The Savvy Aviator #18: Avoid an Annual Calamity
There are many things that can go wrong during an annual inspection, but the most critical start with an uninformed and uninvolved owner. AVweb's Mike Busch takes us through the things we could do to mess it up, and how to avoid being messed up by others.
My last column related the story of an aircraft owner who purchased a twin Cessna, took the aircraft to an IA for its first annual inspection, and had a truly horrific experience. At the end of that column, I promised to take a look at what an owner could do to avoid such a calamity. In fact, a debacle during an annual inspection is usually the product of a classic "error chain" -- a sequence of mistakes that culminates in a bad outcome. If any one of these mistakes can be avoided, the bad outcome can be averted.
I've talked to lots of owners who got caught by error chains like this, and there are lessons to be learned. Let's look at some common mistakes that occur when someone buys a plane and then goes on to get that "first" annual.
The Purchase Decision
To begin with, we need to discuss the decision to purchase an older airplane; especially if it is a high-performance or twin-engined plane, or if the plane will be purchased by a first-time owner.
As the Cessna 300/400 tech rep for the Cessna Pilots Association, I'm frequently asked for advice by owners of single-engine airplanes who want to upgrade to a twin. I generally ask these owners a lot of questions about exactly why they want to upgrade, and more often than not I find that are doing it for all the wrong reasons. In such cases, I try my best to talk them out of buying a twin. I've had this happen so many times that in 1997 I wrote an article on the subject -- Do You Really Want A Twin?
For those who actually have good reasons for wanting to buy or upgrade to a twin, my advice is invariably to purchase the latest-year and best-maintained aircraft they can possibly afford. I've seen way too many cases where an aspiring twin owner purchased an older airplane for what seemed like a bargain price, only to discover that the airplane they acquired was a proverbial money pit. Very simply, if you purchase a twin whose maintenance has been neglected, it will eat you alive.
While researching this issue, I performed a little experiment: I sought out three different A&P/IA shop owners whom I knew had a lot of experience maintaining twin Cessnas, and I posed the following question to each of them:
"Suppose that a first-time twin buyer purchased a mid-1960s, turbocharged, piston twin for $70,000, and then brought it to your shop for the first annual inspection on the new owner's watch ..."
At this point, all three IAs rolled their eyes and sighed, because they could see what was coming.
"... What would be your best guess as to what the owner might expect to spend to get the aircraft in airworthy condition and approved for return to service?"
After some hemming and hawing, the best guesses I received from these IAs ranged from $25,000 to $50,000. All agreed that if the aircraft was in worse-than-average condition, the bill could be considerably higher than that.
If you're a seasoned owner with lots of excess cash, free time, and wrench-swinging aptitude (and maybe an A&P ticket), buying a 40-year-old fixer-upper twin might be a good "project airplane" to keep you occupied. Otherwise, it's probably a good way to decimate your finances and make you wish you never got involved in aviation.
Do you really want to buy a twin? If so, buy the newest and cleanest one you can possibly afford.
The Pre-Buy Inspection
After hearing about owners whose new (to them) plane turned out to have lots of problems, many people ask how it could have happened. "Surely any pre-purchase inspection would have revealed the state of disrepair," they say, "and convinced that buyer to pass on it."
I've preached before about getting a pre-buy inspection, especially when buying an older plane. But such an inspection must be done right. One or more of the following factors could cause a buyer to incorrectly assume a plane would be good to purchase:
- The mechanic who does the pre-buy is not knowledgeable about that type of plane;
- The mechanic who does the pre-buy has a relationship with the seller or broker, and thus a stake in the sale going through; or
- The mechanic who does the pre-buy advises the new owner that the airplane has problems, but the buyer decides to buy it anyway.
I've seen all three of these factors at work many times, and the result is always expensive for the buyer. It is essential for any prospective buyer to seek out a mechanic who has as much expertise as possible in the particular make and model involved. It is equally important that the inspecting mechanic have no previous relationship with the aircraft, the seller, or anyone else involved in the transaction; his allegiance must be solely to the buyer.
It's also crucial for the buyer to pay attention to what the mechanic has to say, and to pass on the purchase if the pre-buy uncovers significant airworthiness issues. All too often, buyers become so enamored of an aircraft because it has a beautiful paint job, snazzy interior or bleeding-edge avionics stack that they overlook serious mechanical problems.
Choice Of A Shop for the Annual Inspection
Owners need to be mindful that just because a mechanic holds an A&P certificate and an Inspection Authorization doesn't mean he's competent to inspector or repair your aircraft. Unfortunately, the FAA has not seen fit to issue "type ratings" for mechanics (although I think it should). My A&P ticket authorizes me to swing wrenches on anything that flies, from a J-3 Cub to a Gulfstream V to a Bell Jet Ranger to a B-29 or P-51, and my Inspection Authorization permits me to sign off an annual inspection or major repair or alteration on any of those aircraft.
That's ridiculous. I'm clearly not competent to inspect or repair most of those aircraft. I know quite a bit about maintaining twin Cessnas; I should, because I've owned one for 18 years. I also know enough about single-engine Cessnas, Beech Bonanzas, and Bellanca Vikings to be dangerous. But present me with a Piper Comanche, a Mooney TLS or a Maule and I don't have a clue.
In the absence of mechanic type-ratings, owners need to be very careful about which A&P mechanics they allow to touch their aircraft. If you own a Cessna P210 or Beech Duke, for instance, it's not enough to find a certificated A&P mechanic; you need to find one who has lots of experience working on P210s or Dukes.
Owners also need to understand that mechanics are not required to take any recurrent training or evaluation once they've earned their A&P certificate. None! There's nothing analogous to the biennial flight review or the instrument proficiency check for mechanics. No requirement that they stay up-to-date on the latest service bulletins and maintenance alerts. No requirement for someone else to assess their competence from time to time. (Obviously, I think there should be.)
So just because someone has an A&P certificate or an IA doesn't mean he's necessarily competent to inspect or maintain your aircraft. It's the owner's job to check out the mechanic's credentials and make sure he knows what he's doing on the particular make and model involved before turning over the aircraft to his care.
Mismanagement Of The Annual
As I explained in The Savvy Aviator #5, there are eight distinct steps involved in annualing an aircraft:
- Open the aircraft;
- Inspect the aircraft;
- Inspect the maintenance records and research applicable ADs;
- Create a list of unairworthy items and other discrepancies;
- Repair the unairworthy items and other discrepancies;
- Perform routine preventive maintenance;
- Close the aircraft; and
- Create the required maintenance record entries ("sign off the annual").
Note that there is a crucial "decision point" between steps #4 and #5. This is the point in the process at which the IA has finished inspecting the aircraft, researched its logbooks, and created a list of everything he has found wrong with the aircraft. Some of them will be "unairworthy items" that the IA feels must be corrected before the aircraft can be approved for return to service. Others will be "discrepancies" that the IA recommends fixing, but which do not rise to the level of criticality to render the aircraft unairworthy.
At this decision point, it is essential for the owner to get involved. The owner and IA should go over the discrepancy list together in detail, item by item. The IA should explain each discrepancy to the owner, provide an estimate of the parts and labor cost of repairing the discrepancy (preferably in writing), and specify whether the IA considers the repair to be mandatory (i.e., an unairworthy item) or discretionary. At the conclusion of this review of the discrepancy list, the owner should have a detailed understanding of the aircraft's mechanical condition, and a very good idea of what it will cost to resolve each discrepancy. The owner can now make a decision about what repair work to authorize and what items to defer, and should give the shop explicit authorization to proceed with the agreed-upon repairs.
It is important to understand that this crucial decision point occurs quite early in the annual. For a fixed-gear, single-engine airplane, it typically requires no more than two days to open the aircraft, perform the inspection and logbook research, and write up the discrepancy list (steps 1-4); for a complex, turbocharged twin, figure four or five days, tops.
A Brief Digression ...
Recently, my wife's minivan started producing more exhaust noise than usual, and some metallic rattles started coming from underneath the vehicle, so she decided to take it in to a national-chain muffler shop to get the exhaust system fixed. Because my wife is rather mechanically challenged, I suggested that she ask the shop to inspect the exhaust system and give her an estimate of what it would cost to fix (parts and labor), and that she should then call me on her cellphone so we could discuss the estimate before she authorized the shop to proceed with the repairs.
An hour later, my wife phoned me to say that the shop found that the car needed a new muffler, tailpipe, and a few tailpipe hangars, and that the cost to repair would be about $325 plus tax. That sounded about right to me, so I suggested that she give the shop the go-ahead to proceed. I figured that was that.
A half-hour later, my wife called once again to say that the mechanic told her that it looked to him as if the vehicle needed new tires, and indicated that the shop had a special sale on Bridgestone tires and could replace all four tires for only $300 more. I told my wife that I really wanted to take a look at the tires myself before authorizing replacement (they'd looked OK to me), and that even if the tires did need replacement I'd prefer to have the work done at the tire store we've patronized for more than a decade rather than at the muffler shop.
Fifteen minutes later, my wife called a third time. The mechanic was now telling her that the front brakes were severely worn, and that the vehicle needed a $400 brake job before it would be safe to drive home. By this time, I was really pissed. I told my wife to instruct the mechanic in no uncertain terms that the only work he was authorized to perform was the $325 exhaust replacement. I suggested that she blame this all on me, to tell them that her husband was a stingy control freak who insisted on inspecting the tires and brakes himself.
The mechanic was not a happy camper. He cautioned my wife in strong terms about the dangers of driving home with tires and brakes in that condition, and reluctantly finished up the exhaust repairs, and settled up. By the time my wife got back home, she was an emotional wreck -- convinced that her tires and brakes might fail at any moment.
The next morning, I carefully inspected the tires and brakes on my wife's minivan. As I suspected, they were just fine. I also inspected the new muffler and tailpipe that the muffler shop had installed. Those looked fine, too -- the exhaust work had been done competently. Nevertheless, the whole ordeal left a bad taste in my mouth. Next time one of our cars needs muffler work, I'm not likely to patronize that particular shop.
Had my wife not called me at the "decision point," the bill would have exceeded $1,000 and my wife's minivan would have driven away with new tires and brakes that it didn't need. I treated the repeated phone calls with reports of more and more mechanical discrepancies as a big red flag that told me that things were escalating out of control, and that I needed to put a stop to it quickly and get the vehicle out of there.
Multiply all this by 40 and you have a rough approximation of what can happen if you mismanage the annual inspection of a sophisticated, high-performance airplane like a turbocharged, piston twin.
Calling In The Feds
I often hear from owners who are angry with their mechanic or shop in connection with some maintenance-related dispute, and who think they can gain leverage by taking their complaint to the FAA. Most of the time, I discourage owners from doing this. I explain to them that the FAA will not get involved in any dispute over charges that the owner considers excessive, work that the owner considers unnecessary, or anything else that looks to the FAA like a simple business dispute between an owner and a shop. The only situations likely to get the FAA's attention are those involving obvious safety hazards or blatant regulatory violations. Even in such cases, the owner may not get the desired response from the FAA unless he handles his complaint properly.
Ideally, the owner should file his complaint with the local FSDO before the aircraft is taken away from the shop; the owner should ask that an airworthiness inspector look at the aircraft while it is still on the shop's ramp. That gives the FAA the strongest possible case against the IA, because the shop or IA cannot claim that the airworthiness discrepancies in question occurred after the airplane left the shop.
Of course, that's not always possible. Sometimes the owner doesn't find out until he flies the plane away, or even later. But the more calendar time and flight hours that elapse before the FAA sees the airplane, the harder it is for the FAA to prove its case against the IA.
Harder, but not impossible. One FAA inspector I talked to pointed out that while criminal charges against an IA have to be proven beyond a reasonable doubt, a certificate action or civil penalty requires only proof by preponderance of the evidence. In other words, to suspend or revoke an IA's certificate and/or levy a monetary fine against him, the FAA's burden is only to prove that it is more likely than not that the IA violated the regulations. There are plenty of precedents for the FAA prevailing in enforcement actions against an IA even when some time and flight hours have elapsed between the IA's signoff and the filing of the complaint.
One FSDO inspector suggested to me that if an owner is unable to get the FAA to take action after using the usual "bottom-up" approach (by filing a complaint with the local FSDO), he still might be able to achieve the desired outcome by using a "top-down" approach. The FAA maintains a Safety Hotline Office in its Washington, D.C., headquarters that reports directly to the Administrator. There's a toll-free hotline number (800-255-1111) for reporting possible violations of the Federal Aviation Regulations or other aviation safety issues such as improper record keeping, non-adherence to procedures, unsafe aviation practices, etc. The inspector suggested that an owner call the hotline, and then follow up with a written complaint, complete with photographs, sent by registered mail to the hotline office at 800 Independence Avenue. The complaint will then be sent from Headquarters to the appropriate FAA Regional Office, and from there to the manager of the appropriate FSDO, and finally assigned to an airworthiness inspector for investigation. According to the inspector who suggested this to me, complaints that come "from the top down" in this fashion almost always result in the opening of a formal investigation.
Let's quickly review the lessons learned from this discussion:
- Think very carefully and do your homework before undertaking the purchase of any complex aircraft, particularly a twin. If you're sure you want to take the plunge, try to find the latest model and most immaculately maintained aircraft you can possibly afford, and expect to pay a premium price. Older aircraft with bargain-basement prices are often disasters waiting to happen.
- Insist on a thorough and comprehensive pre-buy inspection by a mechanic who is an expert on the particular make and model involved, and who has no prior relationship with the aircraft, the seller, or the broker, and whose sole allegiance is strictly to you, the buyer.
- Be very careful about who you allow to work on your aircraft. That goes double for annual inspections. Check out the mechanic's credentials and make sure he has substantial experience maintaining your particular make and model. When it comes to choosing a mechanic, "time in type" is more important than "total time."
- When you put your aircraft in the shop for an annual, make sure to instruct the IA that you want to come in and review the discrepancy list in detail before authorizing the shop to order any parts or proceed with any repairs. This "decision point" should occur within a few days of the time you put your airplane in the shop -- a week at most. Sit down with the IA and have him walk you through each item on the discrepancy list, providing specific estimates or parts and labor to resolve each discrepancy, and clearly identifying which he considers to be mandatory "airworthiness items" and which are discretionary. Make sure you fully understand each discrepancy, the proposed repair, and the estimated cost before you authorize the shop to do the work. When in doubt, get a second opinion.
- Any time a shop keeps finding additional discrepancies and/or revising its cost-to-repair estimate upwards, consider this a "red flag" that the situation is out of control. Do not authorize the additional work until you've done your homework. If you're uncomfortable (and you probably should be), seek a second opinion from a mechanic you trust. Consider instructing the shop to stop work, close up the airplane, and take it to another shop. (Obtain a ferry permit if necessary.)
- If you get upset with a shop or mechanic because they charged you too much or did work you didn't authorize, don't bother to call the FAA -- the agency will not get involved in business disputes between owners and mechanics. On the other hand, if you think a shop or mechanic has committed a serious regulatory violation and/or created a serious safety problem, you may want to consider filing a complaint with the FAA. If the usual bottom-up approach of contacting the local FSDO doesn't elicit the desired response, try the top-down approach of calling the FAA Safety Hotline. File your complaint as quickly as possible after the violation, because any delay can seriously weaken the FAA's case against the violator.
Hopefully we can all learn something useful from others' misfortunes.
See you next month.
Want to read more from Mike Busch? Check out the rest of his Savvy Aviator columns.