Appliance and Accessories ADs in the Airframe and Engine Summaries

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;

1) If the AD does not apply to the aircraft in question; superseded, revised, STC installed, N/A by serial number, N/A by Certification date, etc., it need not be shown in the Compliance Report,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.

We have spent several months examining the issues here and have made several discoveries;

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.

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.
e.g. All US manufactured Cessna Aircraft are now only under Textron Aviation in the FAA's system.

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.
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.