Feds Strike Again....

[Zach Grant L1011jock]

All,
If you do not have the AMOC letter attached to your perminent records allowing you to use Piper SL 782B as compliance data for complying with AD 77-13-21para. A,C (1000 hr gear inspection), then you are in violation because there is no way that your AD was done as 782B is un approved data according to the AD (AD requires use of only SL 782A for compliance, and does not have the clause "or latest revision to series" so no other document is allowed to be used). Shops and A&P/IA's, if you have a copy of the old Piper SL 782A as required to comply with the AD, then YOU are in violation as it is unapproved data and any reference to it is to a non document as SL 782B superseeds and voids all previous documents in the series, and oh yeah is you dont have the AMOC document and you sign off the AD using 782B, then you are also in violation!

The reason I bring this up again is that this has been reported again, that a shop was cited and fined, and several aircraft were grounded due to this situation. The only aircraft that did not have to redo the 1000 gear inspection was one with the AMOC in its records, and the owner knew enough to produce it thus satisfying the FAA inspectors. So for all you out there that don't have this document, here it is!

Zach

[Andres Darvasi]

Thank you very much for sharing Zack, please enlighten me, do we need to apply for a letter for each particular aircraft of this letter should satisfy any aircraft?

[Zach Grant L1011jock]

This letter is supplied to Piper aircraft by the ACO and as is instructed in the last line of the letter, should be distributed with SL782B ( so to answer your question it is not aircraft specific, it is specific to a Service Letter, essentially amending the service letter to be equivalent to SL 782A, and thus in compliance with satisfying the AD). Well it hasnt been and most people don't know it exists until it is too late. This is a first rate case of letter of the law trumping common sense or intent...
-Zach

[Andres Darvasi]

Thank you Zach

[Kristin Winter]

In my considered opinion, the FAA is wrong in trying to make a bust for using SL 782A to accomplish AD 77-13-21, para A. The AD is approved data, which means SL 782A remains approved by incorporation. I could defend that one. Better however to use SL 782B and expressly reference the AMOC by date and author in the logbook entry. Of course, a copy of the AMOC should be provided to the owner because it is part of the AMOC. However, whether the owner is required to keep it is another matter.

[Zach Grant L1011jock]

Kristin,
What got this particular shop was the fact that they had a copy of 782A and 782 B in their docs library. The feds took a look at the first line of 782B and issued a finding based on having unapproved data on the reference shelf (this is a CRS and the CRS manual specifically states thou shalt use the latest and or current revision etc...). So then the shop went back to the last few airplanes that they did, and reissued the logbook signoff to comply with the Feds findings citing 782B. They then responded to the Feds as to their action to resolve the finding. The Feds responded by grounding the aircraft associated with the AD as now non compliant...well you get the picture....As for the owner keeping a copy with the perminent records, it is up to the owner/operator to ensure (and prove) airworthiness, not the maint. facility. With idiots out there like this saving us from old paper, I would for sure want to have it in my records when there was a compliance request from the Feds.

BTW, the ramp checks are getting more difficult due to the latest FAA guidence. Be prepared to not only produce licence, medical, airworthiness and registration, but also Flight manual with suppliments, and expect a request for submission within 7 days of copies of your logs to include all AD compliance, last 100hr/annual, ELT check, and IFR/VFR static/txp chack as applicable.

Zach

[Kristin Winter]

It is getting so that you practically have to be an attorney to be in IA. There are a couple of shops that have me on speed dial for dealing with stupidity. I am hoping that sequestration keeps the FAA inspectors chained to their offices. Since they moved most of the FSDO's off the field, that will keep them off any airport.

[Charles Schefer]

Thanks Zach. My last 1000hr gear AD was in compliance with 782B. I printed the letter you attached and put in in my maint records. I agree with Kristen's comment on the complexity...

Thanks again,

- Charles

[Michael Rath]

I'm not an A&P so I am having a little trouble trying to follow this. I just looked in my logs and my 1000 gear AD was completed in 1997. My logs reference " inspected dimensions IAW SL 782A". Obviously, at some point 782A was the approved data right? Do I need to do anything?

MR

[Charles Schefer]

[Zach Grant L1011jock]

Michael,
You do not have an issue. Your AD was signed off appropriately as that is the document that is called for in the AD. The issue has come about that that document SL 782A has been superceeded by SL 782B, and the AD still calls for compliance via 782A. From an owners standpoint, if your AD was signed off as complied IAW SL 782A you are fine (the feds might have an issue with your mechanic at this point as they did with the aformentioned shop, but you are good to go). If you had the AD signed off as per SL782B, then you need the AMOC paper to properly comply with the AD.

-Zach

[N3322G]

Zach,

Thanks for the continuing education

[bernard nowlen]

Point of interest. SL 782B was published a few months after SL 782A in 1977. Any sign off using 782b after the published date of SL 782A is not correct becasue SL 782A is no longer valid and SL 782B isn't referenced in the AD. The AMOC is the only way to go if you are concerned with those here to help(FAA).
All the FAA had to do was revise the AD to incorperate the latter SL 782B. Piper voided SL 782A and all other SL's of the 782 varity as stated on the header page of SL 782B so there is no other option.
bernie

[Zach Grant L1011jock]

...except as Kristin noted, it is valid for the AD by incorporation, it's just not a valid document to reference in a shop or by a mechanic...go figure... BTW, the ONLY difference in the documents is the inspection interval is changed from 500 to 1000 hrs to agree with the AD, the actual inspection remains unchanged!