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HeliTorque :: View topic - R22 MR Temp Light Inoperative - legal to fly?
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HeliTorque Forum Index » Instructor Forum

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R22 MR Temp Light Inoperative - legal to fly?
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Legal?
Yes
0%
 0%  [ 0 ]
No
100%
 100%  [ 2 ]
Depends...
0%
 0%  [ 0 ]
Voted : 2
Total Votes : 2
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JB77UK
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PostPosted: Mon Feb 11, 2013 7:44 pm    Post subject: R22 MR Temp Light Inoperative - legal to fly? Reply with quote

Hi and thank you all for any feedback.

I know the practical answer to this - "I wouldn't fly with a MR Temp light inoperative", but what is the position regarding regulations?

Firstly I would check the day VFR required equipment (91.205) - and the MR Temp Light is not on that list. So now I go to inoperative equipment 91.213(d) and this is where it gets a bit less clear to me. It seems to say that as long as the instrument/equipment is not required for day VFR (91.205), not "Indicated as required on the aircraft's equipment list" (the R22 POH?) and the aircraft doesn't have a MEL then it is OK to fly without the equipment being operational - as long as the pilot removes/placards (remove the bulb?) and doesn't consider it a hazard to safe flight (which is subjective).

I would conclude that legally, if it was a short flight maybe to a repair facility, you could legally fly with the MR Temp Light pulled (that is my version of removed/placarded). What do you guys think - legally?

I want to know because I want to make sure I tell my students the correct thing. And this issue doesn't just apply to the MR Temp light, what about other equipment/instruments not on the day VFR or POH lists of required equipment? (Heater, Carbon Monoxide light, VSI, etc).

Like I said the practical advice for this example would be "call the mechanics/don't fly etc" but I would appreciate some clarification on the legal issue.

Many thanks

Jay
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haggishunter
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PostPosted: Thu Feb 14, 2013 4:03 pm    Post subject: Reply with quote

Disclaimer: I work in JAA/EASA land.

My experience is that a private owner is subject the limitations laid down in the RFM/POH of minimum equipment required for flight. Usually in the limitations section of the manual.

If you are operating an aircraft under an AOC, part of the requirements is that the operator has a MEL for each type which has been approved by the authority. This will be more restrictive that the manufactures minimum required equipment, mainly depending on the type of operation your AOC allows you to do.

Clear as mud.
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flip2
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PostPosted: Thu Feb 14, 2013 5:32 pm    Post subject: Reply with quote

You seem to be quoting FAA regs, in which case Pat Cox's answer on 'the other forum' is spot on.

Incidentally, Pat Cox is Robinson's Technical Support Supervisor so he generally knows what he is talking about!
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rjc
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PostPosted: Thu Feb 14, 2013 5:37 pm    Post subject: Reply with quote

Well, I voted for no. On the basis that how do you know it is just a bulb failure?

You push the button, the light doesn't come on, so where is the fault? Bulb, button, or wire broken. You're not testing the sensor itself but the warning system associated with it, presumably the sensor is designed to fail in such a way to trigger the light(?).

Taking the R22 example, the POH says the Pilot can do some preventative maintenance (section 8 ), warning bulbs is not on that list. So, according to the POH, you cannot touch it. Which doesn't help your legal situation.

If you look at the requirements (in EASAland anyway) to certify a small rotorcraft, document here http://www.easa.eu.int/agency-measures/docs/agency-decisions/2012/2012-021-R/CS-27%20Amendment%203.pdf page 61, "An oil temperature warning device to indicate when the temperature exceeds a safe value in each main rotor drive gearbox..."

then perhaps there is an argument that if it's a requirement for certification of the aircraft in the first place, the logic holds it's needed to safely operate the machine too?

The other instruments are also listed on page 61, to be certified it must have An airspeed indicator, An altimeter, and A magnetic direction indicator {why cannot they say compass?}. So is a VSI needed at all?
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rjc
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PostPosted: Thu Feb 14, 2013 5:41 pm    Post subject: Reply with quote

flip2 wrote:
You seem to be quoting FAA regs, in which case Pat Cox's answer on 'the other forum' is spot on.

Incidentally, Pat Cox is Robinson's Technical Support Supervisor so he generally knows what he is talking about!


Typical, I check in here then notice the thread 'over there'.... note to self, must try harder to keep up.
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flip2
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PostPosted: Thu Feb 14, 2013 6:16 pm    Post subject: Reply with quote

rjc wrote:

The other instruments are also listed on page 61, to be certified it must have An airspeed indicator, An altimeter, and A magnetic direction indicator {why cannot they say compass?}. So is a VSI needed at all?

I cannot answer your question.
Outside of EASA-land, I have flown aircraft without a VSI fitted... 4 hole dash (MAP, RPM, ASI, Altimeter) plus compass.
If my memory serves me correctly Laughing
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Skunkyd
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PostPosted: Thu Feb 14, 2013 8:52 pm    Post subject: Reply with quote

Whatever's right or wrong, is it really worth the risk?
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flip2
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PostPosted: Fri Feb 15, 2013 1:19 am    Post subject: Reply with quote

Skunkyd wrote:
Whatever's right or wrong, is it really worth the risk?

Quite right.
However, as an instructor / line trainer you should always be able to qualify your statements and assertions... and I think that is where the original poster is coming from.
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