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100 hours checks "same work as an annual" (UK)

I think 14 CFR 43 Appendix D as referenced in Snoopy’s post above might be an interesting read for some. Link

This is a days work at most, can be signed off by an A&P mechanic (no IA for 100 hr) and satisfies the FAA inspection requirements. If you want to do more, that’s your own business. If you can get your mechanic to operate by those inspection minima, anywhere in the world, it’s a good thing for you.

This is how I maintain my plane, in terms of regulated process: no pre-planned or documented maintenance plan of any kind, no need to talk about it and no record of any such thing, anywhere. No “50 hour checks”, no “100 hr checks”, no “150 hr checks” no matter how much I fly, oil changes when I want to do them, no mandatory TBO either by hours or years and no special inspections required post-TBO, no government airworthiness certification renewals (ever), no “maintenance organizations” except for a 5 minute biennial transponder cert done in my hangar, no paperwork required for parts except the prop and no periodic inspection paperwork required other than hand written A&P entries in the owners maintenance log book… although sometimes my A&P friends like to make stickers for me. They do look nice

Last Edited by Silvaire at 30 Sep 19:28

There is a lot of confusion over the requirements of the SDMP, the U.K. CAA has just published a guide to SDMP that should not be as impenetrable as the regulations.

@A_and_C is there any way to do an SDMP without a 100hr service even if the MM mentions such a service?

Bearing in mind that an FAA MM mentions the 100hr not because the aircraft needs it but because it is a requirement for the above mentioned “commercial” ops.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

is there any way to do an SDMP without a 100hr service even if the MM mentions such a service?

No. You have two options for the SDMP: Base it on the EASA MIP, which includes 100hr or base it on the MM which you assumed did also.

ESKC (Uppsala/Sundbro), Sweden

When I was on G I had just the 50hr and 150hr, but this was 2002-2005. LAMP did not follow the MM schedules. Then I went N-reg.

On N-reg, the MM is not legally compulsory regarding the intervals, other than for the Annual.

This SDMP requirement is clearly a big problem for owners who do “just the wrong number” of hours a year, because a lot of planes have the 100hr schedule in their MM. Not just US ones (for the reasons above, not related to the aircraft itself, and not followed in the US anyway) but also at least some European ones and Socata is one of them.

Administrator
Shoreham EGKA, United Kingdom

I have maintained F-16s, and are now maintaining two ULs. The “paper maintenance” of EASA/FAA aircraft seems odd IMO.

Nothing is as “European” as an UL. They are maintained in more or less the same way all over Europe. The national regulations typically say it must be maintained according to the manufacturer, if the manufacturer has published something. Engine manufacturers for sure has, but not all aircraft manufacturers has. In those circumstances, some national minimal list, or suggestion is used.

Those I know are Pipistrel (Slovenia) and ICP (Italy). Both have very good manuals. Components (from every bolt to complete structures) and equipment is readily available at very reasonable cost. It can also be sourced from elsewhere.

The main principle seems to be on hours, and with the “100h” as the “bread and butter” task. Both also have a “yearly”, which is used if the 100h is not flown during a year. Thus the 100h and yearly is the same thing, whichever occurs first. Both resets time. Then they have items for 300h for instance, which is flight hours exclusively, and others for calendar years, which also is exclusively. Some stuff are both (max 300h or max 3 years for instance). These are to be done at convenience. The maintenance is the owners responsibility exclusively. The owner is free to use any help he wants, but the responsibility remains at the owner. What the EU say about this is, according to Pipistrel, that each UL must undergo at least one “100h” each year. I have no idea where Pipistrel has got this from though, they give no refs about it. A bit odd EASA should bother about this at all IMO, so I take with a grain of salt

Pipistrel has a long list of things that shall be “replaced” at certain intervals, hours and/or calendar year. It is a bit funny what they write about this list:

The limits mentioned in Table 05-001 DO NOT indicate product lifetime and must not be interpreted as such.

One of these items is the “5 year rubber hose replacement” of engine hoses (and stuff). This is also in the Rotax maintenance manual. In principle they don’t need to actually be replaced with new stuff. It’s enough to take them out, inspect them and re-install them if OK. The problem is how to inspect the inside of a 10 mm black rubber hose without cutting it up The cost of these items are so low anyway, it’s just stupid not to replace them when you finally have the time to look at it. It’s a very cheap insurance. I just bought the entire 5 year hose thing from Pipistrel. Every bit and piece included, a dozen of pre-cut correct quality and size hoses (fuel, oil, coolant, pre cut, all fittings, all throttle wires, everything, filters, all rubber stuff). It cost €700. It takes a (long) evening to replace all of it, but that’s just nice tinkering.

It is possible to go to the local hardware store and get most of it, probably much cheaper. That’s not a good idea though due to unspecified specs regarding fluid and temperature. A professional store for industrial quality hoses certainly have this stuff, but I doubt it will be much cheaper in such low quantity.

Each year an UL must be inspected by an inspector. You fill out some forms saying you have done this and that, and the inspector signs it, and take a quick look at the aircraft. Similar to the LAA regime I guess. This is needed to:

  • Keep the aircraft airworthy according to the CAA.
  • To get the legally required third party damage insurance.

It’s all up to the owner how he actually maintains his aircraft. How well he adhere to the manufacturers suggestions, how nitpicky he is about keeping the aircraft in good shape. When flying a lot, you certainly want the aircraft to be in tip top shape. Due to the low cost of all the items, it’s also the cheapest (life) insurance available.

With certified aircraft we talk about paperwork, and how to get the maintenance cost down. With non certified aircraft we talk about hose clamps and the best way to synchronize the carbs – we talk about how to keep the aircraft in tip top shape, how to do stuff, what and where to purchase stuff. It’s a much more healthier environment. The (certified) maintenance shops are only interested in:

  • Doing as little as possible and get as much money as possible for it.
  • Signing the papers to get their back free.
The elephant is the circulation
ENVA ENOP ENMO, Norway

Peter

Having been very busy with other projects I have not taken too much time together into the detail of the MIP, I have just built my SDMP around one that was done for another DR400 and added ( and removed ) things to allow for the avionics fit.

As most of my work involves aircraft flying commercial tasks almost all the maintenance is done on the manufacturers program so I don’t claim to be an expert on the finer points of SDMP but your post and the end of a big project have prompted me to look a lot deeper into this…….

Once I have my head around this. i will get back to you but I do believe that you can amend manufacturer recommendations if you have the evidence to do so. A typical example might be the frequency of landing gear inspections on the DR400, clearly the manufacturer has to cover all cases and as DR400’s are used as glider tugs that get six or more landings a flying hour a DR400 used for touring with a landing rate of 0.5/ hour clearly needs less landing gear maintenance and the maintenance program amended to reflect this usage.

No. You have two options for the SDMP: Base it on the EASA MIP, which includes 100hr or base it on the MM which you assumed did also.

In the case of the C172, that means only an annual inspection, regardless of hours.
That would be nice. Is there any rule saying otherwise?

always learning
LO__, Austria

With certified aircraft we talk about paperwork, and how to get the maintenance cost down. With non certified aircraft we talk about hose clamps and the best way to synchronize the carbs – we talk about how to keep the aircraft in tip top shape, how to do stuff, what and where to purchase stuff. It’s a much more healthier environment.

Obviously I operate on the same philosophy with my N-registered certified aircraft, as do others. Nothing else is legally necessary when the plane is operated on condition with no documented maintenance plan. Simple annual inspections by an A&P mechanic and ADs are the only externally imposed factors for most planes and operators, and the paperwork burden is minimal as per my post above.

Having said that, your point is a good one. It is indeed a healthier environment and doing does matter more than talking. When discussions such as this thread are necessary due to complex over regulation, the paper process takes on a life of its own. The function and goals of the activity itself lose focus, the participants are kept away from their own property and don’t learn much of any practical use, and worse (not better) maintenance results.

Last Edited by Silvaire at 01 Oct 15:25

Peter wrote:

This SDMP requirement is clearly a big problem for owners who do “just the wrong number” of hours a year, because a lot of planes have the 100hr schedule in their MM.

What is the “big problem”? If you base the SDMP on the EASA MIP and fly more than 100 hr/yr, you do a check each 100 hrs. If you fly less than 100 hr/yr you do a check once a year.

ESKC (Uppsala/Sundbro), Sweden
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