Inoperative Equipment Inoperative Equipment And And

Minimum Equipment ListMinimum Equipment List

Phil RandallPhil Randall Airworthiness Airworthiness

Safety Program ManagerSafety Program Manager

Greensboro, NC FSDOGreensboro, NC FSDO

Topics of DiscussionTopics of Discussion FAR 91

General Operating and Flight Rules FAR 91* Subpart C / 91.213

Inoperative Equipment & MEL FAR 91* Subpart E / Maintenance, Preventive, Maintenance, & Alterations AC 91-67

Minimum Equipment List (MEL) Requirements Summary

CONFUCIUS SAYSCONFUCIUS SAYS

‘The Real World’, not everything works all the time, for every aircraft operator must have some LEGAL way to defer inoperative equipment BEFORE they, fly.

WHAT IFWHAT IF All my instruments and equipment are All my instruments and equipment are

working, that’s good !working, that’s good ! WHAT IF A INSTRUMENT OR PIECE OF

EQUIPMENT IS NOT WORKING ?

BUBBA BUBBA LOGBOOK POLICELOGBOOK POLICE

I SMELL A VIOLATION

Get Out of Jail Free CardGet Out of Jail Free Card

A Legal Way---- to defer inoperative equipment on your aircraft

OUT OF FAR JAIL 91.213(d)

Inoperative Instruments and Equipment

Defines ; OPERATING WITH & WITHOUT A MEL 5 Main Para./ 12

Para./ 9 Subpara. ****************************************

91.213 ( d )….A person may takeoff an aircraft in operations conducted under this part with inoperative

instruments or equipment without an approved Minimum Equipment List (MEL) provided---

4 Paragraphs / 8 Subparagraphs

The Process Of Deferring The Process Of Deferring Inop Equipment Inop Equipment under 91.213 (d)under 91.213 (d)

CESSNA 150

NAVIGATION LIGHTS ARE

INOPERATIVE

1. Check Your Equipment List 2. Type Certificate Data Sheet

( TCDS ) 3. Kinds of Operation

Equipment List SEE IF THE LIGHTS ARE

REQUIRED EQUIPMENT Lets say they are

NOT REQUIRED

Decision SequenceDecision Sequence

4. Check If Navigation Lights are required to be operative by FAR 91.205 or any other FAR Operating Rule

91.205 ( b ) VFR Flight Rules

(day) 17 Items

Instruments and Equipment that are REQUIRED

91.205 (b) Instrument & Equipment 91.205 (b) Instrument & Equipment requirement VFR-DAY requirement VFR-DAY

Airspeed indicator Altimeter Magnetic direction indicator Tachometer for each engine Oil pressure gauge...... Temp gauge for each liquid-cooled engine. Oil Temp gauge for each air-cooled engine. Manifold pressure gauge for each altitude engine. Fuel gauge.......(for each tank) Thru 17; ELT’s, 91.207(f)(10)(i)&(ii), seat belts, etc.

Decision ChecklistDecision Checklist

Well …………. They are required

for VFR (night)

BUT not for

VFR (day)

5. Are They Required to be working by an Airworthiness

Directive (AD) or STC

Our research tells us….NO

Decision ChecklistDecision Checklist

6. Now you can

Deactivate the NAV Lights IAW

FAR 43.13 & 91.213(d), then

Placard it as “INOPERATIVE”

7. Also, the Pilot

or Mechanic MUST Make A Signed Logbook Entry IAW FAR

43.9

Deactivation

The operator must evaluate any proposed deactivation to assure there is no adverse effect that could render another system less than fully capable of its intended function

A certificated pilot can accomplish deactivation involving routine pilot tasks, such as turn off a system, that task must come under the definition of preventive maintenance in FAR Part 43, Appendix A(c)

The The Placard Placard AC91-67AC91-67

AC 91-67, Paragraph 6 ‘Definitions’, page iv, subparagraph (t). “A placard is a decal or label with letters at least 1/8-inch high.”

The operator or mechanic must place the placard on or near inoperative equipment or instruments so that it is visible to the pilot or flight crew and alerts them to the inoperative equipment.

LOGBOOK ENTRYLOGBOOK ENTRY7. stating that……..

“The Navigation Lights Are Deferred for VFR Flight Only and Do Not Constitute A Hazard to the Aircraft”Signature Jimmy B.

LunchbucketLunchbucketcertificate no. certificate no. 444347744444347744

PART 91: General PART 91: General Operating and Flight RulesOperating and Flight Rules

Subpart C: Refers to additional equipment that must be maintained.

Subpart E: Is about maintenance, preventive maintenance, and alterations.

FAR 91 Subpart CFAR 91 Subpart C

References equipment, instruments, & certification requirements. Items that were never part of the aircraft’s original type design

This additional equipment was added to the aircraft

because it either enhances the aircraft’s operating

environment or because it was required by regulation

Some ExamplesSome Examples

ENHANCES the ENVIRONMENT Transponders, Supplemental Oxygen, TCAS, GPS, even Aircraft Lights

by REGULATION Congress Passed a

mandatory Law requiring…ELT’s

Part 91 Subpart EPart 91 Subpart E

Requirements for Inspections, Annuals, 100 hours, Progressive, and the Inspections for

large and turbine aircraft under Section 91.409(e)(f)

FAR 91.405 ( c )FAR 91.405 ( c ) don’t forget (d)don’t forget (d) SHALL have any INOPERATIVE instrument

or item of equipment, permitted to be INOPERATIVE by FAR 91.213 (d)(2) of this part, REPAIRED, REPLACED, REMOVED, or INSPECTED at the NEXT REQUIRED

INSPECTION; AND (d)..When listed discrepancies include

inoperative instruments or equipment, SHALL

ensure that a placard has been installed as required by FAR 43.11 of this chapter

The Big QUESTIONThe Big QUESTION

Whether an item of equipment can go indefinitely in an inoperative status under the rule. IF it meets all of the criteria and is inspected for hazardous conditions at each required inspection, then it can continue to be inoperative. BUT, the intent of the rule is to provide temporary relief until a repair or replacement.

Areas of ConcernAreas of Concern The mechanic can get in trouble, if you do not

inspect each inoperative part under 91.213 (d) in accordance with 91.405 ( c ) at each

100 hour and or Annual inspection. The FAA interprets this as Not Inspecting an

‘alteration’

Areas of ConcernAreas of Concern

If you do not perform or record that you inspected the ‘major alteration’

to the aircraft’s type design you could be

in violation of Sections 91.213 and 43.11 inspections.

Mechanics Favorite Rule Mechanics Favorite Rule 91.403 9(a)91.403 9(a)

91.403 (a) The owner operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with * Part 39 of this chapter

Part 39--Airworthiness Directives

AC 91-67 MEL AC 91-67 MEL Related FAR’sRelated FAR’s

FAR 43.9; Content, form, and disposition of maintenance, preventive maintenance, and alteration records (except inspections performed in accordance with FAR part 91...)

FAR 43.11; Content, form, and disposition of the records for the INSPECTIONS conducted under FAR 91

MEL Related FARsMEL Related FARs

FAR 91.205; Powered civil aircraft with standard category U.S. airworthiness certificate: Instruments and Equipment Requirements

FAR 91.405; Maintenance Requirements FAR 91.213; Inoperative Instruments and

Equipment

Removal of equipmentRemoval of equipment Removal of equipment that affects the

airworthiness of an aircraft requires following an approved procedure.

A properly certificated maintenance person (A&P) must record; The removal, Adjustment of the weight & balance & equipment

list; Submit FAA Form 337; and approve the aircraft for return to service.

IN SUMMARY FAR 91

FAR 91 “C” FAR 91 “E”

Inoperative Equipment Deactivation & Placard Procedures

Inspect Inoperative Instruments and Equipment.

AC 91-67 Minimum Equipment List

QUESTIONSQUESTIONS

SAFETY SAFETY is the Bottom lineis the Bottom line

Every instrument and item of

equipment adds an extra level of safety, so try to

keep it all working

THE ENDTHE END

FLY SAFE