The Cracked Step Bracket, the Dead Attitude Indicator, and the Untagged Doubler
A Cessna 182P, normal category, privately operated under Part 91, arrives for its annual inspection at 4,120 hours total time. The owner needs the airplane Friday for a business trip. Findings: (1) the left main landing gear step bracket is cracked through one of its two attach bolts, and the skin around the bolt holes is distorted; (2) the attitude indicator is inoperative, removed and the lines capped, cockpit placarded INOPERATIVE, and the owner flies VFR only; (3) last year a shop riveted a doubler across a 4-inch longitudinal crack in the skin near the firewall; the log entry is signed by an A&P but references no FAA Form 337 and no approved data. The owner asks you to 'sign it off as inspected and just hand me the list of squawks,' then fly it 60 miles to his home shop.
1. Can you sign an approval for return to service? What exactly goes into the maintenance records?
Read the worked answer
No. Section 43.11(a) gives an annual inspection only two lawful outcomes: a certification that the aircraft was inspected in accordance with an annual inspection and was determined to be in airworthy condition, or, when the aircraft cannot be approved for return to service because of needed maintenance, noncompliance with applicable specifications or airworthiness directives, or other approved data issues, a list of discrepancies and unairworthy items furnished to the owner.
The cracked step bracket with distorted skin, and the doubler repair with no Form 337 and no approved data, are airworthiness items. There is no middle option. Signing the airworthy statement 'with squawks noted' is a false certification and is precisely the document the owner would rely on to operate under Section 91.407(a).
Record: type of inspection and its extent, date, aircraft total time, your signature and certificate number, and the discrepancy list, with a copy furnished to the owner. No approval for return to service.
2. How do you dispose of the inoperative attitude indicator?
Read the worked answer
Work Section 91.213(d). It permits operation of a non-turbine aircraft not operated under Part 121, 135, or 129 with inoperative instruments or equipment only if all of the following hold: the item is not required by the aircraft's equipment list or kinds-of-operations equipment list; it is not required by Section 91.205 for the intended operation; it is either removed with the cockpit control placarded and the maintenance recorded under Section 43.9, or deactivated and placarded; and it does not constitute a hazard to safe operation.
Check three things: (a) does the TCDS or approved equipment list for this serial number show the attitude indicator as required equipment (if so, it cannot be deferred as configured); (b) is there a Section 43.9 entry for the removal, or did someone pull it without a record; (c) are the vacuum lines capped so they cannot create a hazard. If the placard and entry are correct and the item is not required equipment for this VFR operation, the instrument is a non-issue for the annual; the other two findings are not.
3. The owner wants to fly it to his home shop for repairs. What are his lawful options, and what can you do?
Read the worked answer
No flight without approval for return to service. Section 91.407(a) prohibits operation after maintenance until the aircraft has been approved for return to service, and you have not approved it.
Three paths. One, repair on site: the doubler requires approved data - the manufacturer's structural repair manual, an STC, or a field approval or DER-approved repair - and if it is a major repair it must be documented on FAA Form 337. A repair derived from AC 43.13-1B methods is acceptable data, not approved data, for a major structural repair. Two, a special flight permit: an Inspection Authorization holder cannot issue one. The owner applies to the FAA (or a designee) under Part 21 for a permit limited to the purpose of flying the aircraft to a repair facility, and it will only be issued if the aircraft is capable of safe flight for that purpose and the permit conditions are met. Three, disassemble and truck it.
The business trip is not an authorized purpose for a special flight permit.