2: The Function of an IA

Introduction

Approving Major Repairs and Major Alterations

Annual, 100-Hour, and Progressive Inspections

Aircraft with Discrepancies or Unairworthy Conditions

Aircraft Owner/IA Relationships

Introduction

An Inspection Authorization accords two additional privileges to an FAA-certificated mechanic with an Airframe and Powerplant rating. These are:

1. The authorization to inspect and approve for return to service of an aircraft or related part or appliance after a major repair or a major alteration.

2. The authorization to perform an annual inspection or to perform or supervise a progressive inspection.

This chapter considers four items of concern to an IA:

1. The approval of major repairs and major alterations

2. Annual and progressive inspections

3. Maintenance records

4. The relationship between an IA and the aircraft owner

Approving Major Repairs and Major Alterations

A primary responsibility of the holder of an IA is to determine airworthiness by inspecting repairs or alterations for conformity to approved data, and ensuring that the aircraft is in a condition for safe operation. During inspection of major repairs or major alterations, the holder of an IA must also determine that these are compatible with previous repairs and alterations made to the aircraft.

14 CFR §43.11 requires the inspector to include in his or her maintenance record entry, either the following statement or a similarly worded one, upon completion of determining airworthiness: “I certify that this aircraft has been inspected in accordance with _________ inspection and was determined to be in an airworthy condition.” Therefore it is important to understand the definition for the term “airworthy.” Although the term is fundamental to all maintenance and inspection activities, only recently did the FAA specifically define it in regulatory material (September 16, 2005). See 14 CFR Part 3 on the next page.

Prior to this regulatory reference, the definition was inferred by reading the requirements found in 14 CFR §21.183 necessary to obtain an Airworthiness Certificate, and the related comment on the
Standard Airworthiness Certificate (FAA Form 8100-2), or referred to in nonregulatory guidance information found in FAA Order 8130.2. These references and now the formal definition in 14 CFR Part 3 state that the definition of airworthiness is based upon two specific issues:

1. Conformity to type design data (or approved alterations).

2. Condition for safe operation.

It is the aviation inspector’s job to determine that these two criteria are met before signing off the required maintenance record entry required in §43.11.

It may help in understanding this definition if the IA considers that “conformity” to type design is really an objective determination. In other words, do all the numbers match? Are the model numbers, part numbers, and serial numbers when applicable, consistent with approved design and alteration data?

The second part—the condition for safe operation—can be considered much more subjective to the technician. This is where the years of personal experience, lunchroom conversations, team meetings, networking at professional tradeshows and seminars, and discussions with coworkers come into the picture. Most differences of opinion regarding airworthiness will occur here, but good and honest dialogue with an open mind are valuable tools for the technician. The IA must learn to balance both a willingness to learn from others, and also to defend one’s own professional opinion — with the final goal of determining whether an aircraft is airworthy or not.

The holder of an IA must personally perform the inspection. The Code of Federal Regulations (CFRs) does not provide for delegation of this responsibility. Approving major repairs and major alterations is a serious responsibility. The approval action should consist of a detailed investigation to establish at least that:

• All replacement parts installed conform to approved design and/or have traceability to the original equipment manufacturer (OEM), or to the appropriate Parts Manufacturing Approval (PMA) or Technical Standard Order (TSO).

• As installed, the installation conforms to approved data that is applicable to the installation.

• Workmanship meets the requirements of 14 CFR §43.13, which specifies that the aircraft or product is equal to its original or properly altered condition.

• The data used is appropriate to the aircraft certification rule (e.g., CAR 3 or 14 CFR Part 23).

• Work is complete and compatible with other structures or systems.

Approved Data

The holder of an IA cannot approve the data for major repairs or major alterations. He or she may, however, inspect to see that alterations conform to data previously approved by the Administrator (14 CFR §65.95). This means the holder of an IA ensures that approved data is available and is used as the basis for the approval. This availability determination should be made prior to beginning the repair or alteration. If data is unavailable, or if the holder of an IA is unsure of the acceptability of the available data, the local Aviation Safety Inspector (ASI) should be consulted. The ASI may, as the circumstances warrant, be able to:

• establish an acceptable basis for approval;

• approve the data; or

• recommend application for a supplemental type certificate.

Often, major repairs are performed that are eventually covered by fabric, metal skin, or another structure. When this situation exists, the holder of an IA should have a clear understanding with the mechanic performing the repair that a precover inspection is necessary. The inspection should ensure that the repair was made in accordance with acceptable methods, techniques, and practices prescribed by 14 CFR Part 43 and that the structure to be covered is free from defects, corrosion, or wood rot, and is protected from the elements. In addition, the holder of an IA should inspect other affected areas for hidden damage, if the aircraft has been involved in an accident or incident. An entry is required to be made in the maintenance record, and FAA Form 337 Major Repair and Alteration must be completed.

Minor deviation from approved data is permissible if the change is one that could be approved as a minor alteration when considered by itself. Be sure to list the deviations on FAA Form 337 and make an entry in the maintenance record when completing the aircraft records. When in doubt, contact the local ASI who may decide the change is not minor and would need specific approval or an amendment of the original approval.

Approved data to be used for major repairs and major alterations may be one or more of the following.

• Type Certificate Data Sheets

• Aircraft Specifications

• Supplemental Type Certificates (STCs) (Note: Persons interested in using an STC must have approval in accordance with 49 U.S.C., §44704, from the holder of the STC prior to its use.)

• Airworthiness Directives (ADs)

• Designated Engineering Representative (DER) Approved Data With FAA Form 8110-3, Statement of Compliance

• Organizational Designation Authorization (ODA) Approved Data

• Appliance Manufacturer’s Manuals (excluding installation instructions)

AC 43.13-1, Acceptable Methods, Techniques, and Practices (Aircraft Inspection and Repair), may be used directly as approved data (for repairs only) without further approval only when there is no manufacturer’s repair or maintenance instructions that address the repair, and the user has determined that it is:

• appropriate to the product being repaired;

• directly applicable to the repair being made; and

• not contrary to manufacturer’s data.

This data may also be used as a basis to gain FAA data approval for major repairs.

FAA field approval (occurs when FAA enters a statement and signs block 3 of FAA Form 337) issued for duplication of identical aircraft may be used as approved data only when the identical alteration is performed on an aircraft of identical make, model, and series by the original modifier. FAA Form 337s approved in 1955 or earlier may be used as approved data.

Inspecting Repairs or Alterations

Inspecting repairs or alterations consists of these basic operations:

• Determine that the repair or alteration data has FAA approval.

• Inspect the configuration of the repair or alteration for conformity to the approved data and the per-formance standards of 14 CFR Part 43. At the same time, the aircraft should still comply with applicable airworthiness requirements, and the repair or alteration be compatible with all other installations.

• All operating limitations affected by an alteration should be appropriately revised. Sometimes limitations are in the form of flight manual supplements, instrument range markings, placards, or combinations of these. See the local ASI for limitations on changes that can be made.

• Determine that aircraft record entries have been made and the weight and balance data and equipment list have been revised, when appropriate. There should be a statement on FAA Form 337 to the effect that the weight and balance data and equipment list have been revised. When an alteration results in a change in the center-of-gravity (CG) position, the affected CG limit should be investigated under adverse loading conditions unless the new CG falls within an approved empty CG range. For instance, if the CG has shifted aft, the loading conditions should be computed to see that the aircraft does not exceed the aft CG limit. It is the pilot’s responsibility to have the aircraft correctly loaded. However, when approving an alteration, it is the IA’s responsibility to see that weight and balance data have been revised. The aircraft record entries may refer to FAA Form 337 for details, such as: “Installed STOL kit in accordance with STC SA 940 CE drawing number 5084 dated April 24, 1996. See FAA Form 337, this date, for details.”

• Indicate approval in block 7 of FAA Form 337, and return both copies to the person who performed the work, for disposition in accordance with 14 CFR Part 43, Appendix B.

Annual, 100-Hour, and Progressive Inspections

The procedures and scope for annual and 100-hour inspections are set forth in 14 CFR Part 43 Appendix D, and 14 CFR §43.15. These should be followed in detail. The scope and detail for a progressive inspection is established by the owner or operator in accordance with 14 CFR §91.409(d). There are additional requirements for annual and progressive inspections listed in 14 CFR §43.15.

The scope and detail of 100-hour and annual inspections are the same.

Record entries are very important as they are the only evidence an aircraft owner has to show compliance with the inspection requirements of 14 CFR §91.409. The following reminders should help in determining that the aircraft complies with all airworthiness requirements (refer to 14 CFR §43.15(a)):

Inspection for Configuration (“conformity to type design”)

The aircraft should conform to the Aircraft Specification or Type Certificate Data Sheet, any changes by Supplemental Type Certificates, and/or its properly altered condition. When the aircraft does not conform, use the procedures for “unairworthy” items listed in 14 CFR §43.11(a)(5).

1. Alterations to the product may have changed some of the operating limitations.

2. Unrecorded alterations or repairs may have been made in the past and warrant one of the following:

a. Contact owner for pertinent information.

b. If approved data is available, conduct inspection and personally approve for return to service by completing FAA Form 337.

c. Contact local ASI for assistance.

3. The Aircraft Specification or Type Certificate Data Sheet indicates when a flight manual is required. It also identifies the limitations that must be displayed in the form of markings and placards.

4. Unlike the Aircraft Specifications, Type Certificate Data Sheets do not contain a list of equipment approved for a particular aircraft. The list of required and optional equipment can be found in the equipment list furnished by the manufacturer of the aircraft. Sometimes a later issue of the list is needed to cover recently approved items. Serial number eligibility should always be considered.

Inspection for Condition (“condition for safe operation”)

The holder of an IA may use the checklist in 14 CFR Part 43, Appendix D, the manufacturer’s inspection sheets, or a checklist designed by the holder of an IA, that includes the scope and detail of the items listed in Appendix D, to check the condition of the entire aircraft. This includes checks of the various systems listed in 14 CFR §43.15.

1. Routine servicing is not a part of the annual inspection. The inspection itself is essentially a visual evaluation of the condition of the aircraft and its components and certain operational checks. The manufacturer may recommend certain services to be performed at various operating intervals. These can often be done conveniently during an annual inspection, and in fact should be done, but are not considered to be a part of the inspection itself.

2. It is very important that the holder of an IA be familiar with the manufacturer’s service manuals, bulletins, and letters for the product being inspected. Use these publications to avoid overlooking problem areas.

3. AC 43-16, Aviation Maintenance Alerts, is also an important source of service experience. The articles for the alerts are taken from selected service difficulties reported to the FAA on FAA Form 8010-4, Malfunction or Defect Reports. Monthly copies of the alerts are provided on the Internet at the following address: www.faa.gov

Comments may be sent by letter, with name and address typed or legibly printed to:
Federal Aviation Administration
Designee Standardization Branch, AFS-640
P.O. Box 25082
Oklahoma City, OK 73125

4. When the holder of an IA approves an aircraft for return to service, he or she will be held responsible for the condition of the aircraft as of the time of approval.

Minimum Equipment List (MEL)

The minimum equipment list (MEL) is intended to permit operations with certain inoperative items of equipment for the minimum period of time necessary until repairs can be accomplished. It is important that repairs are accomplished at the earliest opportunity in order to return the aircraft to its design level of safety and reliability.

1. When inspecting aircraft operating with an MEL, the holder of an IA should review the document where inoperative items are recorded, (aircraft maintenance record, logbook, discrepancy record, etc.) to determine the state of airworthiness with regard to those recorded discrepancies. Inspections of aircraft with approved MELs will be in accordance with the 14 CFR Part under which the MEL was issued.

2. Those MELs specifying repair intervals through the use of A, B, C, D codes require repairs of deferred items at or prior to the repair times established by the letter designated category. In such instances, some items previously deferred may not be eligible for continued deference at the
inspection or may require additional maintenance. Where repair intervals are not specified by codes in the MEL, all MEL-authorized inoperative instruments and/or equipment should be repaired or inspected and deferred before approval for return to service.

3. Aircraft established on a progressive inspection program require that all MEL-authorized inoperative items be repaired or inspected and deferred at each inspection whether or not the item is encompassed in that particular segment.

4. When inspecting aircraft operating without an MEL, 14 CFR §91.213(d) allows certain aircraft not having an approved MEL to be flown with inoperative instruments and/or equipment. These aircraft may be presented for annual or progressive inspection with such items previously deferred or may have inoperative instruments and equipment deferred during an inspection. In either case, the holder of an IA is required by 14 CFR §43.13(b) to determine that:

a. The deferrals are eligible within the guidelines of that rule.

b. All conditions for deferral are met, including proper recordation in accordance with 14 CFR §§43.9 and 43.11; and

c. Deferral of any item or combination of items will not affect the intended function of any other operable instruments and/or equipment, or in any manner constitute a hazard to the aircraft. When these requirements are met, such an aircraft is considered to be in a properly altered condition with regard to those deferred items.

Airworthiness Directives (ADs)

The holder of an IA is required by 14 CFR §43.13 to determine that all applicable airworthiness directives (ADs) for aircraft, powerplants, propellers, instruments, and appliances have been accomplished.

1. If the maintenance records indicate compliance with an AD, the holder of an IA should make a reasonable attempt to verify the compliance. It is not uncommon for a component to have compliance with an AD accomplished and properly recorded then later be replaced by another component on which the AD has not been accomplished. The holder of an IA is not expected to disassemble major components such as cylinders, crankcases, etc., if adequate records of compliance exist.

2. When the maintenance records do not contain indications of AD compliance, the holder of an IA should:

a. make the AD an item on a discrepancy list provided to the owner, in accordance with 14 CFR §43.11(b);

b. with the owner’s concurrence, do whatever disassembly is required to determine the status of compliance; or

c. obtain concurrence of the owner to comply with the AD.

3. Often, an AD calls for an inspection at one time with a modification or inspection required at a later date. It is very important to identify, in the maintenance record entry, the portion of the AD complied with and the exact method of compliance.

4. 14 CFR §91.417(a)(2)(v) requires each registered owner or operator to keep a record of the current status of applicable ADs. This status includes, for each, the method of compliance, AD number, and revision date. If the AD involves recurring action, the time and date should be recorded when the next action is required. As a vital part of the services performed, the holder of an IA may wish to provide the owner with information he/she is expected to keep.

5. The owner should also be informed of any subsequent requirements of an AD or whether a reinspection is required at operating intervals other than at annual inspections. Often, the subsequent requirements are at 100-hour intervals and will need to be done whether or not the aircraft is required to have 100-hour inspections. Where a progressive inspection is involved, the approved program should state how and when the AD review will be accomplished. However, as a mechanic or IA, you should be aware of an AD that is pending or due, and even though is not in the area you are inspecting, it is good customer relations to inform the owner or pilot of the situation.

Malfunction or Defect Reports

All malfunctions or defects that come to the attention of the holder of an IA should be reported on FAA Form 8010-4. Copies of the self-addressed form are available at all FSDOs, easy to fill out and require no postage. Prompt reporting will contribute much toward improving air safety by helping correct unsafe conditions. In addition to the old style “postcards,” it is now possible to submit these M & D reports electronically via the web. The FAA still accepts both. Some technicians will find it easier to keep the cards in their toolbox.

Paperwork Review

The owner or operator is responsible for maintaining the equipment list, CG and weight distribution computations, and loading schedules, if necessary.

1. The holder of an IA is required by 14 CFR §43.13 to determine that the required placards and documents set forth in the aircraft specification or type certificate data sheet are available and current. The aircraft should be reported as being in an unairworthy condition if these placards and documents are not available. Missing, incorrect, or improperly located placards are regarded as an unairworthy item, and the owner or operator should be informed that, under the requirements of 14 CFR §91.9, the aircraft may not be operated until they are correctly installed.

2. The holder of an IA should refer to the registration and airworthiness certificates for the owner’s name and address; the aircraft make, model, registration, and serial numbers needed for recording purposes. Be sure not to use manufacturers’ trade names as they do not always coincide with the actual model designation (Cessna Skylane is 182, Piper Seneca III is PA 34 220T, etc.). If registration and airworthiness certificates are not available, the aircraft does not need to be reported in unairworthy condition; however, the owner or operator should be informed that the documents required by 14 CFR §91.203 (a) and (b), should be in the aircraft and the airworthiness certificate displayed, when the aircraft is operated.

3. Other documents often needed but not a part of the airworthiness requirement might be a state registration, and if the aircraft is equipped with a transceiver, a Federal Communications Commission radio license. The owner or operator is responsible for maintaining these documents. However, the IA holder will be performing an appreciated service by informing the operator of any deficiencies in the display and carriage of these documents.

4. On aircraft for which no approved flight manual is required, the operating limitations prescribed during original certification, and as required by 14 CFR §91.9, must be carried in or be affixed to the aircraft. Range markings on the instruments, placards, and listings are required to be worded and located as specified in the Type Certificate Data Sheet.

Aircraft Markings

Required aircraft identification markings are discussed in 14 CFR Part 45. It is the owner’s or operator’s responsibility to have the nationality and registration markings properly displayed on the aircraft (14 CFR §91.9(c)). The holder of an IA can, and should, offer advisory service to owners and operators in regard to any deficiencies in markings; however, such deficiencies are not cause to report an aircraft in “unairworthy” condition.

Aircraft with Discrepancies or Unairworthy Conditions

If the aircraft is not approved for return to service after a required inspection, use the procedures specified in 14 CFR §43.11. This will permit an owner to assume responsibility for having the discrepancies corrected prior to operating the aircraft.

1. The discrepancies can be cleared by a person who is authorized by 14 CFR Part 43 to do the work. Preventive maintenance items could be cleared by a pilot who owns or operates the aircraft, provided the aircraft is not used under 14 CFR Parts 121, 129, or 135; except that approval may be granted to allow a pilot operating a rotorcraft in a remote area under 14 CFR Part 135 to perform preventive maintenance.

2. The owner may want the aircraft flown to another location to have repairs completed, in which case the owner should be advised that the issuance of FAA Form 8130-7, Special Flight Permit, is required. This form is commonly called a ferry permit and is detailed in 14 CFR §21.197. The certificate may be obtained in person or by fax at the local FSDO or from a Designated Airworthiness Representative.

3. If the aircraft is found to be in an unairworthy condition, an entry will be made in the maintenance records that the inspection was completed and a list of unairworthy items was provided to the owner. When all unairworthy items are corrected by a person authorized to perform maintenance and that person makes an entry in the maintenance record for the correction of those items, the aircraft is approved for return to service.

Incomplete Inspection

If an annual inspection is not completed, the IA holder should:

• Indicate any discrepancies found in the aircraft records.

• Not indicate that an annual inspection was conducted.

• Indicate the extent of the inspection and all work accomplished in the aircraft records.

Maintenance Records

The holder of an IA and other maintenance personnel or agencies are required to record maintenance, inspections, or alterations performed or approved in accordance with the requirements of 14 CFR §§43.9 and 43.11. The owner or operator is required by 14 CFR §91.417 to keep maintenance records. The holder of an IA is also required to indicate the total aircraft time in service when a required inspection
is done.

Significance of Maintenance Record Entries

Responsibility for maintenance work performed rests with the person whose signature and certificate number are entered on the appropriate maintenance record and/or forms. The responsibility for annual and progressive inspections and approval for return to service of major repairs or major alterations is assumed by the holder of an IA whose signature and certificate number appear on the appropriate maintenance records.

Completion of FAA Form 337

FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), serves two purposes. One is to provide owners and operators a record of major repairs and major alterations indicating details and approval. The other purpose is to provide the FAA with a copy for the aircraft records.

1. The person who performed or supervised the major repair or major alteration prepares the original FAA Form 337 (two copies, or three if extended-range fuel tanks are installed in the passenger or baggage compartment). The holder of an IA then further processes the forms when they are presented for approval.

2. Instructions for the completion of FAA Form 337 appear in AC 43.9-1F, Instructions for Completion of FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance).

3. Disposition of FAA Form 337.

a. The IA holder who has found a major alteration or a major repair to be in conformity with FAA-approved data should review the FAA Form 337 for completeness and accuracy, and complete item 7.

b. The person performing a major repair or major alteration shall in accordance with Part 43:

(1) Give a signed copy of FAA Form 337 to the aircraft owner.

(2) Make the proper entry in the maintenance records.

(3) Forward the duplicate copy to the local FAA Aircraft Registration branch in Oklahoma City within 48 hours.

c. The holder of an IA should ensure that the duplicate copy is an exact and legible reproduction of the original. The signatures should not be carbon copies but original signatures written in ink.

d. If the FAA Form 337 is completed for extended-range fuel tanks installed within the passenger compartment or a baggage compartment, the person who performs the work and the person authorized to approve the work by 14 CFR §43.7 shall execute an FAA Form 337 in at least triplicate, as required by 14 CFR Part 43, Appendix B. One (1) copy of the FAA Form 337 shall be placed on board the aircraft as specified in 14 CFR §91.417. The remaining forms shall be distributed as previously noted.

e. If FAA Form 337 has been completed for engines, propellers, spare parts or components, both copies of the form, with the approval portion completed, should be attached to the part or component until it is installed on an aircraft.

(1) The mechanic who makes the installation will, in accordance with 14 CFR §43.9(a)(4), complete both copies of FAA Form 337 by filling in blocks 1 and 2 and sign for the installation in the aircraft records, making reference to the FAA Form 337 in the record entry.

(2) He or she will give a copy to the owner and forward a copy to the FAA Aircraft Registration branch in Oklahoma City.

Weight and Balance

Although weight and balance data are no longer required to be entered on FAA Form 337, it is still imperative that weight and balance checks and computations be made very carefully. Since practically every aircraft manufacturer uses a different method of weight and balance control, it would be impossible to provide a universally adaptable method. When revising weight and balance data, these general guidelines should be followed.

1. The weight and balance data should be kept together in the aircraft records.

2. When making revisions, use a permanent, easily-identified method, with full-size sheets of paper large enough to contain complete computations and minimize the possibility of them becoming detached or lost.

3. Each page should be identified with the aircraft by make, model, serial number, and registration number.

4. The pages should be signed and dated by the person making the revision.

5. The nature of the weight change should be described.

6. The old weight and balance data should be marked “superseded” and dated.

7. A new page should show the date of the old figures it supersedes.

8. Appropriate fore and/or aft extreme loading conditions should be investigated and the computations shown.

9. Example loading computations may be helpful.

10. On large aircraft, be careful to distinguish between empty weight and operating weights that may include items, such as commissary supplies, spare parts, lavatory water, etc.

11. On small aircraft, it is often convenient to post a placard in the aircraft indicating the empty weight, useful load, and empty CG, along with example loadings or general instructions, to cover the most likely loading conditions.

Aircraft Owner/IA Relationships

Be sure to come to a mutual agreement with the aircraft owner concerning exactly what work is to be performed. Misunderstandings usually result from a lack of clear communication. Attention to the following details will usually avoid the ill will a later disagreement may generate.

1. Itemize the work to be done so the owner will have a clear understanding of the work order.

2. Establish a firm understanding about the cost, or range of cost, anticipated for the job.

3. If an annual inspection is involved, indicate that certain maintenance is required to perform the inspection, such as:

a. Removing cowling and fairing, opening inspection plates, etc.

b. Cleaning the aircraft and engine.

c. Disassembling wheels and other components to determine their condition.

4. Advise the owner that an annual inspection involves determination of compliance with aircraft specifications and airworthiness directives (ADs).

5. Agree whether routine servicing is to be included as part of the inspection or if it is to be performed separately. Such servicing is not a part of the inspection, but may be conveniently done while conducting the inspection. Such items might be:

a. Cleaning spark plugs.

b. Servicing landing gear shock struts.

c. Changing oil.

d. Making minor adjustments.

e. Servicing brakes.

f. Dressing nicked propeller blades.

g. Lubricating where necessary.

h. Stop-drilling small cracks and minor patching of cowling and baffles.

6. The owner should be made aware that the annual or progressive inspection does not include correction of discrepancies or unairworthy items, and that such maintenance will be additional to the inspection. Maintenance and repairs may be accomplished simultaneously with the inspection by a person authorized to perform maintenance if agreed on by the owner and holder of the IA. This method would result in an aircraft that is approved for return to service upon the completion of the inspection.

A written list of discrepancies and unairworthy items not repaired concurrently with the inspection must be made and given to the owner. Record uncorrected discrepancies and unairworthy items in the maintenance records. The owner must make arrangement for correction or deferral of items on the list of discrepancies and unairworthy items with a person authorized to perform maintenance prior to returning the aircraft to service.

The holder of the IA ensures that any item permitted to be inoperative by an MEL or under 14 CFR §91.213(d)(2) are properly placarded and any maintenance for deferral has been carried out. Any deferred items are to be included on the list of discrepancies and unairworthy items. The owner should be informed that the aircraft should not be operated until the discrepancies and unairworthy items are corrected or are appropriately deferred.

7. Establish a reasonable time frame to accomplish the inspection.

8. Request the owner to supply the complete aircraft records (airframe, engines, and propellers) for study, review, and entries. Point out that this is necessary to properly conduct an annual inspection.

9. Complete the inspection as soon as practicable. Often, an aircraft will sit around the shops waiting for parts, even though the inspection has actually been completed. In this cases, it is advisable to officially report the aircraft unairworthy. (Refer to 14 CFR §43.11(a)(5).) When the parts arrive, the repairs can be completed and the aircraft approved for return to service in the usual manner by the person who makes the repairs. The time lapse may represent several weeks, or even months, and things can deteriorate on the aircraft. Also, there is the chance that an AD involving some part of the aircraft may have been issued in the interim. In these cases, it might be unwise to complete the repairs originally intended and sign off the aircraft as “airworthy” without doing another complete inspection.

10. Complete the aircraft record entries as required by 14 CFR §§43.9 and 43.11 and provide sufficient information for the owner to comply with 14 CFR §91.417(a)(2)(i). Make adequate descriptions of repairs or alterations if accomplished along with the inspection.

11. Record compliance with all ADs actually accomplished. Provide sufficient information for the owner to comply with 14 CFR §91.417(a)(2)(v). A general statement, such as “All ADs complied with” is not an adequate entry and should be avoided. Many owners keep a separate record of AD compliance in the back of the logbook or in a section specifically provided for this record. This is a good place to identify the ADs of a recurring nature and show when the next compliance is required.

12. When approving repairs and alterations, the holder of an IA should be available as work progresses on major jobs. In this way, affected areas and structures can be seen more readily than after completion of the entire job. In many cases, the workmanship can be inspected and improved easier during the process of the job rather than having to redo it later.

13. Remind the owners or operators that they are responsible for operational requirements, such as:

a. VOR equipment checked in accordance with 14 CFR §91.171.

b. Altimeter and altitude reporting equipment test and inspections in accordance with 14 CFR §91.411*.

c. ATC transponder test and inspection in accordance with 14 CFR §91.413*.

*These tests and inspections are not part of the annual inspection.