Signing off an AD

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ahramin
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Signing off an AD

Post by ahramin »

Who can sign off an AD as not applicable?
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boeingboy
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Re: Signing off an AD

Post by boeingboy »

The pilot.....if its private and hes the owner. Otherwise an AME
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photofly
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Re: Signing off an AD

Post by photofly »

Nobody.

An inapplicable AD doesn’t need to be “signed off”. It’s just, not applicable.

Think about it: 99.9999% of all ADs are “inapplicable by type” to any particular aircraft. Are they all signed off? No.

As far as who makes the decision as to whether an aircraft is airworthy, it’s always the responsibility of the pilot and owner (both) under 605.84. If an AME incorrectly “signs off” an applicable AD as inapplicable, and the aircraft is flown, without complying, the PIC commits an offence, along with the owner. Not the AME.
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455tt
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Re: Signing off an AD

Post by 455tt »

ahramin wrote: Tue Aug 04, 2020 10:19 pm Who can sign off an AD as not applicable?
The purpose of an AD is to identify an unsafe condition in an aircraft type and to specify required corrective action.

Failure of an aircraft owner to comply with an applicable AD is serious, because it puts the C of A out of force, and it makes it an offence to fly the aircraft.

Applicable AD's are normally sent by TC to the aircraft owner to which they apply. So aircraft owners should know which AD's they must comply with for their aircraft.

If in doubt about the existence or applicability of any AD, you can consult your local TC Inspector, or TC Aircraft Certification, Continuing Airworthiness Division in Ottawa (CAWWEBFEEDBACK@TC.GC.CA).

You can also hire a licenced AME to complete a search and report of all applicable AD's. This would be "maintenance" under CARs 571 and the AME's release certification following this research task would offer a strong defence to any allegation an aircraft had been operated with an outstanding AD.
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groncher
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Re: Signing off an AD

Post by groncher »

Hiring an AME to complete a search and a report is NOT maintenance under CAR 571, and is not subject to a maintenance release.

The owner of the aircraft is responsible for AD compliance.

An AME is responsible to sign a release for maintenance performed with respect to an AD. Not all ADs involve maintenance.

To answer the original question. The owner can sign as NA. Though as mentioned you don't have to if not applicable.
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455tt
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Re: Signing off an AD

Post by 455tt »

groncher wrote: Wed Aug 05, 2020 5:23 am Hiring an AME to complete a search and a report is NOT maintenance under CAR 571, and is not subject to a maintenance release.
Yes it is: see the information note from CARs 571.10 (3) Maintenance Standard where TC considers an AD search to be a "separate maintenance task".

"(3) Responsibility for compliance with airworthiness directives (ADs) is assigned to the owner of the aircraft in accordance with section 605.84 of the CARs.

Information Notes:

(i) Some inspection check sheets contain a check box with a statement to the effect that “...all applicable ADs have been complied with”. Such a statement transfers this responsibility to the AME signing the maintenance release for the inspection, even though it may be impractical for the AME to undertake the level of research required. Since compliance with ADs are the responsibility of the owner, AMEs should strike out this item on the inspection check sheets that they sign.

(ii) If the owner wishes to have this research undertaken by the AME as a separate maintenance task, it can be raised as a separate item on the work order, work card, or other document detailing the maintenance arrangement. "
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photofly
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Re: Signing off an AD

Post by photofly »

Information notes are not regulatory; the definition of “maintenance” is in CAR101. It’s very hard to interpret CAR101 as suggesting that a search for AD’s meets the definition of maintenance.

I’m fairly sure that whoever wrote the note in Standard 571.10 was a current or former AME describing existing practice, and not a lawyer. So I wouldn’t hang my hat on what’s written there.
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digits_
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Re: Signing off an AD

Post by digits_ »

photofly wrote: Wed Aug 05, 2020 9:07 am Information notes are not regulatory; the definition of “maintenance” is in CAR101. It’s very hard to interpret CAR101 as suggesting that a search for AD’s meets the definition of maintenance.

I’m fairly sure that whoever wrote the note in Standard 571.10 was a current or former AME describing existing practice, and not a lawyer. So I wouldn’t hang my hat on what’s written there.
If my AME checks that box the note mentions, would that not transfer the responsibility to him? As an owner, I could realistically assume an AME is capable of performing such a task. If I pay him to do so, why would he not be responsible if he misses something?
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photofly
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Re: Signing off an AD

Post by photofly »

Because it’s very clear in the Regulations whose responsibility it is. You can’t assign it to someone else.

Now if you got an enforcement action you could pursue the AME for negligence, citing your fine as a loss.

And if you have an AME sign off on an AD, and they were wrong, you would have a good defence and would (I imagine) be unlikely to have an enforcement action.

But it’s still your responsibility.
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digits_
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Re: Signing off an AD

Post by digits_ »

photofly wrote: Wed Aug 05, 2020 11:56 am Because it’s very clear in the Regulations whose responsibility it is. You can’t assign it to someone else.

Now if you got an enforcement action you could pursue the AME for negligence, citing your fine as a loss.

And if you have an AME sign off on an AD, and they were wrong, you would have a good defence and would (I imagine) be unlikely to have an enforcement action.

But it’s still your responsibility.
Thanks, makes sense!
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lhalliday
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Re: Signing off an AD

Post by lhalliday »

"Not applicable" is my decision as aircraft owner. "Already complied with" is noted in the logs.

At each annual I go through the ADs applicable to my plane, review their compliance and hand the list to the AME. They're pleased that I do it: they prefer to work on planes, not do paperwork. It's a long time since there were any new ADs on WHG, but there are a handful of recurring ones that we do each annual (e.g. 87-02-08), plus a couple more out of phase ADs (e.g. 98-02-08). Their sign off goes in the logs. They take it seriously. So do I.

...laura
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rigpiggy
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Re: Signing off an AD

Post by rigpiggy »

https://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/ ... d_qs1.aspx

https://www.faa.gov/regulations_policie ... irectives/

Download the AD's go through your logs check for applicability and compliance. Then do an AVERY sticky with all the AD's, SBs, and SLs note all non-applicable due to serial, model, installation etc.... then note all single compliance items, and Recurring items....... put in the applicable tech, and AD log. Next time around all you will have to look for is any new Ads, and any recurring. BTW don't expect TC's AD list to be correct, they are so broad that you will look at ad's for a piston engine when you have a PT6 upfront
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Heliian
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Re: Signing off an AD

Post by Heliian »

Does nobody keep an AD log anymore?
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ahramin
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Re: Signing off an AD

Post by ahramin »

Thank you to everyone. Good information.
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nine sixteenths
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Re: Signing off an AD

Post by nine sixteenths »

rigpiggy wrote: Wed Aug 05, 2020 11:32 pm https://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/ ... d_qs1.aspx

https://www.faa.gov/regulations_policie ... irectives/

Download the AD's go through your logs check for applicability and compliance. Then do an AVERY sticky with all the AD's, SBs, and SLs note all non-applicable due to serial, model, installation etc.... then note all single compliance items, and Recurring items....... put in the applicable tech, and AD log. Next time around all you will have to look for is any new Ads, and any recurring. BTW don't expect TC's AD list to be correct, they are so broad that you will look at ad's for a piston engine when you have a PT6 upfront

I’ve never run into TC’s list being way off. It’s based on the info you submit in your AAIR, so if that info is right it should be fairly accurate. It does NOT address miscellaneous ADs though, and if they AD is issued against multiple types your aircraft my not be applicable by serial or what have you, but by model.

My $0.02, as a private aircraft owner keep a log of the ADs and if you can the SB’s. It doesn’t have to be a fancy logbook, just a word document is fine, or even a notebook. It should say information like AD # XXX completed in aircraft on DATE, HOURS, CYCLES(if applicable), no recurring action required, or AD # XXX found Not Applicable to aircraft on DATE, HOURS, due to (reason, such as serial number, equipment not installed, etc). Use the TC listing by registration as the basis of that for the AD’s. Go back to AD’s from the day your airplane was born and work forward, looking through your tech logs. You should also review the AD database wherever the aircraft’s type certificate is from (FAA probably), and miscellaneous AD’d for possible work needed. If you want to be extra diligent, search your aircraft model, engine model and prop model in the databases as well. It’s a bit of work to establish, but I think it’s worth it in the end. At your annuals you are then far better equipped to say “please review for new AD’s, and these are the outstanding or repetitive AD’s I want done”, thus better able to save yourself a little money every year by not repeating the work, as well as developing a better relationship with the AME/AMO you are working with for the annuals.

You could also straight up pay an AME/AMO to do the above work for you, set up your log in the first place, if you didn’t want to do the legwork yourself.
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Heliian
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Re: Signing off an AD

Post by Heliian »

digits_ wrote: Wed Aug 05, 2020 9:23 am
photofly wrote: Wed Aug 05, 2020 9:07 am Information notes are not regulatory; the definition of “maintenance” is in CAR101. It’s very hard to interpret CAR101 as suggesting that a search for AD’s meets the definition of maintenance.

I’m fairly sure that whoever wrote the note in Standard 571.10 was a current or former AME describing existing practice, and not a lawyer. So I wouldn’t hang my hat on what’s written there.
If my AME checks that box the note mentions, would that not transfer the responsibility to him? As an owner, I could realistically assume an AME is capable of performing such a task. If I pay him to do so, why would he not be responsible if he misses something?
We've been marking these as "N/A owner responsibility"
Done.

However, I have signed these off before, after checking the Ad's and OEM sb's. Import, sales and bridging inspections are common. Once in a while a private owner would have that completed to catch up on their status.
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boeingboy
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Re: Signing off an AD

Post by boeingboy »

nine sixteenths wrote: Thu Aug 06, 2020 10:39 am
rigpiggy wrote: Wed Aug 05, 2020 11:32 pm https://wwwapps.tc.gc.ca/Saf-Sec-Sur/2/ ... d_qs1.aspx

https://www.faa.gov/regulations_policie ... irectives/

Download the AD's go through your logs check for applicability and compliance. Then do an AVERY sticky with all the AD's, SBs, and SLs note all non-applicable due to serial, model, installation etc.... then note all single compliance items, and Recurring items....... put in the applicable tech, and AD log. Next time around all you will have to look for is any new Ads, and any recurring. BTW don't expect TC's AD list to be correct, they are so broad that you will look at ad's for a piston engine when you have a PT6 upfront

I’ve never run into TC’s list being way off. It’s based on the info you submit in your AAIR, so if that info is right it should be fairly accurate. It does NOT address miscellaneous ADs though, and if they AD is issued against multiple types your aircraft my not be applicable by serial or what have you, but by model.

My $0.02, as a private aircraft owner keep a log of the ADs and if you can the SB’s. It doesn’t have to be a fancy logbook, just a word document is fine, or even a notebook. It should say information like AD # XXX completed in aircraft on DATE, HOURS, CYCLES(if applicable), no recurring action required, or AD # XXX found Not Applicable to aircraft on DATE, HOURS, due to (reason, such as serial number, equipment not installed, etc). Use the TC listing by registration as the basis of that for the AD’s. Go back to AD’s from the day your airplane was born and work forward, looking through your tech logs. You should also review the AD database wherever the aircraft’s type certificate is from (FAA probably), and miscellaneous AD’d for possible work needed. If you want to be extra diligent, search your aircraft model, engine model and prop model in the databases as well. It’s a bit of work to establish, but I think it’s worth it in the end. At your annuals you are then far better equipped to say “please review for new AD’s, and these are the outstanding or repetitive AD’s I want done”, thus better able to save yourself a little money every year by not repeating the work, as well as developing a better relationship with the AME/AMO you are working with for the annuals.

You could also straight up pay an AME/AMO to do the above work for you, set up your log in the first place, if you didn’t want to do the legwork yourself.

Excuse me....Your $0.02???...a word document???...A notebook???

You are required by law to keep a logbook record of AD's, It's part of your tech logs. Every airplane should have 4 tech logs - airframe (section 1 - blue) records of installations and modifications (section 2 - green), Engine (section 3 - yellow), and propeller (section 4 - red).

Section 2 - record of installations and modifications - is a record of 1) Engine installations 2) Propeller installations 3) Airworthiness directives 4) Service bulletins 5) Special inspections 6) modifications

If you don't have a full set of logbooks - I suggest you fix that.
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photofly
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Re: Signing off an AD

Post by photofly »

The requirements for technical records are in 605.92.

How you meet those requirements isn’t specified, and there are lots of ways to do it other than the traditional blue/red/yellow/green books. Quite obviously there’s no requirement for the covers to be any particular colour, or even to have covers.

I’m not sure that a word document alone meets the extra requirements for electronic record keeping, but if you keep printouts in a file folder in a way that prevents alteration etc, sure, why not.

Note that there is no requirement for a separate record of ADs other than the regular work done to inspect and/or comply, which should be in the regular technical logs, in chronological order.

A separate list of ADs complied with is going to be helpful but I don’t see anything that requires one, do you?

Regardless, a record of which AD’s *don’t* apply to a component or airframe is not part of any technical record, so you can keep it however you like. I also have a spreadsheet.
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Last edited by photofly on Fri Aug 07, 2020 11:27 am, edited 1 time in total.
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boeingboy
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Re: Signing off an AD

Post by boeingboy »

photofly wrote: Fri Aug 07, 2020 11:10 am The requirements for technical records are in 605.92.

How you meet those requirements isn’t specified, and there are lots of ways to do it other than the traditional blue/red/yellow/green books. Quite obviously there’s no requirement for the covers to be any particular colour, or even to have covers.

I’m not sure that a word document alone meets the extra requirements for electronic record keeping, but if you keep printouts in a file folder in a way that prevents alteration etc, sure, why not.

Regardless, a record of which AD’s *don’t* apply to a component or airframe is not part of any technical record, so you can keep it however you like. I also have a spreadsheet.
Of course your right.
Nine sixteenths comments seem to suggest that in his mind owners should keep a record of AD's and SB's as a good idea and how he would do it. I was merely stating that it's required by law to be a kept record. The majority of private owners still have the traditional logbooks, so I was just making things simple...maybe some don't have or know about that book.

Obviously - If one has gone to an electronic system that can meet the CAR's requirements then you wont have colored books and your happily on your way. I would imagine though that all the info is still the same and probably laid out rationally. In any case - a pocket pad with your AD's scribbled on it is not the way it needs to be done.
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Last edited by boeingboy on Fri Aug 07, 2020 11:30 am, edited 1 time in total.
photofly
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Re: Signing off an AD

Post by photofly »

But you don’t *need* a separate record of AD’s at all. It’s really helpful when it comes to checking compliance, but...
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