Narrative:

On the advice given to us by our principal maintenance inspector, we switched to a progressive care inspection program to give more flexibility in maintenance scheduling. The program consists of 4 operations at 50 hour intervals. If all the operations are not completed within 12 calendar months, a complete inspection of all the unfinished operations plus operation #4 must be complied with before the aircraft can be put back in service. The problem arises at the 50 hour intervals. It is not a 'hard' time since the program permits you to have 10 hours of grace time prior to and after each interval of operation to allow flexibility in maintenance scheduling. There are also examples given to illustrate how to comply with the 50 hour interval inspections and the +/-10 hours grace periods. The examples look like the following: a) 10 hour grace period prior to 50 hour operation interval inspection -- operation #1 45 hour completed, 50 hour due, 100 hour next due. Operation #2 98 hour completed, 100 hour due, 150 hour next due. Operation #3 140 hour completed, 150 hour due, 200 hour next due. B) 10 hour grace period exceeding 50 hour operation interval inspection: operation #1 50 hour completed, 50 hour due, 100 hour next due. Operation #2 105 hour completed, 100 hour due, 150 hour next due. Operation #3 156 hour completed, 150 hour due, 200 hour next due. About 3 weeks ago, I told the maintenance scheduler that we had about 10 hours left until operation #2 was due on the aircraft. We counted the scheduled trips, estimated the approximately flight times and determined a date to schedule the aircraft for the next inspection. The following day I had a 135 instrument check ride with my principal operation inspector and during the oral we talked about the inspection program. I explained how the complete inspection of the aircraft was done prior to being put on the program, and that there were 50 hour interval inspections with 10 hour grace periods prior to and after each interval inspection. 2 days later the principal maintenance inspector and avionics inspector inspected our facilities and aircraft at our hangar. When they left, I informed the maintenance scheduler that we would be right at the 50 hour inspection limit after our next flight. He informed me again that he had just looked it up in the maintenance program and that we had a 10 hour grace period. The next day I took a part 91 flight to the alo airport. My principal operations inspector was there and ramp checked me again. Although I was within a few tenths of the 50 hour inspection time, I was not over it. However, we both knew I would exceed it by 2-3 tenths of an hour on the flight home. Again we discussed the inspection program, the 40 hour interval inspections and the 10 hour grace periods. He indicated that he was not familiar with the program and therefore he was going to make an effort to visit our facilities and familiarize himself with the programs. I took the part 91 flight home when my passenger showed up. Upon reaching my flight facilities again I decided to look at the program. I skimmed it quickly to reassure myself that there was a 10 hour grace period. I then proceeded later that day to take another part 91 flight since I knew it would not take more than 2.5 hours flight time and that would keep me well within the 10 hour grace period which I had just confirmed by referencing the inspection manual. The following day I had no flts and since I knew my principal operations inspector would be coming, I decided to study both inspection programs for the turboprop and the piston twin. As I read the inspection program everything appeared to be in order as I had interpreted it except I noticed a 'note' on the very last line of the page which gave reference to far 91.409 (D)(ii). When I looked the regulation up, it refers to 'instructions for exceeding an inspection interval by not more than 10 hours while en route.' I informed the maintenance scheduler and to our dismay we both had missed the note on the bottom of the page which referred to the 10 hour grace period exceeding the inspection interval as being for en route flight. Needless to say, I exceeded the interval inspection by 2.5 hours inadvertently because of inadequate reading, but I did not do it deliberately since I thought I was in full compliance with the inspection program. I still have questions as to if I violated flight inspection procedures. The flts were part 91 and far 409 (D)(ii) states that if you discontinue the progressive program inspection, the first annual inspection is due 12 calendar months after the last complete inspection under the progressive inspection program. Since the last inspection was sep/97 and the next complete inspection is due sep/xa/98, the part 91 flight I took on may/xa/98 does not violate that date. I believe the program is a good program, but with 2 minor changes it could alleviate the potential problems I had. If they would incorporate the 'instructions for exceeding an inspection by not more than 10 hours while en route' with their statements about 10 hour grace periods and include the statement in their examples, I believe the problem about having a true grace period of +/-10 hours would be alleviated. I am also left with confusion with respect to part 91 flight inspections regarding the progressive maintenance program. Are they restr by the time interval inspections similar to flts for hire under part 135 or does the 12 calendar month inspection still apply? Callback conversation with reporter revealed the following information: the reporter said that there was no action taken by the poi after the ramp check. This reporter called a legal branch in aviation and received advice to file a NASA report. The question of part 91 flight inspections were answered, the 12 calendar month inspection still applies.

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Original NASA ASRS Text

Title: AN FBO OPERATOR GETS CONFUSED AS TO THE LEGALITIES OF THE PROGRESSIVE INSPECTION PROGRAM AND FLIES HIS ACFT OVER THE ALLOWABLE TIME FOR INSPECTION. HE GETS RAMP CHKED DURING THAT FLT BUT NOT VIOLATED. THE POI WASN'T INFORMED AS TO THE PROGRAM'S SPECIFICS.

Narrative: ON THE ADVICE GIVEN TO US BY OUR PRINCIPAL MAINT INSPECTOR, WE SWITCHED TO A PROGRESSIVE CARE INSPECTION PROGRAM TO GIVE MORE FLEXIBILITY IN MAINT SCHEDULING. THE PROGRAM CONSISTS OF 4 OPS AT 50 HR INTERVALS. IF ALL THE OPS ARE NOT COMPLETED WITHIN 12 CALENDAR MONTHS, A COMPLETE INSPECTION OF ALL THE UNFINISHED OPS PLUS OP #4 MUST BE COMPLIED WITH BEFORE THE ACFT CAN BE PUT BACK IN SVC. THE PROB ARISES AT THE 50 HR INTERVALS. IT IS NOT A 'HARD' TIME SINCE THE PROGRAM PERMITS YOU TO HAVE 10 HRS OF GRACE TIME PRIOR TO AND AFTER EACH INTERVAL OF OP TO ALLOW FLEXIBILITY IN MAINT SCHEDULING. THERE ARE ALSO EXAMPLES GIVEN TO ILLUSTRATE HOW TO COMPLY WITH THE 50 HR INTERVAL INSPECTIONS AND THE +/-10 HRS GRACE PERIODS. THE EXAMPLES LOOK LIKE THE FOLLOWING: A) 10 HR GRACE PERIOD PRIOR TO 50 HR OP INTERVAL INSPECTION -- OP #1 45 HR COMPLETED, 50 HR DUE, 100 HR NEXT DUE. OP #2 98 HR COMPLETED, 100 HR DUE, 150 HR NEXT DUE. OP #3 140 HR COMPLETED, 150 HR DUE, 200 HR NEXT DUE. B) 10 HR GRACE PERIOD EXCEEDING 50 HR OP INTERVAL INSPECTION: OP #1 50 HR COMPLETED, 50 HR DUE, 100 HR NEXT DUE. OP #2 105 HR COMPLETED, 100 HR DUE, 150 HR NEXT DUE. OP #3 156 HR COMPLETED, 150 HR DUE, 200 HR NEXT DUE. ABOUT 3 WKS AGO, I TOLD THE MAINT SCHEDULER THAT WE HAD ABOUT 10 HRS LEFT UNTIL OP #2 WAS DUE ON THE ACFT. WE COUNTED THE SCHEDULED TRIPS, ESTIMATED THE APPROX FLT TIMES AND DETERMINED A DATE TO SCHEDULE THE ACFT FOR THE NEXT INSPECTION. THE FOLLOWING DAY I HAD A 135 INST CHK RIDE WITH MY PRINCIPAL OP INSPECTOR AND DURING THE ORAL WE TALKED ABOUT THE INSPECTION PROGRAM. I EXPLAINED HOW THE COMPLETE INSPECTION OF THE ACFT WAS DONE PRIOR TO BEING PUT ON THE PROGRAM, AND THAT THERE WERE 50 HR INTERVAL INSPECTIONS WITH 10 HR GRACE PERIODS PRIOR TO AND AFTER EACH INTERVAL INSPECTION. 2 DAYS LATER THE PRINCIPAL MAINT INSPECTOR AND AVIONICS INSPECTOR INSPECTED OUR FACILITIES AND ACFT AT OUR HANGAR. WHEN THEY LEFT, I INFORMED THE MAINT SCHEDULER THAT WE WOULD BE RIGHT AT THE 50 HR INSPECTION LIMIT AFTER OUR NEXT FLT. HE INFORMED ME AGAIN THAT HE HAD JUST LOOKED IT UP IN THE MAINT PROGRAM AND THAT WE HAD A 10 HR GRACE PERIOD. THE NEXT DAY I TOOK A PART 91 FLT TO THE ALO ARPT. MY PRINCIPAL OPS INSPECTOR WAS THERE AND RAMP CHKED ME AGAIN. ALTHOUGH I WAS WITHIN A FEW TENTHS OF THE 50 HR INSPECTION TIME, I WAS NOT OVER IT. HOWEVER, WE BOTH KNEW I WOULD EXCEED IT BY 2-3 TENTHS OF AN HR ON THE FLT HOME. AGAIN WE DISCUSSED THE INSPECTION PROGRAM, THE 40 HR INTERVAL INSPECTIONS AND THE 10 HR GRACE PERIODS. HE INDICATED THAT HE WAS NOT FAMILIAR WITH THE PROGRAM AND THEREFORE HE WAS GOING TO MAKE AN EFFORT TO VISIT OUR FACILITIES AND FAMILIARIZE HIMSELF WITH THE PROGRAMS. I TOOK THE PART 91 FLT HOME WHEN MY PAX SHOWED UP. UPON REACHING MY FLT FACILITIES AGAIN I DECIDED TO LOOK AT THE PROGRAM. I SKIMMED IT QUICKLY TO REASSURE MYSELF THAT THERE WAS A 10 HR GRACE PERIOD. I THEN PROCEEDED LATER THAT DAY TO TAKE ANOTHER PART 91 FLT SINCE I KNEW IT WOULD NOT TAKE MORE THAN 2.5 HRS FLT TIME AND THAT WOULD KEEP ME WELL WITHIN THE 10 HR GRACE PERIOD WHICH I HAD JUST CONFIRMED BY REFING THE INSPECTION MANUAL. THE FOLLOWING DAY I HAD NO FLTS AND SINCE I KNEW MY PRINCIPAL OPS INSPECTOR WOULD BE COMING, I DECIDED TO STUDY BOTH INSPECTION PROGRAMS FOR THE TURBOPROP AND THE PISTON TWIN. AS I READ THE INSPECTION PROGRAM EVERYTHING APPEARED TO BE IN ORDER AS I HAD INTERPED IT EXCEPT I NOTICED A 'NOTE' ON THE VERY LAST LINE OF THE PAGE WHICH GAVE REF TO FAR 91.409 (D)(II). WHEN I LOOKED THE REG UP, IT REFERS TO 'INSTRUCTIONS FOR EXCEEDING AN INSPECTION INTERVAL BY NOT MORE THAN 10 HRS WHILE ENRTE.' I INFORMED THE MAINT SCHEDULER AND TO OUR DISMAY WE BOTH HAD MISSED THE NOTE ON THE BOTTOM OF THE PAGE WHICH REFERRED TO THE 10 HR GRACE PERIOD EXCEEDING THE INSPECTION INTERVAL AS BEING FOR ENRTE FLT. NEEDLESS TO SAY, I EXCEEDED THE INTERVAL INSPECTION BY 2.5 HRS INADVERTENTLY BECAUSE OF INADEQUATE READING, BUT I DID NOT DO IT DELIBERATELY SINCE I THOUGHT I WAS IN FULL COMPLIANCE WITH THE INSPECTION PROGRAM. I STILL HAVE QUESTIONS AS TO IF I VIOLATED FLT INSPECTION PROCS. THE FLTS WERE PART 91 AND FAR 409 (D)(II) STATES THAT IF YOU DISCONTINUE THE PROGRESSIVE PROGRAM INSPECTION, THE FIRST ANNUAL INSPECTION IS DUE 12 CALENDAR MONTHS AFTER THE LAST COMPLETE INSPECTION UNDER THE PROGRESSIVE INSPECTION PROGRAM. SINCE THE LAST INSPECTION WAS SEP/97 AND THE NEXT COMPLETE INSPECTION IS DUE SEP/XA/98, THE PART 91 FLT I TOOK ON MAY/XA/98 DOES NOT VIOLATE THAT DATE. I BELIEVE THE PROGRAM IS A GOOD PROGRAM, BUT WITH 2 MINOR CHANGES IT COULD ALLEVIATE THE POTENTIAL PROBS I HAD. IF THEY WOULD INCORPORATE THE 'INSTRUCTIONS FOR EXCEEDING AN INSPECTION BY NOT MORE THAN 10 HRS WHILE ENRTE' WITH THEIR STATEMENTS ABOUT 10 HR GRACE PERIODS AND INCLUDE THE STATEMENT IN THEIR EXAMPLES, I BELIEVE THE PROB ABOUT HAVING A TRUE GRACE PERIOD OF +/-10 HRS WOULD BE ALLEVIATED. I AM ALSO LEFT WITH CONFUSION WITH RESPECT TO PART 91 FLT INSPECTIONS REGARDING THE PROGRESSIVE MAINT PROGRAM. ARE THEY RESTR BY THE TIME INTERVAL INSPECTIONS SIMILAR TO FLTS FOR HIRE UNDER PART 135 OR DOES THE 12 CALENDAR MONTH INSPECTION STILL APPLY? CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE RPTR SAID THAT THERE WAS NO ACTION TAKEN BY THE POI AFTER THE RAMP CHK. THIS RPTR CALLED A LEGAL BRANCH IN AVIATION AND RECEIVED ADVICE TO FILE A NASA RPT. THE QUESTION OF PART 91 FLT INSPECTIONS WERE ANSWERED, THE 12 CALENDAR MONTH INSPECTION STILL APPLIES.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.