would have to be sent out for overhaul. All the
cylinder assemblies would have to be sent out
for overhaul or replaced with new ones. The list
was rather daunting.
“Do I really have to do all that stuff?” Jim
asked me. He pointed out that Continental’s
list of “mandatory replacement parts” was
contained in service bulletin SB97-6B. “I
thought Part 91 operators like me were not
required to comply with manufacturer’s service
bulletins,” he added, “but my mechanic says
he’s required by regulation to replace all those
parts at engine overhaul. Who’s right?”
“You’re both right,” I replied, and paused for
a moment while the irony of that apparent
contradiction sunk in before starting my
explanation.
“As a Part 91 operator, you aren’t required by
regulation to comply with any manufacturer’s
service bulletin unless compelled to do so by
an Airworthiness Directive,” I explained. “Nor
are you required by regulation to overhaul your
engine…now or ever! Legally, you could run
that engine for 20,000 hours—repairing it
whenever it breaks—and never have the word
‘overhaul’ appear in your engine logbook.”
“However,” I continued, “if you ask your
mechanic to work on your engine and sign
that work off as an ‘overhaul,’ he is required
by regulation to follow Continental’s guidance
to the letter, and that includes complying with
SB97-6B. So if you don’t want him to replace
those $5,000 gears and you’re happy with your
fuel pump and alternator, just ask him to log
his engine work as a ‘repair’ instead of as an
‘overhaul’ and then he can do—and not do—
whatever you ask for.”
Watch your language!
When an aircraft component (such as an
engine, propeller, instrument, accessory
or other appliance) becomes inoperative,
unairworthy, or just plain sick or worn out,
we usually have a number of options: We can
replace the bad component with a new one or
a rebuilt one, or have our defective component
overhauled or repaired.
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