ELT Checks

Interesting point! I think the original intent there was lead-acid
starter batteries, but it does indeed just say "batteries".
And I should correct my statement to say that while the owner/operator
can replace the battery (hell, he can replace the entire engine), he
can't make the logbook entry for return to service.
My reasoning goes like this:
The preventive maintenance section deals in particular with either
easily replaceable parts, or SPECIFIC examples of life limited parts
that the owner/operator can replace or repair. Given that the ELT
battery is a life limited part (like an air or oil filter), to what
extent is the owner allowed to dismantle an object to effect the
replacement? Can he open a GPS to replace a memory back-up battery?
If not, why not? It's a battery after all. I think the answer lies in
what must be done after the replacement to declare that the item is
airworthy, and just flipping the switch on the ELT and listening for a
few sweeps doesn't qualify (IMHO). The all important g-switch must also
be exercised (and probably the output power too), and neither of these
falls under the purview of the owner/operator.
Just my view; as always I'm looking forward to seeing reasons why I may
be wrong!

Rip
Navion 5186K

Ron Natalie wrote:
"rip" wrote in message . com...

Nope. The list of things an owner/operator is allowed to do is very
specific. Replacing, testing, or logging the replacement or testing of
an ELT battery is not on the list. (Appendix A to Part 43 -- Major
Alterations, Major Repairs, and Preventive Maintenance).


Item 24 on 43xA.vc is "Replacing and servicing batteries."

"rip" wrote in message . com...

Just my view; as always I'm looking forward to seeing reasons why I may
be wrong!

I'll argue two things here. First, for TSO-91c ELT's the instructions for
the continued maintenance are spelled out specifically in the manual,
including how to change the batteries. There's no requirement to do the
G switch test (nor any overriding need to do so). That only has to be done
every 12 months.

However, even if such testing were required, I argue the the owner-pilot is
still authorized to return it to service. After I replace my main aircraft
battery you can be danged sure I'm going to test it before returning the aircraft
to service.

You're making requirements that don't exist in the regulations. As for changing
internal batteries in things not designed to be easily accessible, that is covered
by the initial phrase in 43xA.c "Preventive maintenance is limited to the following
work provided it does not involve complex assembly operations."

If it's not spelled out in the ICA, that's good enough. Thanks, Ron!

Ron Natalie wrote:
"rip" wrote in message . com...


Just my view; as always I'm looking forward to seeing reasons why I may
be wrong!


I'll argue two things here. First, for TSO-91c ELT's the instructions for
the continued maintenance are spelled out specifically in the manual,
including how to change the batteries. There's no requirement to do the
G switch test (nor any overriding need to do so). That only has to be done
every 12 months.

However, even if such testing were required, I argue the the owner-pilot is
still authorized to return it to service. After I replace my main aircraft
battery you can be danged sure I'm going to test it before returning the aircraft
to service.

You're making requirements that don't exist in the regulations. As for changing
internal batteries in things not designed to be easily accessible, that is covered
by the initial phrase in 43xA.c "Preventive maintenance is limited to the following
work provided it does not involve complex assembly operations."

"Ron Natalie" wrote

You're making requirements that don't exist in the regulations.
As for changing internal batteries in things not designed to be
easily accessible, that is covered by the initial phrase in 43xA.c
"Preventive maintenance is limited to the following
work provided it does not involve complex assembly operations."

Those distinctions always make me chuckle. One man's
complex is another man's simple. (Kind of like the
distinction they make between major and minor alterations).

For instance I changed the internal battery in my NorthStar M2
GPS. Given my skills I did not find this particularly complex,
although many would. (The battery was soldered into a board
that couldn't be removed without also removing dozens of screws,
cables, connectors, etc).

Yet I still usually err on the side of caution. For example
I would be perfectly legal changing my brake pads, but in my
airplane I find this complex (given my skills - or lack thereof
So I feel more comfortable relegating this task to my mechanic.

~Paul

"Ron Natalie" wrote in
:

I'll argue two things here. First, for TSO-91c ELT's the
instructions for the continued maintenance are spelled out
specifically in the manual, including how to change the batteries.
There's no requirement to do the G switch test (nor any overriding
need to do so). That only has to be done every 12 months.

Very true. More specifically, the ELT battery life limit has been
around for many decades. The G-switch test requirement is what, 10
years old?

However, even if such testing were required, I argue the the
owner-pilot is still authorized to return it to service. After I
replace my main aircraft battery you can be danged sure I'm going to
test it before returning the aircraft to service.

I think we all agree that you can clearly test the ELT (within the other
limits set forth as to when and how such testing should be done). I
would recommend it.

Unfortunately, my reading (and this is purely my reading, nothing I have
seen from the FAA) is that this testing does NOT replace the required
yearly test of the ELT. That, it would appear, must be done by an A&P
and or IA.

You're making requirements that don't exist in the regulations. As
for changing internal batteries in things not designed to be easily
accessible, that is covered by the initial phrase in 43xA.c
"Preventive maintenance is limited to the following work provided it
does not involve complex assembly operations."

Lots of the Part 43.13 regs have that "complex assembly" phrase. I have
never seen a definitive statement on what that means. To my mother it
should probably include changing batteries in a flashlight. But I
replace surface mount components on multilayer PCB's all the time.
Pulling the cover of my ELT (six screws) and one molex connector hardly
constitutes "complex" in my book.

I would love for the definition of complex assembly to be "assemblies
involving tools and techniques not familiar to the operator" - but
somehow that seems entirely too reasonable. Has anyone ever seen an FAA
definition?

-----------------------------------------------
James M. Knox
TriSoft ph 512-385-0316
1109-A Shady Lane fax 512-366-4331
Austin, Tx 78721
-----------------------------------------------

rip wrote:

Interesting point! I think the original intent there was lead-acid
starter batteries, but it does indeed just say "batteries".
And I should correct my statement to say that while the owner/operator
can replace the battery (hell, he can replace the entire engine), he
can't make the logbook entry for return to service.

According to a Wings seminar I once attended, not only is allowed to log what
he/she did, the owner is *required* to log it.

George Patterson
A man who carries a cat by the tail learns something that can
be learned no other way.

rip wrote:

Nope. The list of things an owner/operator is allowed to do is very
specific. Replacing, testing, or logging the replacement or testing of
an ELT battery is not on the list.

Yes, it is. The only question is whether the owner is allowed to perform the
functional test of the ELT. I do it and log it anyway. If my IA also performs
the test at annual, hey - I'm covered.

George Patterson
The actions taken by the New Hampshire Episcopalians (ie. inducting a gay
bishop) are an affront to Christians everywhere. I am just thankful that
the church's founder, Henry VIII, and his wife Catherine of Aragon, and his
wife Anne Boleyn, and his wife Jane Seymour, and his wife Anne of Cleves,
and his wife Katherine Howard, and his wife Catherine Parr are no longer
here to suffer through this assault on traditional Christian marriages.

One additional thing I thought of is.....

Why do ground schools teach all of the rules of when you can test the ELT
( first 5 minutes of each hour ) if you are not authorized to test it?

Anyone else find this curious?
Kevin

"Kevin Chandler" wrote in message ...
One additional thing I thought of is.....

Why do ground schools teach all of the rules of when you can test the ELT
( first 5 minutes of each hour ) if you are not authorized to test it?

Who says you're not authorized to test it? The question is whether your testing
satisfies the annual inspection requirement. There's more to the test than just
turning it on.

"Kevin Chandler" wrote in message ...
One additional thing I thought of is.....

Why do ground schools teach all of the rules of when you can test the ELT
( first 5 minutes of each hour ) if you are not authorized to test it?

Anyone else find this curious?
Kevin


'cuz that's what the aim says: 6-2-5:

b. Testing.

1. ELT's should be tested in accordance with the
manufacturer's instructions, preferably in a shielded or
screened room or specially designed test container to
prevent the broadcast of signals which could trigger a false
alert.

2. When this cannot be done, aircraft operational testing is
authorized as follows:

(a) Analog 121.5/243 MHz ELT's should only
be tested during the first 5 minutes after any
hour. If operational tests must be made outside
of this period, they should be coordinated with
the nearest FAA Control Tower or FSS. Tests
should be no longer than three audible sweeps.
If the antenna is removable, a dummy load
should be substituted during test procedures.

(b) Digital 406 MHz ELT's should only be tested
in accordance with the unit's manufacturer's
instructions.

(c) Airborne tests are not authorized.



you can do this test, but this doesn't satisfy the requirement of
91.207(d), which includes a test of the "crash sensor". the ai
must do this test (i think he drops it on the floor or something).
anyway, that's my take, fwiw.

g_a