2. Inoperative Equipment And Minimum Equipment List

3. Phil Randall Airworthiness Safety Program Manager Greensboro, NC FSDO

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

5. 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.

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

7. BUBBA LOGBOOK POLICE
I SMELL A VIOLATION

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

9. Inoperative Instruments and Equipment
Defines ; OPERATING WITH & WITHOUT A MEL Main Para./ 12 Para./ 9 Subpara ****************************************
( 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 Paragraphs / 8 Subparagraphs

10. 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

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

12. 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, (f)(10)(i)&(ii), seat belts, etc.

13. 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

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

15. 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)

16. 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.

17. 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

18. 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.

19. 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

20. 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

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

22. FAR 91.405 ( c ) don’t forget (d)
SHALL have any INOPERATIVE instrument or item of equipment, permitted to be INOPERATIVE by FAR (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 of this chapter

23. 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.

24. 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 (d) in accordance with ( c ) at each hour and or Annual inspection.
The FAA interprets this as Not Inspecting an ‘alteration’

25. 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 and inspections.

26. Mechanics Favorite Rule 91.403 9(a)
(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

27. AC 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

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

29. 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.

30. 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 Minimum Equipment List

31. QUESTIONS

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

33. THE END
FLY SAFE