particular problem to the exclusion of all else. This is dangerous. If there is a problem in flight, the pilot's first priority must be safe flight. Attention to a faulty radio, airsick passenger, or navigation problem must be a secondary task. If you are feeling stressed before a flight, consider whether you should cancel. If you can foresee a period of high workload during the flight, rehearse it mentally, prepare as much as possible ahead of time, and, above all, remember that your first priority at all times is to fly the aircraft! 5. ONLY A MACHINE A. Trust Me, I'm Electronic Just as human beings can make errors, mechanical and electronic devices can also be faulty. Think about what your instruments should say--do a mental "reality check." Always cross check with a second source (e.g., landmarks in the outside view) if possible. Change--especially movement-attracts attention from our senses, but a static condition, or a very slow rate of change, is more likely to go unnoticed. It is important to check all instruments regularly, never think that your attention will automatically be drawn to a deteriorating situation. If your fuel gauge is stuck on full, the needle will remain steady, although actual fuel levels will be dropping. There will be no rapid movement or change to attract your attention. B. GPS GPS is becoming a common accessory for GA pilots. It can be tremendously helpful at times and is probably an overall safety "plus." However, a few words of caution: • Never use GPS as your primary means of navigation • Never use it to land in poor visibility (and that means you too, helicopter pilots!) Never spend time head down, fiddling with GPS, and not watching the outside world. • Never believe GPS data without question. It is NOT infallible and it CAN go wrong. Never fly in conditions that you would normally avoid, because you believe GPS will reduce the risk and get you there safely. 6. HOW DO ACCIDENTS HAPPEN? COMMON A. Controlled Flight Into Terrain In a CFIT accident the pilot does not lose control, and the aircraft has not failed. They simply fly into the ground, often hills or mountains. The pilots who had fatal CFIT accidents were typically over fifty years old and very experienced. More than a third were flying in their home base local area, and accidents were not restricted to mountainous regions. Of all CFIT accidents, 82% included unwise reaction to weather conditions (such as continuing to fly into worsening weather); 64% had not adhered to their MSA (if they had calculated one at all), trying to get "below the weather" or hoping to confirm their position. More than a third found out too late that they had made an error in navigation. B. Loss of Control in VMC Loss of control in visual meteorological conditions (VMC) is almost as common as CFIT. In the accident review, it was noticed that many of these loss of control accidents involved an unfamiliar situation, a distraction, or a minor technical failure. The inexperienced pilot was probably coping quite well until they were overloaded by some unforeseen event. This is probably difficult to avoid, but it is worth rehearsing--even mentally--exactly what you would do if you had a technical failure or encountered a distraction. Also, remember that if the flight you have planned is going to require 100% of your current skill capacity to cope with it, then you won't have anything left in reserve for unplanned or unusual events that crop up. C. Low Flying Aerobatic Highly experienced young male pilots (often with an informal audience) who fly low and perform aerobatics without adequate height are putting themselves and others at risk. Accidents are not unusual in these circumstances. D. Loss of Control in IMC All but one of the pilots killed when they lost control in IMC were flying in instrument conditions without an Instrument Rating. This is extremely unwise to say the least. Possibly they believed that their IMC rating was sufficient for prolonged, intentional flight in instrument conditions. Unfortunately, the IMC rating is not sufficient for such conditions. It should only be regarded as a minimum skill to "get out of trouble," if an unintentional excursion into IMC occurs. Disorientation can affect anyone, particularly those who have not been adequately trained to fly on instruments AND kept in practice And finally, the bottom line is: Don't gamble, safe flying is enjoyable flying. 7. SUMMARY Most pilots want to enjoy the freedom to fly when, where, and how they want to, whilst maintaining safety for themselves and others. The way to achieve and sustain this situation is to: ⚫ be realistic about the weather • work out a Minimum Safe Altitude • allow for contingency ⚫ be prepared to divert • rehearse for possible "situations" use good practice in your planning and flying don't take unnecessary risks. This will avoid the need for additional regulations and restrictions and give you safe, enjoyable flying. S pring is the time of year when animals are beginning to emerge from their winter habitat and move to areas where they can feed. Coincidentally, pilots are also beginning to escape from their winter pastimes to enjoy the freedom of flight. Spotting animals from the air and then descending to get a better look is a pastime that fascinates most people. Here in Alaska, one of the animals that gets a lot of attention is the migrating Humpback Whale. The months ahead will be the time to enjoy the migration of pods of Humpback Whale from the air. The fascination and awe these huge animals inspire draw many people to get a closer look. What we humans fail to understand is that these wonderful creatures are mammals, frightened by the proximity of the boats and aircraft we use to enhance our view of their migration. Put yourself in their place. Let's suppose that you are returning from the market. Just walking down the street with the family, minding your own business. Suddenly you are encircled by hoards of strange looking beings, enveloped in roaring objects that appear to be chasing you and your family. You would be scared to death. You would try to run and hide, protect your young, separate yourselves from the menace. You might hurt yourself just trying to get away. Yet we humans think nothing. of going to great lengths to "observe" the whale. (National Marine Fisheries Service guidelines state that "Aircraft should not fly lower than 1,000 feet while within a horizontal distance of 100 yards from a whale.") The issue of animal spotting goes a lot further than the whales frequenting our waters. Seals and sea lion pups during this time of year spend a period of time on the beaches and rocks of outlying islands, preparing their young for the winter months. Bear, seen with cubs born during the winter, graze and hunt on the slopes of nearby mountains. Sheep and goats are on the rocks that jut out from the steep slopes surrounding the area. All of these animals, and more, are in peril when frightened by the roar of an airplane engine. Not to mention the pilots who place themselves in a dangerous situation attempting to view Alaskan wildlife. There are situations that occur each year involving low flying aircraft trying to spot indigenous animals. The fascination with wild creatures coupled with the mountainous terrain we have here in southeast Alaska creates a potentiality for an accident to occur. Each spring and summer we see accidents and incidents that are directly related to the infamous "Moose Turn." Pilots try to divide their atten tion between the process of flying the airplane, satisfying the passengers urge to view wildlife, and looking at the animal themselves. In order to do this it becomes necessary to fly at a slow airspeed while executing a turn as well as maintaining a low altitude. Almost certainly a deadly combination. After some pilots gets their licenses, they seldom, if ever, practice the basic flight maneuvers that they learned as a student pilot. Some pilots do not realize that a stall does not have to be a violent falling out of the sky accompanied by associated buffeting. Whether the power is on or off doesn't really matter to an aircraft that has creased to fly. An aircraft stalls when the wing ceases to develop lift, period. Straight ahead, turning, climbing, or descending, given the right set of circumstances an aircraft can enter a stall. No violent whip of the wing or buffet from the control surfaces, just a descent to the ground that no amount of back pressure on the yoke can cure. That is a situation that pilots can find themselves in while doing the "Moose (or any animal of your choice) Turn." My advice is to view animals from a safe altitude. Use some binoculars or a camera zoom lens and avoid placing yourself and your passengers lives in danger. Enjoy the good weather days of spring "safely!" In my preceding article, "The Code, Part 1," for this venerable publication, I went over the Code of Federal Regulations, its format and content, and I finished by reviewing Federal Aviation Regulations (FAR) Parts 1, 11, 13, and 21. As a closing thought and in keeping with my personal motto that terrorism is a form of communications, I made a veiled warning to write a second article on the remaining subjects and parts. Well, here it is. But first, for those of you who survived my first mesmerizing article on the code, congratulations! Your sheer courage is duly noted. For those of you who actually enjoyed the article, I regret to tell you that there must have been a barrister somewhere in your genes pool and I send my regrets. For those of you who read just a few paragraphs of last month's article and found my words as un-appetizing as bureaucratic salmonella, hunker down and try to work though this. Good or bad, it is a fact that we live in a litigious society and someday the difference between spending a day in court or a day out fishing just might be a regulatory factoid that you pick up after spending nine minutes reading this article. Part 39 is a part with a very specific mission. It corrects unsafe conditions. discovered in either the manufacturing of the product or corrects a defect that pops-up during the product's service life time. Most mechanics are surprised to learn that each Airworthiness Directive (AD) is an individual rule or section with its own amendment number. Since we are now up to amendment number 11,017 it makes Part 39 the biggest part in the federal regulations with over 11,000 sections or rules. AD's are divided into three books. Book one has all the AD's issued from the day after the world was made through 1979. Book two covers all the AD's issued from 1980 through 1989. Book three covers all the AD's from 1990 to the present. Each book is broken down into five sections: large aircraft, small aircraft, appliances, powerplants, and propellers. There are three kinds of AD's. The emergency or priority letter, the immediate adopted rule, and the notice of proposed rule making. Because safety is paramount, the emergency (or priority) letter and the immediate adopted rule are exempt from the long and laborious rule making process. The notice of proposed rule making travels the same route that other proposed rules must travel. It is not unusual for a proposed AD to be canceled by the rule making process. This usually happens when there is a bevy of unfavorable comments to the notice of proposed rule making by the public. The fastest way to determine the difference between the emergency or priority letter is the emergency AD starts with the words "prior to flight." Most emergency AD's grounds the aircraft until a fix is made. An immediate adopted rule, doesn't ground the aircraft, it gives the owner a little wiggle room to get it taken care off. Immediate adopted rules usually begins with the words: "within the next 10 hours/cycles/days perform the following." The language used in an AD issued under the normal rule making process usually give the owner months de ap A or hundreds of hours to make the fix. The AD numbering system is straight forward. The first two numbers are the year, the second group of two describe the bi-weekly issue that the AD was assigned. And the last two numbers identify its position within that year, and bi-weekly issue. Part 43: Maintenance, Preventive Maintenance, Rebuilding and Alterations Part 43 is where mechanics live. There are only 12 regulations you have to learn, but that in itself is not exactly true. There are only 11 that apply to U.S. certificated mechanics, the 12th rule, Section 43.17, applies to work done on U.S. aircraft by certain Canadian persons. Okay, so U.S. mechanics have 11 rules or sections and six appendices, to work to, but that's not right either. There is nothing in Appendix C, it's reserved, so you only have five appendices to learn. Part 43's eleven rules or sections can be broken down into five elements: 1. Applicability, in other words 2. Who can do work on aircraft? 5. Performance standards Applicability Section 43.1 applicability limits its authority to only aircraft having a U.S. airworthiness certificate and foreign registered aircraft used in a Part 121, 127, or 135 air carrier operation. In other words, this rule allows you to work on a German "N" number A320 Airbus operated by United Airlines. Paragraph (b) of this section states that Part 43 does not apply to any aircraft which has only been issued an experimental airworthiness certificate, such as an amateur-built aircraft. This makes sense if you stop and think that by its very design an experimental aircraft meets no known published standard. It does not make sense for the FAA to impose a maintenance standard on a unknown and hold a mechanic to that standard. Who can work on an aircraft? Sections 43.3 gives a long list of individuals who can perform maintenance--manufacturers, repair stations, air carriers, mechanics, people working under the supervision of mechanics, and it evens allows pilots to work on aircraft. In reality, anyone in the world can work on an aircraft, either by holding a certificate or working under supervision of someone holding a certificate. Who can sign a log book? While the entire world can work on an aircraft, Sections 43.5 and 43.7 allows only a privileged few to "approve an aircraft for return to service." Just mechanics, repair stations, manufacturers, air carriers, and pilots performing preventive maintenance can approve an aircraft for return to service. Although earning an A&P is an important accomplishment, the real power in being an A&P mechanic is not so much having the ratings, the real power of the A&P certificate is the authority given by the U.S. Government to approve an aircraft for return to service. What about record keeping? If you think about it, mechanics have to sign only three pieces of paper. However, the A&P mechanic has the authority to approve the aircraft/component for return to service in only two out of the three pieces of paper. The first two are maintenance and inspection log book entries. In Part 43. Section 43.9 talks to maintenance entries and Section 43.11 talks to inspection entries. The third piece of paper is the Form 337. While a certificated mechanic can perform a major repair or major alteration, it is an IA, repair station, or air carrier who return the aircraft or component for return to service. Appendix B in Part 43 is the appendix that talks to maintenance entries on Form 337 and maintenance releases for major repairs and major alterations. Let's look a little closer at the entries. Section 43.9, Maintenance Entries, requires all log book entries to have: 1. A description or reference to "ac ceptable data" used 2. The date the work was completed 3. Name of the person performing the work 4. Signature and kind of certificate held If you noticed there is no requirement to approve the work for return to service in Section 43.9. But the FAA lawyers have that covered. Paragraph. (a)(4) in that section says very plainly that the signature constitutes the approval for return to service for "only the work performed." Also, note that the person who signs off the work does not necessary have to be the one who performs the work. If you have a person working under your supervision, even if he or she is not certificated, you must put down his or her name as well as your own. How long are you held responsible? For maintenance work, such as minor repairs and alterations, the mechanic is held responsible only for the work he or she performed until that work is re-inspected, altered, replaced, damaged, or reached its life. limit. In the Part 91 world, the maximum length of time to be held responsible is approximately one year or until the next annual inspection. Section 43.11 inspection entries requires all log book entries to have: 1. The type of inspection and a brief description of the extent of the inspection. 2. Date and total time in service. Time in service is defined the time accumulated from takeoff to landing and, yes, using Hobbs time and tach time is just fine-except please do not mix the two together, it makes for a convoluted set of records. 3. The signature and certificate number of the person approving or disapproving the aircraft or component part for return to service. Remember, inspections--big and small--which are conducted on Part 91 aircraft cannot be delegated to another individual. The one signing the log book entry must be the one who performed the eye ball inspection. How long are you held responsible for an inspection? For an inspection, the mechanic is held responsible for as long as it takes for the ink to dry on the log book. While this drastic departure from sanity might sound like the FAA is free basing, the truth is the mechanic has no control over the airworthiness condition of the aircraft once the aircraft leaves his or her care. The FAA would be unreasonable to hold the mechanic responsible for the future airworthiness of an entire aircraft for a undetermined period of time, especially when the aircraft is at the mercy of every pilot out there! So Part 43, Section 43.11 says that the inspection log book entry declares that every AD and/or every major and minor repair and alteration is airworthy at that moment in time. Another way of looking at this rule is, an inspection approves the past--not the future. Before I close out inspection requirements. It is a wise mechanic who also understands that Section 43.15 talks to additional performance rules for inspections. It is in this rule where specific inspection items are called out for rotorcraft, annual, 100 inspections, and progressive inspections. The Form 337 Major Repairs and Major Alterations is a very old form going back to the CAA Form 337 which the FAA embraced. While a mechanic does not have the authority in Part 65 to approve an aircraft for return to service after a major repair or major alteration, it is the mechanic who first makes the decision whether or not the repair or alteration is major or minor. While Part 43 requires a Form 337 to be made out for a major repair or alteration, it is Part 91, Section 91.417, Recordkeeping, that states the length of time the owner or operator is required to keep the Form 337. For a major repair, § 91.417(a)(1) requires that Form 337 is kept only one year. The FAA thinking behind this rule is based on the fact that this major repair returns the aircraft or component part back to its original type design so nothing has been changed. Furthermore, in most cases, within a year the repair would be bought off again by a new inspector so the form can be discarded because a copy of the major repair is kept in the aircraft's file in Oklahoma City. While trashing the major repair Form 337 after a year is perfectly legal, from a purely mechanic's point of view, I sure would want a copy of the Form 337 in the maintenance records in order to see who, what, when, where, and how the aircraft was repaired. So in your and my own personal interest I would tell the owners to hold on to all major repair Form 337's. On the other hand, §91.417(a)(2) says major alterations Form 337 should be treated different. These Form 337, unlike their major repair cousins, require the owner to hold them forever. This is because each major alteration changes the aircraft's type design. So a record of each change must be kept with the aircraft. Also, starting last year, the FAA changed its policy on field approved major alterations. Now the mechanic has to develop instructions for continuing airworthiness (ICA) in order to aid the next mechanic a year from now, who has to inspect the alteration that was installed today. Mechanics usually get into trouble when they write something in the log book. Maybe that is why their handwriting is so small and a little smudgy. But handwriting alone is not the problem, usually the hammer falls because they describe the work performed based on what they think they did and not what was the legally done. To avoid this trap read on. Section 43.2 is a relatively new rule, as you can tell by its even number suffix. This rule defines the terms: "overhauled and rebuilt." The section defines the major difference between the overhauled unit and a rebuilt unit by stating the overhauled unit must meet manufacturing service limits and a rebuilt unit must meet new part limits. How many times have you and I used the term "rebuilt," to describe installing some seals in a Cessna nose strut, when we should have used the word "repaired" in the log book. Performance Rules Mechanics have it a lot easier than pilots because the FAA set the standard for our overall job performance, or how we do our work, in just one rule. Section 43.13, Performance Rules, is a three paragraph rule. Paragraph (a) sets the standard for data and tools that we must use. The rule requires that each person performing maintenance shall (imperative) use the methods, techniques, and practices identified in the "current" manufacturers' manuals or instructions for continuing airworthiness or other methods, techniques, and practices acceptable to the Administrator. The mechanic must also use the tools, equipment, and test apparatus to assure completion of the work in accordance with accepted industry practices. Paragraph (b) sets the standard for the acceptable quality of work. The rule requires that each mechanic performing maintenance shall do the work |