FLC OF AN ATX FLT EXCEEDED AN ACFT INSPECTION TIME LIMITS.

Narrative

ON MAY/XX/95 I WAS ACTING AS PIC (CAPT) FOR AN FAR PART 135 CARGO FLT FOR MY COMPANY. UPON ARR TO THE ARPT AT MY APPOINTED DUTY TIME AND WHILE BEGINNING MY PREFLT DUTIES; I WAS GREETED BY AN FAA INSPECTOR WHO INFORMED ME THAT HE WOULD BE RIDING ALONG WITH ME ON THE FIRST SEGMENT OF MY TRIP (PDX-BFI) AND HE FURNISHED ME WITH THE APPROPRIATE PAPER WORK. HIS AUTH TO RIDE ALONG WAS ALSO VERIFIED VIA PHONE WITH MY DISPATCHER. AFTER CONFIRMING THAT I DID HAVE AN FAA INSPECTOR ON BOARD FOR THE FLT; I MADE A MENTAL NOTE THAT MY ACTIONS WERE NOW BEING OBSERVED AND SCRUTINIZED BY AN OFFICIAL OUTSIDE OBSERVER; AND ONE NOT FAMILIAR WITH OUR OPS. THE NET EFFECT BEING THAT I TOOK EXTRA TIME TO VERIFY AND DOUBLE-CHK CERTAIN ITEMS. I'D BE ASKED TO EXPLAIN THEM TO AN INDIVIDUAL UNFAMILIAR WITH OUR OPS. WHILE VERIFYING THE AIRWORTHINESS OF THE ACFT I REFERRED A SHEET OF PAPER; KEPT WITH THE FLT AND MAINT LOG OF THE ACFT. THIS SHEET OF PAPER INDICATES THE LAST INSPECTION COMPLETED AND THE NEXT INSPECTION DUE; PER OUR MAINT PROGRAM. UNDER THE INSPECTION DUE COLUMN; THERE ARE GENERALLY 2 FIGURES; THE FIRST INDICATING WHEN THE NEXT INSPECTION IS DUE; THE SECOND; IN PARENTHESIS; INDICATING THE MAX TIME BY WHICH THE FIRST FIGURE MAY BE EXCEEDED; A 'BUFFER;' IF YOU WILL. THIS BUFFER FIGURE IS AS EXPLAINED BY OUR MAINT DEPT. WHILE THIS CONCEPT IS CLR AND ACCEPTABLE TO ME; I WAS CONCERNED THAT IT MAY NOT BE AS CLR TO THE SCRUTINY OF AN FAA INSPECTOR UNFAMILIAR WITH OUR OPS. I DECIDED TO CALL OUR MAINT DEPT TO VERIFY THAT; INDEED; THE ACFT WAS OFFICIALLY AIRWORTHY. AS A PRECAUTIONARY MEASURE; AND AS A SIGN OF GOOD JUDGEMENT; I EXPRESSED MY CONCERN THAT THE FAA INSPECTOR MAY QUESTION ME AS TO WHY THE ACFT AIRFRAME TIME APPARENTLY EXCEEDS THE NOTATION FOR A REQUIRED INSPECTION; AND WANTED TO BE ABLE TO TELL HIM WITH IMPUNITY; THAT I HAD JUST CHKED WITH OUR MAINT DEPT AND VERIFIED THAT WE WERE OK AND OPERATING WITHIN THE BUFFER INTERVAL. MY MAINT DEPT WAS UNABLE TO VERIFY ANY RECORDS PERTAINING TO THE ACFT AND SO I REQUESTED TO SPEAK WITH THE DIRECTOR OF MAINT. IN SPEAKING WITH THE DIRECTOR OF MAINT; HE WAS ALSO UNABLE TO DETERMINE THE STATUS OF THE ACFT AND AUTH AN INSPECTION TO BE PERFORMED. THAT INSPECTION WAS COMPLETED BY A LCL MAINT PERSONNEL AND AN ENTRY WAS MADE ON THE FLT SHEET INDICATING SUCH. I EXPLAINED THE SIT TO THE FAA INSPECTOR AND TOLD HIM I WAS SATISFIED THAT THE ACFT WAS AIRWORTHY; AND HE CONCURRED. DURING THE FLT TO BFI THE INSPECTOR EXAMINED THE FLT AND MAINT LOG AND MADE NOTATIONS OF ALL PREVIOUS FLTS OF THAT ACFT THAT OCCURRED BTWN THE REQUIRED INSPECTION DUE FIGURE (NOT THE BUFFER FIGURE; BUT THE FIRST FIGURE) AND THE AIRFRAME TIME FOR THE BEGINNING OF THAT TRIP (THE TRIP WE WERE ON). HE NOTED THAT SEVERAL FLTS HAD OCCURRED DURING THIS INTERVAL; INCLUDING AT LEAST 4 DIFFERENT FLCS. I WAS ACTING AS PIC DURING ONE OF THESE FLTS THAT OCCURRED DURING THIS INTERVAL; SPECIFICALLY MAY/XX/95 FLT LOG. AS THE FAA INSPECTOR WAS EXITING THE ACFT AT BFI; HE INDICATED THAT HE FELT THAT THE ACFT HAD BEEN OPERATED OUTSIDE AN INSPECTION INTERVAL; THAT I WAS PIC ON ONE OF THOSE FLTS; AND THAT HE WOULD BE SUBMITTING HIS DOCUMENTATION TO OUR COMPANY'S POI FOR FURTHER INVESTIGATION; INCLUDING POSSIBLE AIRMEN CERTIFICATE ACTIONS OR SANCTIONS. I SAID VERY LITTLE AND THANKED HIM FOR COMING ON THE FLT. I IMMEDIATELY CALLED MY DIRECTOR OF MAINT AND EXPLAINED TO HIM WHAT HAD JUST TRANSPIRED. HE REASSURED ME THAT THE ACFT I WAS OPERATING WAS AIRWORTHY AND THAT I HAD NOTHING TO BE CONCERNED ABOUT -- THAT HE COULD PROVE THE AIRWORTHINESS OF THE ACFT TO ANYONE WHO ASKED; AT ANY AIRFRAME TIME. 2 DAYS LATER I SPOKE WITH MY DIRECTOR OF OPS WHO ASKED ME TO EXPLAIN WHAT HAD TRANSPIRED WITH THE FAA INSPECTOR. I EXPLAINED TO HIM THE SIT AND MY ACTIONS. HE ALSO ASKED ME HOW I DETERMINED THE ACFT WAS AIRWORTHY ON THE FLT THAT I WAS PIC DURING THE INTERVAL IN QUESTION. I EXPLAINED TO HIM THAT I INTERPRETED THE AIRFRAME NUMBER IN PARENTHESIS TO BE THE 'OUTSIDE BUFFER LIMIT;'AND THAT OP OF THE ACFT BEYOND THE REQUIRED INSPECTION FIGURE; BUT INSIDE THE PARENTHESIS BUFFER FIGURE; WAS ACCEPTABLE AND STANDARD LINE PROC. HE THEN INFORMED ME THAT I WAS BEING INVESTIGATED BY THE FAA IN REGARDS TO THIS MATTER AND THAT HE WOULD CONTACT ME AT A LATER DATE WITH FURTHER INFO. AT NO TIME DID I KNOWINGLY OR INTENTIONALLY OPERATE THE ACFT OUTSIDE OF ANY REQUIRED INSPECTION INTERVAL; OR DID I KNOWINGLY OR INTENTIONALLY OPERATE THE ACFT IN AN UNAIRWORTHY CONDITION. I USED THE FLT AND MAINT LOG SHEET; PROVIDED BY THE COMPANY; AND KEPT WITH THE ACFT; TO DETERMINE COMPLIANCE WITH INSPECTIONS AND I USED COMMONLY ACCEPTED LINE PROCS FOR INTERPRETING THE MEANING AND VALIDITY OF THOSE FIGURES; AS WELL AS DIRECT PHONE CONVERSATIONS WITH MAINT PERSONNEL FOR VERIFICATION; AMPLIFICATION AND CLARIFICATION. IF IT IS DETERMINED THAT I OPERATED AN ACFT AS PIC CONTRARY TO FAA REG OR COMPANY POLICY; IT WAS PURELY UNINTENTIONAL AND COULD ONLY HAVE RESULTED FROM A MISINTERP OR A MISUNDERSTANDING OF THE INFO AVAILABLE TO ME. I WOULD SUGGEST THAT IN THE FUTURE; THE FLT LOG SHEET BE REDESIGNED TO AVOID ANY POSSIBLE AMBIGUITY AND THAT COMPANY MAINT PERSONNEL HAVE 24 HR ACCESS TO ACFT COMPUTER MAINT LOGS.