SB643B-Bendix mags *mandatory* overhaul every 4 years now?

Jim Burns wrote:
: The case I remember reading was an NTSB decision, without stating or
: referencing any precedent, that stated a manufacturer could include, by
: reference, Service Bulletins into their overhaul manuals. So if an overhaul
: manual referred to an SB, compliance of the SB actually became part of the
: overhaul procedure and therefore mandatory at OVERHAUL. (which would make a
: blanket statement of "must comply with all SB's" posted at the end of an
: overhaul manual pretty spooky) But this was an NTSB case against an A&P,
: not an FAA case. To my knowledge, Part 43 Appendix D doesn't include
: compliance with manufacturer's SB's in the scope and detail of either a 100
: hour or annual inspection, and all the FSDO inspectors or training personnel
: in the world can't make that ink magically appear. I'd like to know if the
: FAA ever issued an opinion or agreed/disagreed with the NTSB.

That's what the AOPA's request for a letter of interpretation seems to say. To respond to your
"spooky" situation of a manufacturer adding that into an overhaul manual, the legal person I talked with
at AOPA seemed to think that such a blanket statement wouldn't be approved by the FAA. The 2001 letter:
http://www.aopa.org/whatsnew/newsite...sb-letter2.pdf
says "FAA policy does not permit a predetermination that compliance with some future document is
mandatory."... so such a thing shouldn't get approved.

: This may be one of those "OJ" situations... FAA says your A&P didn't commit
: a crime, but the NTSB finding gives the family of the deceased enough
: ammunition to secure your lifetime position in the poor house.

Just like every confusing FAR question I've ever investigated.... if you look close enough, you
*might* find an answer, but if something happens, you're gonna get busted anyway.

: The continued airworthiness statement is most often seen in STC's where a
: manufacturer submits it's methods of continued airworthiness to the FAA and
: if the FAA agrees, they sign off on it and it becomes part of the STC.
: Without an FAA sign off on "methods of continued airworthiness" I see no
: authoritative confirmation that these methods meet the requirements of the
: FAA, although the manufacturer may insist that they do. Imagine a
: manufactoers "MoCA" that happend to be directly contrary to current FAR's or
: proper safety practices. Now who is right? The manufactorer and his SB? or
: the FAA with it's FARs, ADs, and ACs?

: Jim

So it seems that even though SB's might contain the magic phrase "instructions for continued
airworthiness," they're not mandatory for part-91 because it's not FAA-approved. At least that's how I
read all of this.

Thanks,
-Cory

--

************************************************** ***********************
* Cory Papenfuss, Ph.D., PPSEL-IA *
* Electrical Engineering *
* Virginia Polytechnic Institute and State University *
************************************************** ***********************

The increasing complexity and cost of SB's, AD's, and Part 91 regs
will never end... It is the inescapable byproduct of an increasingly
socialized society and a dysfunctional political system... We are
headed where Europe is already, we are simply 20 years behind them...
20 years from now there will be essentialy no private certified
aircraft owned by ordinary persons in europe and we will be slowly
twisting in the wind here...

Experimentals will be the only GA planes a private person can afford
within 20 years...
Don't worry, order an RV7/8/9/10 kit, and be happy...

denny

If it comes to that point Denny, I would be more inclined to just keep
what I have at the time and recertify it as experimental.

The bitch will be if the airlines decide to have the FAA rule that
experimentals can't fly in controlled airspace; probably not in my
lifetime.


Kindest regards,
Jim Carter

Politicians fear most an armed, educated electorate.

-----Original Message-----
From: Denny ]
Posted At: Wednesday, July 25, 2007 6:59 AM
Posted To: rec.aviation.owning
Conversation: SB643B-Bendix mags *mandatory* overhaul every 4 years
now?
Subject: SB643B-Bendix mags *mandatory* overhaul every 4 years
now?

The increasing complexity and cost of SB's, AD's, and Part 91 regs
will never end... It is the inescapable byproduct of an increasingly
socialized society and a dysfunctional political system... We are
headed where Europe is already, we are simply 20 years behind them...
20 years from now there will be essentialy no private certified
aircraft owned by ordinary persons in europe and we will be slowly
twisting in the wind here...

Experimentals will be the only GA planes a private person can afford
within 20 years...
Don't worry, order an RV7/8/9/10 kit, and be happy...

denny