2 Q's

[GAHorn]

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.

Actually, there are quite a few people who seem to have a problem with replacing Duracells on an annual basis. I'm amazed but it's true. It's possible they don't know about the issue, or simply disagree, or ???? but... I just wanted folks to know what more than one FSDO Inspector says about it. (I simply put them in my household flashlights and use them in that capacity, and operate my ELT with new Duracells each year. Depending on where I buy the new Duracells, it's actually possible to install batteries in the ELT that have dates which imply they are "lesser" than the ones '"ve removed.)

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.

I understand your point Bruce, but it's contrary to what I've been told by the FSDO. For example, in the case of the ACK ELT E-01 already discussed, the ELT mfr's manual requires they be replaced upon reaching the date stamped on the battery.... BUT... that date does not guarantee that 50% of the Duracell battery's capacity is still valid. This implies that EITHER the date OR the 50% rule can limit the life of the battery. Duracell will not offer any guarantees their batteries will retain 50% capacity after installation. NOW what is the limit? (Unless the battery can be tested... once installed, it's shelf-life is no longer applicable. The date on the battery is a SHELF life...not an INSTALLED life.)

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.


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

Well, ... that's not exactly what they are saying. Unless para. (c) (2) can be verified, the annual inspection requirement of 91.207 establishes the chronological limit of installed batteries.

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.

According to my FSDO, the ELT mfr does not have authority to extend the shelf life of Duracells (different mfr's), and once installed, the clock begins. (Also once installed, if used more than 1 hour, or if less then 50% of their capacity remains (there's the question again)...they must be replaced, and unless they are tested (something we all have the capability to do, right? ) to determine/verify that capacity, they are to be replaced at the annual inspection of the ELT.)

Not saying I agree with them....just repeating what they explained to me.

(By the way, ACK also states under their "battery replacement' section, that "Section 7" dictates periodic maintenance. Section 7 stipulates that the date of batteries must be checked every 12 months, and replaced in accordance with Section 1 (which re-iterates the 50% rule.) Do your batteries have 50% capacity?

I personally hold an opinion in disagreement with the FSDO, but wanted to let everyone know what I've been told directly by their avionics inspector. Duracells are cheap enough to replace annually, and the old batteries do good work in my flashlights. I wish the ELT's were as reliable as common flashlights.

[Bruce Fenstermacher]

George sometimes I wish you where closer than Texas so I could just fly over to your place a duke it out with you in person, verbally of course.

Look at the FAR 91.207. Its says: (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. (This time I've bolded it AND italicized it.)

It is the ELT manufacturer who has tested batteries and determined the deterioration of the capacity of the battery and when it would be at 50% of its capacity. That is why the date sticker on the batteries say "DO NOT install after this date".

Look close at FAR 91.207. No where does it call for ANYONE other than the manufacturer to test for 50%. Why? You've already said it, you can't.

FAR 91.207 calls for an inspection of the following items every 12 months:
(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.

No where in these 4 inspection points does it call for ANYONE to test for 50% capacity because the manufacturer has already done that.

Think about it George. Since no one can actually test these batteries at anytime you could install new batteries and the next day me or a FSDO guy could ask how you know the battery has more than 50% of its rated capacity.

You couldn't answer the question and would be faced with replacing the new battery but wait does the new battery your going to use have the capacity. It would be a viscous cycle.

But fear not because you would say the ELT manufacturer has determined that given the age of the battery as determined by its date it will have 50% or more of it's rated capacity.

I suspect that in the case of the ELTs that can use Durocell batteries the manufacturer has proven to the FAA that you can't buy a Durcell that meets the requirements of the manufacturer that will have less than 50% capacity when the manufacturer calls for there replacement which might be every year in the case of Durocells, I don't know.

In any case I would be extremely comfortable arguing this point and the FAR with any FSDO inspector. Fortunately we don't have to around here but don't velcro a GPS antenna to your windshield cause that's a no no.

[mit]

George

If you want to change your durcells every year go for it. But they don't have to be. Your right they are cheap. I don't care how many FAA guys say they do. Its's right in the book. and I put down when the RCPI battery has to be changed. Its in the book.

[squaretail]

" Holly Cow batgirl looks like a cock fight is goin on"

[mit]

"and replaced in accordance with Section 1 (which re-iterates the 50% rule.) Do your batteries have 50% capacity?"


Just went and re- read sec 1 and I don't see 50% mentioned anywhere.

sec 7, recommends replacing on a yearly bases But it is NOT required.

Shelf life isn't mentioned anywhere.

Its says after 1 year they have over 95% of their original capacity.

5% per year would be 10 years and that isn't how long the date on the batteries.

[GAHorn]

...Look at the FAR 91.207. Its says: (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. (This time I've bolded it AND italicized it.)

It is the ELT manufacturer who has tested batteries and determined the deterioration of the capacity of the battery and when it would be at 50% of its capacity. That is why the date sticker on the batteries say "DO NOT install after this date". ...

That refers to the batteries which the manufacture produces (produced under their control) under their approval basis...so-called "proprietary" batteries. (Aftermarket batteries must undergo their own approval under the STC or PMA process. Duracells do neither.) It does not apply to Duracells (which are never tested by Duracell for ELT use, and which the ELT mfr has no control over the quality-control issues necessary to predict their installed capcity. (And Tim, the prediction of 95% by ACK is only their opinion, and is based upon non-use (which would require a radio log) and is not a prediciton utilizing controlled environment and therefore is not approved data. The installation data is the only portion of the ACK manual which is approved data.)

Like I said,... I considered the FSDO interpretation as "extreme" also, but decided it's too inexpensive to replace the Duracells and be done with it. (And three years in a row I've found Duracells to indicate corrosion after less than 12 months. )

[spiro]

come on Bruce and Tim, you know Geo is never wrong. Just glad I don't have his FSDO....

[Robert Eilers]

Out here in California ELTs are beginning to seem redundant. There has been so much building going on out here that if you wind up going down sowe where it will most likely be in the backyard of someone's brand new $800,000 house.

[bradbrady]

come on Bruce and Tim, you know Geo is never wrong. Just glad I don't have his FSDO....

Spiro,
Give George a break! My FSDO agree's with his! (and 10 extra bucks a year isn't going to kill you!) Then you have flashlight batterys to who hung the goat. Along with George I have found corrosion in the battery boxes of ack and and the likes, elt's when doing an inspection as per 14 CFR 91.207 (d) In less than a year! It is realy over kill, but to keep in complyance it's simple! Put them in every year and don't look back. I'm not even going to mention my distane for the need for elt's mounted to airframes anyway They should probably be personal!
brad

[Bill Hart]

Soooo......How about those Braves?

[iowa]

did i start all this?
iowa

[Bruce Fenstermacher]

did i start all this?
iowa

Trouble maker.

This is just a good healthy discussion. Just think a week ago we where just ordinary pilots. Now we are all experts on 91.207.

It would appear from George's last response he is only talking about ELTs with Durocells when we is calling for battery replacement yearly. Somewhere in the thread that was lost.

So here is where we stand I think. You must replace the ELT battery at the interval the manufacture has approval for. In the case of special design batteries with a do not use after date it is this date. In the case of Durocells according to George it's after one year installed. Of course in either case if there is 1 hour of accumulative use the battery(s) must be replaced.

Depending on what FSDO you live in you a pilot can to perform this task but everywhere an A&P can change the batteries and perform the test.

[Indopilot]

Duracells like FSDO's and inspectors have their uses. But they are all different and they all have the capacity to make a big mess wheather young or old.

[cessna170bdriver]

I think a pilot (non A&P/IA) is allowed change his own ELT Duracells once every seven years only if he also uses E-85 mogas mixed with MMO, uses PepBoys oil and a lawn mower battery, and can prove he installed the 8-track player and CB radio in the panel.

Miles

[Indopilot]

Miles, I always enjoy Blueldr's input and comments too.