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tbo-regulatory? recommendation? grace period?

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Da Vinci

Well-known member
Joined
Aug 11, 2005
Posts
85
can anyone quote law that it is illegal to fly past a tbo? i was real sure about it until the chief said -naw, that's a recommendation... now i think i know better but he's making me think twice. the plane is already about 100hrs over and their asking me to fly it for about a 120hr mission. i'm thinking if i accept and fly it, i'm illegal, unsafe and will the actually the company could prob sue me if something happened. basically i'd be responsible for ANYTHING!! is that right??? is there a 10% grace period on tbo's?? any grace period? thanks to whoever might know this answer. refusing the trip will prob equal "fired!"
 
The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service.

Try this.. :)

And if they say 'fired' to you, just call the FSDO and tell them what happened, then have a beer and look for another job :)
 
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i just read that for part 91 the tbo isn't regulatory. b/c our company operates under 91...i guess no rules apply. sucks
 
That depends on the aircraft. If the manufacturer provides no leeway and considers it mandatory, under Part 91, you're in a very "grey" area. If the aircraft isn't in compliance with approved documentation, it isn't legal or airworthy, any other regulation or approved data notwithstanding.

You haven't provided enough information to answer your question, nor any details regarding your operation.

Consider what your insurance company might say.

TBO becomes a required component time under Part 121 and 135.
 
Da Vinci said:
i just read that for part 91 the tbo isn't regulatory. b/c our company operates under 91...i guess no rules apply. sucks
I don't understand. Why "sucks?"
 
I believe he means that he feels that without a regulation to fall back on, he must do whatever his employer tells him to do. Even if he disagrees.

He apparently does not realize that each of us has the right not to be pressured into hurting or killing ourselves.

Or breaking a regulation.

Or merely doing something we don't wish to do.

This much I do know. If you feel strongly about something in this business and then bend on it, it's over for you. You'll do it again, and others will expect you to do it again. Set your minimums and limits, and live by them as though your life depends upon them.

It does.
 
Da Vinci said:
i just read that for part 91 the tbo isn't regulatory. b/c our company operates under 91...i guess no rules apply. sucks

There two kinds of wear you are concerned with:

1) Gradual wear that dilutes performance over time and is easily measureable (compression tests, etc).

2) Fatigue cycles that can lead to catastrophic failure of critical parts (not easily measureable without disassembly and expensive tests)

Annuals and 100 hours keep track of #1, but the risk of #2 increases gradually with engine life. It exists for a brand new engine, but the risk is lower than a high-time unit. TBO is an arbitrary number where somebody decided that statistically speaking the risk level had reached a certain point.

The flight schools I worked at generally replaced the engines at TBO, but were not legally required to do so (insurance I think). Your comfort on exceeding TBO should depend on your knowledge of the engines mx history and how it has been used. Flight training is hard on engines what with shock cooling and idle/full power cycles in the pattern, and slow flight overheating. A cross-country cruiser that only did pancake runs on Sunday might be another story. My personal comfort zone for a low-stress engine would probably be TBO + 20%, and I suspect that such an engine would be safer than a beater that was 20% under TBO. You have to decide for yourself...

There is no massive sudden increase in risk at the moment you exceed TBO.
 
There was a recent discussion about a judges ruling that appeared to make all SBs mandatory (including observance of mfg TBO) even for pt 91 but an interpretation handed down by, I believe it was a D.C. FAA-lawyer, that countered that idea..... and the SBs are not mandatory for Pt 91 according to this.

"The issue was raised by the NTSB's ruling in the case of Administrator v. Law, in which a mechanic was accused of performing unairworthy repairs. In essence, the FAA claimed the mechanic used procedures not approved by the administrator.
But the NTSB took it a step farther, saying that "by not using the manufacturer's prescribed inspection technique, [the] respondent violated the regulations...."
 
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