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jkevinl(at)bellsouth.net
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 Posted: Mon Jun 13, 2011 6:22 pm Post subject: AD 95-19-15 R1 and SB-185A - word to the wise |
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Hi folks. This question was brought to my attention and I thought it
sounded like it needed to be cleared up - Maybe I can help.
First, be sure you are reading the latest revisions of the SB and AD. There
were some clarifications in the revision intended to help clarify the proper
compliance issues here.
As you know, Service Bulletins are not mandatory. They are "words to the
wise."
The process the FAA uses to make them mandatory is to reference them in the
Administrative Directive.
So in this case, the AD makes the SB mandatory.
Page 7 of the AD contains the following Question and Answer:
"Does This AD Incorporate Any Material by Reference?
(g) You must do the actions required by this AD following the instructions
in American General
Aircraft Corporation Service Bulletin No. SB-185-A, Revision A, dated
January 10, 2005."
That means that the SB is mandatory and if you read the SB it clearly
requires recurring checks every 500 hours.
Options? Back to the AD:
"May I Request an Alternative Method of Compliance?
(f) You may request a different method of compliance or a different
compliance time for this AD
by following the procedures in 14 CFR 39.19. Unless FAA authorizes
otherwise, send your request to
your principal inspector."
The question Gary asks about the "unless already done" statement (in the
Compliance column of the chart explaining how to address this issue) is a
good one. The statement applies to the initial inspection required within
the next 100 hours Time in Service (TIS). I agree that his is confusing.
Remember that when the AD was revised it was likely that the inspection had
already been done as the original AD had already required the inspection and
the SB (word to the wise) was out prior to that - the intent was not to make
everyone who had just inspected their planes do it again within the next 100
hrs. Once the initial inspection was done, the next column instructs the
reader to follow the SB going forward.
As for the source of the AD, Cliff is close but he has his stories a little
mixed up. The planes that were damaged by hail were at Embry Riddle's
Prescott campus and E.R. performed the wing panel replacements and that had
no bearing on this AD. There were never any planes hail damaged on the ramp
at American General.
According to Loyd, who helped author the AD, it originated out of a flight
school in the UK that had removed and replaced the wings without properly
shimming them. They had 3 (yes, 3!!) instances of spar bolt fretting due to
improper shimming, over torqueing or some other undetermined practice.
There was also one instance reported in the US on an earlier model Grumman
which is how they were all swept up in the FAA net and included in the AD.
So the "word to the wise" is, follow the SB, check the bolts within 100
hours and every 500 hours thereafter - I do. And, "word to the legal" per
the AD, perform the inspections according to the SB which says to check them
every 500 hours. Being legal is up to you and your A&P, but please be wise!
J. Kevin Lancaster, President
True Flight Aerospace, LLC
---
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teamgrumman(at)yahoo.com
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| Posted: Mon Jun 13, 2011 7:09 pm Post subject: AD 95-19-15 R1 and SB-185A - word to the wise |
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Thanks Kevin,
I've been doing them each 500 hours. I even have a calculation in my data base for each of the planes I maintain showing # hours until the next inspection. It's a shame the AD isn't written to address the frequency of inspections.
As part of a PMA application I had to submit drawings that were clear and non-ambigious. Anyone should be able to take a drawing and make a part. I think the least the FAA could do would be make sure Airworthiness Directives were clear.
Thanks for the feedback.
Gary
From: Kevin Lancaster <jkevinl(at)bellsouth.net>
To: teamgrumman-list(at)matronics.com
Sent: Mon, June 13, 2011 7:19:23 PM
Subject: AD 95-19-15 R1 and SB-185A - word to the wise
Hi folks. This question was brought to my attention and I thought it sounded like it needed to be cleared up - Maybe I can help.
First, be sure you are reading the latest revisions of the SB and AD. There were some clarifications in the revision intended to help clarify the proper compliance issues here.
As you know, Service Bulletins are not mandatory. They are "words to the wise."
The process the FAA uses to make them mandatory is to reference them in the Administrative Directive.
So in this case, the AD makes the SB mandatory.
Page 7 of the AD contains the following Question and Answer:
"Does This AD Incorporate Any Material by Reference?
(g) You must do the actions required by this AD following the instructions in American General
Aircraft Corporation Service Bulletin No. SB-185-A, Revision A, dated January 10, 2005."
That means that the SB is mandatory and if you read the SB it clearly requires recurring checks every 500 hours.
Options? Back to the AD:
"May I Request an Alternative Method of Compliance?
(f) You may request a different method of compliance or a different compliance time for this AD
by following the procedures in 14 CFR 39.19. Unless FAA authorizes otherwise, send your request to
your principal inspector."
The question Gary asks about the "unless already done" statement (in the Compliance column of the chart explaining how to address this issue) is a good one. The statement applies to the initial inspection required within the next 100 hours Time in Service (TIS). I agree that his is confusing. Remember that when the AD was revised it was likely that the inspection had already been done as the original AD had already required the inspection and the SB (word to the wise) was out prior to that - the intent was not to make everyone who had just inspected their planes do it again within the next 100 hrs. Once the initial inspection was done, the next column instructs the reader to follow the SB going forward.
As for the source of the AD, Cliff is close but he has his stories a little mixed up. The planes that were damaged by hail were at Embry Riddle's Prescott campus and E.R. performed the wing panel replacements and that had no bearing on this AD. There were never any planes hail damaged on the ramp at American General.
According to Loyd, who helped author the AD, it originated out of a flight school in the UK that had removed and replaced the wings without properly shimming them. They had 3 (yes, 3!!) instances of spar bolt fretting due to improper shimming, over torqueing or some other undetermined practice. There was also one instance reported in the US on an earlier model Grumman which is how they were all swept up in the FAA net and included in the AD.
So the "word to the wise" is, follow the SB, check the bolts within 100 hours and every 500 hours thereafter - I do. And, "word to the legal" per the AD, perform the inspections according to the SB which says to check them every 500 hours. Being legal is up to you and your A&P, but please be wise!
J. Kevin Lancaster, President
True Flight Aerospace, LLC
---
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http://www.matronics.com/Navigator?TeamGrumman-List |
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dmwhite(at)e3ra.com
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| Posted: Wed Jun 15, 2011 6:24 am Post subject: AD 95-19-15 R1 and SB-185A - word to the wise |
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Good morning,
I’ve seen both arguments here and putting on a lawyer hat would argue that while the AD points to the SB for the required ACTIONS, it fairly clearly states the FREQUENCY of those actions on its own. So it is easy to consider this a one-time item, especially using the common sense applied by Cliff. Yes, it is ambiguous and Gary should know that the government always expects us to do better than they do – they do not lead by example, instead they follow poorly.
My 2 cents worth for you all,
Dean
Dean White (Tiger N81166)
Edmonds, WA 98026
dmwhite(at)e3ra.com
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flyv35b(at)minetfiber.com
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| Posted: Wed Jun 15, 2011 9:42 am Post subject: AD 95-19-15 R1 and SB-185A - word to the wise |
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My thoughts on some of this:
1. It used to be that an AD note would state whether or not the AD was
recurring in the AD no matter if a SB was referenced or not. The
original AD95-19-15 was never considered to be recurring to my knowledge.
2. AD95-19-15R1 makes the following statements:
"What events have caused this AD? The FAA has received four report
(three in England and one in the United States) of wing attach shoulder
bolt failure on Tiger Aircraft LLC (Type Certificate A16EA formerly held
by American General Aircraft Corporation (AGAC) and Grumman American
Aviation Corporation (GAAC)) Models AA-5, AA-5A, AA-5B, and AG-5B
airplanes. Investigation reveals that excessive wing to center spar
clearance could have contributed to the bolt failures;
however, in each of the four instances, the bolts failed before reaching
the service life of 7,250 hours time-in-service (TIS). The FAA has
determined that, to assure the safety of these airplanes, the
established service life of these bolts needed review. Our review of
service life on Tiger Aircraft LLC (Type Certificate A16EA formerly held
by AGAC and GAAC) Models AA-5, AA-5A, AA-5B, and AG-5B airplanes caused
us to issue AD 95-19-15, Amendment 39-9377 (60 FR 48628, September 20,
1995). AD 95-19-15 currently requires the following on Tiger Aircraft
LLC (Type Certificate A16EA formerly held by AGAC and GAAC) Models AA-5,
AA-5A, AA-5B, and AG-5B airplanes, all serial numbers:"
"AD 95-19-15 was written to apply to all serial numbers of all models. A
design change was made in this area beginning with serial number 10175
of the Model AG-5B airplanes. Therefore, FAA determined that the action
should not apply to Model AG-5B airplanes with a serial number of 10175
or higher."
3. So did any shoulder bolt failures occur on any AG-5B Tiger Aircraft
produced aircraft? And what was the design change that made the FAA
believe that they did NOT need to be included in the AD note. I wonder
if the AD was revised at Tiger Aircraft's urging so that new aircraft
would not need to comply with the AD within 100 hrs TIS as they had not
previously complied with the AD.
4. The AD states at the beginning of the regulatory portion:
"What Must I Do To Address This Problem?
(e) To address this problem, you must do the following, unless already
done:" So it would appear that if AD95-19-15 has be previously complied
with that AD95-19-15R1 does not apply.
5. The format of AD's has changed since this one was first issued. Now
there are 3 columns for Actions, Compliance and Procedures. I see
nothing here that states that this AD is recurring at any interval. The
only significant change IMO other than the exclusion of AG5B's after
serial #10174 is that "wear" of the shoulder bolt is defined to include
removal of the cad plating from the shoulder area of the bolt as copied
below. This in effect means that any time a bolt is removed for
inspection (required by the SB and maybe by the AD not if you believe
that) that a new bolt will need to be installed as the cad plating gets
damaged by installation and removal.
"(e)(6) Do not install any wing attach shoulder
bolt that has wear resulting in removal of
the cad plating from the shoulder of the
bolt or if the threads contact the shoulder
bevel of the shoulder bolt profile"
6. Section (g) of the AD note says that "You must do the actions
required by this AD following the instructions in American General
Aircraft Corporation Service Bulletin No. SB-185-A, Revision A, dated
January 10, 2005." So I suppose that this issue is still debatable!
Cliff
| Quote: | I’ve seen both arguments here and putting on a lawyer hat would argue
that while the AD points to the SB for the required ACTIONS, it fairly
clearly states the FREQUENCY of those actions on its own. So it is easy
to consider this a one-time item, especially using the common sense
applied by Cliff. Yes, it is ambiguous and Garyshould know that the
government always expects us to do better than they do – they do not
lead by example, instead they follow poorly.
My 2 cents worth for you all,
Dean
|
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http://www.matronics.com/Navigator?TeamGrumman-List |
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teamgrumman(at)yahoo.com
Guest
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| Posted: Thu Jun 16, 2011 8:36 am Post subject: AD 95-19-15 R1 and SB-185A - word to the wise |
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Like I said before, I measured the bolts I checked with a digital micrometer. Both old and new bolts were .3741 with and without cad.
Based on the way the new AD is worded, it would be legal to sign off the plane as having the AD complied with if the original AD had been previously complied with.
With regard to paragraph (g):
(g) You must do the actions required by this AD following the instructions in American General
Aircraft Corporation Service Bulletin No. SB-185-A, Revision A, dated January 10, 2005."
the SB is only referred to in paragraph (e) and then only as to procedures required to comply with actions required by the AD.
The gray area is (1) inspect any inboard wing attach shoulder bolt using the procedure in SB-185A. Problem is, the compliance column stops me from going to the procedures since it's already been previously accomplished.
Too bad someone at Tiger LLC didn't work with the FAA to resolve this problem.
Regarding the new wing design. Personally, I say, "Bullshit." I'd like to see the revised drawings before I believe that.
From: flyv35b <flyv35b(at)minetfiber.com>
To: teamgrumman-list(at)matronics.com
Sent: Wed, June 15, 2011 10:40:16 AM
Subject: Re: AD 95-19-15 R1 and SB-185A - word to the wise
--> TeamGrumman-List message posted by: flyv35b <flyv35b(at)minetfiber.com (flyv35b(at)minetfiber.com)>
My thoughts on some of this:
1. It used to be that an AD note would state whether or not the AD was recurring in the AD no matter if a SB was referenced or not. The original AD95-19-15 was never considered to be recurring to my knowledge.
2. AD95-19-15R1 makes the following statements:
"What events have caused this AD? The FAA has received four report (three in England and one in the United States) of wing attach shoulder bolt failure on Tiger Aircraft LLC (Type Certificate A16EA formerly held by American General Aircraft Corporation (AGAC) and Grumman American Aviation Corporation (GAAC)) Models AA-5, AA-5A, AA-5B, and AG-5B airplanes. Investigation reveals that excessive wing to center spar clearance could have contributed to the bolt failures;
however, in each of the four instances, the bolts failed before reaching the service life of 7,250 hours time-in-service (TIS). The FAA has determined that, to assure the safety of these airplanes, the
established service life of these bolts needed review. Our review of service life on Tiger Aircraft LLC (Type Certificate A16EA formerly held by AGAC and GAAC) Models AA-5, AA-5A, AA-5B, and AG-5B airplanes caused us to issue AD 95-19-15, Amendment 39-9377 (60 FR 48628, September 20, 1995). AD 95-19-15 currently requires the following on Tiger Aircraft LLC (Type Certificate A16EA formerly held by AGAC and GAAC) Models AA-5, AA-5A, AA-5B, and AG-5B airplanes, all serial numbers:"
"AD 95-19-15 was written to apply to all serial numbers of all models. A design change was made in this area beginning with serial number 10175 of the Model AG-5B airplanes. Therefore, FAA determined that the action should not apply to Model AG-5B airplanes with a serial number of 10175 or higher."
3. So did any shoulder bolt failures occur on any AG-5B Tiger Aircraft produced aircraft? And what was the design change that made the FAA believe that they did NOT need to be included in the AD note. I wonder if the AD was revised at Tiger Aircraft's urging so that new aircraft would not need to comply with the AD within 100 hrs TIS as they had not previously complied with the AD.
4. The AD states at the beginning of the regulatory portion:
"What Must I Do To Address This Problem?
(e) To address this problem, you must do the following, unless already done:" So it would appear that if AD95-19-15 has be previously complied with that AD95-19-15R1 does not apply.
5. The format of AD's has changed since this one was first issued. Now there are 3 columns for Actions, Compliance and Procedures. I see nothing here that states that this AD is recurring at any interval. The only significant change IMO other than the exclusion of AG5B's after serial #10174 is that "wear" of the shoulder bolt is defined to include removal of the cad plating from the shoulder area of the bolt as copied below. This in effect means that any time a bolt is removed for inspection (required by the SB and maybe by the AD not if you believe that) that a new bolt will need to be installed as the cad plating gets damaged by installation and removal.
"(e)(6) Do not install any wing attach shoulder
bolt that has wear resulting in removal of
the cad plating from the shoulder of the
bolt or if the threads contact the shoulder
bevel of the shoulder bolt profile"
6. Section (g) of the AD note says that "You must do the actions required by this AD following the instructions in American General
Aircraft Corporation Service Bulletin No. SB-185-A, Revision A, dated January 10, 2005." So I suppose that this issue is still debatable!
Cliff
| Quote: | I’ve seen both arguments here and putting on a lawyer hat would argue
that while the AD points to the SB for the required ACTIONS, it fairly
clearly states the FREQUENCY of those actions on its own. So it is easy
to consider this a one-time item, especially using the common sense
applied by Cliff. Yes, it is ambiguous and Garyshould know that the
government always expects us to do better than they do – they do not
lead by example, instead they follow poorly.
My 2 cents worth for you all,
&/www.matronics.com/Navigator?TeamGrumman-List">http://www.matronics.com/Nav -Matt Dralle, List target="_blank" href="http://www.matronics.com/contribution">http://ww
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