Turnbuckle Safety Wire Guage

[CBogle]

Dear fellow members:

The A&I performing his first annual on my 1948 170 says that the standard for single wrap turnbuckles is .040 guage safety wire and since all of mine are wired with .032 guage he wants to note this in the log books as a "discrepancy."

This 48 was meticulously re-built by a very reputable shop that is known for first rate classic re-building and has been through 9 annuals with several different, but very reputable and competent shops, none of which had any concern regarding the guage of the wire used for the turnbuckles.

I know that it is possible that all 9 could be wrong and this current A&I correct, but any assistance and opinions that you can give me on this would be greatly appreciated as I don't like the idea of this being written up as a problem in my books.

Sincerely,

Curt

[Tom Downey]

Read AC 43.13,1B chapter 7 section 10.

I can't believe that 9 A&P-IAs missed the saftey ties on all of your turn buckles.

Figure 7-8 is the guide you are looking for.

Your IA is correct.

[GAHorn]

But, ...Curt! Don't let him write up discrepancies in your aircraft logs! Have him write them up on seperate paper, and give you a copy. There is no reason to write up discrepancies in the aircraft logs (and no provision in the regs for an inspector to do so.)
IN the case of an annual that is not satisfactory, the correct entry should be: "Aircraft/Engine (whichever) inspected in accordance with Annual/Periodic/(whatever) INspection Forms, (yadda-yadda-yadda). A list of discrepancies was provided the owner." or words to that effect, ... END OF ENTRY!! (if no other work was performed, i.e., no discrepancies repaired.)

ON the other hand, .....if discrepancies are worked/repaired....then that repair work should be detailed. When all the discrepancies are repaired, THEN the annual may be signed off,...or another annual performed.

Do not fear that an inspector is going to write some detailed report on your aircraft's shortcomings. He is not authorized to do that, and he should not be allowed to do that.

[Tom Downey]

There is no method of tracking the discrepancies discovered during an annual, I can inspect your aircraft and hand you a list of discrepancies, and enter that in the logs as you discribe, you can then throw that list away and have your mechanic replace/repair a xxxx, any thing you want, and return the aircraft to service as airworthy.

Leaving me on the hook for 12 months. with discrepancies not repaired.

The FAA has adopted the method of entering these discrepancies in the log.
WE as IAs get this direction from FSDO. This is how they want it done, specially if we are signing it off as UNAIRWORTHY.

I feel there is no problem entering these discrepancies in the log, leaving room for a return to service entry, between each.

You had a discrepancy, it needs to be logged and repaired.

[Tom Downey]

The proper entry would be :

I certify that this aircraft Nxxxx has been inspected IAW the (aircraft maintenance manual) and FAR 43 D and found to be in an unairworthy condition due to the following conditions.

1. discrepancy

4 or 5 lines

2. discrepancy

4 or 5 lines

3 bla bla

Some one must repair and return to service on each discrepancy.

I'm off the hook.

[Tom Downey]

The other way:

15 discrepancies signed off in the logs, and then:

I certify that this aircraft has been inspected IAW the (aircraft maintenance manual) and FAR 43 D and found to be in an airworthy condition.

AD 87-20-03 R2 complied with at XXX.X tach hours

Plus the Engine, and Equipement re occuring ADs in the same format.

Plus the ELT requirement under 91.207

If you do not have that entered in the airframe log book, you are not legal.

There is no such thing as an annual on a engine. When installed on an airframe the engine is a system inspected as part of the aircraft. The engine log does not require a separate inspection, see FAR 43,D

[CBogle]

I spoke with the I/A who restored and rebuilt the aircraft and he said that he has been restoring aircraft for over 40 years and ALWAYS double wraps turnbuckles using .032 as he prefers that over .040 single wrap. He said there is no chance that he only single wrapped these.

HOWEVER, he did say that on the smaller turnbuckles, for trim tabs, etc. he often single wraps where the force isn't great enough to require double wrap.

Any thoughts?

Thanks,

Curt

[CBogle]

I spoke to another I/A who used to be a field inspector for the FAA and he said that AC 43.13, 1B is a service advisory, not a regulation. Therefore, he said that unless the I/A can point to a regulation that shows that double wrapping is required, it is not required.

In his opinion, he said that he is not aware of any regulation that requires double wrapping and therefore, the I/A "may not" withhold approval unless he can point to a regulation that is being violated.

There seems to be no simple answer here!

Regards,

Curt

[GAHorn]

There is no method of tracking the discrepancies discovered during an annual, I can inspect your aircraft and hand you a list of discrepancies, and enter that in the logs as you discribe, you can then throw that list away and have your mechanic replace/repair a xxxx, any thing you want, and return the aircraft to service as airworthy.

Leaving me on the hook for 12 months. with discrepancies not repaired.

The FAA has adopted the method of entering these discrepancies in the log.
WE as IAs get this direction from FSDO. This is how they want it done, specially if we are signing it off as UNAIRWORTHY.

I feel there is no problem entering these discrepancies in the log, leaving room for a return to service entry, between each.

You had a discrepancy, it needs to be logged and repaired.

I don't agree, Tom. Firstly, You are not "on the hook" since you never signed the logs authrizing the aircraft's "return to service". You merely inspected, found discrepancies, and did NOT approve it for return to service. (In fact, I believe you'd be even more exposed should you actually write that list into the permanent aircraft logs. What if you'd missed something? What if then, those discrepancies you'd written (but which were incomplete) were signed off and the aircraft returned to service by someone else based solely on that permanent logbook entry?)
The FARS provide the exact wording approved for an unsatisfactory inspection. See: FAR 43.11(5) "...if the aircraft is not approved for return to service because of needed maintenance, ... the following or similarly worded statement (should be placed in the aircraft records)...I certify that this aircraft has been inspected...and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator." (end of rule) NO PROVISION/AUTHORIZATION exists to write those items in the aircraft mx logs.
In addition, the exact listing of discrepancies is specified to be in a seperate list...NO AUTHORIZATION to log them in the aircraft logs is given. See FAR 43.11 (7)(b). "If the person performing any inspection required by Part 91....finds that the aircraft is unairworthy....that person must give the owner or lessee a signed and dated list of those discrepancies."
Secondly, any subsequent inspector would be assuming any/all liability should he/she authorize return to service....not you.

While not a mx item, I'll never get over my self-embarrassment from a logbook entry I once made in a flight student's log. He had come to me for an aircraft checkout, and he was not up to par. I wrote in his logbook that his performance was "unsatisfactory,...not competent to fly this aircraft." I hate the fact that the person will go thru their entire life with that entry made over my signature. (What I should have stated was "observed in Cessna 182 series aircraft" and simply not authorized the flight school to rent to him until he'd rec'd further instruction.)
While as purchasers we'd all like to know every thing that ever happened to a potential purchase....as owners we'd like to make certain that unairworthy items (since they are temporary) are not made a permanent record...since such items are made airworthy...before the machine is returned to service anyway. That repair should be logged of course. A logbook is a record of airworthiness and maintenance and repair...not a record of un-airworthiness.

[zero.one.victor]

Logbooks can be interesting reading...... my airframe logbook has a Nov 3,1966 entry for an annual inspection: "...determined to be in an airworthy condition." There is an entry dated 5 days later: ".... determined to be in an UNAIRWORTHY condition." Followed a month and a half later by an entry "...airworthy for ferry flight...." with limitations noted, which included cabin heat safetied off, mix safetied rich,flaps safetied off,engine primer line disconeected, & windows taped shut. Whew! Two months later (feb 67) there's an entry for another annual including some maintenance work, signed off as airworthy by the same guy who originally signed it off November.
No mention of any major repair work. Engine logbook shows simialr entries, but more (deferred) maintenance work done--replacing scat hoses, etc. Seems like if the airplane was unairworthy, it would have been a better deal all around to just fix the stuff that needed fixing, then sign it off, instead of making the unairworthy entries. Sounds like maybe the owner wouldn't pony up the money for work done, so the logbooks were held hostage? I've heard of that kind of thing happening. In fact, I know of an airplane whose logbooks disappeared ( "tonight you sleep with the fishes....") due to money allegedly owed by the owner to someone for a deal on another airplane. Sure complicated things later when it was for sale, especially as it (a Champ) had a clipped wing/O-200 mod done to it--with (now) no paperwork.
Moral of the story-- pay your mechanic, OR, keep one hand on your logbooks!

Eric

[Tom Downey]

Let me see if I can respond to several questions / statements in the same message with out getting every one confused.

First GA.

FAR 43.11

(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with Part 91, 123, 125, 135.411(a)(1), or 135.419

SHALL !!!!

make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

A&Ps are required by FAR to make an entry, the FAA at my last IA renewal seminar stated the method they wanted us IAs to do the UNAIRWORTHY list of discrepancies.

That was the method I discribed in my earlier post. Like it or not, the LAWYERs are working at the FAA HQ. It would not suprise me if the wording on this subject changes soon. William O'Brien gave this song and dance to over 45,000 A&P-IAs last year, I would expect to see some one besides me using it.

THE AC 43.13,1B

It is an "Advisory Circular", as the tile suggests, it is advisory in nature, and does not carry the weight of a FAR. What this AC does, is give us acceptable data that can be used to request an approval on the 337 form block 8, for major repairs/alterations,
AND
inspection criteria for inspecting the older aircraft that do not have specific manuals. such as the C-170

If you have any questions about that, read the fly leaf of the AC "Purpose"

When the FAA (William O'Brien) spends 2 years getting the AC re-written, giving us mechanics guidance in the methods that the FAA feels are acceptable why in the world would any one want to say that is not the way to do something like wire a buckle?

IF I ever must stand up in court and tell the judge, I'll point to this AC and say I did it as the FAA suggested.

If your IAs are smart enough to see the difference between the single wrap and a double wrap safety in figure 7-24. I would think they would read the next column over in figure 7-8 and see there is NO wire suggested for ANY buckle smaller than .040"

His IA is correct, and he should write it up in the logbook if he wants to stay an IA.

[GAHorn]

Let me see if I can respond to several questions / statements in the same message with out getting every one confused.

First GA.

FAR 43.11

(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with Part 91, 123, 125, 135.411(a)(1), or 135.419

SHALL !!!!

make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

A&Ps are required by FAR to make an entry, the FAA at my last IA renewal seminar stated the method they wanted us IAs to do the UNAIRWORTHY list of discrepancies.

That was the method I discribed in my earlier post. Like it or not, the LAWYERs are working at the FAA HQ. It would not suprise me if the wording on this subject changes soon. William O'Brien gave this song and dance to over 45,000 A&P-IAs last year, I would expect to see some one besides me using it.

I don't disagree with the FAR 43.11 in items 1,2,and 3 as you posted it, Tom...but... The REST OF THE STORY (as Paul Harvey would say) is contained in items 4, 5, 6, and 7(b). In EACH of those items the person performing the inspection is specifically instructed to provide a "list of discrepancies" to the owner/operator. No provision is made to write them in the aircraft permanent records. (See FAR 43.11 (4)(5)(6)(7)

If the FAA wants those discrepancies written into the aircraft logs...then let them re-write the FAR's to reflect that. Inspectors have a penchant for interpretation of FAR's in order to satisfy their own idea of bureacracy, but if they don't have the support of the FAR....then they don't have the authority to require such actions. IMHO