Question to Zach

[Ray B]

Zach I'm a bit confused on the Horn AD. In last Novembers Comanche Flyer on page 14 (bottom of page point #3) you said "inspections are then required every 500 hours TIS or five years, whichever comes FIRST". However reading a later AD horn thread on the Comanche Owner's Forum it was said to read 100 hours after 22 Oct 2012 or 500 hours TIS or five years after inspection, WHICHEVER COMES LATER. Can you please set me straight on this point as my old computer refuses to down load the AD from this site or the FAA's. Thanks Ray B

[Michael Bryant]

Ray,

While I am not Zach, I think I can answer your question.

The AD is 2012-17-06. You have 100 hrs after the AD was effective (October 22, 2013) to complete the first inspection.

After that, you must reinspect every 5 years or 500 hours if you reuse the old parts. If you replace the horn, then you must reinspect after 10 years or 1000 hours. These two intervals then repeat depending on whether old or new parts were used.

Hope that helps.

Michael

[Ray B]

Thanks for trying Michael, but the question is on the wording, "whichever ocurrs FIRST" or "whichever occurs LATER". It can make a big difference if you fly alot. I had Denny Haskins do the inspection and rebuild two years ago. The 500 hr mark will come for me before the 5 year mark. So "FIRST" or "LATER" becomes important. Ray B

[Tom Veatch]

Ray, the answer to your question is:

Per AD 2012-17-06 (g)(1) the initial inspection is "whichever comes later". Per AD 2012-16-06 (g)(1)(i) and (ii) the repetitive inspections following the initial inspection are "whichever comes first".

I'd suggest anyone who is interested get a copy of the AD from the FAA website and read what it says. Don't base decisions on what somebody else (and that includes me) tells you what they think it might say because their ex-brother-in-law overheard someone talking about it in the barbershop. Go to the document and get the information first hand. It's really pretty straightforward and easy to understand - especially for a bureaucratically produced document.

[Zach Grant L1011jock]

Ray,

Excerpt from the AD:

(1) When a new stabilator horn assembly has been installed (during production or replacement)
and the stabilator horn assembly reaches a total of 1,000 hours time-in-service (TIS) or 10 years after
installation, or within the next 100 hours TIS after October 22, 2012 (the effective date of this AD),
whichever occurs later, do one of the following actions:

(i) Initially inspect the stabilator horn assembly for corrosion or cracks. Repetitively thereafter
inspect at intervals not to exceed 500 hours TIS or 5 years, whichever occurs first.
(ii) Replace the stabilator horn assembly with a new stabilator horn assembly. When the new
stabilator horn assembly reaches a total of 1,000 hours TIS after replacement or within 10 years after
replacement, whichever occurs first, you must do one of the actions in paragraph (g)(1) of this AD.
(iii) Replace the stabilator horn assembly with a used serviceable stabilator horn assembly that
has been inspected before installation and found free of cracks or corrosion. Repetitively thereafter
inspect at intervals not to exceed 500 hours TIS or 5 years, whichever occurs first.

Tom is correct in his explaination.

-Zach

[Ray B]

Ok Tom and Zach, I went to the airport FBO and got a copy of the AD. It says on Page 15 under (g)Inspections/Replacements (2) When a used serviceable stabilator horn assembly that has been inspected before installation and found free of cracks or corrosion has been installed and the stabilator horn assembly reaches a total of 500 hours TIS or 5years after installation, or within the next 100 hours TIS after October 22, 2012 (the effective date of this AD), WHICHEVER OCCURS LATER, do one of the following actions: (i) (ii) (iii). All three actions listed then give limiting TIS or hours WHICHEVER OCCURS FIRST. ----- So it appears to me that the FAA did give credit to those of us that did the inspection early. 500 hours TIS, 5 years, or 100 hours TIS after October 22, 2012, WHICHEVER OCCURS LATER is only available to the early complyees (before Oct. 22, 2012).------ Zach your excerpt is from para. (g) (1) and pertains to a new stabilator horn assembly. Para. (g) (2) pertains to a used serviceable stabilator horn assembly. However, both (1) and (2) state "WHICHEVER OCCURS LATER". Ray B

[Tom Veatch]

[Zach Grant L1011jock]

Ray,
In the instance you cite, the 5 year, 500 hr, or 100 hrs after Oct 22, 2012, whichever is later, would only apply if there was a used servicable horn installed prior to the effective date of the AD. This is different from inspecting the existing horn as the existing horn was probably installed new during production (and would fall under part 1). How it is different I don't know but the FAA saw fit to make the distinction. It probably has to do with the fact that it would be impossible to inspect as per the SB 1189 before that SB was actually published. They gave us an out for that in section two I believe. In my best legal opinion thinking like a Fed, if you inspected prior to the release of SB 1189 dated 29 April 2010, then you would have had to install a used servicable horn assembly (even if it was the same part that was removed from your airplane). After that date, if you reinstalled the existing horn, the horn would have been the same one as installed new, inspected IAW SB 1189, and thusly compliant with this AD, and would subsequantly be covered under the repetitive inspection requirements of the AD. You would have inspected your horn as per SB 1189, not replaced with a used servicable horn, and would not fall under part 2, but rather the simple 5 yr or 500 hour reinspection requirement found in (1) (i). Note also that part (j) (2) requires that the only acceptable stated method of compliance with the inspection requirements of this AD are contained in Piper SB 1189. The referenced sections are attached below. -Zach

(1) When a new stabilator horn assembly has been installed (during production or replacement)and the stabilator horn assembly reaches a total of 1,000 hours time-in-service (TIS) or 10 years after
installation, or within the next 100 hours TIS after October 22, 2012 (the effective date of this AD),
whichever occurs later, do one of the following actions:
(i) Initially inspect the stabilator horn assembly for corrosion or cracks. Repetitively thereafter
inspect at intervals not to exceed 500 hours TIS or 5 years, whichever occurs first.
(ii) Replace the stabilator horn assembly with a new stabilator horn assembly. When the new
stabilator horn assembly reaches a total of 1,000 hours TIS after replacement or within 10 years after
replacement, whichever occurs first, you must do one of the actions in paragraph (g)(1) of this AD.
(iii) Replace the stabilator horn assembly with a used serviceable stabilator horn assembly that
has been inspected before installation and found free of cracks or corrosion. Repetitively thereafter
inspect at intervals not to exceed 500 hours TIS or 5 years, whichever occurs first.

(2) When a used serviceable stabilator horn assembly that has been inspected before installation
and found free of cracks or corrosion has been installed and the stabilator horn assembly reaches a
total of 500 hours TIS or 5 years after installation, or within the next 100 hours TIS after October 22,
2012 (the effective date of this AD), whichever occurs later, do one of the following actions:
(i) Initially inspect the stabilator horn assembly for corrosion or cracks. Repetitively thereafter
inspect at intervals not to exceed 500 hours TIS or 5 years, whichever occurs first.
(ii) Replace the stabilator horn assembly with a new stabilator horn assembly. When the new
stabilator horn assembly reaches a total of 1,000 hours TIS after replacement or within 10 years after
replacement, whichever occurs first, you must do one of the actions in paragraph (g)(1) of this AD.
(iii) Replace the stabilator horn assembly with a used serviceable stabilator horn assembly that
has been inspected before installation and found free of cracks or corrosion. Repetitively thereafter
inspect at intervals not to exceed 500 hours TIS or 5 years, whichever occurs first.

(j) Material Incorporated by Reference
(1) The Director of the Federal Register approved the incorporation by reference (IBR) of the
service information listed in this paragraph under 5 U.S.C. 552(a) and 1 CFR part 51.
(2) You must use this service information as applicable to do the actions required by this AD,
unless the AD specifies otherwise.
(i) Piper Aircraft, Inc. Service Bulletin No. 1189, dated April 29, 2010.
(ii) Reserved.

[Ray B]

So the mind twisting exercise goes on. Sorry I brought it up guys. I'll have my IA call our local FAA office and get their opinion in writing, he agrees with me on what it appears to say in English. However, as Zach is more versed in FAA Speak it may well be that logic is out the window! Ray B

[Michael Bryant]

Ray,

I missed the nuance of your OP. The only time the whichever occurs later applies is the first inspection after the effective date of the AD.

As Tom said, the first inspection must be done at 1000 hours TIS or 10 years from a new install, 500 hours TIS or 5 years from a reused stabilator horn, or 100 hours from the effective date of the AD, whichever occurs later. This means for many of us who have not had the stabilator horn inspected yet, that we must get it inspected within 100 hours of the effective date. If you have already had the stabilator horn inspected IAW SB1189 prior to the effective date of the AD, you may wait until the later of the 3 timeframes. Note that it must have be inspected IAW SB1189 to use either the 1000 hours TIS or 10 years.

Thereafter, the interval is 500 hours TIS or 5 years, whichever occurs first, every time a horn is reused. Every time a new horn is installed the interval is 1000 hours TIS or 10 years, whichever occurs first.

It makes sense if you think about it. You always get 1000 hours TIS or 10 years for a new installation. You always get 500 hours TIS or 5 years if the stabilator horn is reused. These apply even if you accomplished the inspection before the AD.

If you have not inspected or replaced your stabilator horn within the appropriate timeframe, the AD is giving you 100 hours to accomplished the inspection/reinstallation/replacement.

Michael

[Zach Grant L1011jock]

Michael,
You said :If you have already had the stabilator horn inspected IAW SB1189 prior to the effective date of the AD, you may wait until the later of the 3 timeframes. Note that it must have be inspected IAW SB1189 to use either the 1000 hours TIS or 10 years.
I fail to follow that statement. First, if you comply with SB 1189, you are stuck with a repetitive inspection every 100 hrs if you did not replace with new, and it is not an installed used horn at that point, it is an inspected new horn and must comply with the repetitive inspection criteria of SB1189 or the AD as applicable. If you replaced with new IAW SB 1189, then you get 1000 hrs/10 years from date of install. The AD does not overturn SB 1189, it only adjusts the repetitive inspection interval and then makes the balance manadatory by incorporation. Now, as I said before, if you inspected your horn prior to the issuance of SB 1189, then you could not have inspected the horn by any means of approved data acceptable to the administrator, so in essence you would have removed a horn installed new (at manufacture or replacement), and replaced with a used horn with parts tracability, inspected and found free of cracks and corrosion (even if it was the same horn, but it is used at this point right?). HOWEVER once SB1189 came out, any inspection not done IAW the service bullitin is a grey area as to how it affects airworthiness according to the FAA, and should probably be considered as not having been done.

Additionally, on an initial inspection, you do not get the later of 3 timeframes, only the later of two timeframes. If you read the sentence and note where the comma is, you will see that the sets are 1000 hrs or 10 years, or 100 hrs TIS from effective date. The same wording and sentence structure exists for the 500hr/5 yr interval.

Bottom line folks. If you are worried about complying, work it from the most conservative angle and you will never get in trouble.

-Zach

[Hank Spellman]

Zach,

My horn was inspected before the AD came out using the eddy current process. My understanding is that eddy current is more sensitive than dye penetrant.
Dye penetrant is specifically mentioned in the testing procedure, while eddy current is not.

Would this count as an inspection under the SB and AD?

Hank
Henry A. Spellman

[Michael Bryant]

Zach,

I guess I have been able to communicate my thoughts clearly in this thread. Note I did not say comply with SB1189, merely inspect IAW SB1189. Since the AD does not describe the required inspections and the SB does, my thought was that the stabilator horn must be inspected IAW the procedures of SB1189 and thought "the procedures" part would be self evident.

The 3 timeframes comment was definitely unclear when I reread my post. As you said, only two of the 3 timeframes can apply to any aircraft and it is the later of the 2 applicable timeframes.

Thanks for catching that. I certainly am not trying to mislead anyone.

Michael

[Zach Grant L1011jock]

Hank,
No, you have not inspected the horn as per SB1189. If the horn was never removed from the tube, you will get to do so within 100 hrs TIS from Oct. 22, 2012 to comply with the AD. The other option would be to ask for an AMOC that would allow you to count the eddy current inspection. If that AMOC were approved, then based on that you will probably fall into the 5yr/500 hr whichever comes first category for reinspection, based on the date of the original inspection, but that information would be included in the AMOC document.

Michael,
No problem here. I just want to make sure everyone understands the issue, pitfalls, and remedies. Just for future reference, as far as the FAA is concerned, when you say IAW (in accordance with) you are stating that the whole document has been complied with. Using the much less legally weighted term "As Per" allows that a part, parts or the whole of the document were used as applicable. That is why I read it the way I did. This is an important distinction when making log and repair/maint. entries as well.

-Zach