Required replacement schedule?

[Steve Scates]

Can someone clarify something for me?  I have been lead to believe that as a Part 91 aircraft driver, TBOs and time life items do not apply to my Bonanza.  Instead, I am told by some, airworthiness of each compenent is the only requirement.  However, according to 91.403(c), "No person may operate an aircraft for which a manufacturers maintenance manual...has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals and related procedures specified in that section...have been complied with.  Of course the Bonanza does have manufacturers maintenance manual with an airworthiness limitations section, Chapter 5.  So, for instance, am I required to change the Nose Gear Retract Rod-Ends at 2,000 hours as called for in Chapter 5?

I know many A&Ps and AIs that believe that I am not bound by these limitations as a Part 91 Bonanza owner/operator.  Can someone clarify this for me and cite the supporting regulation.

Thanks!
Steve

[Scott Newpower]

You didn't quote the whole thing. That paragraph is specifically for part 121 and 135 ops, that's the for hire guys.

[Steve Scates]

Scott,

Thanks for your reply.  If you read paragraph (c) again, the part I left out only refers to Part 121 and 135 operations that may have an approved alternative program for maintenance items (such as the MORE program for the PT-6 engine series) and that whole section is prefaced with the word "or".  The way I interpret this is that is since as a Part 91 operator, I am not authorized to develop an alternative maintenance program, I must follow the manufacturer's maintenance manual.

Again, I have always believed that I didn't have to follow the time life requirements found in Chapter 5 of the maintenance manual, but I cannot find anything in the regs that support that so far.

Steve

[Tom Turner]

Hi, Steve:

First, because of frequent reports of landing gear collapses, many resulting from rod end failure, the ABS tehcnical staff recommends following manufacturer's guidance on landing gear parts inspection, overhaul and replacement.

The key to your question is that Chapter Five of the Hawker Beechcraft maintenance manuals are not labeled "airframe limitations".  Here is the precise wording from the Maintenance Manual:

Time Limits/Maintenance Checks
General 
Inspection/Check

1. Airworthiness Limitations Statement - Inspection/Check
There are no additional Airworthiness Limitations as defined in 14CFR 23, Appendix G, G23.4 for the Bonanza airplanes. The Airworthiness Limitations section is FAA approved and specifies maintenance required under Section 43.16 and Section 91.403 of the Federal Aviation Regulations unless an alternative program has been FAA Approved.

There is a similar note in the Manuals for other ABS-type airplanes.  Consequently, the time limits and maintenance checks of the Beech maintenance manuals are recommendations, but not airworthiness limitations. 

That said, I know from first-hand sources that the Beech manuals are currently being revised to make at least some of the now-recommended time limits into airworthiness limitations.  It is entirely within the manufacturer's authority to do this under Federal regulations.  ABS continues to be in touch with the FAA and Hawker Beechcraft about this, and will provide updates as news occurs.

[Steve Scates]

Tom,

Thanks!  The way you explain this makes perfect sense to me.  It is amazing to me how few of us (me included) don't know the "whys" of what we routinely do sometime.  I appreciate very much you taking the time to lay this out for me and all of the others who might have been confused by this issue.

By the way, my nose gear rod ends have been replaced; I just used that as an example.   
Best Regards,
Steve

[Vince Murray]

That said, I know from first-hand sources that the Beech manuals are currently being revised to make at least some of the now-recommended time limits into airworthiness limitations.  It is entirely within the manufacturer's authority to do this under Federal regulations.  ABS continues to be in touch with the FAA and Hawker Beechcraft about this, and will provide updates as news occurs.

Tom,

It's important to understand that even Hawker Beechcraft cannot now make these items mandatory UNLESS the FAA approves of this change.

//Vince//

[L23017]

Something most people don't think about is their insurance.  Some companies require you to comply with all TBOs.  I personally know someone that overhauled a flawless engine because of this.  AOPA also published an article confirming this.  Personally, I would find another insurance provider before I would spend that kind of money.

[Scott Newpower]

Something most people don't think about is their insurance.  Some companies require you to comply with all TBOs.  I personally know someone that overhauled a flawless engine because of this.  AOPA also published an article confirming this.  Personally, I would find another insurance provider before I would spend that kind of money.

Name that company.

[L23017]

The AOPA article was a few years ago and I don't recall if they named names or not.  I didn't ask the guy at my airport that told me why he was having to overhaul his engine.  All I can say is, ask your agent before you commit to the policy.

[Marvin Dorris]

I'm in a pre-buy for a 35-C33 which includes an annual.  Prop is McCauley 3A36C434/80 VEA-0 with 577 TTSN installed March, 2003.  TBO is 2,400 OR 72 months.  McCauley SB137AE, February 17, 2010 page 2, 1., E. "Even though a propeller, governor, or accumulator may be operting normally and have a good external appearance, when the TBO flight time OR calendar limit is reached, operation beyond the specified TBO limits is NOT permitted."

Prop is now almost 4 years past calendar limit.  My old chief of maintenance says there is a reason for the calendar limit.  My insurance company says if I have an accident they will investigate.  If cause of accident is prop failure they will assume I knew or should have known it was past TBO.  They will pay the claim but I will never get another insurance policy (at least with them).

Now what?

[Tom Turner]

Hi, Marvin:

I see our Techincal Advisors answered your direct email.  Although they went into more detail, the short answer it that the propeller overhaul is not required on the basis of time or calendar time in service alone under U.S. Part 91 rules.