Cessna SIDs for 400 series

[indefinitehold]

Anyone operating any Cessna 400s under FAA FAR Part 135?

Anyone complying with the SIDs?

Anyone being forced to comply by the feds?

Anyone complying FAA FAR Part 91?

Cessna states that the SIDs are a suplement to the MX manual, and shall comply with Chapt 4 time limitations of the MX manual.

My FSDO is wishy- washy about them and have allowed us to only comply the higher due interval- hourly or calander as stated in our AAIP. This has given us great flexability. However it conflicts with the MX manual. The MX manual states either hourly or calender, which ever occurs first. The feds say that SIDs are not required, thier example compairs them to service bulletins which is not required by regulations. I have seen some aircraft that include SBs into the 100-hour inspection. This makes it required by the Manufacturor's Inspection form/MX manual.

But going back to the MX manual which now includes the SIDs as per Cessna, is obviously in conflict. Our AAIP states that the most current manufacturor's approved inspection form/criteria shall be used. The AAIP is also in conflict with the manufactor's inspection criteria.

The old round Robin.

Whats your take?

Keep in mind I am not complaining to our feds. We are very happy as is. Just curious if any one else is dealing with this SID stuff. Lets hear it for Cessna taking the initative by being the only manufacturor leading the way in the aging aircraft issue.

 

[avbug]

This is an involved subject. For a long time, general wisdom (and the viewpoint of the FAA) has been that whereas a service bulletin is not part of the approved maintenance document, and has not been attached by an airworthiness directive, then it is not mandatory. A manufacturer obtains approval for a maintenance publication, but then attempts to add requirements under the weight of FAA mandatory requirement by use of service bulletins after the fact. This is generally held to be of ill effect. If manufacturers consider these things mandatory, sometimes they issue "emergency service bulletins," or "mandatory service bulletins," to add a sense of urgency. Manufacturers may also (and frequently do) petition the FAA to incorporate these bulletins in an AD, adding the full weight of regulation to the requirement. Traditional wisdom has held that the service bulletin doesn't become mandatory until it's incorporated in the AD, or the maintenance publications have been amended to reflect the change, with an appoved ammendment.

In 2006, the NTSB revisited this issue, and it's become more complex. The following link will discuss it in general terms. The short answer is "it depends."

http://www.amtonline.com/publication/article.jsp?pubId=1&id=2522

From that link:

The board concluded that the Lycoming overhaul manual incorporates all future service instructions by reference. The board referenced the Lycoming overhaul manual where it says “In addition to this manual and subsequent revisions, additional overhaul and repair information is published in the form of service bulletins and service instructions. The information contained in these service bulletins and service instructions is an integral part of, and is to be used in conjunction with, the information contained in this overhaul manual.”

Most owners, and many mechanics, repair stations, and shops, consider service bulletins (and all their named forms...they're called different things by different manufacturers) to not be mandatory until incorporated into an AD. I tend to take the conservative approach; I want to see the SB's complied with. In addition to enhancing the value of the aircraft, it has the effect of reducing civil liability. You can easily imagine a case in which an act is called out by a SB but not an AD, and is therefore not in compliance...in the ensuring law suit resulting from an injury or accident, that noncompliance, while not mandatory by regulation, could easily be held against an owner/operator by a sympathetic jury of non pilots and non mechanics...who couldn't care less about FAA regulation.

I believe in complying with the SB's. It's very hard to argue under pressure that while the manufacturer of the aircraft said it's necessary to do something, you elected not to do so...it puts the full burden of the decision squarely on you, and that's the kind of heat you don't want, especially if things are turning against you all around in the wake of an aircraft accident or incident.

A letter of interpretation on the topic, issued by the Manager of the Aircraft Maintenance Division, FAA addresses the issue. It doesn't carry the same weight as one issued by the FAA Chief or Regional Legal Counsel, but does shed some light...as well as add to the confusion to some degree owing to the FAA's position against Law (cited in the link above), as well as the NTSB affirmation that the manufacturer may indeed attach future unapproved documents by a statement in an approved document.

http://www.aopa.org/whatsnew/newsitems/2006/060614sb-letter.pdf

 

[indefinitehold]

I am going to start calling you Doctor avbug. The man with the info. Thanks man.

 

[avbug]

I'll settle for "Your Airworthiness."

 

[indefinitehold]

"were not worthy"
"were not worthy"

Ha, ok your Airworthiness.