Why annual inspections by Busch

[PeterNSteinmetz]

I do wonder if less invasive means can work here?

Why annual inspections?

Given today’s acute shortage of GA mechanics and the difficulty owners are having getting their airplanes on shop schedules, I’ve been receiving an increasing number of inquiries about the need for annual inspections from frustrated owners.

www.aopa.org

 

[rotorwrench]

I do wonder if less invasive means can work here?

Can’t access the article, but if its similar to his other articles on the same topic then no. And that is a professional opinion. His argument of a comparison to the “big boys” is moot on several levels. The most prevalent is on recreational, Part 91 aircraft the annual is the only time the aircraft gets looked at.

And given the many posts and discussions on various aviation forums highlighting the benefits or results of 20-minute annuals, then by his reckon we should never hear about someone having a $10,000 1st annual after buying an aircraft.

Where the argument does hold water is with the “big boys” as they are inspecting their aircraft at a rate 10x more than a recreational aircraft is. And in most cases, especially at the Part 135 level, they will pursue an AAIP vs an OEM inspection program so they can reduce the number of repetitive, invasive inspections and lower the chances of maintenance induced failures.

But this discussion is nothing new and has been going on for a lot longer than I’ve been working in aviation maintenance.

 

[Ron Wanttaja]

I'm in agreement regarding avoiding paper-whipped annuals. Planes DO need to be occasionally inspected.

But shouldn't this be based on hours, not calendar days?

I fly 25-30 hours a year, but each year, I have to disassemble the aircraft and splay it all out so the A&P can look at it. Then I have to re-assemble the aircraft. This essentially means I'm doing an hour of inspection (NOT maintenance, just disassembly/inspect/reassembly) for each five hours of flying.

That ratio seems a bit off.

I'd be more inclined to combine the hours flown and calendar years.... Full inspection every three years or 100 hours, whichever comes first.

Ron Wanttaja

 

[PeterNSteinmetz]

For those who are not AOPA members.

 

[rotorwrench]

But shouldn't this be based on hours, not calendar days?

Full inspection every three years or 100 hours, whichever comes first.

My comments were directed to Standard AWC aircraft as an annual inspection serves as more than just an inspection of the condition for safe flight.

However, from strictly a flight condition point, your 100hr/3 year idea would work so long as all possible discrepancies or issues were caused only by flight hours. Unfortunately, issues like corrosion, static deterioration, hidden damage events, etc. thrive on the calendar only side and especially when the aircraft is not flown much.

So if you were to wait 3 years between inspections what could have been a simple preventative measure to fix at the 12 month level, could very well end up a more extensive repair or a replacement at the 36 month level. Its basically the same result when someone gets several pencil whip annuals in a row then gets hammered when they have a proper annual done.

For those who are not AOPA members.

Thanks. But it’s the same tact as other articles. This article fails on several points and intermixes inspection requirements between aircraft and ops types that aren't applicable, eg., 91 vs 135.

The big question that wasn’t asked is how many King Air owners would pick an 91.409(a) annual inspection over a 91.409(f) phase inspection if they could?

 

[PeterNSteinmetz]

So if you were to wait 3 years between inspections what could have been a simple preventative measure to fix at the 12 month level, could very well end up a more extensive repair or a replacement at the 36 month level. Its basically the same result when someone gets several pencil whip annuals in a row then gets hammered when they have a proper annual done.

As always my question is what data is there to suggest that requiring these inspections per regulation improves either the safety of flight or of those on the ground?

If the vast majority of accidents are pilot error and not mechanical failure, then is this sort of annual inspection at all cost effective?

 

[rotorwrench]

As always my question is what data is there to suggest that requiring these inspections per regulation improves either the safety of flight or of those on the ground?

As I’ve explained previously, or maybe not as well as I should, in aviation you will see “data” requirements usually for one or two reasons: there is a new or revised rule proposal or to determine safety levels. In most cases there will is no current data for rules that existed prior to the APA Act issuance (mid-40s) or rules/guidance that are required to service an international treaty or agreement.

Now for new regulations/rules added after APA there will be NPRM data requirements. For example, the recent AD NPRMs on Piper spars or for the rewrite of Part 23 or even for our discussion on why metal detectors were needed all had data and reasoning behind those rules. And all of which are listed in the Federal Register.

As to the treaty/agreement side, a simple review of the ICAO Annexes or the various FAA country specific bilateral agreements will give a list of requirements that can be crossed to existing FARs.

So in the case of an annual inspection, it actually serves two purposes: it technically renews the aircraft AWC and provides an airworthiness review of condition. The renew portion services a treaty and the condition review predates the APA so there is no data easily available without a rabbit hole dive into the Federal Register archives of which any pertinent data may not be accessible online.

An interesting note, at one time before 1955 or so, there were 2 required aircraft inspections: a periodic at 6 months that was performed by a CRS and the annual inspection which was only performed by CAA personal. So the current aircraft inspection requirement already has been reduced by the elimination of the periodic insp.

 

[PeterNSteinmetz]

As I’ve explained previously, or maybe not as well as I should, in aviation you will see “data” requirements usually for one or two reasons: there is a new or revised rule proposal or to determine safety levels. In most cases there will is no current data for rules that existed prior to the APA Act issuance (mid-40s) or rules/guidance that are required to service an international treaty or agreement.

I thought it was reasonably clear and had gathered there really is no data to justify the practice - other than that is what some people thought was a good idea and we've always done it basically that way. But I wanted to check that I hadn't misunderstood or missed something.

Of course in the early days of the CAA I don't know they would have had the ability to actually gather and analyze much data. So they tried to make their best guess based on experience and gut feel.

An interesting note, at one time before 1955 or so, there were 2 required aircraft inspections: a periodic at 6 months that was performed by a CRS and the annual inspection which was only performed by CAA personal. So the current aircraft inspection requirement already has been reduced by the elimination of the periodic insp.

So I guess we are presently a little better off in part 91.

 

[rotorwrench]

I thought it was reasonably clear and had gathered there really is no data to justify the practice

Curious. What other transportation industry, or any other federally regulated industry, requires data and analytics to justify the implementation of rules or regulations?

 

[PeterNSteinmetz]

Curious. What other transportation industry, or any other federally regulated industry, requires data and analytics to justify the implementation of rules or regulations?

I think the only industry I have much knowledge of in that regard would be biomedical. Decisions by agencies like the FDA tend to be very data and analysis driven.

 

[rotorwrench]

I think the only industry I have much knowledge of in that regard would be biomedical. Decisions by agencies like the FDA tend to be very data and analysis driven.

Do you have any examples where data/analytics are required before the FDA proposes a new regulation/rule?

A quick look through the FDA regulatory structure I find more similarities to the FARs than not. There’s definitely more data driven requirements on the specific product certification side, but that is quite the same on the specific aircraft certification side. Just not the volume of certifications.

I also found numerous international FDA regulatory agreements that require similar rules on both sides to be mutually acceptable. Do you know of any data analytics were performed on these FDA mutual agreement rules?

On the rule making side, it appears the CARES Act allowed the FDA to remove OTC drug approvals from the normal APA rulemaking process. Can you provide FDA data or analytics that shows moving the OTC drug approval to an internal process actually increases drug safety to the public vs the previous APA process?

 

[PeterNSteinmetz]

Do you have any examples where data/analytics are required before the FDA proposes a new regulation/rule?

A quick look through the FDA regulatory structure I find more similarities to the FARs than not. There’s definitely more data driven requirements on the specific product certification side, but that is quite the same on the specific aircraft certification side. Just not the volume of certifications.

I really haven’t looked at it that carefully. You may be right that nearly all Federal regulatory agencies suffer from this lack of real data and analysis for justification.

Many of the regulations are put in place due to legislative action. And politicians don’t generally care about that sort of thing very much.

 

[rotorwrench]

Many of the regulations are put in place due to legislative action. And politicians don’t generally care about that sort of thing very much.

FYI: politicians only provide the legislative law to base the regulation on. Regulations are developed by agencies via the APA rulemaking process. No politicians involved. However, the big difference with regulations is the general public has an opportunity to make a direct comment about them in the NPRM phase.

If you would like to see how this process works, perhaps make a comment to help your fellow Piper aviators? Links below and post comment on how these two NPRMs will affect private aviation especially with the implementation of life limits? Data and reasoning supplied in the respective NPRM links.

NPRM 2142 *Comment option lefthand side menu

NPRM 2143 *Comment option lefthand side menu