Response from FAA concerning AD 74-17-04

[at7615]

Any chance of getting an MorD for the 4 findings? That would help support the request!

Tony Baumgard
NTX FSDO
8700 Freeport Parkway, Suite 225
Irving, TX 75063
Office- 214-277-8513
Cell- 214-605-9846
Currently teleworking daily


-----Original Message-----
From: Anthony Tinsman <at7615@yahoo.com>
Sent: Wednesday, October 07, 2020 7:19 PM
To: Baumgard, E Tony (FAA) <E.Tony.Baumgard@faa.gov>
Subject: AD 74-17-04

Hey Tony, there has been a fabric seperation at the windshield channel on a PA-22 recently. The forum I'm a member of is saying that there have been 4 seperations in the last few years, all aircraft with synthetic covering systems and NO METAL CHANNEL INSTALLED.

Even though the AD states that only cotton and linen fabric coverings are applicable, I am asking and recomending that this AD be amended to include any and all fabric covering systems of these aircraft. The pilots description of the flight, in which he declared an emergency, is something that needs to be avoided at all cost.

Thanks, Anthony Tinsman


https://www.univair.com/piper/parts/...ification-kit/


Federal Aviation Administration

14 CFR Part 39

Amendment 39-2865; AD 74-17-04



Airworthiness Directives; Piper Models PA-12, PA-14, PA-15, PA-16, PA-17, PA-20, and PA-22 Airplanes PDF Copy (If Available):


Hide details for Preamble InformationPreamble Information
AGENCY: Federal Aviation Administration, DOT





DATES: Effective April 11, 1977.






Hide details for Regulatory InformationRegulatory Information

74-17-04 PIPER: Amendment 39-1919 as amended by Amendment 39-2154 is further amended by Amendment 39-2865. Applies to the following Models which are covered with cotton or linen at the critical area on top of the windshield where the fabric attaches to the channel: PA-12, Serial Numbers 12-2904 and higher, except 12-2907, 12-2911, 12-2914, 12-2915, 12-2917, 12-2925, 12-2950, 12-3028-S and 12-3901 through 12-3903; PA-14; PA-15; PA-16; PA-17; PA-20; and PA-22 airplanes, Serial Numbers 22-1 and up, certificated in all categories.

To prevent sudden failure of the fabric at the top of the windshield where the fabric attaches to the channel, accomplish the following:

1. For all airplanes, unless already accomplished, the indicated Piper Kits or equivalent parts approved by the Chief, Engineering and Manufacturing Branch, FAA, Eastern Region, must be installed within the next 25 hours in service after the effective date of this AD on airplanes which have fabric exceeding three years since installation:

(a) Kit 760 799 effective on: PA-12, Serial numbers 12-2904 and higher, except 12-2907, 12-2911, 12-2914, 12-2915, 12-2917, 12-2925, 12-2950, 12-3028-S and 12-3901 through 12-3903; all PA-12S and PA-14 airplanes.

(b) Kit 754 404 effective on: All PA-15, PA-16, PA-17 and PA-20 and PA-22 Airplane Serial Numbers 22-1 and up.

2. For all airplanes at every 100 hours in service after accomplishment of 1(a) or 1(b), remove the metallic strip and inspect the fabric over the top surface.

(a) If no cracks or fraying are found, reinstall the metallic strip.

(b) If any cracks or fraying are found, prior to further flight, add a fabric reinforcement strip (pinked-tape) starting from a line formed by the intersection of the windshield and the leading edge of the channel and extending aft at least three inches from the trailing edge of the channel. Reinstall the metallic strip.

3. For all airplanes which have fabric installed within the last three years, every 100 hours in service after the effective date of this AD, until three years are accumulated, inspect the fabric over the top surface.

If any cracks or fraying are found, prior to further flight, install Piper Kits or equivalent parts approved by the Chief, Engineering and Manufacturing Branch, FAA, Eastern Region, as in 1(a) or 1(b) as appropriate.

Upon request and appropriate substantiating data submitted through an FAA maintenance inspector, the compliance time specified in this AD may be increased by the Chief, Engineering and Manufacturing Branch, FAA, Eastern Region.

Piper Service Letter No. 362A pertains to this subject.

This AD supersedes AD 61-06-06.

Amendment 39-1919 was effective August 16, 1974.

Amendment 39-2154 was effective April 9, 1975.

This amendment 39-2865 is effective April 11, 1977.

[dgapilot]

Dis you send in a SDR? https://av-info.faa.gov/sdrx/


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[at7615]

Any A & P/IA who has first hand knowledge of this issue can submit a report to Tony, he is willing to help!

[LarryV]

Any chance of getting an MorD for the 4 findings? That would help support the request!

Tony Baumgard
NTX FSDO
8700 Freeport Parkway, Suite 225
Irving, TX 75063
Office- 214-277-8513
Cell- 214-605-9846
Currently teleworking daily


-----Original Message-----
From: Anthony Tinsman <at7615@yahoo.com>
Sent: Wednesday, October 07, 2020 7:19 PM
To: Baumgard, E Tony (FAA) <E.Tony.Baumgard@faa.gov>
Subject: AD 74-17-04

Hey Tony, there has been a fabric seperation at the windshield channel on a PA-22 recently. The forum I'm a member of is saying that there have been 4 seperations in the last few years, all aircraft with synthetic covering systems and NO METAL CHANNEL INSTALLED.

Even though the AD states that only cotton and linen fabric coverings are applicable, I am asking and recomending that this AD be amended to include any and all fabric covering systems of these aircraft. The pilots description of the flight, in which he declared an emergency, is something that needs to be avoided at all cost.

Thanks, Anthony Tinsman
.../

Seriously?

I realize there was a recent crash attributed to this, and I'm not doubting you when say there have been a total of 4 similar events in the "last few years", but recommending an AD be extended to all PA-22s with Dacron covering has a huge downside. There are currently 3,077 PA-22s show as active in the FAA registry and another 377 PA-20 Pacers and you're potentially inflicting an AD on all of them.

Assuming you mean "3 years" when you say "the last few years", and given 4 events in a fleet of 3,077 US registered PA-22s, that's an accident rate of 0.0004 per year, or 0.04% of the fleet per year. If you meant "4 years" then it drops to 0.03% per year.

Were any of these events fatal and/or did they result in significant injury to people in the air or on the ground?

If not, you're demanding a lot of regulatory and financial burden for an issue that is both exceedingly rare, and comparatively minor in severity. It's also an issue that can more economically be addressed with a service bulletin educating AP/IAs to pay attention to the fabric in this area during the annual inspection, as well as by educating owners to inspect this area for signs of deterioration when they preflight and refuel the aircraft.

I'm normally the token liberal on these forums, but asking for this level of intervention with the low incidence and minor severity of the events seems way over the top, even by my fairly moderate government standards.

[dgapilot]

A better and less costly FAA response would be an SAIB.

[at7615]

Doing nothing will be the most costly! I will not be in the group saying” I should have done something". The strip is on my Colt, and if it was not there, it would be installed. As an IA, I will not sign off an annual unless the aircraft has the strip or an AMOC, don't care what the fabric is. The owner of course can get an A & P or other IA to sign it off, and then my hands will be clean. I am seeing a lot of fabric work that is not in conformance with the STC and common practice, which tells me there is a knowledge/ethical gap between those that "do it right" and those that don't. An AD ends the argument and if 1 life is saved it would be worth the pain! Don't shoot the messenger!

[Steve Pierce]

Having worked with the FAA on several issues on the Super Cub that could have been potential ADs, one was the original mag switch placement and the propensity to getting accidently shut off by heavy clothing in winter and another on the tail post cracking I would agree that they would most likely issue an SAIB Special Airworthiness Information Bulletin). That is what they did in both of those cases. I dealt with an engineer in ATL ACO who had been assigned to deal with airworthiness concerns on the tube and fabric Pipers.

[LarryV]

Doing nothing will be the most costly! I will not be in the group saying” I should have done something". The strip is on my Colt, and if it was not there, it would be installed. As an IA, I will not sign off an annual unless the aircraft has the strip or an AMOC, don't care what the fabric is. The owner of course can get an A & P or other IA to sign it off, and then my hands will be clean. I am seeing a lot of fabric work that is not in conformance with the STC and common practice, which tells me there is a knowledge/ethical gap between those that "do it right" and those that don't. An AD ends the argument and if 1 life is saved it would be worth the pain! Don't shoot the messenger!

We are all seeing substandard fabric work. It's an artifact of losing a lot of institutional knowledge as people who knew how to properly recover aircraft retire, and also a result of light sport aircraft increasing the popularity of fabric covered aircraft and increasing demand for recovering services that are now being provided by much less experienced people who don't know the important nuances of doing the work properly.

Requiring the expansion of an AD won'r address any of that. At best it's a bandaid, not a fix for the larger problem.

[dgapilot]

We are all seeing substandard fabric work. It's an artifact of losing a lot of institutional knowledge as people who knew how to properly recover aircraft retire, and also a result of light sport aircraft increasing the popularity of fabric covered aircraft and increasing demand for recovering services that are now being provided by much less experienced people who don't know the important nuances of doing the work properly.

Requiring the expansion of an AD won'r address any of that. At best it's a bandaid, not a fix for the larger problem.

Couldn’t agree more. Dope and fabric has been removed from most A&P training in favor of composite and “advanced avionics”. The basic skills of machining, welding, reading measuring tools, all pretty much a thing of the past.


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[Jeff J]

Couldn’t agree more. Dope and fabric has been removed from most A&P training in favor of composite and “advanced avionics”. The basic skills of machining, welding, reading measuring tools, all pretty much a thing of the past.


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Don’t forget the Part 65 mechanics who received little or no formal training at all. Just OJT until they could test.