FAR 91.207 ELT inspection

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whitefaced's picture
FAR 91.207 ELT inspection

During scheduled surveillance by the FAA, one of the ASIs made a comment regarding ELT maintenance.

He was inspecting mx records for a Hawker 700A on our 135 certificate. As he looked over a major mx event entry from back in the spring and noted that the ELT battery had been replaced. After a pause, he said that he was going to "bust" them................"I don't see an entry for FAR 91.207 ELT inspection. Whenever you change an ELT battery, you have to comply with the 91.207 ELT annual inspection" he said.

Before I could say anything, he found the entry for the ELT inspection, and went on.

I did not say anything to him about his comments, but I do feel that he is completely incorrect.

I am unaware of any requirement to comply with the ELT annual inspection items in 91.207 just because one performs a transmitter battery replacement mx task. Does anyone have an opinion on this?

Doug Hereford

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anyoneofus (not verified)
Anonymous's picture

My opinion is that Mr. FSDO is speaking from his backside again.

When he says 91.207, he may be referring to battery replacement and the ELT Manufacturer's instructions for that which may include a post replacement functional test encompassing the 91.207 (d) tests.

You didn't say he referred specifically to 91.207 (d).

I'd make sure that I was in compliance with the ELT manfufacturer's data for battery replacement, then give him a little tun up.

I know dealing with these simple minds is frustrating.

I do feel better that the flying public is assured of a higher level of safety as a result of the FSDO visit. (:

whitefaced's picture

I agree. In my opinion ELT battery replacement is by definition maintenance, and as such must be performed IAW FAR 43.13. Nothing in the 91.207 regulation calls for repeating that inspection after replacing the battery. So the only record requirement would be FAR 43.9.

To me, what the inspector is suggesting is that the performance of maintenance on the transmitter somehow invalidates the inspection status of the ELT.

Obviously, we perform maintenance tasks every day, without effecting the overall inspection status of the product.

I am going to do as you suggest.

Doug Hereford

n14ky's picture

91.207(c) covers battery replacement, 91.207(d) covers inspection requirements. There is no inspection requirement following battery replacement. Performing the maintenance function described in 91.207(c) doesn't trigger the inspection unction of 91.207(d). The only thing that triggers the inspection is calendar months.

The ELT Manufacturers ICA may cover a test following battery replacement, but it is not in the regulation.

whitefaced's picture

That is what I think too. I did not get a chance to discuss this with the ASI, but I plan to discuss it with him when it is appropriate.

Like I said above, he stated that he was going to "bust them", referring to the maintenance provider who had performed the battery replacement. Immediately my wheels started turning since I am the DOM for the cert. Before I could respond at all, he found where the 91.207 sign-off was made in a different part of the entry.
So I just stayed quiet.

The ironic part that he was unaware of is that the ELT inspection had actually been due anyway, and an original part of our work scope. When the mx provider complied with the inspection, they did so IAW our AAIP (as they should), but they merely noted the inspection as referenced to our item code. I asked that they add 91.207(d) verbiage because it seems like the FAA loves to see that. I actually don't know why they do, but that is the only reason I had it included in the entry in the first place.

I also had prior knowledge that he had this ELT "hang-up" as he had been out two days earlier to inspection another 135 cert. that I am DOM for. He mentioned to one of my guys who told me about it. I blew it off then, but probably shouldn't have.

I think I got lucky there in that if the 91.207 signoff had not been there, we would have been in a argument, and he might have pushed the other issue of me not signing my certs.

Doug Hereford

n14ky's picture

Sounds like an ASI with an axe to grind. I really hate when they try these power trips.

Denny (not verified)
Anonymous's picture

My two cents worth is the FAA inspector is more than likely a new hire and feeling his/her oats and certainly shot from the hip on the ELT issue. Changing the batter as required in part 91.207 only requires a maintenance entry per part 43.9 and it does not trigger a ELT inspection.

This is a part 135 aircraft with a set of operation and maintenance manuals that will address the ELT compliance and battery change, it would be interesting to know what the 135 manuals say about this. In addition, if there is an ICA for this ELT those instructions would address the inspection or maintenance entry for replacing the battery.

Bottom line if an FAA inspector questioned me about a ELT inspection I would certainly asked to them to show me in the CFRs where it says to do more that part 91.207 requires. Next is I would contact the FSDO maintenance supervisor and asked what the FAA policy is making certain comments to operators that is covered under the Pilots Bill of Rights. You need to nip this is the butt right from the start.

Cessnarigging's picture

The way this was presented to me by my PMI when working at a Repair Station. "When you remove the Battery the unit is rendered INOP" thus required to be returned to service. Most of the Manuals for ELT's also require a functional check be made after Battery replacement. These vary with Manufacturer & Model but most ICA's require a functional check, placard etc.

IA/Pvt Pilot

skybob5's picture

When you change the battery, you'd just need to do an ops check and sign it off that way. No need to do the entire 91.207(d).

Stacheair1's picture

I know this is an old post but an important one.  As a retired ASI PMI I used to have an ASI (avionic) inspector that acted this way on inspections looking to burn everyone.  None of us know it all and I would ask the A&P to help me find record entries sometimes.  Entries do not have to be in a logbook anymore and may be included in some other document. The ELT battery is a part 43.9 maintenance entry for replacement.  The thinking of the FAA is how do you know it works?  This is a simple test and to prevent or defuse situations I find it best to do an ELT test and include it with the battery maintenance entry.  Some of the battery ICAs do require an ELT test some don’t say anything.  This is a CYA test and with a maintenance entry to lesson your risk factor.  Just remember some FAA ASIs are like pigs and like to roll in the mud and will questions mechanics to show they know more than the mechanic on certain topics.  It’s a game some ASIs play so play along with it to a point and question authority.

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