Was at the airport today tweaking some ads-b stuff on the 182 heavy. While minding my own business, a friend of mine (fairly newish IA) approached me with a question on how to sign off a condition inspection on an experimental with a certified engine. ?¿ I honestly didn’t have an answer, especially after I heard the whole story.
The engine was a Lycomings O-320E2D. A once airworthy certified engine we are all familiar with when found in its natural habitat under the cowl of a Cessna 172. Someone, somewhere converted the engines pistons to higher compression ones and gave it 20 or so extra ponies. Then someone took an engraving pencil to the data tag and with questionable penmanship, proclaimed th engine “EXPERIMENTAL”.
So the question is: if the engine in an experimental aircraft has a “certified “ engine with a data tag, is it not still required to meet its original design and subject to any AD’s for that engine? And a smaller question; who de-certifies engines and by what method is this done?

No method or de-certification necessary. Once the engine is installed on a experimental aircraft it becomes an experimental engine and can only be re certified if ‘zero timed.’ I know there are some that will disagree with me but that’s what the EAA, my FSDO, and the guy at FAA OK City told me.

Since the engine in question has been modified, high compression pistons, it is undeniably an experimental engine. There is no requirement to comply with ADs, service bulletins or anything else.

When performing a ‘condition inspection’ on a experimental your not determining if the airplane/engine meet the type design like when doing a ‘Annual’ on a certified plane. There is no ‘type design’ for an EAB aircraft. Your just making sure that it is “in condition for safe operation.”

Here's how the DAR that issued the airworthiness certificate for my experimental kitfox explained the Certified parts on an experimental: He said, to remain certified, the part...in this case the engine...must be maintained in accordance with the requirements of the manufacturer. ie, have a separate log book documenting hours, and all work done to it signed by an IA etc. the same as if it was in a certified plane. I would suspect that would include it having always been used with a propeller certified as compatible by the engine manufacturer.

The operating limitations issued with the airworthiness certificate for the experimental plane will show exactly how the sign off for a condition inspection is to be worded.

It sounds like this engine has not met the criteria to remain certified. To sign off the condition inspection for the experimental no separate log book for the engine is required.

I admit that I may have spent too long in the certified aircraft world and as such having a hard time with this. But just because an engine or component on the engine, or airframe, Is deemed experimental doesn’t excuse it from certain conditions. There are a lot of AD’s that affect parts no matter if they are in certified or experimental aircraft. So as in the case I have listed in the beginning of this thread; the engine has pistons that don’t necessarily belong in the engine. It also has an AD that “should” affect the engine, if it were in its certified condition. So how are those two thing supposed to be squared up?
I don’t have a dog in this fight, but in my mind I could be on either side. If a crank had internal corrosion or some other known potential risk of failure; who the hell cares what it it is installed in. On the other hand I understand it is in an experimental aircraft and as such allowed certain exceptions.

The description TCJ got from his DAR seems perfectly reasonable to me. It doesn't line up with what I was told but it sure seems reasonable.

ADs have no regulatory meaning to EAB aircraft. That doesn't mean it is a good idea to ignore ADs but since ADs are not regulatory to EAB aircraft an owner could simply ignore them. If the mechanic is uncomfortable signing off the condition inspection because of an AD on the engine then he can treat is just like an annual with a squawk list. Sign off the condition inspection with a squawk list, give the squawk list to the owner and let them put their name next to the ignored AD.

whee wrote:ADs have no regulatory meaning to EAB aircraft.

That doesn't seem to be entirely true as the FAA can issue an AD agains a non Type Certificated aircraft.
https://www.faa.gov/documentLibrary/med ... 039-7D.pdf

AC 39-7d wrote:b. Non-TC’d Aircraft and Products Installed Thereon. Non-TC’d aircraft
(e.g., amateur-built aircraft, experimental exhibition) are aircraft for which the FAA has not
issued a TC under part 21. The AD applicability statement will identify if the AD applies to
non-TC’d aircraft or engines, propellers, and appliances installed thereon.

Although I know of no examples of an AD being issued against EAB aircraft.

However:
The owner/operator of an EAB is still responsible to ensure the aircraft is safe for flight 91.7(a) and does not pose a risk to others.
If the manufacturer of a component they are using on said aircraft has stated the component is not airworthy until something is complied with.
How does the owner/operator ensure their EAB is safe for flight without complying with the manufacturer's instructions?

A good example is the crank bolt AD on an IO-540, AD 2004-05-24. Without complying with that AD, how are you showing your aircraft is safe to fly and would it be considered reckless to fly while ignoring the AD? (91.13)

Your right Bagarre. I get carried away thinking about thinking about all the old ADs on engines and don't think about the point you brought up. The FAA can issue ADs on EAB aircraft but EABs have to be specifically listed. I can't remember for sure but I think they have issued a couple of those; one on a ADSB unit and another on ELTs.

I don't know how an owner would determine that his aircraft is safe to fly without complying with an AD. I guess that would be up to the owner to determine and his liability to accept.

Bagarre wrote:

whee wrote:ADs have no regulatory meaning to EAB aircraft.

That doesn't seem to be entirely true as the FAA can issue an AD agains a non Type Certificated aircraft.
https://www.faa.gov/documentLibrary/med ... 039-7D.pdf

AC 39-7d wrote:b. Non-TC’d Aircraft and Products Installed Thereon. Non-TC’d aircraft
(e.g., amateur-built aircraft, experimental exhibition) are aircraft for which the FAA has not
issued a TC under part 21. The AD applicability statement will identify if the AD applies to
non-TC’d aircraft or engines, propellers, and appliances installed thereon.

Although I know of no examples of an AD being issued against EAB aircraft.

However:
The owner/operator of an EAB is still responsible to ensure the aircraft is safe for flight 91.7(a) and does not pose a risk to others.
If the manufacturer of a component they are using on said aircraft has stated the component is not airworthy until something is complied with.
How does the owner/operator ensure their EAB is safe for flight without complying with the manufacturer's instructions?

A good example is the crank bolt AD on an IO-540, AD 2004-05-24. Without complying with that AD, how are you showing your aircraft is safe to fly and would it be considered reckless to fly while ignoring the AD? (91.13)

I think the AD against the Bendix ignition switch would de a good example too. That AD was for any plane it was installed in.

Some AD's are simply a legal CYA, others have some "serious" thought and engineering to back them up, ignore at your own peril !!!!!! I carry "loved ones" regularly, care to guess which side of the fence I error on ???

Bagarre wrote:

whee wrote:ADs have no regulatory meaning to EAB aircraft.

That doesn't seem to be entirely true as the FAA can issue an AD agains a non Type Certificated aircraft.
https://www.faa.gov/documentLibrary/med ... 039-7D.pdf

AC 39-7d wrote:b. Non-TC’d Aircraft and Products Installed Thereon. Non-TC’d aircraft
(e.g., amateur-built aircraft, experimental exhibition) are aircraft for which the FAA has not
issued a TC under part 21. The AD applicability statement will identify if the AD applies to
non-TC’d aircraft or engines, propellers, and appliances installed thereon.

Although I know of no examples of an AD being issued against EAB aircraft.

However:
The owner/operator of an EAB is still responsible to ensure the aircraft is safe for flight 91.7(a) and does not pose a risk to others.
If the manufacturer of a component they are using on said aircraft has stated the component is not airworthy until something is complied with.
How does the owner/operator ensure their EAB is safe for flight without complying with the manufacturer's instructions?

A good example is the crank bolt AD on an IO-540, AD 2004-05-24. Without complying with that AD, how are you showing your aircraft is safe to fly and would it be considered reckless to fly while ignoring the AD? (91.13)

Although rare, some EAB aircraft do have AD's. My glider being one, had an AD issued for spar reinforcement. Just a thought to keep in mind if shopping for an EAB aircraft is to keep an eye out for the occasional AD....

whee wrote:e that his aircraft is safe to fly without complying with an AD. I guess that would be up to the owner to determine and his liability to accept.

So, prefacing this with the FAA largely doesn't care too much about experimentals until you kill someone else.
That's not entirely how it works. To comply with 91.7 like stated above you would have to comply with an AD. AD's are issued against engines, not just airframes. If your engine has an AD and you are experimental, you have to do something to correct the unsafe condition. It doesn't HAVE to be what is prescribed in the AD, but you are required to correct the unsafe condition. Just saying, eh I know better than the engine manufacturer and the FAA is not sufficient. You also cannot just accept the liability of flying an airplane the FAA has deemed is unsafe for flight via the AD.