As we all know, there are four categories of ADs; 1)
Airframe, 2) Engine, 3) Prop and 4) Appliances. On the
surface it might seem simple to determine in which category
an AD belongs, and it is, but not for the reasons you might
expect. Everything in this business is based on the Type
Certificate. If an AD is issued against an Airframe Type Certificate
holder, it is an Airframe AD; pretty simple !! The same
applies to Engine and Propeller ADs. If the AD addresses a
Non-Type Certificate Holder (Gramin, Bendix, etc.) it is, by
definition, an Appliance or Accessory AD. However, several years ago, the FAA started showing
Appliance ADs in the Airframe and Engine AD Summaries. At
first we thought it was just another government mistake, but
they persisted. Now it is clear that they intend to show
Appliance and Accessory ADs in the Airframe and Engine
Indexes when the AD references specific Makes and Models
where the Appliance or Accessory may be installed. To accommodate this twist, we started showing some
Appliance ADs in the Airframe and Engine Summaries with the
Subject title; "Non-Type Certificate Holder" to
indicate that is was not actually an Airframe or Engine
AD. There are two
philosophies among
inspectors;
We have spent several months examining the issues here
and have made several discoveries; We have modified our System to show the Appliance ADs
where the AD contains a list of Make/Models where the
Appliance could be installed. Essentially, we are trying to
mimic the FAA's interpretation and give you what the
inspector will have produced from the FAA's data. There are,
however, some differences and given the above described
problems, a complete system will take some time. The following summary will be helpful: We try to show all the models where you might expect
them; Beech Aircraft, Hawker Beechcraft and Raytheon
Aircraft are all the same. The FAA only shows them under the
most recent TC Holder. We show you the Superseded, Revised, etc. ADs. The FAA
throws the old ones away. We sort top down (new at the bottom). The FAA sorts
bottom up (new at the top.) We show the Appliance ADs separately (with one
exception). The FAA mixes them in with the Airframe or
Engine ADs without telling you that they are really
Appliance ADs and that they only apply if the Appliance is
installed. The aforementioned exceptions are the ADs labeled
"Non-Type Certificate Holder" that are in the
Airframe and Engine Summaries. That will change as this
System evolves. Last:
It is important to note
that this change does not do your Appliance AD
research for you.
1) If the AD does not apply to the aircraft in
question; superseded, revised, STC installed, N/A by serial
number, N/A by Certification date, etc., it need not
be shown in the Compliance Report,
2) If the AD did apply in the past or could apply
under any circumstance, it should be shown in the Compliance
Report indicating that the IA has read the AD to actually
determine that it does not now apply to the aircraft in
question and indicating in the Compliance Report why it does
not apply.
We can argue all day about which is correct or what
variation might be adequate or appropriate. That's not the
point!! We have already seen several events where inspectors
have challenged a shop's work because the uninstalled
Appliance ADs were not shown in the Compliance Report. Its
not our job to argue about it. Its our job to give you the
tools to keep the FAA happy. Its up to you as to how you use
them.
1) There are over 15,000 records in the Appliance
DataBase where the AD could apply to a given Airframe or
Engine.
2) There are hundreds of errors (omissions) in the
FAA's interpretation of applicability.
3) There are inconsistencies in the Model
designations between the Type Certificate, the AD and the
FAA's data.
4) There are ambiguities in the Type Certificate
Holder's identity e.g. Bell Textron is the system three
times, Bendix and Goodyear 5 times, the list goes on
.
Sometimes there is a reason for it - divestiture or
re-incorporation, but frequently it is only because someone
typed the name slightly differently on a new or revised Type
Certificate. In any case, it makes tracking down a given
Aircraft or Engine Model very difficult.
e.g. All US manufactured Cessna Aircraft are now only under
Textron Aviation in the FAA's system.
There are still a few hundred Appliance and Accessories ADs
that do not reference Aircraft or Engine Makes and Models.
Therefore, that 4th category of ADs still has to be
researched to complete your Appliance list.