Narrative:

I took the position of director of maintenance here at this new company. In the course of assuming my duties; I looked into each of our 135 chartered aircraft and their compliance with 135 regulations. One item that turned up as questionable concerned our cessna 414. In august of 2002; cessna came out with a large supplemental inspection document (SID) concerning repetitive ndt testing on airframe parts and various components of the cessna 414's. This is a fairly comprehensive; time consuming inspection. To complete the inspection alone (not to fix anything found during the inspection) would be in excess of $80;000. There seems to be some disagreement within the FAA as to whether or not these inspections are required for 135 operators. I have contacted the FAA afs-340 in washington; dc; and they say the SID's are not required to be done by 135 operators; unless the individual operator's operations specifications require it. I've contacted various other operators that fly cessna 414's; some say their FSDO's require them to comply with the SID's; other operators say their FSDO's do not require them to do so. Our cessna 414 has not had any part of these SID inspections complied with. The possible fine imposed by the FAA; should they decide to go through with a 'violation' proceeding; would be very substantial. After reviewing the inspection criteria of the SID's; they seem to be aimed at the high time aircraft; mostly used for freight operations. Our aircraft and possibly most of the fleet don't fit into this usage area. We have some 5400 hours on our aircraft; although it does fit into the 'blanket' of most of the inspections being due if the aircraft is over 20 years old; as are most aircraft. I feel that when this SID inspection was issued by cessna; they as a manufacturer; should have contacted the FAA and come up with a reasonable time frame to complete these inspections or decide realistically; which aircraft should be inspected. Now it is up to us operators to work out the details with our individual FSDO; which we will be meeting with shortly. Callback conversation with reporter revealed the following information: the reporter is caught in a situation that requires a decision from some authority that can decide if the SID is only a service bulletin or a required mandatory document that must be accomplished. Contact with FAA as-340 in washington; dc; say the SID's are not required to be accomplished by 135 operators. But checking with operators of C414 aircraft in the local region of the country revealed some flight standards district offices require the inspection be performed and other flight standard district offices do not require them to make the inspection. The manufacturer has offered no guidance on the inspection requirements. The reporter has scheduled a meeting with the local FSDO to try and work out the details.

Related reports:

Google
 

Original NASA ASRS Text

Title: A PART 135 DIRECTOR OF MAINT OPERATING C414 ACFT IS UNABLE TO GET A DEFINITIVE ANSWER FROM ANY REGULATORY AGENCY OR MANUFACTURER ON INSPECTION REQUIREMENTS CONCERNING A SUPPLEMENTAL INSPECTION DOCUMENT.

Narrative: I TOOK THE POSITION OF DIRECTOR OF MAINT HERE AT THIS NEW COMPANY. IN THE COURSE OF ASSUMING MY DUTIES; I LOOKED INTO EACH OF OUR 135 CHARTERED ACFT AND THEIR COMPLIANCE WITH 135 REGULATIONS. ONE ITEM THAT TURNED UP AS QUESTIONABLE CONCERNED OUR CESSNA 414. IN AUGUST OF 2002; CESSNA CAME OUT WITH A LARGE SUPPLEMENTAL INSPECTION DOCUMENT (SID) CONCERNING REPETITIVE NDT TESTING ON AIRFRAME PARTS AND VARIOUS COMPONENTS OF THE CESSNA 414'S. THIS IS A FAIRLY COMPREHENSIVE; TIME CONSUMING INSPECTION. TO COMPLETE THE INSPECTION ALONE (NOT TO FIX ANYTHING FOUND DURING THE INSPECTION) WOULD BE IN EXCESS OF $80;000. THERE SEEMS TO BE SOME DISAGREEMENT WITHIN THE FAA AS TO WHETHER OR NOT THESE INSPECTIONS ARE REQUIRED FOR 135 OPERATORS. I HAVE CONTACTED THE FAA AFS-340 IN WASHINGTON; DC; AND THEY SAY THE SID'S ARE NOT REQUIRED TO BE DONE BY 135 OPERATORS; UNLESS THE INDIVIDUAL OPERATOR'S OPS SPECS REQUIRE IT. I'VE CONTACTED VARIOUS OTHER OPERATORS THAT FLY CESSNA 414'S; SOME SAY THEIR FSDO'S REQUIRE THEM TO COMPLY WITH THE SID'S; OTHER OPERATORS SAY THEIR FSDO'S DO NOT REQUIRE THEM TO DO SO. OUR CESSNA 414 HAS NOT HAD ANY PART OF THESE SID INSPECTIONS COMPLIED WITH. THE POSSIBLE FINE IMPOSED BY THE FAA; SHOULD THEY DECIDE TO GO THROUGH WITH A 'VIOLATION' PROCEEDING; WOULD BE VERY SUBSTANTIAL. AFTER REVIEWING THE INSPECTION CRITERIA OF THE SID'S; THEY SEEM TO BE AIMED AT THE HIGH TIME ACFT; MOSTLY USED FOR FREIGHT OPS. OUR ACFT AND POSSIBLY MOST OF THE FLEET DON'T FIT INTO THIS USAGE AREA. WE HAVE SOME 5400 HOURS ON OUR ACFT; ALTHOUGH IT DOES FIT INTO THE 'BLANKET' OF MOST OF THE INSPECTIONS BEING DUE IF THE ACFT IS OVER 20 YEARS OLD; AS ARE MOST ACFT. I FEEL THAT WHEN THIS SID INSPECTION WAS ISSUED BY CESSNA; THEY AS A MANUFACTURER; SHOULD HAVE CONTACTED THE FAA AND COME UP WITH A REASONABLE TIME FRAME TO COMPLETE THESE INSPECTIONS OR DECIDE REALISTICALLY; WHICH ACFT SHOULD BE INSPECTED. NOW IT IS UP TO US OPERATORS TO WORK OUT THE DETAILS WITH OUR INDIVIDUAL FSDO; WHICH WE WILL BE MEETING WITH SHORTLY. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE RPTR IS CAUGHT IN A SIT THAT REQUIRES A DECISION FROM SOME AUTHORITY THAT CAN DECIDE IF THE SID IS ONLY A SERVICE BULLETIN OR A REQUIRED MANDATORY DOCUMENT THAT MUST BE ACCOMPLISHED. CONTACT WITH FAA AS-340 IN WASHINGTON; DC; SAY THE SID'S ARE NOT REQUIRED TO BE ACCOMPLISHED BY 135 OPERATORS. BUT CHKING WITH OPERATORS OF C414 ACFT IN THE LOCAL REGION OF THE COUNTRY REVEALED SOME FLT STANDARDS DISTRICT OFFICES REQUIRE THE INSPECTION BE PERFORMED AND OTHER FLT STANDARD DISTRICT OFFICES DO NOT REQUIRE THEM TO MAKE THE INSPECTION. THE MANUFACTURER HAS OFFERED NO GUIDANCE ON THE INSPECTION REQUIREMENTS. THE RPTR HAS SCHEDULED A MEETING WITH THE LOCAL FSDO TO TRY AND WORK OUT THE DETAILS.

Data retrieved from NASA's ASRS site as of January 2009 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.