The Duncan Download Blog: Business Aviation Advice & Observations

Contributed by Scott Shefke, Airframe Tech Rep.

SAFA ramp inspections are occurring more often to N-registered aircraft operating in EASA-controlled countries. The purpose of these inspections is to ensure aircraft are meeting minimum standards in several areas, such as emergency exit, altimeters, flight recorders, GPWS, ELT and electronic navigation data management. The list goes on and on. The complete list from for the SAFA Program can be found here: http://www.icao.int/FSIX/_library/coscapsea/ Reference_ANNEXES_for_
ICAO_Ramp_Inspections_Guidance_2009_07_02.pdf.

Identification Plate Requirement

On page seven (7) of the above document is a reference to a required Identification Plate that must be displayed in a prominent position aboard the aircraft. ID Plates are not required by the FAA in the United States, but if you plan to fly in EASA-controlled countries, be aware that you will need to have a plate installed or risk getting hit with a fine during a SAFA Inspection.

A8. Documents required to be carried on board - Identification Plate

“An aircraft shall carry an identification plate inscribed with at least its nationality or common mark and registration mark. The plate shall be made of fireproof metal or other fireproof material of suitable physical properties and shall be secured to the aircraft in a prominent position near the main entrance or, in the case of an unmanned free balloon, affixed conspicuously to the exterior of the payload.”

The reference gives direction as to the material the plate must be made from, but nothing is stated about the dimensions.

If you want to make your own plate, one OEM recommends cutting it to .98” x 3.94” from a .063” stainless steel sheet. Engrave the plate with .60” high lettering at an engraving depth of .04”. One operator said he went to his local trophy engraving shop and had them make a placard. He installed it in a prominent place using a two-part epoxy.

Scott Shefke is an Airframe Tech Rep. located at Duncan Aviation's Lincoln, Nebr., facility. He specializes in educating operators about and troubleshooting the Challenger and Global airframes. Scott currently services on Bombardier's Challenger 600 Series Advisory Board and Bombardier Industry Steering Committee. His aviation career began in 1991.

Contributed by Don Heinlein, Domestic & International Parts Team Leader

Operators are sometimes unaware that parts or units listed on the United States Munitions List (military items) must meet specific requirements to be shipped to the U.S. Without proper authorization, shipments can be delayed at the border for months. Here’s what you need to know to avoid delays.

The United States Government has International Traffic in Arms Regulations (ITAR) pertaining to the import and export of parts or units on the United States Munitions List.

ITAR items shipped to theU.S.are not allowed into the country unless the company or person shipping the item (shipper) has registered with the U.S. Department of State (DOS) and has obtained an import license, or that the shipment qualifies for a license exemption.

If items are shipped to the U.S.without this prior-authorization, they maybe held at the border for up to 60 days while the DOS decides whether to approve their admittance into the U.S. 

To prevent days and weeks of delays, I highly recommend you notify your U.S.aircraft parts service provider prior to shipping any aircraft parts for repairs or exchange cores. They should be able to identify if the part is ITAR controlled and provide the proper language required for the commercial shipping invoice.

If your chosen aviation parts service provider is not knowledgeable of U.S. ITAR, is not capable of pre-clearing your shipment or is not able to provide the necessary language and paperwork for your shipment to enter the U.S., stop and find one that is.

Duncan Aviation screens all incoming shipments for ITAR-controlled items and provides our broker with the proper information for U.S. Customs so the parts are easily approved by the DOS and pass through U.S. Customs without delay. We monitor all shipments as they go through this process and will swiftly deal with any delays in a timely manor.

To ship parts to Duncan Aviation, please complete a shipping notice form.

Duncan Aviation provides extensive repair and overhaul services—including loaners and exchanges—for business aircraft parts, avionics, instruments, accessories and propellers. We maintain a large inventory of aircraft parts for sale. We also hold more than 70 manufacturer authorizations for avionics, instruments, accessories and propeller units.

Don Heinlein serves as the Domestic & International Parts Team Leader at Duncan Aviation, specializing in parts requests. He began working in aviation in 1977.

Contributed by Mike Bernholtz, Turbine Engine Services Sales Rep.

December 31, 2011, is the last day to comply with the FAA Airworthy Directive (AD) 2005-05-15. This AD requires the replacement of low pressure turbine LPT stage 1 discs for affected TFE731-3, -3A, -3AR, -3R, -3B, and -3BR series engines.

Delayed Inspection May Mean Delayed Capacity & Parts

According to the Honeywell website, there has been a low compliance rate for this AD since it was issued in 2005. They are encouraging all operators who are affected to contact an authorized service center immediately to schedule the inspections and part replacements.

Consequently, at Duncan Aviation, we believe as the deadline gets closer, the demand and lead time for parts will increase significantly. There is also a real possibility that engine maintenance shops will not have the capacity to handle these requests on a 'last minute' basis.

Affected TFE731 Engines

All TFE731-3, -3A, -3AR, -3R, -3B, and -3BR engines installed on one of the following aircraft models must have this AD performed before 2012.  

• Learjet 55   
• Hawker 400, 600,700
• Westwind I and II (IAI 1124)
• Falcon 50
• Jetstar
• Astra
• Citation III/VI
• Sabreliner

This AD does not apply on engines that have had the 3C or 3D upgrade.

Engines that are still running a LPT1 disc part, numbers 3072070-All, 3072351-All, 3073013-All, 3073113-All, 3073497-All and 3074103-All, require replacement prior to 2012.

To further emphasize the importance of complying sooner rather than later, Honeywell has issued a Service Information Letter (SIL). If applicable, Honeywell has a pricing program for the replacement of the disc and the LPT1 blades.

Duncan Aviation is a Honeywell Authorized Service Center and operates a 20,000 square foot engine maintenance shop dedicated to the support of TFE731 engines.

For more information about this AD, contact Shane Heier, Duncan Aviation's Honeywell Engine Tech Rep. To schedule this inspection and parts replacement, contact Engine Maintenance Service Sales.

Mike Bernholtz is a Turbine Engine Services Sales Rep specializing in Honeywell TFE731 inspection and maintenance services. His aviation career began in 1989.

Contributed by Pete Mills, Chief Inspector and Mike Mertens, Regulatory Compliance Manager. Written in conjunction with the Lincoln, Neb. Flight Standards District Office (FSDO).

Understanding what regulatory requirements must be met for a service provider to issue an approval for return to service for Reduced Vertical Separation Minimums (RVSM) maintenance and inspections can be very confusing. Boiling down the requirements is best done by referring back to Federal Aviation Administration (FAA) regulations and supporting documentation. The primary document providing this guidance is FAA Order 8100.9, Volume 4, Chapter 10, Paragraph 4-1235.

The RVSM Maintenance Program Requirements

Only an FAA approved RVSM maintenance program will allow a service provider to sign off on RVSM services. FAA regulations require that operators follow “…an approved RVSM maintenance program” to operate in RVSM airspace, as per an Part 91 operator’s Letter of Authorization (LOA), Part 91K operator’s Management Specifications (MSpecs), or Part 121 – 135 operator’s Operations Specifications (Ops Specs)

The Differences Between an LOA, MSpecs & Ops Specs

The LOA, MSpecs and Ops Specs are often confused with each other. The difference lies in how the aircraft is operated. This is identified in FAA Order 8900.1, Volume 3, Chapter 18, Paragraph 3-736.

• Part 91 RVSM-certified operators will have an LOA stating they may operate in RVSM airspace as long as they follow "...an approved RVSM maintenance program."
• Part 91K (Fractional operator) RVSM-certified operators will have MSpecs stating they may operate in RVSM airspace as long as they follow "...an approved RVSM maintenance program."
• Part 121 - 135 RVSM-certified operators will have Ops Specs issued in place of an LOA or MSpecs. The Ops Specs require an operator to follow an approved RVSM maintenance program.

What the LOA, MSpecs or Ops Specs Mean

One of the more common points of confusion is how the LOA, MSpecs or Ops Specs are involved in an RVSM maintenance program. All of these documents outline the regulatory requirements for the operator’s RVSM approval, and verifies the need for an approved RVSM maintenance program. If there is ever a question about whether or not an approved RVSM maintenance program is required to issue approval for return to service for RVSM maintenance or inspections, refer to the operator’s LOA, MSpecs or Ops Specs, as appropriate.

An ICA, AFM, MM, SB or AAIP Do Not Replace the Approved Maintenance Program Requirement

There is no documentation that will waive the requirement to follow an approved RVSM maintenance program. Instructions for Continued Airworthiness (ICA), an FAA approved Aircraft Flight Manual (AFM), maintenance manual (MM) instructions, service bulletins (SB) or an Approved Aircraft Inspection Program (AAIP) are not an approved RVSM maintenance program. Nor is the LOA, MSpecs or Op Specs a substitute for an approved RVSM maintenance program. The ICA, AFM, MM, SB and AAIP information may be a part of or contained in, the FAA Approved RVSM program, but does not replace it.

An FAA Approved RVSM Maintenance Program may be a stand alone document or it may be incorporated in some other document such as a General Maintenance Manual (GMM), International Operations Manual (IOM), or Continuous Airworthiness Maintenance Program (CAMP). No matter where it is located, there still must be an indication that the RVSM maintenance program has been FAA Approved. This approval will be indicated by:

1. the Approval date,
2. the word Approved,
3. the approving FSDO Inspector signature (pen and ink or electronic), and
4. the approving FSDO’s office designator being placed on the document.

Duncan Aviation provides complete business aircraft maintenance, repair and overhaul (MRO) services and we work closely with the FAA to ensure RVSM compliance. RVSM maintenance and inspections are supported by our full-service facilities and our network of avionics shops located across the United States

Pete Mills is a Chief Inspector at Duncan Aviation’s Battle Creek, Mich. facility, specializing in general aviation maintenance. He began working in aviation in 1976. Mike Mertens is the Regulatory Compliance Manager at Duncan Aviation’s Lincoln, Neb. facility, specializing in general aviation maintenance and alteration regulation compliance. He began working in aviation in 1975.

Contributed by Steve Rothanzl, International Compliance Officer

It’s easy to assume that shipping aircraft parts is as simple as packing them up and sending them off to a service provider. The problem is, units that are sent without necessary documentation can experience long shipping delays and incur hundreds of dollars of extra shipping fees.

I’ve been working in and with Duncan Aviation’s shipping department for 13 years, and I’ve seen more than one case where a unit was received without any documentation whatsoever. No department had any record of who it was from, or what services were needed. Several days were lost while we researched which customer sent in the unit (the return address on the air waybill was from a freight forwarder) so we could contact them to understand what service was being requested on the unit. In overseas shipping cases, units missing the proper documentation, broker information or shipping account numbers were delayed for weeks at U.S. customs.

We work diligently to help customers experience as little downtime as possible when these mishaps occur by providing loaner and exchange units. However, following these five simple steps can help avoid these delays and fees altogether.

1.  Call Ahead

If a service provider knows a unit is being shipped, they can verify critical information like the part number, what services are needed, where it needs to be returned, and if the part is AOG or requires a faster turn time. Sometimes service providers have more than one shop location, and verifying the shipping address can prevent shipping and handling delays.

2.  Include Necessary Documentation

Always include your account number and provide any necessary PO or waybill numbers. It’s also not a bad idea to duplicate any verbal instructions you provided such as turn time requirements.

A Commercial Invoice which states the part number, quantity, description, value of the unit, and the services requested are essential, especially for international shipments. The Commercial Invoice must be in English per U.S. regulations concerning customs clearance. If the item is controlled under the International Traffic in Arms Regulations (ITAR), it must be shipped to the U.S. on a license or under an exemption, this must be stated properly on the Commercial Invoice in order to avoid possible delays and fines. If you are unsure about these regulations, contact your service provider.

3.  Ask About Preferred Shipping Partners

Some service providers partner with specific carriers to handle their shipments. These preferred shipping partners can help waive handling fees, offer substantial discounts, and ensure that packages reach their destinations on schedule. It’s always worth asking if your service provider has a preferred shipping partner and what advantages it offers.

4.  Include Carrier Account Numbers

Service providers often have account numbers with major shipping carriers. It’s always wise to include this information in your shipping documentation in order to take advantage of the above mentioned benefits as well as to ensure quick and accurate billing.

5.  Shipping Internationally? Ask For Broker Info

International shipments are processed by customs before they are delivered. Knowing who your service provider’s customs broker is, and documenting that information on both the Commercial Invoice and the air waybill can save you weeks of delay and frustration.

Duncan Aviation is a full service aircraft parts supplier. Our shipping information and preferred shipping partner is available online at www.DuncanAviation.aero/parts.

 

Once upon a time, a regulatory compliance manager for an aircraft service provider sat between representatives of the Federal Aviation Administration (FAA) and the Environmental Protection Agency (EPA). The topic of discussion was aircraft painting regulations.

The FAA rep said "you must apply aircraft paint according to the manufacturer’s maintenance manual." The EPA rep said "the chemicals required by the maintenance manual aren’t environmentally friendly. You must paint aircraft using other, safer chemicals."

The compliance manager asked: "Now wait a minute, who has the bigger stick?"

Turning to the FAA rep he asked: "If I don't use the processes specified in the maintenance manual, you’ll slap my hand?" To which the FAA rep said: "Yes, absolutely."

Turning to the EPA rep he asked: "If I continue to use the chemicals specified in the maintenance manual, you’ll slap my hand?" To which the EPA rep said: "Oh yes, definitely."

Before he could ask, both reps said at the same time: "And I’m the most important agency!"

Long story short, the compliance manager, the FAA rep and the EPA rep reached a conclusion that all parties could drink to. If an aircraft paint shop had an FAA-approved paint process, it would provide an acceptable alternative to the paint process specified in the maintenance manual.

By using an FAA-approved process, the service provider would be in compliance with FAA regulations, which made the FAA rep happy. The service provider would also be using more environmentally friendly products, which made the EPA rep happy. And no matter what a maintenance manual would require, the paint shop would be able to use one standard paint process, which made the compliance manager happy.

Everyone went home without any hand-slapping and the paint shop manager rejoiced.

That was 15 years ago, but the story holds true today. Ask Mike Mertens, Regulatory Compliance Manager at Duncan Aviation’s Lincoln, Neb. facility. He says for an aircraft paint shop to be a FAA certified repair station, they must apply aircraft paint according to the processes specified in an aircraft’s maintenance manual, no matter what.

This poses a unique problem for manuals that do not specify a paint process. According to FAA regulations, those aircraft technically can’t be painted. Service providers seeking to provide chrome-free aircraft paint also find themselves caught between the two regulatory agencies.

Using a paint manufacturer’s process is not an FAA-accepted alternative, says Mike. The only legal way to provide a paint process that differs from the maintenance manual is to have an FAA-approved aircraft painting procedure. Not many service providers have them.

Duncan Aviation is among the few business aircraft maintenance, repair and overhaul companies with a FAA-approved, chrome-free aircraft painting procedure. So no matter what’s specified in an aircraft’s maintenance manual, the paint procedure meets federal regulations.