A Piper PA-28 aircraft was found out of Airworthiness Directives (AD's) compliance by a Designated Pilot Examiner (DPE). The Reporter described the difficulty and complexity of complying with Airworthiness Directives.
Synopsis
A Piper PA-28 aircraft was found out of Airworthiness Directives (AD's) compliance by a Designated Pilot Examiner (DPE). The Reporter described the difficulty and complexity of complying with Airworthiness Directives.
Narrative
I inadvertently flew an aircraft several times not knowing a recurring Airworthiness Directive (AD) had not been complied with. I learned of the situation when a Student I recommended for an Instrument Check went for his flight test. The Designated Pilot Examiner (DPE); examined the aircraft records and found the Non-Compliance. This was after an Airframe & Powerplant (A & P) Mechanic had checked the records a few days prior. The Owner/Pilot was not aware either. The AD; an Inspection of the Control Wheel; was complied with on the spot in a few minutes. My complaint; as a Pilot and A & P; is the complexity and difficulty of complying with AD's. First; the system for identifying AD's is flawed. They are identified with a meaningless system that uses the calendar year; bi-weekly period; and the AD number issued in that bi-weekly period; e.g. 2009-12-23. Pilots and Maintenance personnel can glean no information as to what the AD applies to. It is not by Type Aircraft; Engine; Propeller; or Appliance (the 4 categories of AD's). So doing an AD check on an Annual or 100-hr Inspection is an arduous process of seeing which AD's apply to a particular Airframe; and it's Engine; Propeller; and Appliances. All these Components may have been modified since the aircraft was manufactured. Appliances are particularly difficult; since an inventory of Avionics; Instruments; etc; must be made each Inspection to see which have changed. The AD system needs revision to more readily show what an AD applies to. Secondly; compliance dates/times for recurring AD's are sometimes confusing. Sometimes it may be every 50 or 100 hours; or every 12 months; etc. This makes it difficult for Owners/Pilots/Mechanics to track when compliance is next due. This is particularly difficult for Pilots who fly several non-owned aircraft; and who may not have access to the aircraft records. Responsibility for compliance is joint between Owners/Operators/Mechanics. It amazes me that we do as good a job of complying as we do. I recommend we change the ID system for ADs and standardize the compliance times. Since an aircraft used for hire requires a 100 hour Inspection; that is OK for AD's that require compliance based on 100 hours. Aircraft not flown for hire that need only Annual Inspections may not fly 100 hours between Inspections. Such AD's should require compliance every 100-hours or 12 months. The same would be true for say; 50 hour AD's. One that requires Inspection every 500-hours should also have a Calendar compliance date as well; say every 60 Calendar months. It is very difficult for Owners/Operators/and Mechanics to meet the regulatory requirements; as most small aircraft have dozens of AD's that apply. Some go back 50 years for older aircraft. In short; a simpler system is needed.
Second reporter narrative
I flew an aircraft without knowing an Airworthiness Directive (AD) had not been complied with. I was getting ready for my Instrument Check ride; when the Designated Pilot Examiner (DPE) examined the aircraft logbooks and found the Non-Compliance. I was not aware of this (AD not accomplished); so I immediately got an Airframe & Powerplant Mechanic to inspect the control wheel and was back in compliance immediately.I; along with other Pilots; have done our best to keep track of AD's and stay in compliance. But the current system makes it nearly impossible.
NASA callback
Reporter stated Mechanics look in the Airframe; Engines; Propeller and Appliance sections of the Airworthiness Directive (AD) list to determine applicability of AD's for the equipment they are performing 100-hour Inspections on. Many use the commercially available search engines to review the FAA's AD list; but the system for identifying AD's is flawed.
Source: NASA Aviation Safety Reporting System (public domain). Reports are voluntary submissions and are not verified by NASA.