Bill,
I belive your comment to have a good relationship with your mechanic and IA before the fact is critical. Discuss with them the issues BEFORE you commit to them doing the annual. Thay have no authority to "ground" your airplane based on conversation, and would be open for litigation if they tried. I would HIGHLY reccomend you find an IA that will let you do an "owner assisted" annual, You will have a much better understanding of your airplane and should be much cheaper,(unless of course you are one of those who just wants to fly and pay the bills) Find an IA and stick with him, no sense in paying for a learning curve every year. An interesting side note is that while a C or CD does not specifically require a no smoking sign, TCDS-718 requires one if you convert to a D (see Note 3 at bottom) (h) "No Smoking" placard should be included in the cabin. And TCDS A-787: A. Models ERCO 415-D, E, G, Forney F-1, F-1A (1) On instrument panel in full view of the pilot: (a) "This airplane must be operated as a Normal Category airplane in compliance with operating limitations, Secs. A and B, Approved Airplane Flight Manual." (b) "This airplane characteristically incapable of spinning." (c) "No acrobatic maneuvers are approved." (2) To be displayed in Cabin: "No Smoking." But the Alons and Mooney's dont require the placard. Bill Biggs To: [email protected] From: [email protected] Date: Wed, 30 Jun 2010 16:01:01 -0500 Subject: Re: [ercoupe-tech] Upholstery Comments interspersed below. WRB -- On Jun 30, 2010, at 13:46, Christopher Koch wrote: Dear Linda, While CAR 3 and 4a do not specify any burn or flammability standards (for example, see CAR 3 below)... The FAA specific standard is FAR 25.853 (a) & Appendix F Part I (a) (1) (ii)... There is still some confusion on the part of your FSDO office, A&P and A&P IA on this subject. There is no confusion whatsoever. Under applicable rules and regulations, no "burn certifications" are applicable or pertinent to aircraft certificated under CAR 3 or 4a. I recently attended the annual all day FSDO A&P IA refresher course and this was the first topic covered. The basic scenario presented to the A&P IAs in attendance by the FAA was "You are performing an Annual and you check out the interior on a CAR 3 or 4a airplane only to discover a newly upholstered interior (any or all seats, side panels, rugs, ceiling). You request the burn certs for each material as they are obviously not the original materials installed when the plane was built. The plane owner is unable to produce them. Do you sign off the airplane Annual placing the airworthiness liability squarely on your shoulders?" The final answer was left up to each A&P IA. That's because even the FAA does not have the authority to mandate that which is not specifically required. Refurbishing these interior materials is an allowable log book activity for the airplane's owner just like changing the engine oil and filter. There is no ambiguity here, whatsoever. Due to the ambiguities of interpretation, Personal interpretation: So as to avoid any possible danger to my certificate or personal financial future... I make certain that I have all the burn certificates for each material in the aircraft records, just as if the airplane was type certificated under FAR 23 rather than CAR 3 or 4a. Personal observation: And so, once again, an owner/pilot is denied his/her RIGHT to refurbish interior materials within applicable regulations by an A&P or IA willing to blackmail them by holding the aircraft hostage...by withholding the necessary certificated "sign-off" of an annual inspection. The owner can't even repossess their own aircraft and take it elsewhere for a "second opinion" because it "unairworthy" until financial tribute is paid and "right" yields to "might. The owner's single to avoid such a situation is to be aware of how pervasive this mentality is, and discussing the subject at length with the shop AND the mechanic before proceeding. The shop OR mechanic understand the regulations and jargon much better than you, and may tell you the "truth" you want to hear and the "whole truth". There is no amount of personal knowledge that will protect an owner if they do not respect them enough to be "honest" up front and deal with them in good faith. One or more witnesses to such a conversation can be good "insurance" before an annual is authorized to commence. There are NO "guarantees". As far as requiring a "No Smoking" sign to meet CAR 3 requirements, please also consider that directly over your knees is a gasoline tank - ON YOUR SIDE of the firewall !!! If I recall correctly, that tank was in precisely the same place in all Ercoupes produced under 4a certification. The presence or absence of the placard does not change the flammability of gasoline. No placard can convey common sense to pilots or mechanics lacking it. Yours, Chris Koch Buffalo, NY CAR 3 Personnel and Cargo Accommodations ยง 3.393 Ventilation. All passenger and crew compartments shall be suitably ventilated. Carbon monoxide concentration shall not exceed 1 part in 20,000 parts of air. If an Ercoupe exhaust system develops a fatigue crack in flight and carbon monoxide poisioning incapacitates the pilot and the aircraft crashes, here's one way bureaucratic reasoning could unfold: 1. An autopsy (or skin color) will confirm that carbon monoxide in high concentration is in the pilot's tissues and blood. 2. The actual cause of the crash was a concentration of carbon monoxide in the cabin in excess of that allowable in an airworthy aircraft. 3. The pilot did not possess or demonstrate the level of preflight clairvoyance obviously necessary in hindsight because a crash occurred. 4. Since the deceased pilot was operating an aircraft that was not airworthy while under his/her command and control, the pilot's subsequent inability to avoid uncontrolled descent into terrain is incontrovertible evidence of pilot error as proximate cause. Postlude: The insurance company is not obligated to for either loss of the aircraft or damages arising out of its untimely return to earth because continued airworthiness is a necessary precedent to purchased coverage. ;<) _________________________________________________________________ Hotmail has tools for the New Busy. Search, chat and e-mail from your inbox. http://www.windowslive.com/campaign/thenewbusy?ocid=PID28326::T:WLMTAGL:ON:WL:en-US:WM_HMP:042010_1
