Inoperative Equipment And Minimum Equipment List

Phil Randall Airworthiness Safety Program Manager Greensboro, NC FSDO

Topics of Discussion Summary FAR 91 General Operating and Flight Rules FAR 91* Subpart C / 91.213 Inoperative Equipment & MEL FAR 91* Subpart E / Maintenance, Preventive, Maintenance, & Alterations AC 91-67 Minimum Equipment List (MEL) Requirements Summary

CONFUCIUS SAYS ‘The Real World’, not everything works all the time, for every aircraft operator must have some LEGAL way to defer inoperative equipment BEFORE they, fly.

WHAT IF All my instruments and equipment are working, that’s good ! WHAT IF A INSTRUMENT OR PIECE OF EQUIPMENT IS NOT WORKING ?

BUBBA LOGBOOK POLICE I SMELL A VIOLATION

Get Out of Jail Free Card A Legal Way---- to defer inoperative equipment on your aircraft OUT OF FAR JAIL 91.213(d)

Inoperative Instruments and Equipment Defines ; OPERATING WITH & WITHOUT A MEL 5 Main Para./ 12 Para./ 9 Subpara. **************************************** 91.213 ( d )….A person may takeoff an aircraft in operations conducted under this part with inoperative instruments or equipment without an approved Minimum Equipment List (MEL) provided--- 4 Paragraphs / 8 Subparagraphs

The Process Of Deferring Inop Equipment under 91.213 (d) CESSNA 150 NAVIGATION LIGHTS ARE INOPERATIVE 1. Check Your Equipment List 2. Type Certificate Data Sheet ( TCDS ) 3. Kinds of Operation Equipment List SEE IF THE LIGHTS ARE REQUIRED EQUIPMENT Lets say they are NOT REQUIRED

Decision Sequence 4. Check If Navigation Lights are required to be operative by FAR 91.205 or any other FAR Operating Rule 91.205 ( b ) VFR Flight Rules (day) 17 Items Instruments and Equipment that are REQUIRED

91.205 (b) Instrument & Equipment requirement VFR-DAY Airspeed indicator Altimeter Magnetic direction indicator Tachometer for each engine Oil pressure gauge...... Temp gauge for each liquid-cooled engine. Oil Temp gauge for each air-cooled engine. Manifold pressure gauge for each altitude engine. Fuel gauge.......(for each tank) Thru 17; ELT’s, 91.207(f)(10)(i)&(ii), seat belts, etc.

Decision Checklist Well …………. They are required for VFR (night) BUT not for VFR (day) 5. Are They Required to be working by an Airworthiness Directive (AD) or STC Our research tells us….NO

Decision Checklist 6. Now you can Deactivate the NAV Lights IAW FAR 43.13 & 91.213(d), then Placard it as “INOPERATIVE” 7. Also, the Pilot or Mechanic MUST Make A Signed Logbook Entry IAW FAR 43.9

Deactivation The operator must evaluate any proposed deactivation to assure there is no adverse effect that could render another system less than fully capable of its intended function A certificated pilot can accomplish deactivation involving routine pilot tasks, such as turn off a system, that task must come under the definition of preventive maintenance in FAR Part 43, Appendix A(c)

The Placard AC91-67 AC 91-67, Paragraph 6 ‘Definitions’, page iv, subparagraph (t). “A placard is a decal or label with letters at least 1/8-inch high.” The operator or mechanic must place the placard on or near inoperative equipment or instruments so that it is visible to the pilot or flight crew and alerts them to the inoperative equipment.

Signature Jimmy B. Lunchbucket LOGBOOK ENTRY 7. stating that…….. “The Navigation Lights Are Deferred for VFR Flight Only and Do Not Constitute A Hazard to the Aircraft” Signature Jimmy B. Lunchbucket certificate no. 444347744

PART 91: General Operating and Flight Rules Subpart C: Refers to additional equipment that must be maintained. Subpart E: Is about maintenance, preventive maintenance, and alterations.

FAR 91 Subpart C References equipment, instruments, & certification requirements. Items that were never part of the aircraft’s original type design This additional equipment was added to the aircraft because it either enhances the aircraft’s operating environment or because it was required by regulation

Some Examples ENHANCES the ENVIRONMENT by REGULATION Transponders, Supplemental Oxygen, TCAS, GPS, even Aircraft Lights by REGULATION Congress Passed a mandatory Law requiring…ELT’s

Part 91 Subpart E Requirements for Inspections, Annuals, 100 hours, Progressive, and the Inspections for large and turbine aircraft under Section 91.409(e)(f)

FAR 91.405 ( c ) don’t forget (d) SHALL have any INOPERATIVE instrument or item of equipment, permitted to be INOPERATIVE by FAR 91.213 (d)(2) of this part, REPAIRED, REPLACED, REMOVED, or INSPECTED at the NEXT REQUIRED INSPECTION; AND (d)..When listed discrepancies include inoperative instruments or equipment, SHALL ensure that a placard has been installed as required by FAR 43.11 of this chapter

The Big QUESTION Whether an item of equipment can go indefinitely in an inoperative status under the rule. IF it meets all of the criteria and is inspected for hazardous conditions at each required inspection, then it can continue to be inoperative. BUT, the intent of the rule is to provide temporary relief until a repair or replacement.

The FAA interprets this as Not Inspecting an ‘alteration’ Areas of Concern The mechanic can get in trouble, if you do not inspect each inoperative part under 91.213 (d) in accordance with 91.405 ( c ) at each 100 hour and or Annual inspection. The FAA interprets this as Not Inspecting an ‘alteration’

Areas of Concern If you do not perform or record that you inspected the ‘major alteration’ to the aircraft’s type design you could be in violation of Sections 91.213 and 43.11 inspections.

Mechanics Favorite Rule 91.403 9(a) 91.403 (a) The owner operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with * Part 39 of this chapter Part 39--Airworthiness Directives

AC 91-67 MEL Related FAR’s FAR 43.9; Content, form, and disposition of maintenance, preventive maintenance, and alteration records (except inspections performed in accordance with FAR part 91...) FAR 43.11; Content, form, and disposition of the records for the INSPECTIONS conducted under FAR 91

MEL Related FARs FAR 91.205; Powered civil aircraft with standard category U.S. airworthiness certificate: Instruments and Equipment Requirements FAR 91.405; Maintenance Requirements FAR 91.213; Inoperative Instruments and Equipment

Removal of equipment Removal of equipment that affects the airworthiness of an aircraft requires following an approved procedure. A properly certificated maintenance person (A&P) must record; The removal, Adjustment of the weight & balance & equipment list; Submit FAA Form 337; and approve the aircraft for return to service.

AC 91-67 Minimum Equipment List IN SUMMARY FAR 91 FAR 91 “C” FAR 91 “E” Inoperative Equipment Deactivation & Placard Procedures Inspect Inoperative Instruments and Equipment. AC 91-67 Minimum Equipment List

QUESTIONS

SAFETY is the Bottom line Every instrument and item of equipment adds an extra level of safety, so try to keep it all working

THE END FLY SAFE