2 Q's

[iowa]

good eve
1st a dumb question,
what is the thing called that sends out a continuous signal
in the back of the plane is case s.o. needs to find you?

and 2nd
is this s.t. that an owner can replace himself?
is there a list on this forum
that details maintenance that a pilot can
do himself?

thanks
dave

[Bruce Fenstermacher]

Dave I'm guessing your are referring to the ELT (Emergency Locator Transmitter.)

The ELT may be located in the back or your aircraft but can be located almost anywhere.

If you are talking about the ELT lots of people think you can change the batteries, lots of people don't agree and say no you can't. In either case I don't believe an owner pilot is qualified under the FARs to perform the test required of the ELT after the battery is replaced.

The list of maintenance items the owner pilot can perform is found in the FARs. 43.13 Appendix A. paragraph (c)

Here is the list current as of 10/8/06

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:
(1) Removal, installation, and repair of landing gear tires.
(2) Replacing elastic shock absorber cords on landing gear.
(3) Servicing landing gear shock struts by adding oil, air, or both.
(4) Servicing landing gear wheel bearings, such as cleaning and greasing.
(5) Replacing defective safety wiring or cotter keys.
(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.
(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.
(8 ) Replenishing hydraulic fluid in the hydraulic reservoir.
(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.
(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.
(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.
(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.
(14) Replacing safety belts.
(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.
(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.
(17) Replacing bulbs, reflectors, and lenses of position and landing lights.
(18 ) Replacing wheels and skis where no weight and balance computation is involved.
(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.
(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.
(21) Replacing any hose connection except hydraulic connections.
(22) Replacing prefabricated fuel lines.
(23) Cleaning or replacing fuel and oil strainers or filter elements.
(24) Replacing and servicing batteries.
(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.
(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.
(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.
(28 ) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.
(29) Removing, checking, and replacing magnetic chip detectors.
(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:
(i) They are performed by the holder of at least a private pilot certificate issued under part 61 who is the registered owner (including co-owners) of the affected aircraft and who holds a certificate of competency for the affected aircraft (1) issued by a school approved under Sec. 147.21(e) of this chapter; (2) issued by the holder of the production certificate for that primary category aircraft that has a special training program approved under Sec. 21.24 of this subchapter; or (3) issued by another entity that has a course approved by the Administrator; and
(ii) The inspections and maintenance tasks are performed in accordance with instructions contained by the special inspection and preventive maintenance program approved as part of the aircraft's type design or supplemental type design.
(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be
designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.
(32) Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)) provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91 of this chapter.

[jrenwick]

Replacement of ELT batteries by the owner/operator is one of the things AC 91-44A addresses. You can find the document here: http://www.airweb.faa.gov/Regulatory_an ... enDocument

It says:

...The replacement can be done by the pilot if the preventive maintenance limitations of Part 43.3(h) of the FAR, are complied with. For example, a portable type ELT that is readily accessible and can be removed and reinstalled in the aircraft by a simple operation should be considered preventive maintenance. Fixed type ELT installations are often permanently mounted in a remote area of the aircraft near flight control cables, vital aircraft components and critical attachments to the aircraft structure. Installations of this nature require an external antenna and often a remote on/off transmitter control switch that is usually located near the pilot's flight position. This type installation is complex and battery replacement should be accomplished by a certificated mechanic or certificated repair station....

I don't know if this really sheds any light on the question or not! I do my own battery replacements (and log them) because all of my ELTs can be removed from the aircraft without disassembly of any structure, or the use of any tools, in fact. I think this AC is saying that FAR part 43 gives me the authority to do that.

Best Regards,

John

[GAHorn]

Be advised that most FSDO's do not interpret that rule similarly. The "battery" referred to in Appdx A is the aircraft battery...not the ELT battery.
Also be aware of the requirements of FAR 91.207(d), which require testing* of the ELT and it's antenna in accordance with the ELT mfr's Instructions for Continued Airworthiness. (Although this can be a simple procedure, it is NOT a preventive maintenance action.)

* An ELT can usually be tested by removing it, and subjecting it to a forward movement and brought to an abrupt stop in order to test it's G-switch. The technique is similar to the action used as if to throw a football, yet abruptly stop the throw. The G-switch should activate.
The antenna can be tested after the ELT is re-installed and reconnected to it's antenna. Using any portable radio (capable of receiving regular AM broadcasts) tuned to any commercial AM frequency OTHER than 121.5/243 mHz, with the ELT activated the portable radio should be capable of receiving the sweeping signals of the ELT when whithin 6 inches of the ELT antenna, but should NOT produce the signal when more than 24 inches away from the antenna. This confirms the continuity of the antenna circuit of the ELT.

Additionally, the ELT batteries should be replaced EACH YEAR. The fact that your ELT happens to use Duracells, and the Duracells installed are dated AUG 2012 does NOT mean they are good until that date in an ELT. Their installed date should be recorded, and their replacement date must occur before the end of the twelfth month from that installed date. (Use them in your flashlights, etc. after a year of installation as an ELT battery/power source is used up.)

Again... ELT Maintenance/Testing does NOT meet the rule for Preventive Maintenance of FAR 43 Appdx A according to most FSDO inspectors. This action must be undertaken by a properly certificated repairman (A&P or Avionics CRS.)

[dacker]

George, I don't see where you read that the battery needs to be replaced yearly. My battery has a specific manufacturer supplied date for the ELT battery, and I don't mean a "best if used by" date. It is a two year date if memory serves me. Part 91.207 addresses using the 50% useful life rule as established by the transmitter manufacturer. You are reading to much into this rule if you are taking the replacement date and only using 50%, that date is the replacement date pure and simple.
I have an e-mail into the Houston FSDO asking how they interpret AC 91-44A. It will be interesting to see their spin.
David

[iowa]

interesting reading gentlemen!
i'll look and see where mine is located.
dave

[Bruce Fenstermacher]

See what I mean. Some think you can some think you can't. Wonder if the "think you cans" also use MMO.

[mit]

George:

The ACK manual says.

The Battery replactment date is found on each Duracell MN 1300 cell. (shows picture of battery) It reads as follows; BEST IF USED BY (DATE). The Date indcated is the date by which the batteries must be replaced. ALL CELLS MUST HAVE THE SAME DATE.

RCPI, lithium battery every eight years, alkaline four years.

Tim

[swanstedt]

All interested in proper maintenance, testing, etc. of their ELTs per FAA...please refer to Advisory Circular 91-44A.

http://www.airweb.faa.gov/Regulatory_an ... enDocument

If this link doesn't work (kind of long) do a Google search on "Advisory Circular 91-44A" and it will come up with the proper page.

As far as battery replacement, see page 6. A pilot can replace the batteries in certain instances dependent on the installation. Read circular for more detail.

Scott

[mit]

Well thats the second time its been linked. how many more

It also says to follow the manufactures instructions....

[swanstedt]

Ya...guess I should read the prior discussion a little closer before relinking to the AC. I found the Advisory Circular through other channels and with all the "yes-you-can / no-you-cannot", "must change out by A&P every year / pilot can change at expiration date" discussions I didn't realize it had been linked. Must have been a few others that didn't follow the original link other than me .

From reading the AC it is apparent, at least to me, that in most our cases as long as the unit is accessible without touching the untouchables then just replace the batteries at or before the expiration date, do a transmission check to verify it has power, log it in the airframe book and carry on with life. A simple transmission check (performed during the first 5 minutes of the hour) was tought to me as being a pilot function during my ground schooling over 20-years ago. If it isn't, then why would an ELT check switch be installed on the panel? The functionality aspects associated with the battery change relates to the question of 'is there power?' which the transmission check verifies. The inertia switch check would be performed at annual anyway and its function should not be effected by changing the batteries. I wouldn't have any problem referencing this circular if questioned by the FAA on what basis I changed and logged the batteries for my ELT. If they are scaping that low in the barrel to make up a violation then they are going to come up with something else anyway...might as well be something I can defend based on FAA's own advice .

Scott

[Bruce Fenstermacher]

Well thats the second time its been linked. how many more

Three times is the charm for many of us.

[GAHorn]

Like some of you, I also once thought the position taken by some FSDO inspectors to be "extreme". I came to understand their interpretation better after several conversations with several different inspectors. Here's some of the different angles:
1. The mfr of the ELT does not bear responsibility, and does not have authority to issue approval of who may access/service the ELT in any given installation. While their literature may promote their product as being so simple, durable, trustworthy (whatever) that owners may perform such tasks, .... they do not have the authority and do not bear the responsibility of determining who may work on an installed ELT. (According to the FARs, an aircraft owner bears the responsibilty of the aircraft's airworthiness.... but he isn't automatically authorized to do the actual work, is he?)
2. A battery once installed, even one having a "best if used by" date, does not have incorporated any method of accurately determining the remaining useful life of that battery. Once that battery is removed from it's mfr's packaging will begin a process of deterioration. In fact, in some arid areas of the country, even fresh batteries with expected lifetime of years, may not meet the 50% rule after a few months of installation in an aircraft's fuselage.
3. Unless the testing facilities are available to test a battery for remaining useful life and determining that the battery meets the 50% rule, ... then any installed battery is suspect. A simple volt-meter does not correctly test a battery. Batteries must be subjected to a load to determine their capacity, and the placement of that load actually detracts from that battery's capacity. Therefore the only way to determine that a battery meets the design voltage and capacity of it's design is if it is fresh. Fresh does not mean that it has not yet reached the date stamped on the battery. It means the battery is still in it's original mfr's packaging and has never been installed. It also means that if intended for installation, that it has not passed it's date...at the time of it's installation. Nor does it guarantee that the installation it's being subjected to will allow that battery to reach it's stated date with it's design capacity.
4. Any service personel who inspects an ELT for the annual requirements of 91.207 must be capable of determining the installed batteries are not expired, AND have at least 50% useful life remaining. Unless a radio-log has been kept, and unless the battery-testing equipment is available to make that determination, then the batteries must be replaced in order to comply with the rule.

Finally: The opinions expressed in the earlier thread were those passed on to me by FSDO Inspectors whom I trust and respect. The Duracell batteries we are talking about here are cheap. Are you telling me that we are now going to take issue over the very low replacement costs of flashlight batteries that we have to access and inspect annually anyway? Oh, Pull-eeze.

I believe that the ELT's installed in most aircraft that use the Duracell batteries are remotely mounted*. (The rule covering remote mounted ELT's would also likely require the antennas be installed in the same bay as the ELT.) Per the Advisory Circular AC 91-44A, this is NOT a simple procedure to access, and the pilot of the aircraft may not perform the ELT inspections, battery replacements and testing required by the rule. It is not preventive maintenance. If so located/mounted, it may not be owner performed unless the owner happens to be a certficated repairman or is closely supervised by one who will make the required mx entry.
I also believe that there are a lot of remotely mounted ELT's that sit back there year after year, un-inspected, because someone, somewhere has written into the logs that the batteries are not due for replacement until next year/century. That is not a good reason to avoid removing your ELT and looking at the batteries and the battery box in that ELT for corrosion. I've found several ELTs with corroded battery boxes that happened to use the Duracells. Unless those were inspected on a regular basis those ELTs would have been destroyed by the Duracells that leaked well before their so-called expiry dates!

Sorry if this little matter upsets you. It's unlikely to be a major additional cost to your annual inspections. Get over it.


=================
Here's an additional consideration: Most remotely mounted ELT's have small cockpit activation switches/monitors available to the pilot. The most common of these involve a battery you may not have known about. Unless that small monitor battery is also fresh and within it's date, it may not control your ELT correctly and you may not be able to activate your ELT remotely. It should also be inspected/replaced at the same time as your ELT batteries. (The type usually employed is a PX28L, and I've found them at Radio Shacks. They're a pain to replace because the monitor requires removal from the instrument panel.)


*If you are contemplating installing a new ELT, you might wish to consider the type that may be removed and taken with you should you abandon the aircraft. Some of those types can also be used along with a cockpit microphone to broadcast to search aircraft. This type ELT will only be useful if you can remove it quickly without having to access hidden compartments. (A sinking aircraft, or one on fire may not give you much time to take it with you.)

[swanstedt]

George,
Do your comments regarding annual battery replacement also pertain to proprietary, specialized, $50+ ELT batteries that have a 5-year life/replacement, or $40+ 2-year life/replacement batteries? I don't think anyone would have a problem of throwing in a new set of Duracells on annual...but not all ELTs take Duracells.

There are situations where replacing batteries between annuals may be in order. Such as when doing an inspection prior to a long trip in remote country and noticing that a Duracell battery change didn't occur/get recorded at last annual. If I used an A&P who's every signature carried a $50 minimum charge I would be inclined to just replace and not record if an A&P signature was required, better 100% safe and 99% legal than 100% legal and 99% safe. Since FAA appears (at least to me) to allow pilot replacement in particular installations then I don't have a problem recording it in the books following replacement in accessible installations.

ELT installation and battery type will be a definate consideration when updating to the new standards coming in 2009 with 406.025 MHz units.

[Bruce Fenstermacher]

George I must disagree with your points 3 and 4.

According to FAR 91.207 the manufacuterer determines when the battery will reach 50% of it's capacity while in storage. The battery is in storage from the time it's manufactured through the time it sits on the shelf and the time it sits in the ELT waiting for ELT activation. That date is the date marked on the battery.

We aren't talking Durocells here but the propriotary batteries I have in both my ELTs. These batteries can not be used after the replacement date regardless when I actually install them.
Some batteries I've bought I've been able to use for 23 months the last one I installed I'll get 25 months of usage.

This of course assuming the ELT never gets used in which case the battery would have to be replaced after 1 hour of accumulative use or the experation date which ever comes first.

There is no requirement by FAR 91.207 for anyone to inspect the battery for capacity annually.

Here are those parts of 91.207 with sections bolded by me:

(c) Batteries used in the emergency locator transmitters required by paragraphs (a) and (b) of this section must be replaced (or recharged, if the batteries are rechargeable)--
(1) When the transmitter has been in use for more than 1 cumulative hour; or
(2) When 50 percent of their useful life (or, for rechargeable batteries, 50 percent of their useful life of charge) has expired, as established by the transmitter manufacturer under its approval.
The new expiration date for replacing (or recharging) the battery must be legibly marked on the outside of the transmitter and entered in the aircraft maintenance record. Paragraph (c)(2) of this section does not apply to batteries (such as water-activated batteries) that are essentially unaffected during probable storage intervals.
(d) Each emergency locator transmitter required by paragraph (a) of this section must be inspected within 12 calendar months after the last inspection for--
(1) Proper installation;
(2) Battery corrosion;
(3) Operation of the controls and crash sensor; and
(4) The presence of a sufficient signal radiated from its antenna.
(e) Notwithstanding paragraph (a) of this section, a person may--
(1) Ferry a newly acquired airplane .....

While I don't have an ELT which uses common commercial batteries such as Durocells since 91.207 gives the ELT manufacturer the authority under other approvals to determine when in storage the battery for their ELT reaches 50% of its capacity, the ELT manufacturer would specify any battery that can be used with their ELT and the relationship of the expertion date any date stamped on those batteries.