Regulatory Roadblock?

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Last December, Larry had the Continental TSIO-360-MB engine in his 1987 Mooney 252 TSE major overhauled by a well-known engine shop. Now, his airplane was going through its annual inspection and the IA was telling Larry there was a big problem with his freshly overhauled engine.

In the course of the overhaul, the engine shop discovered that Larry’s crankcase had a large crack that was deemed unrepairable, so the engine shop procured a used serviceable crankcase. The shop built up Larry’s overhauled engine using this serviceable crankcase. They removed and destroyed the original data plate from the serviceable crankcase and installed the data plate from Larry’s engine on it. Now Larry’s engine had the same data plate and same engine serial number as it had before. The engine shop documented all this in their logbook entry.

In the course of doing his logbook research for the annual inspection, Larry’s IA read the engine shop’s logbook entry and became concerned. He told Larry that the engine shop improperly switched the engine data plates without FAA authorization, and referenced FAR 45.13(c) which states:

…no person may remove or install any identification plate required by §45.11, without the approval of the FAA.

Larry called the overhaul shop to ask them about this. He spoke with the shop owner, who told Larry that what they’d done with the data plates was proper procedure that was done routinely by all engine shops, and that no special FAA authorization was required. Larry related his conversation with the shop owner to his IA, who remained unpersuaded and maintained that Larry’s engine was not airworthy unless the data plate swap was approved in writing by the FAA.

At this point, Larry felt he was between a rock and a hard place. His engine shop was saying his engine was legal, but his IA was telling him it wasn’t. Larry realized he needed help to get this roadblock resolved. He had enrolled his Mooney in the SavvyQA consulting program, so he contacted Savvy and was soon in conversation with Savvy’s technical director Jeff Iskierka.

Jeff carefully reviewed the regulation in question (FAR 45.13) and concluded that the engine shop was correct and that Larry’s IA was mistaken. That’s because what FAR 45.13(c) actually says is:

Except as provided in paragraph (d)(2) of this section,no person may remove or install any identification plate required by § 45.11, without the approval of the FAA.

and the exception in 45.13(d)(2) says:

(d) Persons performing work under the provisions of Part 43 of this chapter may…

(2) Remove an identification plate required by § 45.11 when necessary during maintenance operations.

Jeff consulted with other members of the Savvy technical team, including two who had extensive experience working at engine shops. They confirmed that what the engine shop had done was proper removal and reinstallation of the data plate during maintenance operations on the engine, and that no FAA approval was necessary. Jeff even asked Savvy CEO Mike Busch A&P/IA to weigh in, since Mike is a well-known expert in the interpretation of FAA maintenance regulations. Mike’s take was:

The original engine data plate MUST be used. The data plate goes with the engine, not with the crankcase. If the replacement case halves were in someone’s inventory as serviceable spares, the data plate should have been removed from the case and destroyed if the case was no longer part of its original engine.

Jeff and Larry even consulted with Continental Motors’ product support engineer Tim Owen, who said:

When crankcases are repaired or replaced, the shops that are approved to perform crankcase repairs install the original engine data plate on the new or replaced crankcase.

Confronted with all of this information, Larry’s IA ultimately relented and agreed that the removal and reinstallation of the engine’s original data plate during the overhaul was proper and did not require any special FAA approval. The IA confessed to Larry he’d gotten himself in serious trouble with another issue involving switching data plates, and was therefore a bit oversensitive to this issue. He signed off Larry’s Mooney as airworthy and approved it for return to service.

Larry’s decision to consult with Savvy about this thorny regulatory matter was a smart move that helped extricate him from a difficult situation that had his airplane imprisoned.

Wouldn’t you benefit by having Savvy’s technical team on your side when issues like this arise unexpectedly? Learn more about SavvyQA.

You bought a plane to fly it, not stress over maintenance.

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