'd like to talk to me about this or anything else I'm available my email address is here it's james.nehoff at FAA.gov I'm at the Minneapolis FISDO there's the address and if you have any questions now's the time yes very good question and it's about an antique aircraft that you can't find parts for anymore there are rules that allow an owner to produce their own parts you must however have something to go by you need some data you need to be able to reverse engineer you need some means to determine what you have but you as an owner do have the right under the rule and I'm not prepared really to talk to at length about this but there is a rule in place that allows you as the owner of the aircraft to produce that part does that answer your question well it was a legal part built by you under the rule and installed under the part now I can't answer it for any liability concerns if that's your question what happens what's your responsibility for that part once you sell the aircraft and it moves on to a new owner you under the rule have manufactured that part installed that part the aircraft subsequently goes under is determined to be air worthy each 12 calendar months it's still an air worthy aircraft with that part on it but liability wise what are you accepting liability wise on that part I can't answer that I do know that as a as a manufacturer of an experimental amateur built aircraft that you are the manufacturer your Cessna your Raytheon and if you sell that aircraft you accept the same liabilities as any manufacturer does for the life of that aircraft so but again I can't speak directly to the liability issues regarding that part other than if you build it in accordance with the rule and you can do it under the approved parts or the owner manufactured parts and it's a good part you had good data it's a good material etc it's a good part and it can be installed and sold and resold with the aircraft alright thanks everybody appreciate it thank you Jim interesting parts interesting about all those various parts that we can check and double check on and of course you mentioned the fact that when you get an annual inspection it's still the owner operator's responsibility to make sure the airplane is still air worthy absolutely absolutely and a lot of pilots I don't think realize their responsibilities on this end of the spectrum their responsibilities they accept as the owner and operator for the maintenance of their aircraft any more questions of the presenter you can come right up here come right up here sir