Posts Tagged ‘ownership’

Hangnails and Hand Transplants

Tuesday, April 12th, 2016
Engine teardown

Here’s what happens to your engine when you send it in for major overhaul. Do you really want to do this?

You know me. I believe in running engines as long as they’re demonstrably healthy, even if that means going beyond the manufacturer’s recommended TBO. Nothing disturbs me more than when I hear about owners who get talked into (or talk themselves into) euthanizing engines that are running just fine.

Case in point: Here’s an email I received from a Bonanza owner seeking a second opinion on what to do about his Continental IO-520 engine:

“The engine is now at 1500 hours (TBO is 1700) and it seems to be running very well. But here’s the bad part: it’s using a quart of oil every 4 hours, and putting a LOT of oil on the belly of the aircraft, even with an air/oil separator installed.

“So what should I do? Should I get a field overhaul, or opt for a factory rebuilt engine? (The engine does NOT have a VAR crank.) Should I consider an STC upgrade to an IO-550? I’m leaning toward using Superior Millennium cylinders, do you agree?”

I took a deep breath and counted to ten. This owner just told me that he as a fine-running engine, yet he’s already concluded it needs to be overhauled or replaced. What was he thinking? It sure wasn’t clear to me that this engine had any major issues, much less anything requiring immediate euthanasia.

Where’s the beef?

So what if it’s using a quart in 4 hours? Is that so terrible?

No, it isn’t. Continental SID97-2B is the bible when it comes to determining the airworthinss of Continental cylinders, and here what it has to say about oil consumption:

Oil consumption can be expected to vary with each engine depending on the load, operating temperature, type of oil used and condition of the engine. A differential compression check and borescope inspection should be conducted if oil consumption exceeds one quart every three hours or if any sudden change in oil consumption is experienced and appropriate action taken.

This guidance indicates that the Bonanza’s oil consumption of a quart in four hours is perfectly acceptable. Even when Continental’s oil consumption threshold of a quart in three hours is exceeded, Continental simply calls for a borescope inspection to determine if there’s really a problem. If the cylinders look okay under the borescope, the engine can remain in service despite the high oil consumption.

SID97-2B also indicates that in February 1997, Continental actually reduced the tension on the oil control rings in its cylinder assemblies to increase oil consumption to achieve improved lubrication of the cylinder bore. A certain amount of oil consumption is essential for maximum cylinder life. When it comes to oil consumption, less is not necessarily always a good thing.

Bottom line is that it’s quite likely that there’s nothing at all wrong with the engine in this owner’s Bonanza. At worst, perhaps it has a couple of worn cylinders that might need to be replaced eventually. Even that’s not clear, since the owner didn’t mention low compression readings. Maybe all he needs is some new piston rings.

A worn jug is like a hangnail

Cracked cylinder head

Cylinder problems (like this head crack) call for cylinder work, not euthaizing the whole engine.

Even if a borescope inspection reveals that the engine has a worn-out jug or two, so what? Both Continental and Lycoming cleverly designed their engines so that the cylinders were bolt-on accessories that can be repaired or replaced without removing the engine from the airframe or splitting the case. If the engine actually does have badly worn cylinders, that’s a reason to repair or replace the jugs, not to tear down the whole engine.

Think about this for a moment. If some other bolt-on engine accessory went bad—say an alternator or vacuum pump or magneto or prop governor—would you let your mechanic remove the engine and have it major overhauled? Of course not.

If you had a hangnail, would you go to a surgeon for an amputation and hand transplant? No, I didn’t think so!

Why would an aircraft owner even consider major overhaul or engine replacement just because one or two cylinders might be worn out? To my way of thinking, it doesn’t matter whether an engine is at 100 hours since new or 100 hours past TBO—a sick cylinder calls for cylinder replacement, not engine replacement.

Euthanasia is a bit much

Here’s what I emailed back to the owner:

“I would NEVER consider overhauling an otherwise good-running engine just because it has high oil consumption. There’s nothing wrong with burning a quart in 4 hours, so long as your sparkplugs aren’t oil-fouled and your compressions are within acceptable limits. If things get bad enough and you find one or more cylinders with unacceptably low compression, you may want to consider replacing them. That’s why Continental makes its engines with bolt-on cylinders: so you can change them without having to overhaul the engine. The ONLY valid reason for overhauling an engine is a problem with the “bottom end” (crankcase, crankshaft, camshaft, gears, main bearings, etc.) that cannot be cured without splitting the case.

“Have you simply tried running the engine at a lower oil level on the dipstick? Big-bore Continental engines are famous for throwing out excess oil if the crankcase is overfilled. The TSIO-520s on my T310R have a 12-quart sump, but I typically run them at 8 quarts on the dipstick.

“Excessive oil on the belly is usually caused by excessive crankcase pressure. Sometimes this is due to worn cylinders that permit excessive blow-by past the rings (in which case your cylinders will show low compression readings and your oil will get dirty very quickly after each oil change). But it can also be due so something as simple as an oil filler cap that isn’t sealing properly (when did you last check the oil cap gasket?) or a leaky front crankcase seal (which is not difficult to change).

“It sounds to me as if you may be a long way from needing to major-overhaul this engine. If you do decide to overhaul it anyway, drop me another email and I’ll offer some suggestions. But I really think that any consideration of rebuild/overhaul at this point is way premature.”

Don’t obsess about the manufacturer’s published TBO. It’s just a suggestion, not a requirement or a life limit. (The engines on my Cessna T310R are made it well past 200% of TBO and were still running magnificently.) When your engine is ready for overhaul, it’ll let you know by starting to make metal or to leak oil or to crack their crankcases or spall their cam lobes or something else obvious to let you know that “it’s time.” That’s the time to overhaul them. Doing it earlier always strikes me as being a capital crime.

Learn like you are going to live forever

Friday, April 1st, 2016

Tell me and I forget.

Teach me and I remember.

Involve me and I learn.

—-Benjamin Franklin

maggie upside downIn mid-August of 2003 I attended an AOPA Air Safety Institute [ASI] pilot safety seminar in Portland entitled “Take Offs and Landings.” Little did I know that a few days later I would be putting both those skill sets in use when I had an engine failure at take off in Hood River, Oregon. My story was used in AOPA’s 2004 Nall Report and as well in AOPA’s seminar series called: ­­­­­­Real Pilot Stories. I credited my flight instructor, the ASI seminar, and my training for turning a potentially life threatening situation into an “off-airport” landing.

 

 

 

 

Recently I got the opportunity to talk with Mark Grady. Mark has presented safety seminars all over the country. A veteran with nearly 20 years of experience, Mark has seen it all. I hope that this interview is helpful for you, and will inspire you to attend one of the many AOPA or FAAST safety seminars offered.Mark&Allegro2-Crop1

How long have you been teaching Mark?

“I’ve been presenting aviation safety seminars for almost 20 years. I started doing seminars for the North Carolina Division of Aviation. I was then signed by the Aviation Speakers Bureau. Shortly thereafter, I became one of the AOPA Air Safety Institute presenters.”

Why do you feel called to teach aviation safety seminars?

“My father was a very safety-conscious man. I think I got a little of that from him. What really sealed the deal for me was during my ten years of being a traffic watch pilot and reporter in Raleigh. I did that from 1980 until 1987. Seeing the number of traffic accidents I covered, I thought often that drivers could learn a lot from pilot training and that pilots who may drive too aggressively have the potential to be unsafe aviators. It really is all about human factors. “

What do you do at your seminars to promote the active exchange of fears/ideas/education?

“The large amount of content in the AOPA Air Safety Institute seminars prevents too much time being taken by the attendees during the actual two-hour seminar, but we certainly promote the continuing education of all pilots. That doesn’t have to just take place during flight reviews. In fact, I think the more we try to stay safety conscious during all we do, including driving, the more likely we are to be better pilots. In addition to the online seminars, AOPA ASI has really great online courses for pilots who take information, training and safety seriously.”AOPA-SAC-12Jan2016

Who is your typical attendee?

“That’s a good question. While most of the attendees have appeared to be over 40, I have been encouraged over the number of younger pilots who have been coming recently. As far as the experience level of the attendees, it’s far reaching. We’ve had people attend who are just becoming interested in learning to fly right on through ATP pilots and even pilots who flew warbirds in World War II.”

 Do you ever hear any stories from attendees about how they have put the seminars to use in the sky?

“Absolutely! It’s rare I’ve given a seminar where a pilot does not come up at the end and tell me a first-hand account of how something he had heard at a seminar helped him in an emergency situation or kept him from getting into one.”

If you had a piece of advice for a lower time pilot in regard to education or safety, what would it be?

“It would be to strive to be a pilot of excellence. In fact, I’m writing a book titled “Pilot of Excellence” now. There is no such thing as a perfect pilot, but we can strive to be excellent. That requires a big commitment to remain aware during all phases of flight. Just one example is when we are going through a checklist. If we are not focusing on each checklist item and why we are doing that item on the checklist, we are simply giving ourselves a false sense of security that everything is ok. There is no reason to be bored on a flight. There is always something to do, especially playing the what-if game.”

Is there anything you would tell your younger, pilot-self that you wished you knew?

“To not look at a flight review as a test, but an opportunity. We ALL have weak areas. None of us knows it all. So, if we want a great flight review, I recommend spending at least 15 minutes the day before we meet with the instructor to be honest and write down our weak areas. Then ask the instructor to help us work on those. Now, that’s a good way to become an excellent pilot! By being honest with ourselves about our weaknesses. “

“I had one guy at a seminar ask me, “How do I decide what my weak areas are?” I told him to use the same thought process he probably had going for his private pilot checkride. I think most of us went to that ride praying the examiner would not get too deep into a subject area we thought we were a little weak on”.

“When you think about it, I find it amazing we can take to the sky, with family and friends on board, and fly all over the U.S. with only 40 hours of flight training. That’s why the examiner always says, “This is your license to learn” when he gives you that first temporary airman certificate. It may seem like a long time, but I recent experienced something that really put it in perspective. I was getting my hair cut when I noticed the young lady had a North Carolina Board of Cosmetology license in her cubicle. I asked her, “Does that take a lot of work to earn that?” Her response really shocked me. She said, “Oh, yes! Twelve hundred hours of training.” Wow.”

 

I suppose if it takes 1200 hours to be licensed to cut your hair, as pilots , we should strive to get as many hours of quality education as possible. Whether you opt for an online training course, a safety seminar, or calling up your local CFI and getting some dual, make sure you are learning like you are going to live forever. It might just be that learning that ensures you do so for many years to come.

Image - Version 2

AOPA Air Safety Institute Events: http://www.aopa.org/Pilot-Resources/Air-Safety-Institute/Events

AOPA Webinars: http://www.aopa.org/Pilot-Resources/AOPA-Webinars

EAA Webinars: http://www.eaa.org/en/eaa/aviation-education-and-resources/aviation-videos-and-aviation-photos/eaa-webinars

 

Choosing the Express Lane…using your private aircraft for business

Sunday, September 6th, 2015

Recently I was set to travel from the Central Coast of California to Oregon’s Columbia River Gorge and on into Kalispell, Mont. for a business meeting and a business consultation.

Ready for business

Ready for business

Had I opted to fly commercially the following scenario seems likely: Looking at commercial flights from San Luis Obispo Airport I would have needed to get to the airport an hour early for security, and then fly to Los Angeles or San Francisco for a connection.  From there, I would probably lay over for an hour or so, and connect into Portland.  Since Hood River is 45 miles east of Portland, I would have to rent a car and drive to the business meeting, which would add another two hours to the process.

Imagine that the initial flight leaves San Luis Obispo at 6:00 a.m.  My day would have started around 4:00 a.m. to get to the airport by 5:00 a.m.  The short, 45 minute flight to Los Angeles or San Francisco would be followed by a layover and change of planes.   Let us say I arrived in Portland at 10:30 a.m. and got to the rental car counter about 11:00.  The one-hour drive to Hood River puts me at my meeting at noonish.

Mt. Shasta

Mt. Shasta

Contrast that scenario, which has not even gotten me to Kalispell, to what I actually did in my private aircraft.  I drove twenty minutes to Santa Maria Airport and pre-flighted the Mooney.   I was in the air by 7:30 a.m. and made the 3.5 hour flight right to Hood River Airport, arriving at 11:00 a.m.  Instead of starting the day at 4:00 in the morning and arriving at noon, I had a wonderful flight up through California and by Mount Shasta.  The route took me over Klamath Falls, Sunriver, Bend, and Redmond, Oregon and then I flew down the Columbia River Gorge to the destination airport.  I was also able to take a full tube of toothpaste, water bottles, and even my hair cutting scissors!

After business was complete in Hood River, I departed the following morning for Kalispell, Mont.  Again I chose to land at Kalispell City Airport [S27] versus the larger international airport.  In under two hours my Mooney and I were in Montana ready for the next business consultation.

Besides saving time, are there other reasons to fly your private aircraft versus commercial travel for business?  You bet there are!  Not only do we avoid long waits, security screening that robs us of even a water bottle, and inflexible scheduling, but also we exercise our privilege to fly and help others to see the value of General Aviation. The view from the Mooney was spectacular and I arrived refreshed and ready for business. I also was able to fly. As pilots we get to live in the world 3-D, a view that most don’t get routinely.

General Aviation and General Aviation airports serve America and our business community.  If your business takes you to smaller communities not served by commercial flights, private air travel might just be the ticket for you.

The End

The End

Is Your Aircraft Okay to Fly?

Thursday, July 23rd, 2015

Who decides whether or not your aircraft is airworthy?

Airworthy steampEarlier this year, I wrote an article titled “Fix It Now…Or Fix It Later” that was published in a major general aviation magazine. The article discussed how to deal with aircraft mechanical problems that arise during trips away from home base. It offered specific advice about how pilots and aircraft owners can decide whether a particular aircraft issue needs to be addressed before further flight or whether it can safely wait until the aircraft gets back home. I considered the advice I offered in this article to be non-controversial and commonsense.

I was surprised when I received an angry 700-word email from a very experienced A&P/IA—I’ll call him “Damian” (not his real name)—condemning my article and accusing me of professional malfeasance in advising owners to act irresponsibly and violate various FARs. Damian’s critique started out like this:

After reading Mike Busch’s commentary “Fix It Now … Or Fix It Later,” I must take exception to most, if not all, the points made in his column. I believe his statements are misleading as to the operation of certified aircraft, to the point of being irresponsible for an A&P to suggest or imply that it’s up to the owner/operator whether or not to fly an aircraft with a known discrepancy. The FARs are quite clear on this matter, and there have been numerous certificate action levied on pilots who have operated aircraft with known discrepancies.

Damian went on to state that the FARs require that any aircraft discrepancy, no matter how minor, must be corrected and the aircraft approved for return to service “by persons authorized under FAR 43.7 (typically the holder of a mechanic certificate).” He went on to explain that the owner/operator may only approve for return to service those preventive maintenance items listed in FAR Part 43 Appendix A. He went on:

It should be noted that the FAA does not take into consideration the inconvenience or cost related to addressing a known discrepancy. Nor is it up to the owner/operator to determine the significance of a discrepancy as the FARs do not confer this discretion privilege to the owner/operator.

Damian’s attack on my article continued at great length, making it quite clear that his believe is that pilots and aircraft owners are mere “appliance operators” in the eyes of the FAA, and that only certificated mechanics are empowered to evaluate the airworthiness of an aircraft and determine whether or not it is legal and safe to fly. He ended his diatribe by saying:

I hope that others in the aviation community such as FAA Airworthiness Safety Inspectorss and aviation legal professionals weigh in on this commentary. I believe all will agree that this commentary is misleading and uninformed to the point of being irresponsible even to publish. At the very least, pilots that follows the advice of Busch’s commentary should enroll in the AOPA Pilot Protection Services plan because they’re likely to need it!

Whew! Strong stuff! If Damian is right, then the FAA had better lock me up and throw away the key. Fortunately for me, I believe he isn’t and (at least so far) they haven’t.

Where Damian Has It Wrong

Damian and I do agree on at least one thing: FAR 91.7 does indeed say quite unequivocally that it is a violation to fly an unairworthy aircraft, and that if the aircraft becomes unairworthy in flight, the PIC is obligated to discontinue the flight. I would never suggest for a moment that any pilot fly a known-unairworthy aircraft, at least without a ferry permit. That’s a no-brainer.

The much more difficult question is: Exactly how does the PIC decide whether or not an aircraft is airworthy or unairworthy, and therefore whether he is or isn’t allowed to fly it? On this question, Damian and I part company. In fact, his view and mine seem to be diametrically opposite.

Damian’s view is that almost any aircraft discrepancy requires the involvement of an A&P mechanic to evaluate and clear the discrepancy and approve the aircraft for return to service. I see absolutely nothing in the FARs to support such a position, particularly when it comes to non-commercial aircraft operated under Part 91.

To begin with, the basic airworthiness rule (FAR 91.7) is crystal clear about who is responsible for determining whether or not the aircraft may be flown. It says:

The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight.

The regulation places the burden squarely on the shoulders of the PIC. I don’t see anything there about A&Ps or repair stations having to be involved, do you?

Looking a bit deeper into the FARs, I can find only three circumstances under which a mechanic is required to get involved in making any sort of airworthiness determination on a Part 91 aircraft used for non-commercial purposes:

  1. Exactly once a year, FAR 91.409 requires that an annual inspection be performed by an A&P/IA or a Repair Station. But the other 364 days of the year, it’s the PIC who determines whether the aircraft is airworthy.
  2. When an Airworthiness Directive or Airworthiness Limitation becomes due, FAR 91.403 requires that a mechanic must certify that the AD or AL has been complied with (with rare exceptions where the PIC may do so).
  3. When an owner actually hires a mechanic to perform maintenance on an aircraft, in which case the mechanic is required to document his work and sign it off to testify that the work was performed properly. Note, however, that the mechanic’s signature in the logbook entry does NOT signify that the aircraft is airworthy, only that THE WORK PERFORMED by the mechanic was done in an airworthy fashion.

This third point is one that is frequently misunderstood by mechanics and owners alike. When I teach this stuff at IA renewal seminars, the hypothetical example I often use to illustrate this important point involves an owner who takes his aircraft to a mechanic for repair. The mechanic immediately observes that the aircraft has two obvious discrepancies: the right main landing gear tire is flat, and the left wing is missing. The owner asks the mechanic to fix the flat tire. The mechanic does so, makes a logbook entry describing the work he did on the right main landing gear, and signs it. His signature denotes only that the work he did (fixing the flat tire) was done properly. When the owner picks up the aircraft, the mechanic tells the owner, “I couldn’t help but notice that your left wing is missing. If you’ll permit me to offer you a word of friendly advice, I would not attempt to fly the aircraft until that issue is resolved.” But the missing left wing does not prevent the mechanic from signing the logbook entry. In fact, the mechanic is required by regulation to sign the logbook entry, regardless of whether the aircraft is airworthy or not. The mechanic’s signature addresses only the work performed by the mechanic, and nothing else.

The PIC’s Burden

If you’re on a trip and some aircraft discrepancy occurs – assuming the aircraft isn’t in the midst of its annual inspection and there’s no AD involved – it is up to you as PIC to determine whether or not that discrepancy makes the aircraft unairworthy or not. If you decide that it does, then you can’t fly the airplane until the airworthiness issue is rectified (and that might require hiring an A&P). On the other hand, if you decide that the discrepancy doesn’t rise to the level of making the aircraft unairworthy, then you’re free to fly home and deal with the issue later.

Under the FARs, it’s totally the PIC’s call. There’s no regulatory obligation for the PIC to consult a mechanic when making such airworthiness determinations. Having said that, however, it would certainly be a wise thing to do if you feel uncomfortable about making the decision yourself. It’s your call.

The FARs provide considerable help to the PIC in making such airworthiness determinations. FAR 91.213(d) describes a specific algorithm for deciding whether or not it’s okay to fly an airplane with various items of inoperative equipment. FAR 91.207 says that it’s okay to fly an aircraft with an inoperative ELT to a place where it can be repaired or replaced, no ferry permit required. FAR 91.209 says that position lights needn’t be working if you’re flying during daylight hours. And so on.

If your experience is anything like mine, what most of us call “squawks” are common occurrences, but the majority of them don’t rise to the level of being airworthiness items that cause us (in our capacity as PIC) to conclude that a fix is required before further flight. Even if you do encounter a genuine airworthiness problem – say a flat tire or dead battery or bad mag drop – that still doesn’t mean that you necessarily need to get a mechanic involved. The FARs provide (in Part 43 Appendix A) a list of roughly three dozen items that a pilot-rated owner or operator is permitted to perform and sign off on his own recognizance (without getting an A&P involved).

If you have a flat tire, for example, you (as a pilot-rated owner) are permitted to repair or replace it yourself. If you have a dead battery, you can charge it, service it, or even replace it. If you have a bad mag drop, the most common cause is a defective or fouled spark plug, and you’re permitted to remove, clean, gap, and replace spark plugs yourself. You are also allowed to make repairs and patches to fairings, cowlings, fabric (on fabric-covered aircraft), upholstery and interior furnishings. You can replace side windows, seat belts, hoses, fuel lines, landing and position lamps, filters, seats, safety wire, cotter pins, and more. You can even remove and install tray-mounted avionics from your panel.

Now, you might well prefer to hire an A&P to do some of these things rather than do them yourself, especially when on the road, far from your hangar and toolbox. I know I certainly would, and I’m an A&P myself. But Damian’s contention that you are compelled by the FARs to place your aircraft in the hands of an A&P any time any sort of discrepancy arises is simply not supported by the regulations.

Contrary to what Damian and many of his A&P colleagues may believe, the FAR’s place the responsibility for determining the airworthiness of the aircraft squarely on the PIC, except for once a year when an IA is required to make an airworthiness determination after performing an annual inspection

My colleague Mac McClellan pointed out to me that this closely resembles how the FAA determines whether a pilot is “airworthy.” One day every year or two or five, we pilots are required by regulation to go get an examination from an Aviation Medical Examiner who pronounces us medically fit to fly, or not. The remaining 364 or 729 or 1,824 days in between, the FAA expects us to self-certify that we’re medically fit. “Can you imagine,” Mac asked me rhetorically, “if we had to go to see an AME every time we got a sore throat or runny nose?”

When to get some Dual on the couch: mental and emotional health needs of pilots

Monday, April 6th, 2015
Take a breath, take an honest look

Take a breath, take an honest look

Recently I suffered three unexpected losses. I use the word suffered on purpose here. In December I needed to get a flight review. I had scheduled this with three instructors, but due to the holidays, I was unable to get it done. In early January I contacted a local CFI that I know only socially. He knew about the losses in my life. After talking with me a few moments, he gently suggested that I was not well enough emotionally to fly that day. Of course, I burst into tears because he was number four on my list of instructors.

After I got done crying about it, I got to thinking about how, as a professional psychotherapist, I was seemingly unable to see the state of my own mental health. Below is an excerpt of an article I wrote for AOPA Pilot as well as a link for online screening tools for depression, anxiety, bi-polar and PTSD.

Here are some simple ways to put you and your emotional health on the pre-flight checklist as well as some ideas on when to get support if needed.

Mood: Think back over the past week. Rate your mood on a 1 to 5 scale with 1 being the lowest, and 5 being a happy mood. What is your average? Has anyone told you that you look tired, depressed, or nervous? Sometimes our spouse or families are the greatest mirrors for us. We might not see our mood, but to them it is written all over our faces.

Sleep: Have you been sleeping well? The average person in a lab setting will sleep a 6-7 hour stretch and take a 1-2 hour nap in the afternoon. Think back and check whether you have had any difficulties falling or staying asleep. Our deep restorative delta sleep typically happens well into an uninterrupted sleep cycle. Think about performing a go-round on every approach, with sleep we simply cannot get down to delta if the cycle is continually disrupted.

Energy: Has your get up and go, got up and went? Do you find yourself drinking coffee or energy drinks just to get through the day? Some pilots find they have too much energy and are unable to relax into a healthy focus. Between the tortoise and the hare, somewhere in the middle of the two is the most efficient.

Anxiety and Worry: Someone once told me that worry is interest on a debt we don’t yet owe. An interesting study on worry shows that it can be healthy in small doses. Worry is a high brain function, one that can help us sort through possibilities and strategies. Too much worry shuts down the function and we can find ourselves in a lower brain: fight, flight, or freeze. 30 minutes of worry once per week is effective. How many minutes this week have you racked up?

Concentration/Focus: Particularly important in being pilot-in command [PIC] is the ability to concentrate and stay focused. If you are noticing that your mind is wandering or you are distracted by worry, it might be best to keep yourself and the aircraft on the ground.

Sex Drive: This might seem a strange item to have on your personal checklist, but the fact is a person’s sex drive can be indicative of emotional health. A lack of desire can be suggestive of a mood problem.

Appetite: Does your favorite food taste good to you? Are you eating for comfort or to excess? Healthy food is fuel for the brain and the body. Make sure that you do not fly without fuel on board.

Bumper Sticker: Ask yourself this question and pay attention to the answer: If you had to summarize your attitude about life to fit on a bumper sticker, what would yours say? Is your bumper sticker upbeat and optimistic, or doubtful and negative?

Below is a link for the Mental Health America online screening tools. These screening tools are for use with adults only. If your screening indicates a problem, it is best to contact a licensed mental health counselor in your community for follow-up.

http://www.mentalhealthamerica.net/mental-health-screen/patient-health

A few days after my crying spell, I completed my flight review and had a great time doing it. My instructor had not flown in a Mooney for some time, and after the necessary maneuvers, I was able to show him a lot about my airplane.

Me and Dad, Christmas Eve

James and Jolie Lucas

One of my losses was the death of my father who was a primary flight instructor in the Army Air Corp and a Mooney pilot for 30 plus years. The day I was to leave for his memorial I was checking and double-checking the weather. I thought to myself, “I wonder if I am okay to fly?” That was the only question I needed to ask. If you wonder if you are okay, you are not okay. I packed up the car and made the five-hour drive with my son. While an hour and a half in the air is quicker, for me, that day, the drive was safer.

Our mental health is equally important as our physical health. We are all subject to the same rules of stress and loss. I am happy that CFI #3 told me he didn’t think I should be flying. His insight could have saved us from a bad outcome. I believe we all do need to have eyes and ears on our fellow pilots. We are a small community and we all get to do something that we love to do. Let’s all make sure we are up to the task emotionally too. Thanks for listening.

 

Champion Aerospace: From Denial to Acceptance

Thursday, March 19th, 2015

Champion Aviation Spark PlugsAccording to the model popularized by Dr. Elisabeth Kübler-Ross in her seminal 1969 book On Death & Dying, there are five stages of grief: denial, anger, bargaining, depression, and acceptance. This is apparently what Champion Aerospace LLC has been going through over the past six years with respect to the widely reported problems with the suppression resistors in its Champion-brand aviation spark plugs. I last discussed this issue in my August 2014 blog post Life on the Trailing Edge.

I first became aware of the Champion spark plug resistor problem in 2010, although there’s evidence that it dates back to 2008. We were seeing numerous cases of Champion spark plugs that were causing bad mag drops, rough running and hard starting even though they looked fine and their electrodes weren’t worn anywhere near the retirement threshold. The thing these spark plugs had in common were that they were all Champion-brand plugs and they all measured very high resistance or even open-circuit when tested with an ohmmeter.

We also saw a number of cases where high-resistance Champion plugs caused serious internal arc-over damage to Slick magnetos (mostly in Cirrus SR20s). If the damaged mag was replaced without replacing the spark plug, the new mag would be damaged in short order. The cause-and-effect relationship was pretty obvious.

In researching this issue, I looked at the magneto troubleshooting guide on the Aircraft Magneto Service website, maintained by mag guru Cliff Orcutt who knows more about aircraft ignition systems than just about anyone I know. Cliff owns and operates my favorite mag specialty shop, and that’s where I send the mags on my own airplane every 500 hours for inspection and tune-up. In reading Cliff’s troubleshooting guide, I came across the following pearls of wisdom:

  • Take an OHM Meter and measure the resistance value from the connection in the bottom of the barrel to the clean center electrode at the firing end, electrode must be bare metal.
  • A new Champion plug will have a value of 800 to 1200 OHMS. New Tempest (formerly Unison-Autolite) will measure 1000 OHMS.  Replace any plug above 5000 OHMS.
  • A spark plug bomb tester can test a bad plug and lead you to conclude it is serviceable. The OHM Meter check is simple, readily available, and amazingly accurate in finding misfiring plugs.

We started asking the maintenance shops we hired to maintain our clients’ aircraft to ohm out the plugs at each 50-hour spark plug maintenance cycle. The number of plugs that measured over 5,000 ohms was eye-opening. Many plugs measured tens or hundreds of thousand ohms, and it wasn’t unusual to find plugs that measured in the megohm range or even totally open-circuit. Here, for example, is a set of 12 Champion plugs removed for cleaning and gapping from a Cirrus SR22 by a shop in South Florida:

Champion spark plug resistance

Notice that only two of these 12 plugs measured less than 5K ohms, and one of those had to be rejected because its nose core insulator was cracked (a separate issue affecting only Champion fine-wire spark plugs, and unrelated to the resistor issue that affected all Champion plugs).

Why spark plugs have resistors

Worn spark plug

A worn-out spark plug.

Early aviation spark plugs didn’t contain resistors. They didn’t last long, either. The reason was that each time the plug fired, a significant quantity of metal was eroded from the electrodes. Magnetos fire alternate spark lugs with alternate polarities, so half of the plugs suffered accelerated erosion of their center electrodes, and the other half suffered erosion of the ground electrodes. Eventually, the ground electrodes became so thin or the center electrode became so elliptical that the plug had to be retired from service.

Spark plug manufacturers found that they could extend the useful life of their plugs by adding an internal resistor to limit the current of the spark that jumps across the electrodes. The higher the resistance, the lower the current. And the lower the current, the less metal eroded from the electrodes and the longer the plug would last before the electrodes got so worn that the plug had to be retired.

Adding a resistor to the plug also raised the minimum firing voltage for a given electrode gap. The result is a hotter, more well-defined spark that improves ignition consistency and reduces cycle-to-cycle variation.

The value of the resistor was fairly critical. If the resistance was too high, the plug would fire weakly, resulting in engine roughness, hard starting, excessive mag drops, and (if the resistance was high enough) arc-over damage to the magneto and/or harness. If the resistance was too low, the plug electrodes would erode at an excessive rate and its useful life would be short. Experimentation showed that a resistance between 1K and 4K ohms turned out to be a good compromise between ignition performance and electrode longevity. Brand new Champion-brand aviation spark plugs typically measure around 1,200 ohms fresh out of the box. New Tempest-brand plugs typically measure about 2,500 ohms. Both of these represent good resistance values right in the sweet spot.

Denial

As word of these erratic and wildly out-of-spec resistance values began reaching aircraft owners and mechanics (primarily via the Internet), Champion went on the defensive. At numerous aviation events and IA renewal seminars, Champion reps dismissed the significance of resistance measurements. They explained that the silicon carbide resistor in Champion-brand plugs is made to show the proper resistance whenever a high-voltage pulse is present, and can’t necessarily be measured properly with an ohmmeter. Further, they stated that the proper way to test a spark plug is on a spark plug testing machine (so-called “bomb tester”), and claimed that if a plug functions well during a bomb test, it should function well in the airplane.

Champion old insulator assembly

Champion old insulator assembly.

Of course, this “company line” from Champion didn’t agree with our experience. We’d seen numerous instances of high-resistance Champion plugs that tested fine on the bomb tester but functioned erratically in service. Nor did it agree with the Mil Spec for aviation spark plugs (MIL-S-7886B) which states clearly:

4.7.2 Resistor. Each spark plug shall be checked for stability of internal resistance and contact by measurement of the center wire resistance by the use of a low voltage ohmmeter (8 volts or less). Center wire resistance values of any resistor type spark plug shall be as specified in the manufacturer’s drawings or specifications. 

One enterprising Cessna 421 owner named Max Nerheim performed high-voltage testing of Champion spark plugs, and found that plugs that measure high-resistance or open-circuit with a conventional ohmmeter also had excessive voltage drop when fired with high voltage, and required a higher minimum voltage to produce any spark. Max Nerheim wasn’t just an aircraft owner, mind you, he was also Vice President of Research for TASER International, Inc. and was exceptionally qualified to perform high-voltage testing of Champion spark plugs. Nerheim’s findings flatly contradicted Champion’s company line, and agreed with what we were seeing in the field. Nerheim also disassembled the resistor assemblies of a number of high-resistance Champion plugs and found that the internal resistor “slugs” were failing.

Anger

What's your resistance?The spit really hit the fan when Champion’s primary competitor in the aviation spark plug space, Aero Accessories, Inc., launched a marketing campaign to promote sales of its Tempest-brand aviation spark plugs by highlighting the resistance issue. (Aero Accessories acquired the Autolite line of aviation spark plugs from Unison Industries in 2010, an re-branded them under its Tempest brand.) In February 2013, they issued a Tempest Tech Tip titled “The Right Way to Check Spark Plug Resistors,” started selling a fancy spark plug resistance tester, and launched a big “What’s Your Resistance” advertising campaign in the general aviation print media.

Predictably, this provoked a rather hostile response from Champion. Their field reps ratcheted up their public relations campaign claiming that the ohmeter check was meaningless, and insisting that Champion spark plugs didn’t have a resistance problem that affected the performance of their plugs.

Bargaining

In the face of both overwhelming technical evidence from the field that their spark plugs had a resistor problem, and a virtual blitzkrieg from their principal competitor that was starting to erode their dominant market share, Champion began having some self-doubts. Max Nerheim discussed his high-voltage test findings with Kevin Gallagher, Manger of Piston and Airframe at Champion Aerospace, and Gallagher acknowledged that Champion was looking into the issue with the resistor increasing in impedance, but did not have it resolved yet. Meanwhile, the Champion field reps continued to insist to anyone who would listen that claims of resistor problems in Champion spark plugs were false and that the ohmmeter test was meaningless.

Finally…Acceptance

Sometime in late 2014, it appears that Champion very quietly changed the internal design of their spark plugs to use a sealed, fired-in resistor element that appears to be quite similar to the design of the Tempest/Autolite plug. They didn’t change any part numbers. So far as I have been able to tell, they didn’t even issue a press release. The Champion Aerospace website makes no mention of any recent design changes or product improvements. But the cutaway diagram of the Champion spark plug now on the website shows the new fired-in resistor. Here are the old and new cutaway diagrams. Compare them and you’l clearly see the difference.

Click on images below to see higher-resolution versions.

Champion spark plug cutaway (old)

Champion spark plug cutaway (old)

Champion spark plug cutaway (new)

Champion spark plug cutaway (new)

I checked with a number of A&P mechanics and they verified that the latest Champion spark plugs they ordered do indeed have the new design. It’s easy to tell whether a given Champion spark plug is of the old or new variety. Simply look at the metal contact located at the bottom of the “cigarette well” on the harness end of the plug. The older-design plugs have a straight screwdriver slot machined into the metal contact, while the newer-design plugs do not.

As I write this, it’s still too early to tell whether Champion’s quiet resistor redesign will cure the drifting resistance problem, but my best guess is that it will. If I’m right, this is very good news indeed for users of Champion aviation spark plugs. I applaud Champion Aerospace for improving its product.

Still, I can’t help but wonder why it took six years for the company to work through its grief from denial to acceptance. I suppose grief is a very personal thing, and everyone deals with it differently.

Owner in command

Tuesday, February 17th, 2015

Every pilot understands the notion of “pilot in command.” That’s because we all had some certificated flight instructor (CFI) who mercilessly pounded this essential concept into our heads throughout our pilot training. Hopefully, it stuck.

As pilot-in-command (PIC), we are directly responsible for, and the final authority as to, the operation of our aircraft and the safety of our flight. Our command authority so absolute that in the event of an in-flight emergency, the FAA authorizes the PIC to deviate from any rule or regulation to the extent necessary to deal with that emergency. (14 CFR §91.3)

In four and a half decades of flying, I’ve overheard quite a few pilots dealing with in-flight emergencies, and have dealt with a few myself. It makes me proud to hear a fellow pilot who takes command of the situation and deals with the emergency decisively. Such decisiveness is “the right stuff” of which PICs are made, and what sets us apart from non-pilots.

Conversely, it invariably saddens me to hear a frightened pilot abdicate his PIC authority by throwing himself on the mercy of some faceless air traffic controller or flight service specialist to bail him out of trouble. How pathetic! The ATC or FSS folks often perform heroically in such “saves,” but few of them are pilots, and most have little or no knowledge of the capabilities of the emergency aircraft or its crewmember(s). They shouldn’t be placed in the awful position of having to make life-or-death decisions on how best to cope with an in-flight emergency. That’s the PIC’s job.

Fortunately, most of us who fly as PIC understand this because we had good CFIs who taught us well. When the spit hits the fan, we take command almost instinctively.

Owner in command

When a pilot progresses to the point of becoming an aircraft owner, he suddenly takes on a great deal of additional responsibility and authority for which his pilot training most likely did not prepare him. Specifically, he becomes primarily responsible for maintaining his aircraft in airworthy condition, including compliance with all applicable airworthiness requirements including Airworthiness Directives. (14 CFR §91.403) Unfortunately, few owners have the benefit of a Certificated Ownership Instructor (COI) to teach them about their daunting new responsibilities and authority as “owner in command” (OIC).

Consequently, too many aircraft owners fail to comprehend or appreciate fully their weighty and complex OIC responsibilities. They put their aircraft in the shop, hand over their keys and credit card, and tell the mechanic to call them when the work is done and the airplane is ready to fly. Often, owners give the mechanic carte blanche to “do whatever it takes to make the aircraft safe,” and don’t even know what work is being performed or what parts are being replaced until after-the-fact when they receive a maintenance invoice.

In short, lots of owners seem to act as if the mechanic is responsible for maintaining the aircraft in airworthy condition. But that’s bass-ackwards. In the eyes of the FAA and under the FARs, it’s the owner who is responsible. The mechanic is essentially “hired help”—a skilled and licensed contractor hired to assist the owner carry out his regulatory responsibilities.

General Contractor

An aircraft owner-in-command acts as the “general contractor” for the maintenance of his aircraft.

I find it helpful to compare the proper role of the aircraft owner in maintaining an airworthy aircraft to that of a general contractor in building a house. The general contractor needs to hire licensed specialists—electricians, plumbers, roofers, masons, and other skilled tradesmen—to perform various tasks required during the construction. He also needs to hire a licensed building inspector to inspect and approve the work that the tradesman have performed. But, the general contractor makes the major decisions, calls the shots, keeps things within schedule and budget constraints, and is held primarily accountable for the final outcome.

Similarly, an aircraft owner hires certificated airframe and powerplant (A&P) mechanics to perform maintenance, repairs and alterations; certificated inspectors (IAs) to perform annual inspections, and other certificated specialists (e.g., avionics, instrument, propeller and engine repair stations) to perform various specialized maintenance tasks. But, the owner is the boss, is responsible for hiring, firing, and managing these various “subcontractors,” and has primary responsibility for the ensuring the desired outcome: a safe, reliable aircraft that meets all applicable airworthiness requirements, achieved within an acceptable maintenance budget and schedule.

Who’s the boss?

The essence of the owner-in-command concept is that the aircraft owner needs to remain in control of the maintenance of his aircraft, just as the pilot needs to remain in control of the operation of the aircraft in-flight. When it comes to maintenance, the owner is supposed to be the head honcho, make the major decisions, ride herd on time and budget constraints, and generally call the shots. The mechanics and inspectors and repair stations he hires are “subcontractors” with special skills, training and certificates required to do the actual work. But the owner must always stay firmly in charge, because the buck stops with him (literally).

Since most owners have not received training in how to act as OIC, many of them are overwhelmed by the thought of taking command of the maintenance of their aircraft. “I don’t know anything about aircraft maintenance,” they sigh. “That’s way outside my comfort zone. Besides, isn’t that my mechanic’s job?”

Such owners often adopt the attitude that it’s their job to fly the aircraft and the mechanic’s job to maintain it. They leave the maintenance decisions up to the mechanics, and then get frustrated and angry when squawks don’t get fixed and maintenance expenses are higher than they expected.

But think about it: If you were building a house and you told your plumber or electrician or roofer “just do whatever it takes and send me the bill when it’s done,” do you think you’d be happy with the result?

No one in his right mind would do that, of course. If you were hiring an electrician to wire your house, you’d probably start by giving him a detailed list of exactly what you want him to do—what appliances and lighting fixtures you want installed in each room, where you want to locate switches, dimmers, convenience outlets, thermostats, telephone jacks, Ethernet connections, and so forth. You’d then expect the electrician to come back to you with a detailed written proposal, cost estimate, and completion schedule. After going over the proposal in detail with the electrician and making any necessary revisions, you’d sign the document and thereby enter into a binding agreement with the electrician for specific goods and services to be provided at a specific price and delivery date.

You’d do the same with the carpenter, roofer, drywall guy, paving contractor, and so forth.

Cars vs. airplanes

If you’ll permit me to mix my metaphors, when I take my car to the shop for service, the shop manager starts by interviewing me and taking notes on exactly what I want done—he asks me to describe any squawks I have to report, and he checks the odometer and explains any recommended preventive maintenance. Once we arrive at a meeting of the minds about what work needs to be done, the shop manager writes up a detailed work order with a specific cost estimate, and asks me to sign it and keep a copy. In essence, I now have a written contract with the shop for specific work to be done at a specific price.

The service manager doesn’t do this solely out of the goodness of his heart. He’s compelled to do so. In California where I live, state law provides that the auto repair shop is required to provide me with a written estimate in advance of doing any work, and may not exceed the agreed-to cost estimate by more than 10% unless I explicitly agree to the increase. If the shop doesn’t follow these rules, I can file a complaint with the State Bureau of Automotive Repairs and they’ll investigate and take appropriate action against the shop. Most states have similar laws.

Discrepancy List & Repair Estimate

Aircraft owners should insist on receiving a detailed written work statement and cost estimate like this one before authorizing any mechanic or shop to perform repairs or install replacement parts.

Unfortunately, there are no such laws requiring aircraft maintenance shops to deal with their customers on such a formalized and businesslike basis, even though the amounts involved are usually many times larger. Aircraft owners routinely turn their airplanes over to a mechanic or shop with no detailed understanding of what work will be done, what replacement parts will be installed, and what it’s all going to cost. All too often, the aircraft owner only finds this out when he picks up the aircraft and is presented with an invoice (at which point it’s way too late for him to influence the outcome).

It always amazes me to see aircraft owners do this. These are intelligent people, usually successful in business (which is what allows them to afford an airplane), who would never consider making any other sort of purchase of goods or services without first knowing exactly what they were buying and what it costs. Yet they routinely authorize aircraft maintenance without knowing either.

Often, the result is sticker shock and hard feelings between the owner and the shop. There’s no State Bureau of Aircraft Repair to protect aircraft owners from excessive charges or shoddy work. The FAA almost never gets involved in such commercial disputes. A few owners even wind up suing the maintenance shop, but generally the only beneficiaries of such litigation are the lawyers.

You can’t un-break an egg. You’ve got to prevent it from breaking in the first place.

Trust but verify

I hear from lots of these disgruntled aircraft owners who are angry at some mechanic or shop. When I ask why they didn’t insist on receiving a detailed work statement and cost estimate before authorizing the shop to work on their aircraft, I often receive a deer-in-the-headlights look, followed by some mumbling to the effect that “I’ve never had a problem with them before” or “you’ve got to be able to trust your A&P, don’t you?”

Sure you do…and you’ve got to be able to trust your electrician, plumber and auto mechanic, too. But that’s no excuse for not dealing with them on a businesslike basis. Purchasing aircraft maintenance services is a big-ticket business transaction, and should be dealt with as you would deal with any other big-ticket business transaction. The buyer and seller must have a clear mutual understanding of exactly what is being purchased and what it will cost, and that understanding must be reduced to writing.

In the final analysis, the most important factor that sets a maintenance-savvy aircraft owner apart from the rest of the pack is his attitude about maintenance. Savvy owners understand that they have primary responsibility for the maintenance of their aircraft, and that A&Ps, IAs and repair stations are contractors that they must manage. They deal with these maintenance professionals as they would deal with other contractors in other business dealings. They insist on having a written work statement and cost estimate before authorizing work to proceed. Then, like any good manager, they keep in close communication with the folks they’ve hired to make sure things are going as planned.

If your mechanic or shop resists working with you on such a businesslike basis, you probably need to take your business elsewhere.

Carbon Monoxide, Silent Killer

Monday, October 20th, 2014

Danger, Carbon Monoxide
On January 17, 1997, a Piper Dakota departed Farmingdale, New York, on a planned two-hour VFR flight to Saranac Lake, New York. The pilot was experienced and instrument-rated; his 71-year-old mother, a low-time private pilot, occupied the right seat. Just over a half-hour into the flight, Boston Center got an emergency radio call from the mother, saying that the pilot (her son) had passed out.

The controller attempted a flight assist, and an Air National Guard helicopter joined up with the aircraft and participated in the talk-down attempt. Ultimately, however, the pilot’s mother also passed out.

The aircraft climbed into the clouds, apparently on autopilot, and continued to be tracked by ATC. About two hours into the flight, the airplane descended rapidly out of the clouds and crashed into the woods near Lake Winnipesaukee, New Hampshire. Both occupants died.

Toxicological tests revealed that the pilot’s blood had a CO saturation of 43% — sufficient to produce convulsions and coma—and his mother’s was 69%.

On December 6 that same year, a physician was piloting his Piper Comanche 400 from his hometown of Hoisington, Kansas, to Topeka when he fell asleep at the controls. The airplane continued on course under autopilot control for 250 miles until it ran a tank dry and (still on autopilot) glided miraculously to a soft wings-level crash-landingin a hay field near Cairo, Missouri.

The pilot was only slightly injured, and walked to a nearby farmhouse for help. Toxicology tests on a blood sample taken from the lucky doc hours later revealed CO saturation of 27%. It was almost certainly higher at the time of the crash.

Just a few days later, a new 1997 Cessna 182S was being ferried from the Cessna factory in Independence, Kansas, to a buyer in Germany when the ferry pilot felt ill and suspected carbon monoxide poisoning. She landed successfully and examination of the muffler revealed that it had been manufactured with defective welds. Subsequent pressure tests by Cessna of new Cessna 172 and 182 mufflers in inventory revealed that 20% of them had leaky welds. The FAA issued an emergency Airworthiness Directive (AD 98-02-05) requiring muffler replacement on some 300 new Cessna 172s and182s.

About 18 months later, the FAA issued AD 99-11-07 against brand new air-conditioned Mooney M20R Ovations when dangerous levels of CO were found in their cabins.

Sidebar: CO Primer

Click on image above for high-resolution printable version.

Not just in winter

A search of the NTSB accident database suggests that CO-related accidents and incidents occur far more frequently than most pilots believe. Counterintuitively, these aren’t confined to winter-time flying with the cabin heat on. Look at the months during which the following accidents and incidents occurred during the 15-year period from 1983 to 1997:

March 1983. The Piper PA-22-150 N1841P departed Tucumcari, N.M. After leveling at 9,600, the right front seat passenger became nauseous, vomited, and fell asleep. The pilot began feeling sleepy and passed out. A 15-year-old passenger in the back seat took control of the aircraft by reaching between the seats, but the aircraft hit a fence during the emergency landing. None of the four occupants were injured. Multiple exhaust cracks and leaks were found in the muffler. The NTSB determined the probable cause of the accident to be incapacitation of the PIC from carbon monoxide poisoning. [FTW83LA156]

February 1984. The pilot of Beech Musketeer N6141N with four aboard reported that he was unsure of his position. ATC identified the aircraft and issued radar vectors toward Ocean Isle, N.C. Subsequently, a female passenger radioed that the pilot was unconscious. The aircraft crashed in a steep nose-down attitude, killing all occupants. Toxicological tests of the four victims revealed caboxyhemoglobin levels of 24%, 22%, 35% and 44%. [ATL84FA090]

November 1988. The Cessna 185 N20752 bounced several times while landing at Deadhorse, Alaska. The pilot collapsed shortly after getting out of the airplane. Blood samples taken from the pilot three hours after landing contained 22.1% carboxyhemoglobin. The left engine muffler overboard tube was broken loose from the muffler where the two are welded. The NTSB determined probable cause to be physical impairment of the pilot-in-command due to carbon monoxide poisoning. [ANC89IA019]

July 1990. While on a local flight, the homebuilt Olsen Pursuit N23GG crashed about three-tenths of a mile short of Runway 4 at Fowler, Colo. No one witnessed the crash, but post-crash investigation indicated that there was no apparent forward movement of the aircraft after its initial impact. The aircraft burned, and both occupants died. Toxicology tests of the pilot and passenger were positive for carboxyhemoglobin. [DEN90DTE04]

August 1990. About fifteen minutes into the local night flight in Cessna 150 N741MF, the aircraft crashed into Lake Michigan about one mile from the shoreline near Holland, Mich. Autopsies were negative for drowning, but toxicological tests were positive for carboxyhemoglobin, with the pilot’s blood testing at 21%. [CHI90DEM08]

July 1991. The student pilot and a passenger (!) were on a pleasure flight in Champion 7AC N3006E owned by the pilot. The aircraft was seen to turn into a valley in an area of mountainous terrain, where it subsequently collided with the ground near Burns, Ore., killing both occupants. A toxicology exam of the pilot’s blood showed a saturation of 20% carboxyhemoglobin, sufficient to cause headache, confusion, dizziness and visual disturbance. [SEA91FA156]

October 1992. The pilot of Cessna 150 N6402S was in radio contact with the control tower at Mt. Gilead, Ohio, and in a descent from 5,000 feet to 2,000 feet in preparation for landing. Radar contact was lost, and the aircraft crashed into a wooded area, seriously injuring the pilot. Toxicological tests on the pilot’s blood were positive for carbon monoxide. Examination of the left muffler revealed three cracks and progressive deterioration. The NTSB found probable cause of the accident to be pilot incapacitation due to carbon monoxide poisoning. [NYC93LA031]

April 1994. Fifteen minutes after takeoff from Long Beach, Calif., the Cessna 182 N9124G began deviating from headings, altitudes and ATC instructions. The aircraft did several 360- and 180-degree turns. The pilot reported blurred vision, headaches, nausea, labored breathing, and difficulty staying awake. The aircraft ultimately crashed in a vineyard near Kerman, Calif., and the owner/pilot was seriously injured. Post-crash inspection revealed numerous small leaks in the exhaust system. The pilot tested positive for carbon monoxide even after 11 hours of oxygen therapy. [LAX94LA184]

October 1994. A student pilot returned to Chesterfield, Mo., from a solo cross-country flight in Cessna 150 N7XC, complaining of headache, nausea, and difficulty walking. The pilot was hospitalized, and medical tests revealed elevated CO which required five and a half hours breathing 100% oxygen to reduce to normal levels. Post-flight inspection revealed a crack in an improperly repaired muffler that had been installed 18 hours earlier. [CHI95IA030]

March 1996. The pilot of Piper Cherokee 140 N95394 stated that she and her passenger became incapacitated after takeoff from Pittsburg, Kan. The airplane impacted the terrain, but the occupants were uninjured. Both were hospitalized, and toxicological tests for carbon monoxide were positive. A subsequent examination found holes in the muffler. [CHI96LA101]

August 1996. A Mankovich Revenge racer N7037J was #2 in a four-airplane ferry formation of Formula V Class racing airplanes. The #3 pilot said that the #2 pilot’s flying was erratic during the flight. The airplane crashed near Jeffersonville, Ind., killing the pilot. The results of FAA toxicology tests of the pilot’s blood revealed a 41% saturation of carboxyhemoglobin; loss of consciousness is attained at approximately 30%. Examination of the wreckage revealed that the adhesive resin that bound the rubber stripping forming the firewall lower seal was missing. The NTSB determined probable cause of the accident to be pilot incapacitation due to carbon monoxide poisoning. [CHI96FA322]

January 1997. The fatal crash of Piper Dakota N8263Y near Lake Winnipesaukee, N.H. (described previously). [IAD97FA043]

December 1997. Non-fatal crash of Piper Comanche 400 N8452P flying from Hoisington to Topeka, Kansas (described previously). [CHI98LA055]

December 1997. A new Cessna 182S was being ferried from the factory in Independence, Kan., to a buyer in Germany when the ferry pilot felt ill and suspected carbon monoxide poisoning (described previously). [Priority Letter AD 98-02-05]

Overall, deaths from unintentional carbon monoxide poisoning have dropped sharply since the mid-1970s thanks mainly to lower CO emissions from automobiles with catalytic converters (most CO deaths are motor vehicle-related) and safer heating and cooking appliances. But CO-related airplane accidents and incidents haven’t followed this trend. The ADs issued against Independence-built Cessna 172s and 182s and Mooney Ovations demonstrates that even brand new airplanes aren’t immune.

CO Checklist

Click on image above for high-resolution printable version.

Close calls

In addition to these events in the NTSB accident database where CO poisoning was clearly implicated, there were almost certainly scores of accidents, incidents, and close calls where CO was probably a factor.

In January 1999, for example, a Cessna 206 operated by the U.S. Customs Service was on a night training mission when it inexplicably crashed into Biscayne Bay a few miles off the south Florida coast. The experienced pilot survived the crash, but had no recollection of what happened. The NTSB called it simple pilot error and never mentioned CO as a possible contributing factor. However, enough carboxyhemoglobin was found in the pilot’s blood that the Customs Service suspected that CO poisoning might have been involved.

The agency purchased sensitive industrial electronic CO detectors for every single-engine Cessna in its fleet, and discovered that many of the planes had CO-in-the-cockpit problems. On-board CO detectors and CO checks during maintenance inspections have been standard operating procedure for the Customs Service ever since.

How much CO is too much?

It depends on whom you ask.

EPA calls for a health hazard alert when the outdoor concentration of CO rises above 9 parts per million (ppm) for eight hours, or above 35ppm for one hour. OSHA originally established a maximum safe limit for exposure to CO in the workplace of 35 ppm, but later raised it to 50 ppm under pressure from industry.

The FAA requires that CO in the cabin not exceed 50 ppm during certification testing of new GA airplanes certified under FAR Part 23 (e.g. Cessna Corvallis, Cirrus SR22, Diamond DA-40). Legacy aircraft certified under older CAR 3 regs required no CO testing at all during certification.

Once certified, FAA requires no CO testing of individual aircraft by the factory, and no follow-up retesting during annual inspections. A March 2010 FAA SAIB (CE-10-19 R1) recommends checking CO levels with a hand-held electronic CO detector during ground runups at each annual and 100-hour inspection, but in my experience very few shops and mechanics do this.

UL-approved residential CO detectors are not permitted to alarm until the concentration rises to 70 ppm and stays there for four hours. (This was demanded by firefighters and utility companies to reduce the incidence of nuisance calls from homeowners.) Yet most fire departments require that firefighters put on their oxygen masks immediately when CO levels reach 25 ppm or higher.

It’s important to understand that low concentrations of CO are far more hazardous to pilots than to non-pilots. That’s because the effects of altitude hypoxia and CO poisoning are cumulative. For example, a COHb saturation of 10% (which is about what you’d get from chain-smoking cigarettes) would probably not be noticeable to someone on the ground. But at 10,000 feet, it could seriously degrade your night vision, judgment, and possibly cause a splitting headache.

After studying this hazard for many years and consulting with world-class aeromedical experts, I have come to the following conclusions:

  1. Every single-engine piston aircraft should carry a sensitive electronic CO detector.
  2. Any in-flight CO concentration above 10 ppm should be brought to the attention of an A&P for troubleshooting and resolution.
  3. Any in-flight CO concentration above 35 ppm should be grounds for going on supplemental oxygen (if available) and making a precautionary landing as soon as practicable.

Smokers are far more vulnerable to both altitude hypoxia and CO poisoning, since they’re already in a partially poisoned state when they first get into the aircraft. Because of COHb’s long half-life, you’d do well to abstain from smoking for 8 to 12 hours prior to flight.

Choosing a CO detector

Five CO detectors

Five CO detectors (left to right): chemical spot, UL-compliant residential (Kidde), non-UL-compliant (CO Experts 2015), industrial (BW Honeywell), TSO’d panel-mounted (CO Guardian 551).

Chemical spot detectors:Stay away from those ubiquitous el-cheapo adhesive-backed cardboard chemical spot detectors that are commonly sold by pilot shops and mail-order outfits for under trade names like “Dead Stop,” “Heads Up” and “Quantum Eye.” They have a very short useful life (about 30 days), and are extremely vulnerable to contamination from aromatic cleaners, solvents and other chemicals routinely used in aircraft maintenance.

These things often remain stuck on the instrument panel for years, providing a dangerous false sense of security. What’s worse, there’s no warning that the detector is outdated or has been contaminated—in some ways, that’s worse than not having a detector at all.

Even when fresh, chemical spot detectors are incapable of detecting low levels of CO. They’ll start turning color at 100ppm, but so slowly and subtly that you’ll never notice it. For all practical purposes, you’ll get no warning until concentrations rise to the 200 to 400 ppm range, by which time you’re likely to be too impaired to notice the color change.

Residential electronic detectors:Although battery-powered residential electronic detectors are vastly superior to those worthless chemical spots, most are designed to be compliant with Underwriter’s Laboratory specification UL-2034 (revised 1998). This spec requires that

(1)   The digital readout must not display any CO concentration less than 30 ppm.

(2)   The alarm will not sound until CO reaches 70 ppm and remains at or above that level for four hours.

(3)   Even at a concentration of 400 ppm, it may take as much as 15 minutes before the alarm sounds.

For aircraft use, you really want something much more sensitive and fast-acting. I like the non-UL-compliant CO Experts Model 2015 ($199 from www.aeromedix.com). It displays CO concentrations as low as 7 ppm and provides a loud audible alarm at concentrations above 25 ppm. It updates its display every 10 seconds (compared to once a minute for most residential detectors), which makes it quite useful as a “sniffer” for trying to figure out exactly where CO is entering the cabin.

Industrial electronic detectors:Industrial CO detectors cost between $400 and $1,000. A good choice for in-cockpit use is the BW Honeywell GasAlert Extreme CO  ($410 from www.gassniffer.com). This unit displays CO concentrations from 0 to 1,000 ppm on its digital display, has a very loud audible alarm with dual trigger levels (35 and 200 ppm).

Purpose-built aviation electronic detectors:Tucson-based CO Guardian LLC makes a family of TSO’d panel-mount electronic CO detectors specifically designed for cockpit use. These detectors detect and alarm at 50 ppm (after 10 minutes), or 70 ppm (after 5 minutes), and will alarm instantly if concentrations rise to 400 ppm. The digital display models ($599 and up) will show concentrations as low as 10 ppm. Available from www.coguardian.com. Obviously, panel-mount detectors cannot be used as a sniffer to locate the source of a CO leak.

For more information…

There is an outstanding October 2009 research paper titled “Detection and Prevention of Carbon Monoxide Exposure in General Aviation Aircraft” authored by Wichita State University under sponsorship of the FAA Office of Research and Technology Development. The paper is 111 pages long, and discusses (among other things):

  • Characteristics of CO-related GA accidents
  • Evaluation of CO detectors, including specific makes and models
  • Placement of CO detectors in the cabin
  • Exhaust system maintenance and inspection

This research paper is available online at:

http://www.tc.faa.gov/its/worldpac/techrpt/ar0949.pdf

Liability: The Price We Pay

Wednesday, October 1st, 2014

As large as the aviation industry looks to those on the outside, once you’re on the other side of the fence, it doesn’t take long to realize that it’s a very small world. One of the big challenges facing that world has been from product liability issues.

The $100 screw. The $9.00 gallon of fuel. The $5,000 part that costs $50 at a local hardware store. We’ve all seen it. I recall the day a friend told me the seat back for my Pitts S-2B, which is literally a small flat piece of ordinary plywood, cost something like $600. I’m not averse to parts manufacturers turning a profit, but that left my mouth hanging open. My friend? He just shrugged and walked away, as though this was ordinary and normal. The saddest part is that I realized he was right. It is.

Liability concerns are a major expense and motivator for many industries. That’s why Superman costumes come with warnings that “the cape does not enable the wearer to fly”, Zippo cautions the user not to ignite the lighter in your face, and irons are sold with tags advising against ironing clothes while they’re being worn. But for general aviation, this sort of thing is dragging the lot of us down as surely as a cement block tossed into the murky waters of the East River.

The classic example of this phenomenon can be seen in the high cost for new products like airplanes. Look at the sharp rise in the price of a new Skyhawk over the past thirty years. The first one was built in 1955, so the research and development costs for this model must have been recouped decades ago. A new Bonanza is a cool million. Low production volumes and high liability costs — a chicken and egg pair if there ever was one — are prime culprits for that inflation.

In fact, for about a decade, the general aviation industry essentially stopped producing new piston airplanes. From the mid-80s to the mid-90s, product liability was such that nearly every major OEM exited the business. The insurance costs rose, the manufacturers had no choice but to pass that on to the consumer, who was summarily priced out of the market. Sales fell, per-unit liability costs rose further, and the cycle spiraled downward until even those companies which still had an operating production line were only turning out a handful of airplanes per year.

The General Aviation Revitalization Act of 1994 helped somewhat. Aircraft manufacturers started producing planes again. The Cirrus, DiamondStar, Columbia, and other such advanced aircraft were brought to market. New avionics systems were developed. But the liability problem never went away. Frivolous lawsuits still abound, grinding away at our diminished world like a wood chipper consuming a sturdy log. Manufacturers have been sued for things as idiotic as not telling a pilot that the engine wouldn’t operate without fuel. I don’t have to tell you how this lunacy looks to people from other countries, do I?

I often wonder, what would an aircraft like the RV-6 cost if it was certified? You can buy one for as little as $45,000 today. Speaking of Amateur-Built aircraft, liability is one of the primary reasons advancements such as electronic ignition proliferate in the E-AB world when they’re almost unheard of in aircraft with a standard airworthiness certificate.

Mike Busch has penned many articles about the ways liability concerns drive decisions in the maintenance business. The result? Lower efficiency, higher cost, and at times even a decrease in the level of safety that is supposedly paramount. But it goes beyond that. Many products which would otherwise be brought to market are not because liability issues tilt the scale away from taking that risk in the first place.

Even proven, well-established products are sometimes lost to this phenomenon. Seven years ago, the largest manufacturer of aircraft carburetors, Precision Airmotive, abruptly decided to stop making, selling, and supporting them. In a letter to customers on their web site, they wrote:

Precision Airmotive LLC has discontinued sales of all float carburetors and component parts as of November 1, 2007. This unfortunate situation is a result of our inability to obtain product liability insurance for the product line. Precision Airmotive LLC and its 43 employees currently manufacture and support the float carburetors used in nearly all carbureted general aviation aircraft flying today. Precision has been the manufacturers of these carburetors since 1990. These FAA-approved carburetors were designed as early as the 1930s and continue to fly over a million flight hours a year. After decades of service, the reliability of these carburetors speaks for itself.

Nonetheless, Precision has seen its liability insurance premiums rise dramatically, to the point that the premium now exceeds the total sales dollars for this entire product line. In the past, we have absorbed that cost, with the hope that the aviation industry as a whole would be able to help address this issue faced by Precision Airmotive, as well as many other small aviation companies. Our efforts have been unsuccessful.

This year, despite the decades of reliable service and despite the design approval by the Federal Aviation Administration, Precision Airmotive has been unable to obtain product liability insurance for the carburetor product line. While we firmly believe that the product is safe, as does the FAA, and well-supported by dedicated people both at Precision and at our independent product support centers, unfortunately the litigation costs for defending the carburetor in court are unsustainable for a small business such as Precision.

Even if you don’t own an airplane, you’ve probably noticed that aircraft rental is prohibitively difficult and expensive. Companies like OpenAirplane are trying to make a dent in this formidable problem, but many aircraft types simply cannot be rented at all for solo flight anymore. Seaplanes, aerobatic aircraft, twins, turbines, and many other types might as well not exist unless you have the cash to buy them outright. And those that are still rented require extensive checkouts, form filling, and a large expenditure of time, money and energy. Why? To check every possible box off when it comes to liability. The manager of one FBO here in Southern California told me in no uncertain terms that it wouldn’t matter if Bob Hoover himself walked through the door, he wouldn’t get one iota of consideration in that regard. Does that sound right to you?

There’s an obvious answer here. If you’re thinking tort reform, you’re only half-right. Suing manufacturers for accidents that are clearly not their fault simply because the plaintiff knows they’ll settle is only ensuring the next generation won’t be able to fly. The real solution is to — in the words of a pilot I know — put on our big-boy britches and come to terms with the fact that life in general, and aviation in particular, involves risk. From the Doolittle Raiders to the folks at Cirrus Aircraft, history shows over and over again that risk is a part of every successful venture. We’d all love to live in a world where there is no risk, where following the dictates of Title 14 would ensure nothing ever goes wrong and nobody ever gets hurt. It’s a fallacy.

Crushing liability costs aren’t limited to carbs. And many parts of our airplanes are manufactured by a very small number of companies. Prop governors come to mind. Vacuum pumps. Brakes. Fasteners. If one firm is having trouble staying in business, odds are the others might be as well. It doesn’t portend a rosy future for the industry, especially when you consider that many of the advances we now enjoy came from small companies just like Precision Airmotive.

Sure, with Experimentals you have more freedom to put what you want on your aircraft. But many of the components on experimental aircraft are certified anyway. Most of them essentially have certified engines, props, skins, wiring, brakes, tires, fasteners, etc. This liability issue affects everyone regardless of what it says on the plane’s airworthiness certificate. This sort of thing isn’t limited to aviation. But GA is particularly vulnerable to abuse because of the implication that anyone involved in it must have deep pockets. The end result is a case like this one, where a jury awarded $480 million verdict against an aircraft manufacturer even though the NTSB indicated pilot error was the cause.

Liability concerns hurt everyone in aviation, not just those with reciprocating single-engines. I’ll give you one example from the corporate and charter business that I work in: time and time again, thousands of dollars of catering from one of our charter flights will go untouched by the passengers. We’ll land at our destination with a eighty pounds of beautifully packaged and prepared food. Five-star presentation of the highest-quality and healthiest food you’ll see anywhere.

At the same time, just beyond the airport fence are people who go to bed hungry. Logic dictates that we might want to put two and two together. But because the operators and customers of these aircraft are high net worth individuals who would certainly find themselves on the receiving end of a lawsuit at the first indication of food poisoning or other malady, load after load of this food goes into the trash every single day all across the country. Over the past three years I’d imagine the total weight of the food from flights I’ve flown that went into the trash would total a couple of tons.

While lawsuits and courtrooms certainly have their place, I personally think it’s high time our society acknowledged the fact that safety does not equate an absence of risk. Failure to do so is putting us, our industry, our economy, and even our way of life at risk. That’s the cost of the society we’ve built. Is it worth it?

Backdoor Rule Making?

Wednesday, September 24th, 2014

On February 10, 2014, the Cessna Aircraft Company did something quite unprecedented in the history of piston GA: It published a revision to the service manual for cantilever-wing Cessna 210-series airplanes that added three new pages to the manual. Those three pages constituted a new section 2B to the manual, titled “Airworthiness Limitations”:

Cessna 210 Service Manual Section 2B

This section purports to impose “mandatory replacement times and inspection intervals for components and aircraft structures.” It states that the new section is “FAA-Approved” and that compliance is required by regulation.

Indeed, FARs 91.403(c) and 43.16 both state  that if a manufacturer’s maintenance manual contains an Airworthiness Limitations section (ALS), any inspection intervals and replacement times prescribed in that ALS are compulsory. FAR 91.403(c) speaks to aircraft owners:

§91.403(c) No person may operate an aircraft for which a manufacturer’s maintenance manual or instructions for continued airworthiness has been issued that contains an Airworthiness Limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section … have been complied with.

and FAR 43.16 speaks to mechanics:

§43.16 Each person performing an inspection or other maintenance specified in an Airworthiness Limitations section of a manufacturer’s maintenance manual or Instructions for Continued Airworthiness shall perform the inspection or other maintenance in accordance with that section…

Sounds pretty unequivocal, doesn’t it? If the maintenance manual contains an ALS, any mandatory inspection intervals and replacement times have the force of law.

The new ALS in the Cessna 210 maintenance manual mandates eddy current inspection of the wing main spar lower caps. For most 210s, an initial spar inspection is required at 8,000 hours time-in-service, with recurring inspections required every 2,000 hours thereafter. However, for 210s operated in a “severe environment” the inspections are required  at 3,500 hours and every 500 hours thereafter:

Cessna 210 inspection times

For P210s, the new ALS also imposes a life limit of 13,000 hours on the windshield, side and rear windows, and ice light lens.

What’s wrong with this picture?

To be fair, the eddy current inspection is not that big a deal.  An experienced technician can do it in a few hours. The most difficult part is that most service centers have neither the eddy current test eequipment nor a trained and certificated non-destructive testing (NDT) technician on staff. So most Cessna 210 owners will need to fly their airplane to a specialty shop  Since most airplanes will need to do this only once every 2,000 hours and since most of them fly less than 200 hours per year, one could hardly classify this recurrent eddy current inspection as Draconian. Similarly, not too many P210s are likely to reach the 13,000-hour life window life limit.

No, the issue isn’t the spar cap inspection or window life limits themselves—it’s the extraordinary method by which Cessna is attempting to make them compulsory.

Normally, if the manufacturer of an aircraft, engine or propeller wants to impose a mandatory inspection interval or a mandatory replacement or overhaul time on the owners of its aeronautical product, the manufacturer goes to the FAA and requests that an Airworthiness Directive (AD) be issued. If the FAA agrees and decides to issue an AD, it does so by means of a formal rule-making process prescribed by the federal Administrative Procedure Act (APA). Ultimately, the AD is published in the Federal Register and becomes an amendment to Part 39 of thee FARs. That’s what gives the AD its “teeth” and makes it compulsory for aircraft owners to comply with it.

§91.403(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter.

The APA governs the way that administrative agencies of the federal government (including the FAA) may propose and establish regulations. It has been called “a bill of rights” for Americans whose affairs are controlled or regulated by federal government agencies. The APA requires that before a federal agency can establish a new regulation, it must publish a notice of proposed rule making (NPRM) in the Federal Register, provide members of the public who would be impacted by the proposed regulation an opportunity to submit comments, and then take those comments seriously in making its final rule. The APA also establishes rights of appeal if a person affected by the regulation feels it is unjust or should be waived.

Because of the APA and other federal statutes, it is difficult for the FAA to issue ADs arbitrarily or capriciously. The agency first has to demonstrate that a bona fide unsafe condition exists, and that its frequency and severity of the safety risk rises to the level that makes rule making appropriate. It has to estimate the financial impact on affected owners. It has to provide a public comment period, give serious consideration to comments submitted, and respond to those comments formally when issuing its final rule.

As someone who has been heavily involved in numerous AD actions on behalf of various alphabet groups, I can tell you that the notice-and-comment provisions of the APA is extremely important, and that concerted efforts by aircraft owners and their representative industry organizations have often had great impact on the final outcome.

Through the back door?

That’s what makes Cessna’s action last February so insidious.

The addition of an Airworthiness Limitations section to the Cessna 210 maintenance manual was done without going through the rule making process. There was no NPRM and no comment period. Affected owners never had an opportunity to challenge the need for eddy current inspections of their wing spars. Cessna was never required to demonstrate that a genuine unsafe condition exists, nor weigh the cost impact against the safety benefit.Cessna 210 service manual By adding an ALS to the maintenance manual rather than ask the FAA to issue an AD, Cessna is attempting to bypass the APA-governed AD process and impose its will on aircraft owners through the back door.

Granted that the initial contents of the new ALS is not excessively burdensome. But if Cessna’s action is allowed to go unchallenged, it could set a terrible precedent. It would mean that any aircraft, engine or propeller manufacturer could retroactively impose its will on aircraft owners.

And if that happens, Katy bar the (back) door!

That’s why I’ve been working with my colleague Paul New—owner of Tennessee Aircraft Services, Inc. and honored by the FAA in 2007 as National Aviation Maintenance Technician of the Year—to challenge what Cessna is doing. On September 15th, Paul sent a letter that we jointly drafted to Mark  W. Bury (AGC-200), the FAA’s top regulations lawyer in its Office of General Counsel at FAA headquarters, asking him to issue a formal letter of interpretation as to whether compliance with the so-called mandatory inspection intervals set forth in section 2B of the Cessna 210 maintenance manual is actually required by regulation. We specifically ask Mr. Bury to rule on the question of whether retroactive enforcement of such a maintenance manual amendment by the FAA would constitute an APA violation.

The wheels of justice turn slowly at FAA Headquarters. We have been advised that AGC-200 has a four-month backlog of requests for letters of interpretation, so our request probably will not be looked at until the first quarter of 2015. But at least our request is in the queue. I am cautiously optimistic that AGC-200 will see things the way Paul and I see them, and will rule that a manufacturer’s publication of an ALS cannot be retroactively enforceable against aircraft owners unless the FAA issues an AD making it so.