Installing seat belts on pre-78 SE aircraft

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gapper
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Installing seat belts on pre-78 SE aircraft

Post by gapper » Sat Feb 02, 2019 3:03 am

I'm considering buying a small aircraft built before the requirement for shoulder belts. This particular aircraft has a single seatbelt for the rear passengers. In the USA in this particular aircraft (Maule M5) people are installing Hooker 4 point inertia belts on the front seats, and 2 fixed(non inertia) 3 point belts in the rear seats.
Has any one done this in Canada and has TC given approval with out much protest? Thank You for any help with this topic
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Sat Feb 02, 2019 7:14 am

PilotDAR will be along shortly...
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Re: Installing seat belts on pre-78 SE aircraft

Post by PilotDAR » Sat Feb 02, 2019 9:24 am

Based upon lots of experience, I suggest that you install a separate four point (Hooker) harness for each occupant. Avoid the inertial reel type, they're expensive, you bang your head on them, and they're really not needed for a small cockpit. Just leave the shoulder portion of the harness slack as you need to to reach things, and snug them up if you think that the world is about to hit you.

Consider your installation as follows:

Read AWM 571, Appendix A,

https://www.tc.gc.ca/eng/civilaviation/ ... a-1893.htm

(b)(5) tells you that it's a major mod.

So, read AWM 571.06 (Minor/Major)

https://www.tc.gc.ca/eng/civilaviation/ ... s-1827.htm

(2)(a) tells you that you must use "approved" or "specified" data for a major mod. "Approved" data is needlessly expensive for what you're going to do IF specified data will cover it.

Read (1), "Specified Data", (d), and the little "i"s

You/your AME may find that AC43.13-2B is appropriate specified data for this installation.

https://www.faa.gov/documentLibrary/med ... .13-2B.pdf

Chapter 9, look at Figure 9-19 in particular, it is probably closest to what you need. Also pay close attention to figures 9-3, 9-4, 9-5, 9-6, and 9-7. And, read the rest of Chapter 9, to assure that you capture all of the themes in there for your intended installation design. As you consider your design, write down how what you are doing to the plane most closely complies with what you have read in Chapter 9. If there are any conflicts, make sure you resolve them, and document what you did. This is a case where writing more is better. If you have done a good job of this, TC Inspectors will issue proud smiles - I discussed this very topic with two TC Inspectors at a recent seminar. They, as I, expressed agreement that any good job you do to make occupant safety better is worthy of appreciation, not TC challenge.

That said, if there is an accident, and someone is hurt in your plane, it will be the insurance company, and TSB who look first, and with most interest as to what you have done. If what you have done genuinely complies with the intent of the AC43.13-2B Chapter 9 data as appropriately as possible, you have met your obligation of compliance for the installation.

Do a good job. Make the installation as if someone's life depends upon it - it could. Further back in these pages, you will find reference to the story of my ripping the seatblets right out of an aircraft, as I was ejected through the windshield. The airplane was correctly equipped, and compliant, just the crash forces well exceeded the design requirements. This is why the very latest GA airplanes require 18G dynamic, rather than 9G static load capacity for seats and seatbelts. Survivable crashes can exceed the design requirements, so don't skimp on compliance.

I have Hooker four point harnesses in all three of my planes. There are other brands which are good too, though I find that Hooker ticks all the boxes for me.

On the topic, for the Cessna owners reading here, be horrifically aware that some Cessnas left the factory with the pin on the lap belt tab for the shoulder harness on the wrong side relative to the shoulder harness. The result can be the with the single shoulder harness connected to the lap belt pin, the occupant was diagonally connected to the plane, even if the lap belt was released. If that errant condition still exists in a Cessna, changing the lap belt side for side might resolve it, though some had uneven lengths of lap belt halves, in which case, that won't work. The Hooker harness is excellent in this regard, as releasing the lap belt releases everything at once.

I was once asked to "inspect" a type I was familiar with, as the AME working on it was not. I looked at the shoulder harness installation (older type, originally did not have a shoulder harness). The four point shoulder harness ceiling attachment was screwed into upholstery trim with a sheet metal screw. I took my Swiss Army knife out, unscrewed the single #8 sheet metal screw, removed the entire shoulder harness, and handed it to the rather surprised AME, as the owner looked on - not compliant = liability all the way around after the crash! I suggested the foregoing data path, and that plane now has a good shoulder harness installation!''

I hope that helps - your friendly DAR....
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Re: Installing seat belts on pre-78 SE aircraft

Post by 5x5 » Sun Feb 03, 2019 9:26 am

And just in case I'm not the only one here that doesn't (now didn't) know what a DAR is ......https://www.tc.gc.ca/eng/civilaviation/ ... 01-917.htm
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Re: Installing seat belts on pre-78 SE aircraft

Post by Pavese » Mon Feb 04, 2019 6:23 pm

Good, solid write up PilotDAR! Thanks for your regular contributions to this forum.

OK, PilotDAR's writeup reminded me of something that I think is overlooked in GA.

While we're on the subject of safety belts, it's worth having a think about the age of the belts you're depending on to save your life.

Safety belt material has a finite life. How old are the belts in your plane? Original??

It's not just physical wear that degrades safety belts, exposure to the environment has a way of degrading the tensile strength of the material used for the webbing. As a result and probably driven by injuries & claims, sanctioning bodies for car racing (no doubt pushed by their insurers) have come to a de facto standard acceptable life of...two years. This limit is applied to local grass roots Saturday night bullrings right up through professional levels. The tag on the belt shows the production date, if it's older than two years you don't race.

This article:

https://www.prpseats.com/replace-harnes ... two-years/

talks to the subject including correct installation and presents some test lab data on the reduction in strength with relatively little exposure to the environment, especially UV.

Worth looking at your belts and if they're old and faded chances are they are past their prime.

Hope this was helpful. :)

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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Mon Feb 04, 2019 6:48 pm

Typical replacement interval for aircraft seatbelt webbing is 12 years, I believe.
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Re: Installing seat belts on pre-78 SE aircraft

Post by Pavese » Mon Feb 04, 2019 6:52 pm

photofly wrote:
Mon Feb 04, 2019 6:48 pm
Typical replacement interval for aircraft seatbelt webbing is 12 years, I believe.
Is that a CARS thing?

I wonder how well known that is....

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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Mon Feb 04, 2019 7:01 pm

Pavese wrote:
Mon Feb 04, 2019 6:52 pm
photofly wrote:
Mon Feb 04, 2019 6:48 pm
Typical replacement interval for aircraft seatbelt webbing is 12 years, I believe.
Is that a CARS thing?
No, it’s set by the aircraft manufacturer. I just did one, but I’ll check and see how many others are set at 12 years.

Oops... 10 years for new 182’s, apparently, but no time limit for legacy Cessnas.

No hard time limits are mandatory for privately operated small aircraft though.
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Re: Installing seat belts on pre-78 SE aircraft

Post by PilotDAR » Mon Feb 04, 2019 8:51 pm

I am aware that Cessna requires replacement of seat belts every ten years (applicable to commercially operated Cessnas) - the C 207 I used to fly got caught by this, and was suddenly grounded awaiting new belts. I recall the actual airworthiness limitation for this being a little obscure, but I have read it as a Cessna document. AC43.13 just directs the reader to the manufacturer's data - so ten year replacement for commercial Cessnas, on condition for private ones.

In the mean time, the TSO requirements for seatbelts are here:

http://rgl.faa.gov/Regulatory_and_Guida ... E/C22g.pdf

In particular, "Marking" which essentially drives you to having to buy TSO's replacement seatbelts, rather than rewebbing. I believe that there are rewebbing companies out there, airlines probably use them, but for GA, I have only known people to buy new belts.

Though they're probably all long gone by now, the old Cessna belts which had a cam type latch, which bore down directly onto the webbing are illegal by AD - and unsafe. Metal to metal latches are required.
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Re: Installing seat belts on pre-78 SE aircraft

Post by Woody42 » Wed Feb 06, 2019 12:48 pm

Hey DAR,
Where do the CARs state the different requirements for Commercial vs. Private maintenance requirements. I know Cessna states right in their maintenance manual to replace the seat belts every 10 years and we do that on our commercial aircraft. But where do the CARs state that for private they can be on condition.

Also we get ours re webbed by Aerotex Interiors in Calgary.
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Re: Installing seat belts on pre-78 SE aircraft

Post by ahramin » Wed Feb 06, 2019 1:10 pm

The selected maintenance schedule is recorded on the front page of your Journey Logbook as well as the Technical Logbook.
Maintenance Schedule
605.86 (1) Subject to subsection (3), no person shall conduct a take-off in an aircraft, or permit a take-off to be conducted in an aircraft that is in the person’s legal custody and control, unless the aircraft is maintained in accordance with

(a) a maintenance schedule that conforms to the Aircraft Equipment and Maintenance Standards; and

(b) where the aircraft is operated under Subpart 6 of Part IV or under Part VII, or is a large aircraft, a turbine-powered pressurized aircraft or an airship, a maintenance schedule approved by the Minister in respect of the aircraft operator pursuant to subsection (2).
625.86 Maintenance Schedules

(1) Pursuant to CAR 605.86, all aircraft, other than ultra-light or hang-gliders, shall be maintained in accordance with a maintenance schedule, approved by the Minister, that meets the requirements of this Aircraft Equipment and Maintenance Standard 625.

(2)

(a) As applicable to the type of aircraft, at intervals not to expire later than the last day of the 12th month, following the preceding inspection, Part I and Part II of the Maintenance Schedule detailed in Appendix B of these standards are approved by the Minister for use on other than large aircraft, turbine-powered pressurized aeroplanes, airships, any aeroplane or helicopter operated by a flight training unit under CAR 406, or any aircraft operated by air operators under CAR Part VII.
(amended 2007/12/30)

(b) Owners of non-commercially operated small aircraft and balloons must also comply with Appendix C with respect to out of phase tasks and equipment maintenance requirements.

(c) Owners of non-commercially operated small aircraft and balloons who choose to comply with Parts I or II of Appendix B as applicable, and Appendix C, need not submit any documents to the Minister for formal approval. The schedule is considered to be approved for their use by the Minister. Owners need only to make an entry in the aircraft technical records that the aircraft is maintained pursuant to the maintenance schedule.
The only scheduled maintenance required is found in 625 Appendix B (I), 625 Appendix C, and any AD. For homebuilts even the ADs aren't mandatory. Everything else is up to the owner to decide.

Specifically 625 B (I) (3) (b)
Seats and safety belts - inspect for poor condition, fraying, and any other apparent defects;

No mention of a calendar limit, and no mention of seat belts in 625 C.
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Wed Feb 06, 2019 1:41 pm

RIght.

So the chain of requirements goes like this:

605.86(1): nobody can conduct a takeoff unless the aircraft is maintained in accordance with a maintenance schedule that conforms to yada yada yada.
605.86(2): the Minister shall approve a maintenance schedule if yada yada yada.

Journey log requirements:

605.94 (1) The particulars set out in column I ... shall be recorded in the journey log at the time set out in column II of the item and by the person responsible for making entries set out in column III of that item.

Well, column 1 includes "(a) a description of the applicable maintenance schedule;" so unless it's a part 7 operation with equivalent dispatch procedures yada yada yada, you *must* be able to find the maintenance schedule at the front of the Journey Log.

Then refer to 625.86 that says...
As applicable to the type of aircraft, at intervals not to expire later than the last day of the 12th month, following the preceding inspection, Part I and Part II of the Maintenance Schedule detailed in Appendix B of these standards are approved by the Minister for use on other than large aircraft, turbine-powered pressurized aeroplanes, airships, any aeroplane or helicopter operated by a flight training unit under CAR 406, or any aircraft operated by air operators under CAR Part VII.
(amended 2007/12/30)

(b) Owners of non-commercially operated small aircraft and balloons must also comply with Appendix C with respect to out of phase tasks and equipment maintenance requirements.

(c) Owners of non-commercially operated small aircraft and balloons who choose to comply with Parts I or II of Appendix B as applicable, and Appendix C, need not submit any documents to the Minister for formal approval.The schedule is considered to be approved for their use by the Minister. Owners need only to make an entry in the aircraft technical records that the aircraft is maintained pursuant to the maintenance schedule.
So that's a bargain: CAR625 Appendices B & C have already been blessed with blanket approval for non-commercially operated small aircraft. No need to apply to the minister with a copy of your proposed maintenance schedule, and no need to pay the fee, whatever it is.

So that's what you need to comply with.
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Re: Installing seat belts on pre-78 SE aircraft

Post by Woody42 » Wed Feb 06, 2019 2:13 pm

Yes but, It states in CARs 625 appx C the following.

"(3) Nothing in these standards relieves the owner from the responsibility for determining the applicability of these requirements to his/her aircraft, or for identifying any other maintenance requirements relating to equipment not listed here.

This is note 3 near the top of the appx.

The way I read this is that seat belts are not listed in Appx C but the owner still has the responsibility to identify that Cessna states 10 year replacement and comply with that.
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Wed Feb 06, 2019 3:23 pm

Cessna can only have a life limitation on a part as part of the type design. Other than that, only an Airworthiness Directive can force your hand at maintenance on a component at specific intervals.
201.09 (1) The manufacturer of a component for which a life limitation has been established by type design shall place thereon, in accordance with subsection 201.05(2), the identification information referred to in subsection (2).
(2) The identification information that shall be placed on a component is
(a) the part number of the component or an equivalent series of identifying characters; and
(b) the serial number of the component or an equivalent series of identifying characters.
So life limited parts also have to be serialized.

Now your Maintenance Control Manual (which commercial operators are obliged to have) may say that you will always obey manufacturer's recommendations, in which case, that's what you have to do.

Or your MCM may say "Upon receipt of all recommendations issued by the aircraft, engine, propeller and component manufacturers in the form of service bulletins or equivalent documents, the maintenance manager shall review the recommendations to determine whether compliance is appropriate."

In which case, that's what you have to do: review the recommendations and determine whether compliance is appropriate.

But just because Cessna says something has to be overhauled, or replaced, don't automatically make it so. In Canada, anyway.
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Last edited by photofly on Sun May 26, 2019 7:58 am, edited 4 times in total.
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Re: Installing seat belts on pre-78 SE aircraft

Post by Woody42 » Wed Feb 06, 2019 3:35 pm

But just because Cessna says something has to be overhauled, or replaced, don't automatically make it so. In Canada, anyway.
But that statement in CAR 625 appx C seems to stay just that. If not what is it saying?
(3) Nothing in these standards relieves the owner from the responsibility for determining the applicability of these requirements to his/her aircraft, or for identifying any other maintenance requirements relating to equipment not listed here.
I agree with service bulletin. Transport is fine with those being reviewed and decided on whether your going to comply or not. But transport does not seem to be ok with things listed in the maintenance manual not being complied with.
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Wed Feb 06, 2019 3:54 pm

Woody42 wrote:
Wed Feb 06, 2019 3:35 pm
But just because Cessna says something has to be overhauled, or replaced, don't automatically make it so. In Canada, anyway.
But that statement in CAR 625 appx C seems to stay just that. If not what is it saying?
(3) Nothing in these standards relieves the owner from the responsibility for determining the applicability of these requirements to his/her aircraft, or for identifying any other maintenance requirements relating to equipment not listed here.
You have to determine the requirements. But Cessna saying so in a service bulletin doesn’t make it a requirement. So when you identify the requirements, that’s not one you have to identify.
I agree with service bulletin. Transport is fine with those being reviewed and decided on whether your going to comply or not. But transport does not seem to be ok with things listed in the maintenance manual not being complied with.
I don’t see why Cessna should be permitted to do an end run around the requirements for formal AD simply by listing something in the maintenance manual.

As far as I know, maintenance has to be conducted “according to” the maintenance manual. So when you change the seatbelts you have to follow the procedures listed for that task. “According to” doesn’t in my understanding mean “everything listed in”.

A recent addition to the MM doesn’t change the approved maintenance schedule, either.

Still, I shall be interested to know if there’s a better answer.

In my case, I’m interested because a part for an airplane I have an interest in was given a “mandatory” service bulletin for replacement at certain intervals, and added to the MM list of life-limited parts. Unlike some MSBs, this one was *not* made the subject of an AD. The newly added limitation certainly wasn’t the basis on which the aircraft met certification. So I’m interested in the “right” answer.
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Sun May 26, 2019 7:58 am


But just because Cessna says something has to be overhauled, or replaced, don't automatically make it so. In Canada, anyway.
Things I have learned recently:

Only section 4 of the Maintenance Manual ("Airworthiness Limitations") has time limits that are mandatory as issues of airworthiness. Everything else is a maintenance issue, and depends on your maintenance schedule.

Cessna tried to get a AD issued for a periodic inspection of the spar of the P210; when the FAA declined to issue an airworthiness directive Cessna got a different branch of the FAA to approve an amendment to Chapter 4 of the Maintenance Manual to mandate the same inspections as an airworthiness limitation. The FAA in Washington subsequently issued a Letter of Intepretation (https://www.faa.gov/about/office_org/he ... tation.pdf) saying this was ineffective: Airworthiness Limitations cannot be added for any aircraft having already been built. An approved change to the Airworthiness Limitations section of the Maintenance Manual would constitute a change to the type design for subsequently-built aircraft of that type but would not have any retroactive effect.

Among the reasons given in the LOI is that the "FAA does not have legal authority to delegate its rulemaking authority to manufacturers".

I note that in Chapter 3 of Transport Canada's "Delegation Handbook for Designated Engineers and Design Approval Representatives" (http://www.tc.gc.ca/eng/civilaviation/c ... u-1295.htm) the Minister writes
In general, Transport Canada retains authority and responsibility for examining, accepting, and approving (as appropriate):...A limitation contained in a Maintenance Manual or a Maintenance Manual Supplement;
and that the same argument could be made in Canada as in the US.
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: Installing seat belts on pre-78 SE aircraft

Post by corethatthermal » Sun May 26, 2019 7:42 pm

Doesnt hooker or the other biggies have an STC covering the Maule ?
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Re: Installing seat belts on pre-78 SE aircraft

Post by boeingboy » Mon May 27, 2019 10:47 am

As far as I know, maintenance has to be conducted “according to” the maintenance manual. So when you change the seatbelts you have to follow the procedures listed for that task. “According to” doesn’t in my understanding mean “everything listed in”.
No - it doesn't.

Any maintenance has to be done in accordance with applicable data. The MM is not an approved manual. SRM's are approved - and you would have to follow them - but not MM's

You could throw the MM over your shoulder and use AC 43. 13 for example, if you wanted....of course - why would you want to?
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Mon May 27, 2019 3:12 pm

boeingboy wrote:
Mon May 27, 2019 10:47 am
As far as I know, maintenance has to be conducted “according to” the maintenance manual. So when you change the seatbelts you have to follow the procedures listed for that task. “According to” doesn’t in my understanding mean “everything listed in”.
No - it doesn't.
Well, let's see:
571.02 (1) Subject to subsection (2), a person who performs maintenance or elementary work on an aeronautical product shall use the most recent methods, techniques, practices, parts, materials, tools, equipment and test apparatuses that are

(a) specified for the aeronautical product in the most recent maintenance manual or instructions for continued airworthiness developed by the manufacturer of that aeronautical product;

(b) equivalent to those specified by the manufacturer of that aeronautical product in the most recent maintenance manual or instructions for continued airworthiness; or

(c) in accordance with recognized industry practices at the time the maintenance or elementary work is performed.
Your choice is therefore a) what's in the maintenance manual b) equivalent to what's in the maintenance manual or c) what every one else does. AC43.13 would fall under (c).

In case anyone was wondering, an "aeronautical product" is defined in the Aeronautics act as "any aircraft, aircraft engine, aircraft propeller or aircraft appliance or part or the component parts of any of those things, including any computer system and software;"

But, the point stands: when you do something, you have to do it in the way the MM says (or an equivalent way, or do what everyone else does) but (other than any tasks in the approved section of airworthiness limitations) you don't have to carry out every task in it.
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: Installing seat belts on pre-78 SE aircraft

Post by Heliian » Tue May 28, 2019 9:26 am

boeingboy wrote:
Mon May 27, 2019 10:47 am
As far as I know, maintenance has to be conducted “according to” the maintenance manual. So when you change the seatbelts you have to follow the procedures listed for that task. “According to” doesn’t in my understanding mean “everything listed in”.
No - it doesn't.

Any maintenance has to be done in accordance with applicable data. The MM is not an approved manual. SRM's are approved - and you would have to follow them - but not MM's

You could throw the MM over your shoulder and use AC 43. 13 for example, if you wanted....of course - why would you want to?
Maybe in some cases where support is no longer available but the majority of aircraft have a MM and the procedures in it are to be used and quoted when performing maintenance. The maintenance manual is an approved document. It's your responsibility to use the most current.

The situation also changes depending on the category of aircraft and the type of operation.
photofly wrote:
Sun May 26, 2019 7:58 am
he FAA in Washington subsequently issued a Letter of Intepretation (https://www.faa.gov/about/office_org/he ... tation.pdf) saying this was ineffective: Airworthiness Limitations cannot be added for any aircraft having already been built.
Well, they don't know what they're talking about. Ch4. ALS can be changed and updated. The manufacturers have to to keep up with new retirement lives or part numbers. Only the useless, antique FAA would say that you can't change it.
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Re: Installing seat belts on pre-78 SE aircraft

Post by photofly » Tue May 28, 2019 9:35 am

The FAA takes the position that after-the-fact airworthiness limitations require an Airworhiness Directive to be mandatory.

Manufacturers can add whatever maintenance requirements they want but matters of airworthiness are reserved to the national regulator to determine. The type design of a particular airframe is not an open ended process open to change but is fixed at the time of certification.
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: Installing seat belts on pre-78 SE aircraft

Post by Heliian » Tue May 28, 2019 10:57 am

photofly wrote:
Tue May 28, 2019 9:35 am
The FAA takes the position that after-the-fact airworthiness limitations require an Airworhiness Directive to be mandatory.

Manufacturers can add whatever maintenance requirements they want but matters of airworthiness are reserved to the national regulator to determine. The type design of a particular airframe is not an open ended process open to change but is fixed at the time of certification.
LOL. They should have taken their own advice with the 737

The FAA must hate it when other jurisdictions make changes to their ALS 4 then.
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Re: Installing seat belts on pre-78 SE aircraft

Post by boeingboy » Thu May 30, 2019 6:47 pm

The maintenance manual is an approved document.
No it's not.
That is a common misconception.

The MM is published by the Manufacturer - it is never submitted to the FAA (or any other regulator) for approval. It is only applicable data.
The SRM on the other hand is approved....and it says so at the bottom of each page. If amended it is sent to the regulator for approval.

As I said - you can toss the MM away and use any applicable data to maintain your aircraft legally....but I don't think anyone really would.
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